Insider Trading

See the file below for the Heineken Holding N.V. Regulations on the holding of and effecting transactions in Shares and certain other Financial Instruments.

Heineken Holding N.V. Insider Dealing Policy

Disclosure Policy

The objective of the Disclosure Policy is to ensure that communication of share price sensitive information concerning Heineken N.V. and Heineken Holding N.V. is timely made, balanced and accurate, and is disseminated in accordance with all applicable legal, regulatory and stock exchange requirements.

This policy applies to all employees of the Heineken Group (HEINEKEN), to the members of the Executive Board and Supervisory Board of Heineken N.V. and to the members of the Board of Directors of Heineken Holding N.V.

This policy applies to all written and oral communications on share price sensitive information.

Disclosure policy Heineken N.V. and Heineken Holding N.V.