TABLE OF CONTENTS

Article 1 – Ethics

1.1 – Gifts and hospitality

1.2 – Conflicts of interest

Article 2 – Fight against corruption and money laundering.

Competition law and international economic sanctions

Article 3 – Human rights

Article 4 – Compliance with labour standards

4.1 – Use of forced or compulsory labour

4.2 – Use of illegal labour

4.3 – Child labour

4.4 – Discrimination

4.5 – Level of remuneration

4.6 – Working hours

4.7 – Freedom of association and the right to collective bargaining

Article 5 – Health, safety and environment

Article 6 – Audit

Article 7 – Whistleblowing

Dragon Rouge Group S.A.S. and its subsidiaries (hereinafter referred to as “Dragon

Rouge”) have engaged in a proactive approach to sustainable development with their

suppliers, service providers, customers and all third parties collectively referred to for the

purposes of this Code, as “Business Partners”.

Dragon Rouge is committed to treating its Business Partners fairly and ethically.

This Code sets out our ethical expectations and applies to all our Business Partners.

It formalises the commitments expected in the areas of anti-corruption, respect for

human rights and labour standards, protection of human health and safety, and

environmental protection.

By undertaking to work with Dragon Rouge, these Business Partners sign their acceptance

of and compliance with the provisions of this Code (unless equivalent principles have been

previously agreed).

Business Partners shall comply with the principles of the United Nations Universal

Declaration of Human Rights, the fundamental conventions of the International Labour

Organisation (ILO) and the Sustainable Development Goals (UN)1 in all areas of the Code,

pursuant to applicable laws, regulations and contractual provisions in force.

Any serious breach by a Business Partner of the principles set out in this Code shall

constitute a breach of its contractual obligations, and may result in the application of the

coercive measures provided for in the contract, including outright termination of the

contract, at the cost of the Business Partner, without prejudice to any damages that may

be claimed by Dragon Rouge.

Where a Business Partner, due to particular circumstances, is unable to comply with

certain provisions of the Code, it will be required to immediately notify the relevant entity

of the Dragon Rouge Group in order to agree on the corrective measures to be

implemented.

1 https://www.un.org/sustainabledevelopment/fr/objectifs-de-developpement-durable/4

Entities of the Dragon Rouge Group and Business Partners shall act loyally to build and

maintain long-term trust relationships.

The entities of the Dragon Rouge group shall treat all their Business Partners with honesty

and fairness, regardless of their size and profile, while respecting the specific framework

of each country, which every employee should be aware of. Dragon Rouge Group

employees and companies shall make all purchases in a fair and open manner.

The business partner shall conduct its activities in accordance with the principles of

honesty and fairness and with applicable laws and regulations, particularly those relating

to competition and the prohibition of corruption. In particular, the negotiation and

performance of contracts must not give rise to conduct or events that may be qualified as

active or passive corruption, complicity in trading in influence or favouritism.

1.1 – Gifts and hospitality

The Business Partners, when working on behalf of Dragon Rouge, agree not to offer

Dragon Rouge employees, Dragon Rouge customers or any other third parties

concerned (such as government representatives or public officials) gifts or hospitality

for an amount exceeding a certain nominal value.

A gift offered by a Business Partner must not be intended to influence a business

decision (or be likely to be perceived as such).

Hospitality offered by Business Partners must be used for business purposes, be of

adequate value and must not be intended (or perceived to be intended to influence

a business decision).

Business Partners must not offer gifts or hospitality of any kind in the framework of

a call for tenders or during contractual negotiations.

1.2 – Conflicts of interest

Business Partners are required to declare any potential conflict of interest before the

selection process begins.

More specifically, the Business Partner must avoid situations in which there is an

actual or potential conflict of interest with employees of the Dragon Rouge Group or

their relatives that could affect the independence or objectivity of their professional

actions or decisions.

Where it has not been possible to rule out the occurrence of a conflict of interest,

the Business Partner must act transparently and loyally by informing the relevant

Dragon Rouge Group entity of the situation so that it can be handled.5

Business Partners are required to comply with all applicable anti-corruption and anti-

money laundering laws and must comply with competition law.

Business Partners shall not engage in any form of corruption for the purpose of obtaining

an undue or improper advantage, whether real or perceived.

Business Partners may not participate in activities that could be perceived as an obstacle

to competition.

Business Partners shall not do business with third parties subject to restrictions and shall

be required to comply with the requirements required by the application of these

international economic sanctions.

Dragon Rouge expects its Business Partners to protect and promote the human rights of

their employees. We expect them to behave as fair employers and to respect international

labour standards, including the main conventions of the International Labour Organisation

(ILO) and legislation prohibiting slavery and trafficking in human beings.

4.1 – Use of forced or compulsory labour

The Business Partner agrees not to use forced or compulsory labour as defined in

ILO Conventions C29 and C105. Convention C29 defines forced or compulsory

labour as ” all work or service which is exacted from any person under the menace of

any penalty and for which the said person has not o ffered himself voluntarily” . The

retention, as a condition of employment, of identity documents, passports, training

certificates, work permits or any other identification document is prohibited, as is the

obligation for workers to provide deposits or financial guarantees.

4.2 – Use of illegal labour

The Business Partner agrees not to use illegal labour as defined by the rules of the

countries in which it operates.

4.3 – Child labour

The Business Partner agrees to apply the provisions relating to the elimination of

child labour and its protection, as defined by the ILO conventions. It specifically

agrees not to employ persons under the minimum age required to work under ILO

Conventions C138 and C182.

4.4 – Discrimination

Under the conditions provided for in ILO Convention C111, the Business Partner

agrees not to make any distinction, exclusion or preference based on race, colour,

sex, religion, political opinion, national extraction or social origin which has the effect

of destroying or altering equal opportunities or treatment in employment or

occupation.6

Pursuant to the same Convention C111, distinctions, exclusions or preferences based

on the qualifications required for a particular job shall not be considered

discriminatory. Likewise, the introduction of certain special measures to consider the

particular needs of persons for whom special protection or assistance is recognised

as necessary on grounds such as gender, age, disability, family responsibilities or

social or cultural level (positive discrimination) shall not be deemed discrimination.

The Business Partner shall comply with local legislation in terms of the employment

of people with disabilities.

4.5 – Level of remuneration

The Business Partner shall respect local minimum wage legislation and agrees to pay

employees their wages on a regular basis. The Business Partner agrees to pay for

overtime in accordance with the rates defined by applicable local legislation.

4.6 – Working hours

The Business Partner shall comply with local legislation on working time, including

overtime. In the absence of national laws, ILO standards should apply, i.e. working

hours may not exceed 8 hours per day and 48 hours per week. Every worker shall

have at least 24 consecutive hours of rest in any 7-day period, other than in

exceptional circumstances.

4.7 – Freedom of association and the right to collective bargaining

The Business Partner agrees to respect the principles of freedom of association,

protection of the right to organise and collective bargaining of the International

Labour Organisation (ILO) Convention C87, in accordance with local laws.

Business Partners are required to comply with all applicable health, safety and

environmental laws when working with Dragon Rouge.

Our Business Partners must ensure that appropriate measures are put in place to protect

the health and safety of their employees and to mitigate as far as possible the impact of

their business activities on the environment.

Dragon Rouge reserves the right to check that Business Partners comply with the

principles set out in this Code through in situ or remote audits. If an in-situ audit is

necessary, Business Partners will be notified sufficiently in advance and the audit should

not unnecessarily disrupt their activities.

If you have any questions about this Code or its application, please contact your Dragon

Rouge contact directly.

If for any reason you prefer to report a problem confidentially by any other means, we

also have a dedicated reporting tool called:7

Dragon Rouge Integrity Line (Dragon Rouge’s ethics line)

http://dragonrouge.integrityline.com

This tool can also be used anonymously if necessary.

Dragon Rouge guarantees that nobody who reports an issue in good faith must be subject

to reprisals. All cases will be properly investigated by Dragon Rouge, and appropriate

action will be taken in the event of any breaches.8

English version

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Dragon Rouge Group S.A.S. is the exclusive owner of all copyrights relating

to this document. All rights reserved.