Sustainability Report FY 2021

56 We preserve value through regeneration We grow by sharing Methodological notes Annex We respect our history through sustainable innovation We manage as if we were guardians Moreover, the “Ethics and Compliance Hotli- ne” has been set up for all collaborators, which is managed by an external professional expert, ensuring an anonymous and continuous service for the various locations of the Group. The noti- fications are collected, documented and commu- nicated to the companies concerned, which are tasked to carry out further investigations. All presumed violations of the “Modello 231” must be communicated in a timely way to the Control Body of the specific company using the dedicated email address. To this end, we have defined a specific policy ai- med at regulating, among other things, the ways to communicate the violations or irregularities in question. Violations that are ascertained are subject to disciplinary action, whose sanction le- vel is directly proportional to the seriousness of the deed, starting from a verbal warning to the dismissal of the employee or the termination of the contract with third parties. A specific disci- plinary system is also provided if the violation is brought back to the members of the corpora- te offices. Individuals who report violations are always protected against any retaliation or inti- midation. With specific reference to anti-corruption, the Anticorruption Policy issued by the Corporate Compliance Department has been in force sin- ce FY 2016; it is valid for the CBI Group, which supports both Constellation Brands, Inc. and its subsidiaries to comply with the anti-corruption laws in force in the various countries where the subsidiaries operate. It is expressly forbidden for CBI employees or representatives to pay, offer, give, authorize or promise, whether directly or indirectly, money or “objects of value” to any “public official” or any other person to obtain improper benefits, to obtain or maintain an activity or to direct activities to third parties (persons or entities). Moreover, the companies comprising the CBI Group must keep and maintain accurate books and ledgers, with a reasonable level of detail, and set up and main- tain a reasonable level of internal checks that is able to alert the management about actual or pos- sible violations of the anti-corruption laws, and ensure the accurate registration of all operations and provisions in the company books. In order to prevent corruption, since FY 2021, our most strategic suppliers have been required to sign the “Certification of Anti-Corruption Receipt and Comprehension – Compliance with An- ti-Corruption Laws”, which requires the explicit declaration of abstention from corrupt practices and compliance with Italian Legislative Decree no. 231/2001. In FY 2021, the suppliers who signed the certifi- cate represent 40% of the total annual turnover.