The Progress Updates Concerning The Letter From Amnesty International

Further to the release on 15 June 2018 in which Kirin stated that it would conduct an investigation into a US$6,000 donation made by Myanmar Brewery Limited (“MBL”) on 1 September 2017, the company would like to provide an update.
The Statement Concerning The Release Amnesty International Published (June 15, 2018)

Investigation

While the donation was requested and given explicitly to serve humanitarian purposes, we initiated this investigation in response to concerns raised by Amnesty International that the donation may have been made to the Myanmar military. Our investigation was able to confirm that the US$6,000 donation was transferred, by way of bank transfer, to the Rakhine state government. However, as of this time, we have been unable to determine conclusively that the donation was used for humanitarian purposes, as intended.

The inability to fully account for the use of this charitable donation is a concern and highlights the need for a more robust charitable donations policy and more rigorous due diligence and follow-up processes at MBL. We will continue the investigation and in parallel have taken urgent steps to strengthen our systems.

Action Plan

In response to our findings to date, Kirin has implemented the following action plan:

1. We suspended charitable donations by MBL upon learning of Amnesty International’s concerns, pending the upgrade of donation policy and due diligence.
2. We engaged an external independent consultant to perform a review of MBL’s charitable donations policy and with their support, developed a new MBL Charitable Donations and Volunteering Policy in August 2018. Further information on the policy is set out below:
   • In October 2018, the policy was approved by the MBL Board of Directors and will be integrated into the MBL code of conduct in 2019. It is available on the MBL website for future partners to read.
     MBL website
   • The policy was drafted to ensure there is absolute clarity in terms of the charitable projects covered by MBL’s corporate citizenship programme. Specifically, the policy states MBL will provide support only to legitimate social organisations who work in the areas of education, health, sport and humanitarian disaster relief and who work for the benefit of all the people in their communities, regardless of ethnicity, social background or religion. The objectives of the programme are exclusively humanitarian, and MBL only supports projects that are politically neutral.
   • MBL sees these charitable contributions as an important part of its corporate social engagement but it is imperative that MBL has a close understanding of its partners and the programmes they would like MBL to support. We worked with the same external independent consultant to draft a set of internal implementation guidelines to support the new Charitable Donations and Volunteering Policy. The guidelines include a checklist to assist MBL in assessing if potential partners meet the criteria of the programme. To ensure MBL has the appropriate visibility on how donations are used, the guidelines also set out what is expected from partners in terms of documenting how the donations are used.
3. As part of launching the new policy and guidelines, in November 2018, MBL’s Managing Director and Deputy Managing Director conducted training with MBL senior leadership including heads of department and key management to ensure they understand the new policy and received practical training in terms of how to apply the implementation guidelines.
4. We also hosted meetings with our joint venture partner, MEHL, in August and October 2018, to ensure they understand the new Charitable Donations and Volunteering Policy and how it forms part of Kirin’s broader commitment to respecting human rights.
5. We have committed to a regular internal audit to ensure compliance of the new Charitable Donations and Volunteering Policy and red-flag areas for improvement.
6. We also expedited a planned human rights impact assessment of Kirin’s operations in Myanmar, conducted by an external independent consultant. The summary findings and action plan from this assessment can be found on our website.
   Kirin Group’s initiatives to support respect for human rights