CENTRAL EUROPEAN DISTRIBUTION CORPORATION CODE OF CONDUCT INTRODUCTION

This Code of Conduct is a statement by Central European Distribution Corporation (“CEDC”) of the manner in which it intends to conduct its business activities. It sets forth the standards of conduct and ethics which CEDC requires of all of its directors, officers and employees and all of the directors, officers and employees of each of its subsidiaries.

This Code of Conduct is not an employment contract. It does not change the status of any employee of CEDC or any of its subsidiaries. Compliance with its terms, however, is a condition to continued employment and, as the case may be, directorship with CEDC and its subsidiaries. Accordingly, each director, officer and employee of CEDC and each of its subsidiaries must acknowledge receipt of this Code of Conduct and agree to be bound by its terms.

CEDC reserves the right, in its sole discretion, to modify this Code of Conduct. CEDC is responsible for updating the standards as it deems appropriate to reflect changes in the legal and regulatory framework applicable to CEDC, the business practices within its industry, its own business practices and the prevailing ethical standards of the community in which it operates. While CEDC’s Chief Executive Officer will oversee the procedures designed to implement this Code of Conduct to ensure that they are operating effectively, it is the individual responsibility of each director, officer and employee of CEDC and its subsidiaries to comply with this Code of Conduct.

All references in this Code of Conduct to the “Company” are intended to include CEDC and each of its subsidiaries.