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The Carlsberg Group shall respectinternational human rights principlesand international labour standards.

We shall support the United Nations Universal Declaration of Human Rights and the International Labour Organi-sation’s Declaration on Fundamental Principles and Rights at Work.

The Policy addresses followingheadings:

1. Non-discrimination2. Forced labour3. Child labour4. Freedom of association

and collective bargaining5. Harassment6. Working hours, benefits

and wages7. Leave8. Employee contracts / letters

CONTENTS

1.0 Non-discrimination2.0 Forced labour3.0 Child labour4.0 Freedom of association

and collective bargaining5.0 Harassment6.0 Working hours, benefits

and wages7.0 Leave8.0 Employee contracts / letters

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YOur employees are of great value to us and are the key to our success. The Carlsberg Groupshall strive to establish a workplace where ouremployees can develop their potential in an open and inspirational working environment. We shall maintain a strong commitment to high standards for a fair, respectable and safe workplace for all employees in the Carlsberg Group.

Jørgen Buhl RasmussenPresident & CEO

Anne-Marie SkovVice-President Group Communication, Chair CSR Steering Committee

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NON-DISCRIMINATION

1.1 We shall not accept any form of discrimination against our employees based on race, colour, gender, language, reli- gion, political or other opinion, caste, national or social origin, property, birth, union affiliation, sexual orientation, health status, age, disability, or other distin-guishing characteristics. Any employment-related decisions, from hiring to termi-nation and retirement, shall be based only on relevant and objective criteria.

FORCED LABOUR

2.1 The Carlsberg Group shall prohibit any form of forced labour, including bonded labour, indentured labour, slave labour, or human trafficking. Workers shall be allowed to move around freely and leave their place of work when their shift ends.

1.0 3.0 4.0 6.0 7.0CHILD LABOUR

3.1 The Carlsberg Group shall not condone the hiring of child labour under any circumstances.The minimum age for full-time employment shall be 15 or the legal minimum age for employ-ment, whichever is greater.If the local minimum working age is 14 in accordance with exceptions for developing countries, this lower age shall apply. The Carlsberg Group shall refrain from hiring workers under the age of 18 for positions that require hazardous work that could jeopardise their health, safety or morals.

FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING

4.1 The Carlsberg Group shall respect employees’ rights to form, join or not join a labour union or other organisation of their choice, and to bargain collectively in support of their mutual interests without fear of punitive actions such as intimidation, harassment or termination of employment. If no legally recognised union exists in the area of operations, or if only state-authorised organisations are allowed, the Carlsberg Group shall respond favourably to initiatives to establish alternative means to achieving effective represen-tation of worker’s interest.

HARASSMENT

5.1 Carlsberg Group companies shall protect workers from any acts of physical, verbal, sexual or psychological harassment, abuse or threats in the work-place by either their fellow workers or their managers.

WORKING HOURS BENEFITS AND WAGES

6.1 The Carlsberg Group shall ensure that we adhere to all applicable laws or industry standards, whichever may be more stringent, relating to wages, working hours, overtime and benefits. Employees shall not be required to work more than 60 hours a week, including overtime, on a regular basis (or the limits on regular hours and overtime allowed by local laws and regulations). Wages for overtime shall be paid in legal tender on a regular basis. Wage deductions as a disciplinary measure shall not be permitted unless provided for by national law. Employees shall be entitled to at least one day off in seven, and shall be given reasonable breaks while working and sufficient rest periods between shifts. The Carlsberg Group shall be committed to continuously developing employee skillsand capabilities, and to providing opportunities for career advancement. In the event of major layoffs, the Carlsberg Group shall meet or exceed applicable laws and industry standards.

LEAVE

7.1 The Carlsberg Group shall grant all employees the right to sick leave and annual holiday, as well as parental leave for employees who have to care for a newborn or newly adopted child as provided by national legislation. Employees who take such leave shall not face dismissal or threat of dismissal, and shall be able to return to their former employment at the same rate of pay and with the same benefits.

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2.0 5.0 8.0EMPLOYEE CONTRACTS / LETTERS

8.1 All Carlsberg Group employees shall be provided with a written, understandable and legally binding labour contract/letter. The Carlsberg Group shall not rely on part-time, short-term or casual labourers, trainees or false apprenticeships to pay lower wages and offer fewer benefits.

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SCOPEThe Carlsberg Group Labour RightsPolicy shall apply to all employeesat Carlsberg Group subsidiaries,including workers who are engagedinformally, on short-term contractsor on a part-time basis.

Our joint ventures and businesspartners are strongly encouragedto adopt and implement our Policy.We require all our suppliers and licensees to comply with the Supplier and Licensee Code of Conduct, which sets out our social, environmental and ethical standards.

Our subsidiaries are defined ascompanies Carlsberg Breweries A/Sdirectly or indirectly owns or controls more than 50% of the voting rights in the subsidiary or which it, in some other way, controls.

COMPLIANCEAll subsidiaries within the CarlsbergGroup shall comply with the provi- sions of the Labour Rights Policy as well as with national laws and regulations. Should there be differ-ences between the content of this policy and national laws or other applicable standards, the more stringent requirements shall apply.

Conflicts between the provisions of this policy and national laws orother applicable standards shall beevaluated by the Carlsberg GroupHeadquarters in cooperation withthe Group companies.

Companies that have recentlyjoined the Carlsberg Group may be granted exemption from the policy’s provisions during the integration period.

APPLICATIONCarlsberg Group subsidiaries shallimplement the Labour Rights Policyin their daily work.

All Group companies shall takeappropriate action to ensure thatthe provisions of this policy arecommunicated to their employeesin their own language.

Compliance with policies, guidelinesand codes shall be regularly tracked, and relevant corrective action plans identified and implemented.

The Labour and Human RightsPolicy is supported by “Labour andHuman Rights Guidelines” which isan integral part of the Policy.

Valid for: Carlsberg Group subsidiariesApproved by: Executive CommitteeDocument type: Policy – level 1Reference: Group CSR PoliciesVersion: 001Approval date: 04.01.2009

The Carlsberg Group shall periodically review the Labour and Human Rights Policy and Guidelines in order to ensure its continued adequacy and relevance for our business. The most recent version will always apply.

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Carlsberg Group100 Ny Carlsberg Vej

1799 Copenhagen VDenmark

Phone +45 3327 3300Fax +45 3327 4808

www.carlsberggroup.com