DIAGEO PLC

Diageo is committed to conducting its business responsibly and in accordance with all laws and regulations to which it's business activities are

subject. We hold ourselves to the principles in our Code of Business Conduct, which is embedded through a comprehensive training and

education programme for all employees. Our employees are expected to act in accordance with our values, the Code of Business Conduct and

in compliance with applicable laws and regulations. The Audit Committee monitors compliance with the company’s ethical standards through

the Business Integrity framework, which helps enhance and protect all aspects of the company’s business. Regular reports are provided to the

Audit Committee by the Chief Business Integrity Officer on progress in providing guidance, training and tools for all levels in the business,

completion rates

for training modules, launch and rollout of new programmes or policies, monitoring use of whistleblowing mechanisms and investigating

allegations of breaches.

Our Code of Business Conduct, available in 19 languages, sets out what Diageo stands for as a company and how Diageo operates,

enabling all employees to understand what is required of them in working for Diageo. Annual training on the Code of Business

Conduct and associated policies is mandatory for all managers and their direct reports globally, encompassing over 24,000 eligible

employees during the year ended 30 June 2024. Training is delivered in an easily accessible e-learning format, with classroom training

delivered to those employees who do not have regular access to a computer. The Code of Business Conduct and other global policies

are available at https://www.diageo.com/en/our-business/corporate-governance.

Third-party risk is also managed through our Know Your Business Partner programme, which is designed to help the company

evaluate the risk of doing business with a third party before entering and during a contractual relationship. Business partners are

assessed for potential risks including economic sanctions, bribery and corruption, money laundering, facilitation of tax evasion, data

privacy, human rights and other reputational issues.

Employees and third-party business partners are encouraged to raise concerns about potential breaches of the Code of Business

Conduct or policies, either to line managers, legal or HR colleagues, risk, compliance and Business Integrity teams or to SpeakUp, a

confidential whistleblowing mechanism. SpeakUp is a global service administered by an independent provider, accessible online or by

telephone. Where legally permitted, it can be used anonymously and reports kept confidential. Allegations are investigated by

independent Diageo teams, with progress being monitored by the Business Integrity team. When allegations are substantiated,

appropriate disciplinary and corrective actions are taken. The Audit Committee receives and reviews regular reports on allegations,

including trends information, root cause analysis and investigation closure rates. Since all of Diageo's Non-Executive Directors attend

the Audit Committee, all Non-Executive Directors who make up the Board routinely review the findings of the company's

whistleblowing processes in accordance with the UK Corporate Governance Code.

During the year ended 30 June 2024, 759 allegations of breaches were reported which is an increase on prior years. The substantiation

rate of allegations confirmed as breaches is 34% (versus 33% in fiscal 23). As of the end of fiscal 24, 70 people exited the business as

a result of breaches of our Code of Business Conduct or policies (fiscal 23: 57 people). The number of leavers for fiscal 23 has been

restated due to a number of open cases from fiscal 23 being concluded this year. At the end of fiscal 24, we had 223 open cases, which

may lead to more people exiting the business. See below a summary of reported and substantiated breaches over the past three years.