1 AUGUST 10, 2021 Dutch Bros Inc., and Dutch Mafia, LLC and its

UTCH BROS INC.

ODE OF BUSINESS CONDUCT AND ETHICS

PPROVED BY THE BOARD OF DIRECTORS

UGUST 10, 2021

Dutch Bros Inc., and Dutch Mafia, LLC and its subsidiaries (which include Boersma Bros. LLC, DB

Franchising USA, LLC, DB Management Co., and Dutch Bros., LLC) (together “Dutch Bros”)

committed to maintaining the highest standards of business conduct and ethics. We expect every employee,

officer and director to not only read and understand the business practices and principles described below,

but to also apply good judgment and the highest personal ethical standards in making business decisions.

Please remember you should consider not only your own conduct, but also that of your family members,

significant others and other people in your household.

Do not hesitate to ask questions about whether certain conduct may violate the code, to voice concerns or

to clarify gray areas. You should also be alert to possible violations and report them without fear of

retaliation. See Section 15 below for instructions on how to ask questions or report violations.

Any employee who violates the standards in this code may be subject to disciplinary action, that, depending

on the nature of the violation and the history of the employee, may range from a warning or reprimand to

termination of employment and, in appropriate cases, civil legal action or referral for criminal prosecution.

While this code covers a wide range of business conduct, it is not the only document that addresses the

conduct of Dutch Bros employees, officers and directors. For instance, this code references separate a more

detailed policy relating to insider trading. Also, the Dutch Bros Shop Employment Handbook and HQ

Employment Handbook include policies relating to, among other things, harassment and discrimination.

Finally, for those Dutch Bros employees who have signed a Proprietary Information and Inventions

Agreement in connection with their employment, they remain subject to the terms thereof. If you have any

questions about whether your behavior or any behavior you observe is appropriate, it is your responsibility

to ask.

1. H

ONEST AND ETHICAL CONDUCT

It is our policy to promote high standards of integrity by conducting our affairs in an honest and ethical

manner. Dutch Bros’ integrity and reputation depends on the honesty, fairness and integrity brought to the

job by each person associated with us. Unyielding personal integrity and sound judgment is the foundation

of corporate integrity.

2. L

EGAL COMPLIANCE

Obeying the law is the foundation of this code. Our success depends upon each employee operating within

legal guidelines and cooperating with local, national and international authorities. We expect employees to

understand the legal and regulatory requirements applicable to their business units and areas of

responsibility. Violation of domestic or foreign laws, rules and regulations may subject an individual, as

well as Dutch Bros, to civil and/or criminal penalties.

3. I

NSIDER TRADING

Employees, officers and directors who have access to confidential (or “inside”) information are not

permitted to use or share that information for stock trading purposes. All non-public information about

Dutch Bros

or about other companies is considered confidential information. To use material non-public

information in connection with buying or selling securities, including “tipping” others who might make an

investment decision on the basis of this information, is illegal. Please refer to Dutch Bros’ Insider Trading

Policy for more detailed information.

4. I

NTERNATIONAL BUSINESS LAWS

Our employees, officers and directors are expected to comply with the applicable laws in all countries to

which they travel, in which they operate and where we otherwise do business, including laws prohibiting

bribery, corruption or the conduct of business with specified individuals, companies or countries. The fact

that, in some countries, certain laws are not enforced or that violation of those laws is not subject to public

criticism will not be accepted as an excuse for noncompliance.

5. A

NTITRUST

Antitrust laws are designed to protect the competitive process and impose severe penalties for certain types

of violations, including criminal penalties. These laws are based on the premise that the public interest is

best served by vigorous competition and will suffer from illegal agreements or collusion among

competitors. Certain kinds of information, such as pricing, production and inventory, should not be

exchanged with competitors, regardless of how innocent or casual the exchange may be.

6. C

ONFLICTS OF INTEREST

We expect our employees, officers and directors to be free from influences that conflict with the best

interests of Dutch Bros

or might deprive Dutch Bros of their undivided loyalty in business dealings. Even

just the appearance of a conflict of interest can be damaging and should be avoided. Whether or not a

conflict of interest exists can be unclear. The following are some (but not all) situations that may involve

problematic conflicts of interests: (a) employment by, consulting for, or service on the board of a

competitor, customer or supplier; (b) owning a significant financial interest in an entity that does business,

seeks to do business or competes with us; (c) soliciting or accepting gifts, favors, loans or preferential

treatment from any person or entity that does business or seeks to do business with us; (d) certain types of

“moonlighting”; and (e) loans to, or guarantees of obligations of, employees, officers or directors or their

family members by Dutch Bros. If you have any concerns about how to comply with this policy, you should

discuss with the General Counsel.

7. C

ORPORATE OPPORTUNITIES

If you are an employee or an officer of Dutch Bros, you may not take personal advantage of opportunities

for Dutch Bros

that are presented to you or discovered by you as a result of your position with us or through

your use of corporate property or information. Even opportunities that are acquired privately by employees

or officers may be questionable if they are related to our existing or proposed lines of business. Significant

participation in an investment or outside business opportunity that is directly related to our lines of business

must be pre-approved. If you are an employee or an officer of Dutch Bros, you may not use your position

with us

or corporate property or information for improper personal gain, nor should you compete with us

in any way. If you are an employee or officer of Dutch Bros and you have any concerns about how to

comply with this policy, you should discuss with the General Counsel.

8. F

INANCIAL INTEGRITY

The integrity of our records and public disclosure depends upon the validity, accuracy and completeness of

the information supporting the entries to our books of account. Therefore, our corporate and business

records should be completed accurately and honestly. The making of false or misleading entries is strictly

prohibited. Our records serve as a basis for managing our business and are important in meeting our

obligations to customers, suppliers, creditors, employees and others. We also rely upon our accounting and

other business and corporate records in preparing publicly-filed reports. Securities laws require that these

reports provide full, fair, accurate, timely and understandable disclosure and fairly present our financial

condition and results of operations. Employees who contribute in any way in preparing or verifying these

reports should strive to ensure that our financial disclosure is complete, accurate and transparent.

9. F

AIR DEALING

Advantages over our competitors are to be obtained through superior performance of our

products and

services, not through unethical or illegal business practices. Statements regarding Dutch Bros’ services

must not be untrue, misleading, deceptive or fraudulent. Acquiring proprietary information from others

through improper means, possessing trade secret information that was improperly obtained, or inducing

improper disclosure of confidential information from employees of other companies is prohibited. You are

expected to deal fairly with our customers, suppliers, employees and anyone else with whom you have

contact in the course of performing your job. Employees involved in procurement have a special

responsibility to adhere to principles of fair competition in the purchase of products and services by

selecting suppliers based exclusively on normal commercial considerations, such as quality, cost,

availability, service and reputation, and not on the receipt of special favors.

10. G

IFTS AND ENTERTAINMENT

Gifts and entertainment relating to government officials are addressed in the Company’s Anti-Corruption

Policy. Gifts and entertainment related to non-governmental third parties (e.g., vendors, contractors,

suppliers, etc.) are addressed in the Dutch Bros HQ Employment Handbook.

11. C

OMPANY ASSETS

All employees, officers and directors are expected to protect our assets and ensure their efficient use. Theft,

carelessness and waste have a direct impact on our profitability. Our

property, such as office supplies,

computer equipment, buildings and products, are expected to be used only for legitimate business purposes,

although incidental personal use may be permitted. You may not, however, use our corporate name, any

brand name or trademark owned or associated with Dutch Bros or any letterhead stationery for any personal

purpose.

12. C

ONFIDENTIALITY

As an employee, officer or director of Dutch Bros, you may learn information about Dutch Bros or other

companies that is confidential and proprietary. You must take care to keep this information confidential.

Materials that contain confidential information should be stored securely. Unauthorized posting or

discussion of any information concerning our business, information or prospects on the Internet is

prohibited. Be cautious when discussing sensitive information in public places like elevators, airports,

restaurants and “quasi-public” areas within Dutch Bros, such as cafeterias. All Dutch Bros emails,

voicemails and other communications are presumed confidential and should not be forwarded outside of

Dutch Bros, except where required for legitimate business purposes. Dutch Bros employees, who have

signed a Proprietary Information and Inventions Agreement in connection with their employment, are

bound by the terms thereof or similar terms that they agree to in connection with their employment.

13. M

EDIA/PUBLIC DISCUSSIONS

It is our policy to disclose material information concerning Dutch Bros to the public only through specific

limited channels to avoid inappropriate publicity and to ensure that all those with an interest in the company

will have equal access to information. All inquiries or calls from the press and financial analysts should be

addressed in accordance with the Corporate Disclosure Policy.

14. W

AIVERS

Any waiver of this code for executive officers or directors may be authorized only by our Board of Directors

or, to the extent permitted by the rules of any stock exchange on which our capital stock is listed and our

Corporate Governance Guidelines, a committee of the Board of Directors and will be disclosed to

stockholders as required by applicable laws, rules and regulations.

15. Q

UESTIONS AND REPORTING POTENTIAL VIOLATIONS

If you are aware of a suspected or actual violation of this code, you have a responsibility to promptly report

it to your supervisor, Human Resources or the General Counsel. If you prefer to report a suspected or actual

violation of this code anonymously, follow the process for filing anonymous complaints outlined in the

Whistleblower Policy. The applicable recipient of the report will investigate all reported possible code

violations promptly and with the highest degree of confidentiality that is possible under the specific

circumstances. As appropriate, the Board of Directors and/or one of its committees shall be notified of any

suspected or actual violation of this code. If any investigation indicates that a violation of this code has

probably occurred, we will take such action as we believe to be appropriate under the circumstances. If we

determine that an employee, officer or director is responsible for a code violation, he or she will be subject

to disciplinary action up to, and including, termination and, in appropriate cases, civil action or referral for

criminal prosecution.

Please note that retaliation against employees reporting violations of this code is prohibited and we will

take prompt disciplinary action against any employee, officer or director who attempts to retaliate against

you for reporting violations.