CAMUS GROUP CODE OF ETHICS

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1 September 4, 2015 CAMUS GROUP CODE OF ETHICS PREAMBLE FIELD OF APPLICATION AND IMPLEMENTATION - The CAMUS Group Code of Ethics is a frame of reference intended to give CAMUS Group ( the Group ) employees, managers, directors and partners clear information enabling the implementation of the values of the Group. - The Code of Ethics applies to the whole Group. However, its subsidiary companies can implement additional rules, subject to their compliance with the principles of the Code hereafter and the approval of the Ethics Committee. ****** All managers, directors, employees, suppliers, customers and other partners should have a good understanding of this Code of Ethics ; it is a frame of reference, a working tool which contributes to a greater fulfilment of everyone s obligations towards the Group. Additional individual and collective rules will of course supplement this Code of Ethics. The implementation of this Code is driven by the Ethics Committee of the Group. The worldwide market in which the Group operates is generally organised around a form of capitalism based on the guiding principles of the WTO, the United Nations and its various charters, especially those regarding the International Labour Organisation. This economic model is considered as being based on a system of values, both collective and individual : the Enterprise system. The latter is basically controlled by notions of risk, freedom, responsibility and profitability. These principles are themselves closely related to a behavioural need based on the permanent application of ethical values which make it possible for the company to thrive, while assuming its share of social responsibility. In this context, the Group has resolutely opted for a system of values which aims to ensure cohesion within the Group with a view to its long-term and sustainable development Thus, the Group certifies that it is managed in accordance with a system of values which has been formalised into a Code of Ethics, which governs both its in-house and external relationships.

2 THE VALUES OF THE GROUP The Group complies with the laws and regulations wherever it is present and represented. Strict morality, ethical behaviour, accountability and integrity are the basis of its rules of conduct. It carries out risk management and is committed to always being responsible for its actions. RESPECT The Group respects its commitments to all the partners it meets in the course of its activities. The Group attaches great importance to people ; its customers, employees and partners. Trademarks are a core value, and its employees are its most valuable resource ; their cultural and social diversity ensure sustained growth. In this regard, the Group affirms that everyone should be respectful and tolerant of others. PASSION CAMUS is a family-run company ; therefore the Group has a strong sense of commitment and customer service, with customers being at the heart of its activities. The Group s excellence, innovation and creativity should all contribute to ensuring customer satisfaction and the outstanding quality of its products. AMBITION Ambition is based on the constant setting of objectives to obtain excellence, which constitute factors of continual improvement. This principle ensures the growth of the Group, as well as the fulfilment and development of its employees.

3 COMMITMENTS Based on our values, we make principles of our duties and responsibilities as follows : INDIVIDUAL We must act with integrity and loyalty, and be respectful of the people and products of the Group. In the course of our day-to-day activities, we make sure that the Group s interests and the image of our brands are protected. We should all contribute to giving a positive image to the Group s brands ; it is an individual responsibility and duty. Ambition, respect, and passion should guide our individual objectives at all times. Lastly, all of the Group s managers, directors and employees should avoid any situation in which their personal interests may conflict with the interests of the Group. Any actual or potential conflict of interest should be reported to the Ethics Committee, which will take the necessary steps to put an end to it. We prohibit any social behaviour which could contravene this principle. COLLECTIVE We promote a human resources policy which contributes to the professionalism, motivation and general wellbeing of all our employees, by giving precedence to training and internal promotion. We respect human rights and the principles of social legislation in the workplace. We do not tolerate discrimination, intimidation, denigration, defamation, rumour spreading, moral harassment or sexual harassment. We banish all recourse to child- or forced-labour, which includes ensuring that our suppliers do not themselves use such means. We respect and encourage social dialogue and trade-union freedom, whatever the country in which we work. We consider that health and safety in the workplace is an essential obligation. Outside the company, all of our customers and partners benefit from our commitment to excellence and the Group s system of values.

4 OUR CUSTOMERS They are at the heart of our activity. Their confidence is earned on a daily basis. In order to preserve it, the Group, through its subsidiary companies and the whole of its distribution network, only sells products which meet the highest quality and safety requirements. In addition to its products, the Group also provides its customers with reliable, honest and lawful information. Lastly, we guarantee our customers complete confidentiality regarding personal information which they may give to us. All of our commitments to our customers are respected in accordance with the applicable laws of the countries where the Group s activities are carried out. We do not allow ourselves to accept gifts from customers whose purpose is to influence our relations. If such gifts are given within a strictly cultural framework consistent with the practices of the countries in which we do business, such gifts must be handed over to the company who will decide what to do with them, at the discretion of the Ethics Committee. OUR PARTNERS AND SUPPLIERS The Group builds honest and fair relationships with its partners and suppliers on a long-term basis. We do not provide financing to political, trade-union, cultural or charitable organisations in exchange for direct or indirect material, trade or personal benefits. We require our suppliers to comply with the relevant principles of our Code of Ethics. We will not be associated, directly or indirectly, with child- or forced-labour. We check the effective implementation of our principles. We affirm our belief in fair and free competition because it alone is a factor of social and economic progress, offering every guarantee to the consumer and final customer.

5 OUR COMPETITORS We believe in respecting the rules of the market economy, particularly where our competitors are concerned. Our behaviour is founded upon loyalty, integrity and respect ; we never make defamatory remarks about our competitors and we do not tolerate any acts of denigration. We insist on using only legal and honest means to obtain information about our competitors, in order to decide on our best business strategy. PROTECTING OUR INTELLECTUAL PROPERTY One of the CAMUS Group s most valuable assets is its Intellectual Property. All trade secrets, trademarks, patents, technical drawings, copyrights and other intangible assets must be protected by all the employees of the Group, whatever their position, and by the brand representatives in all markets. For this reason, confidentiality is one of the primary obligations of all the CAMUS Group s employees, suppliers and partners. Lastly, the Group undertakes to protect the Intellectual Property of third parties, and to only use copyrights in strict accordance with the terms of use defined contractually. RESPECTING THE ENVIRONMENT Protecting the environment is a priority for the CAMUS Group, when conducting its industrial activities. The Group informs its employees about the management of environmental risks. Lastly, it affirms that the principle of environmental protection is one of the key factors for its future and sustainable development.

6 THE ETHICS COMMITTEE The CAMUS Group is a family-owned company managed by a President who is also the main shareholder ; in this capacity, he is the instigator of the Group s Code of Ethics and the guarantor of its implementation. To make sure that it is effectively applied, the President of the CAMUS Group has appointed an Ethics Committee, which is responsible for ensuring compliance with the Code of Ethics. The Ethics Committee is named by the Board of Directors. The Ethics Committee is responsible for all ethical issues related to the activities of the Group. It meets as often as necessary for problems to be brought to its attention; it ensures application of the Group s ethical rules contained in the present Code and the CAMUS Group s Worldwide Human Resources Code. Its prerogatives : - provide Ethics recommendations to the President of the Group - submit an annual report to the Board of Directors - take responsibility for the Ethical coordination of all departments, subsidiaries and representative offices of the Group in France and overseas. Members of the Ethics Committee : - Philippe BERNARD, President of the Ethics Committee, Group Chief Commercial Control Officer - Patrick COCHET, retired from the DIAC Group - Frédéric DEZAUZIER, Global Brand Ambassador - Pascal LECAMP, Director of BUSINESS FRANCE NORVEGE - OSLO - Stéphanie LEGER ETOURNEAU, Group Chief Legal Officer - Dominique SOULE, Managing Director of PREPASIA - LA ROCHELLE