Green Claims

Policy & Governance

Process
MARCH 2023

For internal purposes only

Always subject to local legislation
CONTENT
03 07
InTRODUCTION Fundamental Principles:
Dos and Don’ts

04 13
Scope of Policy Global Green Claims
Governance Process

05 18
DEFINITIONs Green Claims Eligible
for Governance Process

06
TOOLBOX

2 For internal purposes only

Always subject to local legislation
 In 2021, HEINEKEN announced our ‘Brew a Better World – Raise the Bar’ 2030 goals. A new set of ambitions aimed at
driving a positive impact on the environment, social sustainability, and the responsible consumption of alcohol.

External communications and claims that demonstrate progress and/or delivery on our Brew a Better World ambitions can
help strengthen our brands with our consumers, investors, and customers, and can also help boost our credibility. At the
introduction

same time, regulators and advertising standards agencies are increasingly scrutinizing businesses over their environmental
advertising and marketing campaigns, and our consumers expect truthful information.

This global policy focuses on the environmental pillar of Brew a Better World – enabling credible and supported Green
Claims without being misleading or facing reputational and legal greenwashing risks, while ensuring our actions and
communications are always coherent. It also establishes a governance process for evaluating and approving new, unique
claims and related external communications through a consistent and cross-functional approach. This policy will be kept up
to date with all relevant external policies, regulations, and standards.

Thank you.

March 2023

James Thompson Stacey Tank Ernst van de Weert

Chief Commercial Officer Chief Corporate Affairs & General Counsel
Transformation

3
Scope of Policy
The fundamental principles set out in this global policy apply to:

• All Global Teams, all OpCos, all brands

• All Green Claims and related external communications made, for example, via marketing,
advertising, labels, packaging materials, point of sale materials, PR, websites, or corporate
communications. Any agencies appointed to create content on our behalf should also
comply with this policy

All Global Team, all OpCos, and all brands are responsible for being acquainted with this policy
and the Green Claims governance process, and for ensuring Green Claims and related external
communications are made in accordance with it.

Global Legal Affairs and Corporate Affairs Sustainability are responsible for managing and
updating this document as necessary, with input from relevant stakeholders. All documentation
will be stored on the HEINEKEN Brew a Better World Hub.

4 For internal purposes only

Always subject to local legislation
 Green claim
definitions
Any claim or communication that shows how
a product, service, brand, or business provides
a benefit or is less harmful to the environment.
This is also referred to as an “environmental
claim” or a “sustainability claim”.
5
Greenwashing
The use of misleading Green Claims (by
suggesting a positive or less negative impact on
the environment, when in fact this is untrue or
exaggerated) in any external communication.
toolbox
This global policy contains the fundamental principles (including dos and don’ts) for Green
Claims as well as the requirements for the Global Green Claims governance process.

To provide further support related to Green Claims, this Toolbox links to the following
company resources:

Greenwashing Video Green Claims Checklist Responsible Marketing Code Global Labelling Policy
(3 minutes)

6
Fundamental
Principles:
Dos and Don’ts
All Green Claims and related external communications must adhere to the following principles:

1. Green Claims must be truthful and backed up by third-party validated evidence

2. Green Claims must be clear and unambiguous
3. Green Claims must be presented in an overall context which does not confuse consumers
4. Green Claims making comparisons must be fair and meaningful
5. Green Claims must consider the full life cycle

To clarify, technical due diligence should always take place before any marketing strategy may be
considered. A proposed marketing strategy, including wording and scope of claims, can only be
defined after the outcome of the technical due diligence is positive.

More details on the “dos and don’ts” for these principles are included in the next pages.

7
Green Claims
Green Claims must be DO
1. Must be truthful and truthful and backed up
 Include true and factually correct information in Green Claims
backed up by evidence by third-party validated and provide all the information needed for consumers to make
2. Must be clear and evidence informed choices
unambiguous  Substantiate every Green Claim and ensure to hold robust,
Green Claims must be truthful and fact-based to enable consumers credible (scientific), relevant, and up to date evidence that is
3. must be presented in to make informed choices about our products. This means Green validated by a reputable third party
an overall context Claims should always be backed up by robust, credible evidence that  Be extra cautious with absolute Green Claims, especially 100%
which does not is validated by a reputable third party. The evidence should be up to claims, which are more likely to be inaccurate and to mislead.
confuse consumers date, meaning any Green Claim should be reassessed on a regular These claims must be supported by a high level of substantiation
basis.
4. comparisons must be
fair and meaningful

5. must consider the

full life cycle

ASK YOURSELF DON’T

 Is the Green Claim true and fact-based?
 Do we have appropriate, up to date evidence, validated by a Use misleading Green Claims that have not been backed up by
 
reputable third party? robust, credible evidence that is validated by a reputable third
 Is the evidence based on accepted science and understanding, party in any external communication
or is it contested/unproven? Make a Green Claim without providing consumers public access
 
 Is the evidence publicly available and can consumers verify the to the evidence to substantiate the claim.
claims?

8
Green Claims
Green Claims must be DO
1. Must be truthful and clear and unambiguous
backed up by evidence  Use correct terminology for Green Claims in line with internal
policies
2. Must be clear and Green Claims should be transparent and straightforward so  Clearly state if a Green Claim is only true if certain conditions or
unambiguous consumers can easily understand them. Green Claims should never be caveats apply
phrased in ways that are likely to confuse or deceive consumers.  Think about the best way to communicate additional, relevant
3. must be presented in information; for example, if product packaging does not allow
an overall context Information that is not included in a Green Claim may also be sufficient information, an additional website may be useful
which does not relevant and have an impact on choices consumers make. It is  Choose the right wording when communicating about strategy
confuse consumers therefore crucial not to omit or hide important relevant information; and future goals or ambitions, acknowledging we’re not there
for example, about the product or production process as a whole. yet. Communication about future plans is only relevant when we
4. comparisons must be have tangible plans to reach any such goal with concrete time-
fair and meaningful bound commitments

5. must consider the

full life cycle ASK YOURSELF
 Is the Green Claim only true and accurate under certain
conditions or with caveats, and are these clear for consumers?
 Have we used terms in accordance with internal policies?
 Is there a risk that the meaning of (terms used in) the Green
Claim is unclear to consumers?
DON’T
Use generic or unsubstantiated wording, including but not
 
limited to ‘sustainable’, ‘environmentally friendly’, ‘eco-friendly’,
‘eco’, ‘green’, ‘nature’s friend’, ‘ecological’, ‘environmentally
correct’, ‘climate friendly’, ‘gentle on the environment’, ‘pollutant
free’, ‘biodegradable’, ‘zero emissions’, ‘carbon friendly’, ‘climate
neutral’, or broader claims such as ‘conscious’ or ‘responsible’
Communicate vague ambitions for the future without having
 
concrete plans to get there
Forget to include (or hide or omit) information in or near a Green
 
Claim that is relevant for consumers to make an informed choice

9
Green Claims
Green Claims must be DO
1. Must be truthful and presented in an overall
backed up by evidence context which does not  Make sure the meaning consumers are likely to take from any
Green Claim, in the context of the entire advertising or packaging
2. Must be clear and confuse consumers (including audio or visual elements), matches with reality
unambiguous  Only use logos or symbols that reflect the standards for which
The entire context of the advertising or packaging where the Green Claim a product is officially certified. The requirements for any such
3. must be presented in is presented must give an accurate impression about the environmental certification should be sufficiently strict and transparent. It must
an overall context impact of the relevant product, process, brand, or business. This includes be clear what a certification stands for and its criteria
which does not the use of audio and visual elements, like images, colours, graphics, logos,  Avoid developing our own logos or symbols. Internally developed
confuse consumers and symbols. The overall impression conveyed by any communication is logos or symbols may only be considered if full checks have
relevant to determine whether it is misleading. been done that no similar, external certifications exist. Proposed
4. comparisons must be logos or symbols must be approved through the Green Claims
fair and meaningful governance process and comply with all Green Claims policies.
 Stay humble, always acknowledging the journey we’re on and the
5. must consider the fact that our overall impact on the environment should be further
full life cycle improved over the coming years
ASK YOURSELF
 Does the Green Claim align with the overall impression given by
the marketing or packaging?
 Is the overall impression given by the marketing or packaging
DON’T
likely to deceive consumers about the actual environmental
impact?  Create a false impression with visual or audio elements, labels, or
 What images do we convey? For example, if we show a car, how certifications
many people are inside? Or if we show a leisure activity, how  Make a product be perceived as more climate friendly than
polluting is it? it actually is, even when the wording of the claim is factually
 Is the Green Claim objective and not subjective? correct; for example, images of planet Earth, leaves, etc
 Is the Green Claim about environmental benefits that are
required by law, or something that consumers would expect
anyway from this type of product?

10
Green Claims
Green Claims making DO
1. Must be truthful and comparisons must be fair
 Compare “like with like,” i.e., products that meet the same needs
backed up by evidence and meaningful and are intended for the same purpose
2. Must be clear and  Present comparisons so that consumers can make informed
It is important that consumers are not misled by the way comparative choices about the relevant merits of one product over another
unambiguous claims are made. Comparisons should be based on clear, up to date,  Make comparisons about our products or production processes
and objective information. We should never promote one product or against (i) comparable previous products or production
3. must be presented in brand to the detriment of another if the comparison is inaccurate or
an overall context processes, or (ii) comparable products or production processes of
false. other companies, or (iii) the generally accepted standard in the
which does not
confuse consumers industry
 Base comparisons on percentages or absolute values, in standard
4. comparisons must be units that consumers know and understand
fair and meaningful

5. must consider the

ASK YOURSELF
full life cycle
Is the claim comparing like with like?

 Is the comparison fair, representative, and clear? DON’T
 Forget to justify comparisons in a clear manner; for example, to
show that a product provides a net environmental benefit over
that of a previous product, or competitor products
 Make claims about improvements (reduced negative impact on
the environment) when such improvements are already required
by legislation

11
Green Claims
Green Claims must DO
1. Must be truthful and consider the full life cycle
backed up by evidence  Consider the entire life cycle of a product or process when
To assess whether a product- or process-specific claim could be making a claim
2. Must be clear and misleading, the full life cycle should be taken into account. This does  Be specific about the life cycle stage being referred to with a
unambiguous not mean that the scope of every claim must consider the full life claim
cycle. It means that, if the claim is referring to a specific life cycle
3. must be presented in stage, then that stage should be clearly identified to consumers, and
an overall context it should not overemphasize a relatively small percentage of the full
which does not life cycle.
confuse consumers DON’T
4. comparisons must be
fair and meaningful ASK YOURSELF  Make claims about a specific aspect of a product or process,
even when clearly indicated, if there are still significant negative
5. must consider the  Does the claim relate to the product or process as a whole, or impacts from that product or process as a whole
full life cycle does the claim only relate to one specific aspect of the product  Cherry-pick information to include in a claim without considering
or process? If yes, is this made clear? the entire life cycle
 By making a claim about one element of a product’s life cycle,  Overemphasise positive environmental aspects that only provide
does the claim mislead the consumer about other aspects? marginal benefits, when the net environmental impact is still
negative

12
Global Green Claims
Governance Process
The global Green Claims governance process applies to new, unique claims that require data
collection, validation, and third-party verification. The Green Claim may refer to the way in which
products are produced, packaged, distributed, used, consumed and/or disposed.

Please see Table 1 for claims that typically qualify and key considerations for each one, including:

 Renewable energy use

 Net Zero / carbon neutral
 Carbon footprint reductions
 FSC/PEFC certifications for packaging
 Recycled content claims
 Organic
 Water-related claims
 Sustainably farmed barley
 Zero waste and/or zero waste to landfill

If you are unsure whether your claim qualifies for the process, please contact Global Legal Affairs
and Corporate Affairs.1 Certain claims may not be included in Table 1 but should still be presented
to the External Communications and Advocacy Working Group, e.g., an exceptionally high-
visibility marketing campaign.

1
Please note the process does not apply to external communications on annual progress toward Brew a Better World emissions reduction targets
in annual reports and similar materials.

13
Step-by-step
process

1
I nitiative owner (OpCos, Global Brands, Global Functions) contacts Working Group lead to request
review process.

a. Working Group lead: Hannah Hunt (hannah.hunt@heinekenusa.com) and

Hannah Verhoeven (hannah.verhoeven@heineken.com)

b. Initiative owners may designate their preferred point of contact from their team to liaise
with the Working Group

c. Initiative owners at OpCos must align internally across local Legal and Corporate Affairs
functions before reaching out to the Working Group

d. Initiative owners must complete the review process before external communication
strategies are created and shared with other internal and external stakeholders

14
2
Initiative owner completes and submits the necessary due diligence to Working Group
lead. The following details must be submitted prior to the first meeting:
a. A written definition of the claim: Full details on the claim’s scope with related
definitions
b. Technical evidence: An Excel file with data and calculations to support the claim
 All data inputs and calculation methodologies must be identified and defined in
the Excel file in an easy-to-understand manner
 All data sources must be provided
15
c. Third-party validation: Documentation and verification from an independent third
party to validate the claim, including a methodology review and confirmation of
data accuracy and compliance with applicable standards or certifications.
i. The initiative owner may select its preferred third party, but they must have
the expertise, equipment, and infrastructure required to perform the necessary
validation activities.
ii. If the Green Claim relates to a supplier’s product, e.g., a glass bottle that is
produced with less carbon emissions, it should be the responsibility of the
supplier to hire the third party and present the validation
d. A written summary of potential risks and impacts:
i. An assessment of the local legal and regulatory landscape, and potential
reputational risks, including how identified risks are being managed
ii. (If relevant) A scalability assessment: Initiative owners for pilot projects must
identify the percentage that the pilot will represent of the total relevant
portfolio; they must also prove commitment to scale to a minimum 5% of the
total relevant portfolio in the next five years
 3
Once all required documentation has been submitted the claim will be reviewed. Where possible,
claims will be addressed efficiently via email. Only the most difficult / highly visible Green Claims will be
reserved for the Working Group meeting. In that case, the initiative owner is invited to the subsequent
Working Group meeting to present and answer any questions. A cross-functional HEINEKEN Global
Team reviews the pending claim.

a. The Working Group will meet on a bi-monthly basis (every 8 weeks)

b. Claims are only escalated to the Carbon SteerCo (and potentially the S&R SteerCo) when a
decision cannot be reached by the Working Group due to exception potential impact on the
business (financial, legal, or reputational). The Carbon and S&R SteerCos also meet on a bi-
monthly basis.

4
Pending approval, the initiative owner may then develop its external marketing and communication
strategy and share with relevant internal and external stakeholders.

16
Process Flow:
Green Claims
Governance Claim Permitted Claim Permitted Claim Permitted

Process Potentially further research Potentially further research Potentially further research
to be done to be done to be done

External Comms and

Request for Green Claim Advocacy Working Group Carbon SteerCO S&R SteerCo

CA Sustainability, Legal, CA Escalation CA Sustainability, Legal, CA Escalation CA Sustainability, Legal, CA

Neccesary Neccesary
Initiative Owner Comms Comms Comms
(OpCo, Global Brands, Glo-
bal Function) As needed As needed As needed
Procurement, Supply Procurement, Supply Procurement, Supply
Chain, Commerce, Chain, Commerce, Chain, Commerce,
Social Sustainability Social Sustainability Social Sustainability

Claim Not Permitted Claim Not Permitted Claim Not Permitted

Potentially further research Potentially further research Potentially further research

to be done to be done to be done

17
direct
Green Claim: Table 1: Green Claims Eligible
Renewable energy use for Governance Process
Carbon neutral / net
zero
Green Claim:
Carbon footprint Renewable energy use Key Considerations
reduction

FSC / PEFC certifications Renewable energy use: Eligible A “brewed with renewable energy” claim may only
renewable energy technologies be considered if all processes in the relevant brewery
Recyclability include solar, wind, geothermal, (including packaging and on-site logistics) are covered
hydro, sustainably sourced by renewable energy. The claim must cover both
Recycled content biofuels, geothermal, and ocean renewable thermal and electricity demand.
Post-consumer material energy.
The scope of the claim should be limited to renewable
Organic energy terminology, e.g., not “sustainable energy”
which is not a clear term. The use of “green energy”
Water and/or “green electricity” terminology may be
considered with clear explanation in the claim.
Sustainably farmed
barley A “brewed with renewable energy” claim can only be
made when it is 100% renewable. Otherwise, claims
Zero Waste / Zero Waste must be qualified with a percentage.
to Landfill
Technical evidence to support the claim must include:
• Fully validated BCS energy module data
• Relevant renewable energy contracts and invoices
for energy imports and exports
• Up-to-date Net Zero roadmap
Renewable energy claims are only allowed for:
• Production sites, i.e., breweries
• A specific brand, including all products (SKUs)
in the specified market, including imported
products, promotions, and line extensions.
If a claim will require mass balance allocation, e.g.,
allocation to a certain brand within a broader portfolio
based on volume, the Working Group will decide
whether to allow this practice on a case-by-case basis,
based on a risk assessment presented by the initiative
owner.
Claims must represent a long-term commitment to
renewable energy. As such, a purchase commitment
equal to the claim must be in place for at least 3 years
after the time period represented by the claim.

18
 Table 1 – Continued

Green Claim:
Green Claim:
Renewable energy use Carbon neutral/ Key Considerations
net zero
Carbon neutral / net
zero
Carbon neutral and/or net zero New claims of achieving carbon neutrality are not currently allowed, pending internal policy on acceptable
Carbon footprint criteria.
reduction
Any claims of achieving “Net Zero” are not currently allowed, as criteria have not been sufficiently defined by
FSC / PEFC certifications external standard-setting organizations.

Recyclability Please see “Renewable Energy Use” section in considering an alternative claim

Recycled content
Post-consumer material Green Claim:
Carbon footprint Key Considerations
Organic reduction

Water
Carbon footprint reduction: The Applicable to packaging materials for our brands, e.g., bottles and cans. Third-party validation must include a life
Sustainably farmed total greenhouse gas emissions cycle analysis completed according to PEFCR for Beer methodology (if not PEFCR for Beer, initiative owner must
barley reduced through the entire life present reasoning for alternative methodology for approval). It should be the responsibility of the supplier to
cycle of a product’s packaging hire the third party and present the validation.
Zero Waste / Zero Waste materials.
to Landfill Claims to a reduced carbon footprint must be based on percentages or absolute values, in standard units
consumers will know and understand, e.g., 30% reduction in carbon dioxide equivalent (CO2e) emissions per 330
mL bottle compared to previous bottles.

19
 Table 1 – Continued

Green Claim:
Green Claim:
Renewable energy use FSC / PEFC Key Considerations
certifications
Carbon neutral / net
zero
FSC / PEFC certifications for FSC and PEFC are both internationally recognised certifications for wood and paper from forests that are
Carbon footprint packaging materials sustainably managed.
reduction
The FSC and PEFC labels can be used on packaging materials for respectively FSC- and PEFC-certified
FSC / PEFC certifications products. Trademark usage must strictly follow FSC and PEFC requirements. Packaging suppliers must provide
documentation to substantiate certifications. If a claim will require mass balance allocation, e.g., supplier
Recyclability allocation of FSC-certified material to a certain customer within total production, the supplier must provide
documentation to confirm we have a unique claim, e.g., through contracts and/or invoices.
Recycled content
Post-consumer material No other claim language (e.g., “sustainable forests” or “sustainable paper/carton”) is allowed on packaging labels.
The use of these phrases in non-label marketing may be allowed if it is clearly substantiated with an FSC/PEFC
Organic certification.

Water

Sustainably farmed
barley Green Claim:
Recyclability Key Considerations
Zero Waste / Zero Waste
to Landfill

Recyclability: The ability of a
product to be recycled, i.e., used
again in any way, at the end of
its life cycle.
Claims related to “100% recyclable” or “fully recyclable” are not currently allowed, pending revisions to EU
legislation on packaging and packaging waste that will provide new recyclability criteria.
Claims to encourage recycling by the consumer are an acceptable alternative, e.g., “Please help us recycle” or
“Bring this package to a recycling point.”

20
 Table 1 – Continued

Green Claim:
Green Claim:
Renewable energy use Recycled content/
Post-consumer Key Considerations
Carbon neutral / net material
zero

Carbon footprint
reduction Recycled content: The Claims to recycled content must be more precisely described as “XX% made from recycled materials.”
proportion of recycled material
FSC / PEFC certifications (pre- and post-consumer) Claims to “100% made from recycled materials” are not allowed due to increasing regulatory complexity.
used to create a product or “Fully made from recycled materials” may be an acceptable alternative depending on available evidence and
Recyclability its packaging. Expressed as a third-party validation. If the claim is not for fully recycled materials, then the claim must be qualified with a
percentage (%) number. percentage.
Recycled content
Post-consumer material Post-consumer material: In any claim, it should be substantiated to which material and part of the packaging the claim is referring. For
Material generated by example, if a claim is made on a glass bottle, it should be clear whether the claim only refers to glass, or also to
Organic households or by commercial, cap and label.
industrial, and institutional
Water facilities in their role as end-users When claiming % recycled content, only post-consumer recycled content should be taken into account. When
of the product which can no calculating recycled content, the methodologies laid out in PEFCR for Beer should be used. If a claim will
Sustainably farmed longer be used for its intended require mass balance allocation, e.g., supplier allocation of recycled material to a certain customer within total
barley purpose. This includes returns of production, the supplier mass balance allocation methodology will be considered acceptable pending third-party
material from the distribution verification.
Zero Waste / Zero Waste chain.2 As an example, pallet foil
to Landfill around pallets of incoming glass
may qualify as post-consumer
material, but scrap from the
production of the foil would not
qualify.

2
ISO 14021:2001, “Environmental labels and declarations - Self-declared environmental claims.”

21
 Table 1 – Continued

Green Claim:
Green Claim:
Renewable energy use Organic Key Considerations

Carbon neutral / net

zero
Organic: referring to the organic
Carbon footprint production of agriculture
reduction products, or any alternative
terms in local languages
FSC / PEFC certifications (including “bio” or “eco”) having
the same meaning
Recyclability
In Europe, the requirements for organic production and labelling of organic products are set out in Regulation
(EC) No 2018/848. This Regulation contains strict criteria that should be met for agriculture products to qualify
as “organic”. In Europe, the requirements of the Regulation should always be followed.
Outside Europe, local legislation should always be followed. In case no local legislation applicable to organic
products exist, Regulation (EC) No 2018/848 should be complied with before any “organic” claim can be made.

Recycled content
Post-consumer material

Organic
Green Claim:
Water Water Key Considerations

Sustainably farmed
barley
Water: Claims related to the Watershed benefits cannot be associated with a brand directly, but rather to a specific facility and watershed,
Zero Waste / Zero Waste positive results of water-related per guidance from the Alliance for Water Stewardship, in alignment with UNGC Water Resilience Coalition Net
to Landfill efforts. Examples include Water Positive concept. The term “water neutral” cannot be used as we only manage direct water impact and not
reductions in water use and indirect water impact, as the term translates.
water-balancing initiatives.

22
 Table 1 – Continued

Green Claim:
Green Claim:
Renewable energy use Sustainably farmed Key Considerations
barley
Carbon neutral / net
zero
Sustainably farmed barley: Initiative owner must follow Global Sustainable Agriculture Initiative (SAI) and Farm Sustainability Assessment
Carbon footprint Barley that is grown in a way (FSA) definitions and methodologies, with at least 75% of barley volume achieving FSA Silver or equivalent.
reduction that ‘protects and improves
the natural environment, the
FSC / PEFC certifications social and economic conditions
of farmers, their employees,
Recyclability and local communities, and
safeguards the health and
Recycled content welfare of all farmed species.’
Post-consumer material

Organic
Green Claim:
Water Zero Waste / Zero Key Considerations
Waste to Landfill
Sustainably farmed
barley
Zero Waste and/or Zero Waste These types of claims can only be made in reference to specific production/event sites, not for specific products.
Zero Waste / Zero Waste to Landfill: The conservation
to Landfill of all resources by means Note: While a widely accepted standard does not exist to certify Zero Waste and/or Zero Waste to Landfill claims,
of responsible production, third-party validation is still possible based on criteria as defined by the Zero Waste International Alliance.
consumption, reuse, and recovery
of products, packaging, and
materials without burning and
with no discharges to land,
water, or air that threaten the
environment or human health.3

23 3
Zero Waste International Alliance.
Questions?
Reach out to

Hannah Hunt
hannah.hunt@heinekenusa.com

Hannah Verhoeven
hannah.verhoeven@heineken.com

Or check

Brew a Better World HUB