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LEGAL DEPARTMENT

LEGAL DEPARTMENT. Michael Lurie, Senior Vice President and General Counsel Andrew Levy, Associate General Counsel October 2007. LEGAL DEPARTMENT. Michael Lurie, Senior Vice President and General Counsel

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LEGAL DEPARTMENT

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  1. LEGAL DEPARTMENT Michael Lurie, Senior Vice President and General Counsel Andrew Levy, Associate General Counsel October 2007

  2. LEGAL DEPARTMENT • Michael Lurie, Senior Vice President and General Counsel Corporate, regulatory, DISCUS, litigation, compliance, real estate, Canadian issues and other legal or regulatory matters at anytime. (312) 873-9218 • Andrew Levy, Associate General Counsel Wholesaler matters, health benefit plans, employee matters, trademark issues, union negotiations, consumer complaints, contracts, leases, Crown matters, etc. (312) 873-9380 • Robin L. Moncrieff, Associate General Counsel DISCUS, consulting/IT contracts, consumer complaints, wholesaler matters, other contracts, international issues, etc. (312) 873-9209 • Karla Carey, Regulatory Compliance Administrator Liquor licenses, salesperson licenses, bonds, marketing approvals, federal and state regulatory matters. (312) 873-9377 • Jill Benoit, Executive Assistant to Legal Department, Consumer Complaints (312) 873-9396

  3. SERVICES

  4. SERVICES • We also review all advertising materials for: • Compliance with the Code of Responsible Practices • Intellectual Property rights • For Example:

  5. Crown Compliance Guidelines • Guideline No. 1 – Statement of Policy • Guideline No. 2 – Company Records • Guideline No. 3 – Return or Exchange of Merchandise • Guideline No. 4 – Relations with Wholesalers • Guideline No. 5 – Relations with Retailers • Guideline No. 6 – Participation in Retailer/Distributor Associations • Guideline No. 7 – Display and Sales Promotion Companies • Guideline No. 8 – Sample Distribution and Record-Keeping Requirements • Guideline No. 9 – Donation of Beer/Purchase of Tickets for Charities • Guideline No. 10 – Other Record-Keeping Requirements • Guideline No. 11 – Relations with Competitors • Guideline No. 12 – Relations with Customers • Guideline No. 13 – Government Inquiries • Guideline No. 14 – General Business Conduct and Conflict of Interest

  6. Crown Compliance Guidelines • Guideline No. 11: Relations with Competitors • Do not exchange or discuss internal data, including: price lists, products costs or profit margins, internal market analyses or forecasts, etc. • Guideline No. 14: General Business Conduct and Conflict of Interest • Treat confidential information as privileged and do not disclose it to anyone who is not authorized to receive it

  7. CROWN JV TRANSACTION • Transition period until August 1, 2007 • Assignment of Barton Distributor Agreements

  8. CODE OF RESPONSIBLE PRACTICES FOR BEVERAGE ALCOHOL ADVERTISING AND MARKETING • Primarily marketing-related, with the theme that we are not targeting under-21 (“LDA”) individuals • 70% LDA demographic – certifications on the front end and audit on the back end • Models to be over 25 years of age and appear that way • Certain restrictions on campus advertising • Responsible content in terms of no cartoon figures, no irresponsibility, no “rites of passage,” no illegal or dangerous activities, good taste • Age verification on websites

  9. YOUR OBLIGATIONS • Review the Compliance Guidelines • Abide by the Code • Pre-clear sponsorship agreements with time for Legal to review, and obtain LDA-certification • Pre-clear promotions since every state is different • Risk to the Company and to you as an individual licensed person as well as an employee of the Company • Pre-clearance can be time-intensive, so leave enough time for this • Consider use of intellectual property – if different or for use by a third party

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