LkSG Com­plaints Procedure

The following describes the complaints procedure applicable to us in accordance with the German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz, LkSG).

Scope

The complaints procedure is open to all reports and complaints regarding possible breaches and risks within Imperial Brands or along our supply chains. In principle, the complaints procedure can be used for all types of possible violations and risks; the following lists are not exhaustive.

Possible human rights risks and violations can relate to the following topics in particular:

• Child labor
• Forced labor and all forms of slavery
• Disregard for occupational safety and work-related health hazards
• Failure to respect freedom of association and the right to collective bargaining
• Unequal treatment in employment
• Denial of adequate wages
• Destruction of the natural basis of life through environmental pollution
• Unlawful violation of land rights
• Hiring or using private/public security guards, which may cause disruption due to lack of training or control
• Acts or omissions contrary to duty that are directly likely to have a particularly serious impact on a protected legal position (= other human rights) and whose illegality is obvious when all relevant circumstances are intelligently assessed

Potential reportable environmental risks and violations may include the following in particular:

• Violation of a ban under the Minamata Convention, which aims to protect human health and the environment from anthropogenic emissions and releases of mercury and mercury compounds into air, water and soil
• Violation of the ban on the production and/or use of substances within the scope of the Stockholm Convention (POP) and non-environmentally sound handling of waste containing POPs
• Violation of the ban on the import and export of hazardous waste within the meaning of the “Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal” of March 22, 1989

Complaint channels

Information and complaints can be submitted via the established channels at Imperial Brands and Reemtsma. In particular, this is the "Speaking Up" service maintained by Imperial Brands as an internal reporting point and central opportunity to provide information to the company. The “Speaking Up” service makes it possible to stay in touch with us afterwards – anonymously if desired.

The “Speaking Up” service can be accessed via the following options:

• Online reporting via the Imperial Brands “Whistleblower Network” (anonymously if desired)
• By telephone on +49 (0)800 5892841 quoting the code 25492 (anonymously if requested)
• Internally with the “Legal Governance” department of Group Legal of Imperial Brands, for example via the email address Governance.Team@impbrands.com

Process

To access the system via your desktop PC or mobile device, please visit https://imperialbrands.whistleblowernetwork.net.

In the system you can then formulate a written report or record a voice message (currently not supported on iOS) and, if necessary, attach documents, photos or videos that support your report. If you choose to record a voice message, your voice will be digitally obscured to protect your identity if you prefer to remain anonymous.

If you wish, all of your communication with us will remain anonymous.

However, no matter which option you choose, you will be asked to create a secure mailbox through which we can securely and effectively communicate with you via the system and provide you with feedback. We recommend making yourself available this way as we may not be able to complete the case without further information from you.

When you create a mailbox, you are assigned a case ID and must choose a password. You can use this case ID and password to access the mailbox and see if you have received any messages or questions. The mailbox cannot be associated with you and is anonymous.

We will examine incoming reports and complaints to see whether they are related to possible human rights or environmental risks or violations.

All incoming reports are documented internally. If you use the Speaking Up channel or otherwise enable us to communicate with you, you will receive confirmation of receipt of your report, usually within one week. If necessary, we will also contact you with any questions we may have for further clarification. If a risk or breach has been identified, we will take the necessary remedial or preventive measures and, if these take longer and it is appropriate, we will give you progress updates from time to time. As soon as the process is completed, you will receive a final message from us.

Protection from discrimination or punishment

Our "Speaking Up" Policy and Code of Conduct make it clear that all reports to us will be treated as anonymously and confidentially as possible and that we will not tolerate retaliation against anyone who contacts us with reports or complaints or assists us in an investigation.

Information and complaints are received and processed by Group Legal at Imperial Brands. This ensures the integrity of the procedure, the impartiality and independence of the reporting office and confidentiality of the process.

Costs

The process is free of charge for whistleblowers.

Contact persons

The complaints office which can be reached via the “Speaking Up” service is located at the “Legal Governance” department within Imperial Brands’ Group Legal. It will process incoming reports and complaints, forward them to the persons responsible for redress and – if necessary – coordinate further measures.

If you have any questions, you can also reach us via the email address Governance.Team@impbrands.com.