CODE OF ETHICS

Peet’s Coffee is committed to conducting its business with integrity, honesty, fairness, and respect. This Code of Business Conduct and Ethics establishes the principles and expectations that guide employees in their daily work and in their interactions with colleagues, customers, suppliers, business partners, contractors, competitors, and members of the communities we serve. Every employee is responsible for understanding these standards and applying them consistently while performing their duties.

Managers, officers, and supervisors have an additional responsibility to demonstrate ethical leadership and encourage their teams to follow both the intent and requirements of these standards. Managers are also expected to promote responsible business practices among vendors and other third parties working with or representing Peet’s.

Employees should understand that ethical responsibilities can sometimes extend beyond their own actions. Conduct involving immediate family members, significant others, or people living in an employee’s household may create a potential conflict or raise concerns about the employee’s business responsibilities. Employees should therefore remain alert to situations involving gifts, financial interests, business relationships, or other circumstances that could affect, or appear to affect, independent judgment.

Peet’s expects all business activities to be carried out in compliance with applicable laws and regulations. Employees are expected to make decisions honestly, protect the company’s interests, and treat others fairly. Anyone who becomes aware of conduct that may violate these standards should raise the concern promptly with an appropriate manager, Human Resources, Legal, or another designated reporting resource. Employees who are uncertain about whether a particular situation creates an ethical concern are encouraged to seek guidance before taking action.

Integrity and respect are fundamental to the way Peet’s conducts business. The company seeks to provide a workplace where employees are treated fairly and where discrimination, harassment, intimidation, and inappropriate conduct are not tolerated. Employment decisions should be based on legitimate business considerations, qualifications, performance, and applicable workplace requirements. Employees are expected to treat coworkers, customers, suppliers, contractors, and other third parties with professionalism and courtesy.

Peet’s also expects suppliers, customers, and other business partners to maintain respectful standards when interacting with employees. Concerns involving inappropriate behavior by a customer, supplier, or other external party should be reported through appropriate management or company reporting channels.

Competition must be conducted fairly. Employees may not obtain an advantage through unlawful or unethical methods, including improperly acquiring confidential information, trade secrets, or proprietary material belonging to another organization. If confidential information belonging to another company is received accidentally or there is uncertainty about whether information may legally be collected or used, employees should consult management or Legal before proceeding.

Business records must be accurate, complete, and maintained honestly. Financial and operational information must properly reflect the company’s transactions, assets, liabilities, revenues, costs, and expenses. Employees must not create misleading records, conceal transactions, misclassify information, maintain undisclosed funds, or otherwise interfere with the accuracy of company records. Transactions should be supported by appropriate documentation, and employees are expected to cooperate fully with internal and external accounting, auditing, and legal reviews.

Company resources must be protected and used responsibly. Peet’s property includes physical equipment, technology, software, facilities, products, confidential documents, customer information, intellectual property, employee time, and other business resources. These assets should be used for legitimate business purposes and safeguarded against theft, misuse, loss, and unnecessary waste. Employees must also respect applicable copyright, trademark, intellectual property, and other legal protections. Information handled through company electronic systems may be subject to appropriate access, review, monitoring, or disclosure in accordance with applicable policies and law.

Gifts, meals, entertainment, and other business courtesies must never be used to obtain an improper advantage. Any such benefits should have a legitimate business purpose, be reasonable in value, comply with applicable laws, and respect the policies of the customer, supplier, or other recipient. Cash or cash equivalents, excessive benefits, travel or lodging intended to influence decisions, and anything that could reasonably be viewed as a bribe or kickback are not appropriate. Special caution is required when government officials or public institutions are involved.

Employees must avoid using their position, company resources, information, or business opportunities for improper personal benefit. A conflict of interest may arise when personal relationships, investments, outside employment, financial interests, or other circumstances interfere with an employee’s ability to act objectively on behalf of Peet’s. Even the appearance of a conflict can damage trust. Potential conflicts should be disclosed and reviewed before the employee proceeds with the activity.

Employees should not work for or provide services to a competitor in circumstances that conflict with their responsibilities to Peet’s. Financial interests in competitors, customers, suppliers, or other business partners may also require prior review. Employees should not solicit improper favors, accept preferential treatment, direct company business toward a family member’s interests, supervise a household member where appropriate safeguards are not in place, or personally benefit from business opportunities discovered through their position at Peet’s.

Confidential information is an important company asset and must be protected. Employees may have access to business plans, financial information, pricing, customer information, marketing strategies, product development materials, technology, personnel information, supplier information, trade secrets, and other sensitive data. Such information should only be shared with individuals who have a legitimate business need to receive it, unless disclosure is authorized or legally required. Employees should also take reasonable precautions when handling confidential documents, computers, devices, and conversations in public or shared environments.

Privacy must be respected whenever employees collect, access, use, or process personal information. Sensitive information should be handled only for legitimate business purposes and in accordance with applicable privacy requirements, contractual obligations, and company policies. Access should be limited to authorized individuals, and reasonable safeguards should be maintained to prevent unauthorized disclosure or misuse.

Employees must comply with applicable laws in every jurisdiction where Peet’s operates or conducts business. Legal compliance includes requirements concerning anti-corruption, international trade, sanctions, export controls, competition, securities, and other areas relevant to the employee’s responsibilities. Employees should seek guidance from management or Legal whenever they are uncertain about a legal requirement.

Material non-public information must never be used improperly for personal investment decisions or shared with others for that purpose. Employees are expected to follow applicable insider trading requirements and maintain the confidentiality of information concerning Peet’s, JDE Peet’s, customers, suppliers, partners, and other companies with which the organization conducts business.

Competition laws must also be respected. Employees must not enter into agreements or arrangements with competitors that unlawfully restrict competition, including improper agreements involving prices, customers, territories, contracts, production, or other commercially sensitive matters. Employees should exercise particular care when communicating with competitors in professional or social settings and seek legal guidance whenever a proposed interaction raises concerns.

Employees have a responsibility to report suspected violations of company policies, laws, or ethical standards. Reports should provide sufficient information to allow the company to understand the nature of the concern, the individuals involved, and relevant circumstances. Concerns may be raised through management, Human Resources, Legal, or an appropriate Speak Up reporting channel. Employees are expected to cooperate honestly with investigations.

Peet’s does not tolerate retaliation against employees who make good-faith reports or raise legitimate concerns. No employee should be threatened, harassed, demoted, suspended, discriminated against, or otherwise disadvantaged because they appropriately report a concern or participate in an investigation. Reports will be reviewed promptly and handled with appropriate confidentiality while allowing the company to conduct a meaningful investigation.

Violations of this Code may result in corrective or disciplinary action, up to and including termination of employment. Depending on the circumstances, violations may also result in civil proceedings, regulatory action, or referral to appropriate authorities. Peet’s may take additional measures when necessary to prevent similar violations from occurring in the future.

Employees are responsible for becoming familiar with the policies and guidelines that apply to their positions. This Code provides broad principles rather than addressing every possible workplace situation. Additional company policies and resources may provide more specific guidance, and employees should seek assistance whenever a situation is unclear.

New employees are expected to review and acknowledge the Code and confirm that they understand their responsibilities. Employees may also be required to reaffirm their understanding periodically. Failure to sign an acknowledgement does not remove the obligation to follow the standards described in the Code.

Any exception to these standards requires appropriate authorization from the company’s General Counsel, while exceptions involving executive officers may require authorization from the Board of Directors. The Code may be reviewed and updated from time to time as business requirements, legal obligations, and organizational standards evolve.

For questions, concerns, or requests for guidance regarding business conduct and ethical responsibilities, employees may contact Peet’s through the appropriate internal reporting resources or use the following contact information: peets@gmail.com, 6295 SAGE AVE FIRESTONE, CO 80504, or +1 605 236 9867.