About the Code of Conduct

The Code of Conduct provides an overview of the laws and policies that govern employees' activities within Altria Group and its companies. In addition to knowing the legal and ethical responsibilities that apply to their jobs, employees are obligated to uphold the Code's commitment to doing what is right and reporting what is not.

Ask Before Acting

The foundation of the Code is based on the following four questions that we ask employees of Altria Group's companies to consider before taking action:

• Is it legal?
• Does it follow Company policy?
• Is it right?
• How would it look to those outside the Company?

As reflected in the Code, our companies are dedicated to protecting employees who are seeking advice, raising concerns or reporting misconduct. We do not tolerate retaliation against an employee who voices a concern or reports misconduct. There are many options available to employees to ask questions or raise concerns, including any member of their management, the Altria Group Chief Compliance Officer, their company's chief compliance officer, or any member of Law, Human Resources or the Compliance and Integrity departments. Additionally, the Integrity HelpLine is available 24 hours a day/seven days a week. If they choose, employees can make anonymous reports through the HelpLine.

Employee-Driven Compliance and Integrity Program

Our Compliance & Integrity Program initiatives would not be successful without regular involvement and input from our companies' employees. Both the Code of Conduct and supplemental web-based training have been developed with employees in mind and are based on internal collaboration.