DONATIONS POLICY

Context

We are committed to creating value for all our stakeholders by supporting the socio-economic development of the communities in which we operate. As an integral part of our community engagement strategy, donations represent a key element of this value creation. Over the years, our donations and community investments have evolved from isolated philanthropic initiatives into long-term, Group-level programmes closely aligned with business priorities and material topics.
We have identified the following priority programmatic areas, considered critically important across all our markets:

• Community resilience, including disaster relief and reconstruction

• Sustainable access to drinking water for our communities

• Economic empowerment for young people and women

• Circular economy projects and initiatives

• Charitable initiatives of local relevance

This policy has been created to define the scope, processes and controls required to ensure that charitable actions are carried out fairly, diligently, and in alignment with our core values and our approach to communities.

Scope

This policy sets out the principles and requirements for making donations and applies to all Coca-Cola HBC operating units and employees. Donations may be made either at Group level or locally. Every donation must comply with the Coca-Cola HBC Code of Business Conduct, the Anti-Corruption Policy, The Coca-Cola Company Responsible Marketing Policy (where applicable), and all applicable laws and regulations.

The term “donations,” as used in this policy, refers to charitable contributions in cash or in kind (including our products). It does not include initiatives related to the funding of specific projects approved at Group or local level according to the current authority matrix and/or gifts or other contributions offered to establish or maintain business relationships with third parties.

This policy does not cover commercial sponsorships (e.g., monetary or product contributions offered to customers/venues or sports organisations in exchange for visibility/promotion of our brands), cause-related marketing activities, or donations made by employees in a personal capacity.

Purpose

We recognise the diversity of people, cultures and social needs. Through donations, we aim to inspire a better quality of life by providing sustainable, long-term support to selected beneficiaries. We also encourage employee participation in donations and in broader community engagement efforts.

Selection Criteria

Coca-Cola HBC supports only initiatives that fall within one of the following pillars: community resilience (including relief and reconstruction), sustainable access to drinking water for communities, economic empowerment for young people and women, circular economy projects and initiatives, or locally relevant charitable initiatives.

All recipients of Coca-Cola HBC donations must be registered non-profit organisations, accredited schools, hospitals or other academic or social institutions. We prefer organisations that:

(a) Have publicly stated long-term goals and objectives;
(b) Are committed to sustainable development;
(c) Are recognised experts in the field relevant to the donation;
(d) Promote stakeholder engagement and volunteering;
(e) Are transparent in their activities and publish reports.

Coca-Cola HBC will not make donations to:

(a) Individuals, religious, political or legislative organisations;
(b) Organisations that discriminate based on race, colour, ethnicity, creed, religion, gender, gender identity/expression, national origin, citizenship, ancestry, sexual orientation, age, pregnancy, disability, or political affiliation;
(c) Organisations that do not fully respect human rights according to the UN Guiding Principles on Business and Human Rights and ILO conventions;
(d) Organisations directly involved in gambling, weapons, tobacco, and recreational or illegal drugs (with the exception of organisations involved in addiction treatment);
(e) Local professional sports teams, family reunions, beauty pageants or trade shows;
(f) Organisations whose values conflict with Coca-Cola HBC’s business principles and Code of Conduct;
(g) Projects that negatively impact the environment or biodiversity;
(h) Organisations that are not compliant or have negative records with authorities;
(i) Projects that could appear to be acts of corruption, bribery, or illicit practices, or that require confidentiality regarding the contribution received.

All donations are made at the discretion of Coca-Cola HBC. The company reserves the right to decline any request for support.

Governance

Donations covered by this policy may be made only in accordance with the following decision-making process:

In addition to the approval of the Country General Manager (GM) or a member of the Executive Leadership Team (ELT), donations intended for Public Institutions or entities directly or indirectly connected to Public Officials must be approved through the CoBC approval portal by the relevant Ethics & Compliance Officer (the request may be submitted by the GM or the ELT member, or on their behalf).

The Corporate Affairs & Sustainability team proposing the donation must verify whether the recipient is a Public Institution or is directly or indirectly connected to Public Officials by gathering publicly available information and/or conducting a due diligence process (also using third-party tools/platforms if available). In case of doubt, the team must consult with the relevant Ethics & Compliance Officer.

The following donations do not require prior approval from the General Manager, a member of the Group Executive Leadership Team, or the relevant Ethics & Compliance Officer:

(a) Free donations of (non-alcoholic) product up to 10 pallets per year to the same recipient
(b) Non-financial donations valued at up to EUR 10,000 per year to the same recipient
(c) Financial donations valued at up to EUR 10,000 per year to the same recipient

Donations may never be made under the following circumstances, regardless of any threshold:

• to obtain or receive, directly or indirectly, an improper business advantage for Coca-Cola HBC or to avoid a business disadvantage;

• to a Public Official or any entity directly or indirectly connected to a Public Official who may influence a current or anticipated matter concerning Coca-Cola HBC, or to “facilitate” or expedite governmental actions or services by a Public Official (e.g., permit requests, approvals or licenses, customs clearance, work permits or other administrative procedures, government inspections, contract negotiations, tenders or supplier selection processes);

• if excessive, unreasonable, inappropriate under the circumstances, or prohibited by local law;

• for any donation in cash or cash equivalents (such as gift cards or per diems/cash allowances).

Relevant expenses (excluding free product donations) must be recorded in the appropriate General Ledger AB accounts.

All contributions must be documented in writing, including the purpose and objectives of the contribution, the intended recipient, eligibility criteria, amount and payment arrangements, as well as any other relevant information.

Donations to charitable entities involving Public Institutions must be granted on the basis of a written agreement.

Coca-Cola HBC applies standard payment terms to donations as well.

Evaluation

Coca-Cola HBC ensures that beneficiaries comply with (and continue to comply with) the terms and objectives of the company’s Donor Policy. The company maintains regular dialogue with beneficiary organisations to assess the effectiveness and impact of donations, improve the management of ongoing projects, and identify future opportunities.

Coca-Cola HBC is also committed to communicating its donations and community engagement activities to employees and the public, to promote employee and stakeholder involvement in volunteer initiatives.

This policy will be reviewed at least once a year to incorporate the latest developments, stakeholder feedback or other relevant learnings.

Marcel Martin
Chief Corporate Affairs and Sustainability Officer
Coca-Cola HBC AG

Issue Date: 13 March 2025

Note: This policy replaces the previous policy titled “Corporate Charitable Contributions Policy” dated December 2020.