CAMUS GROUP CODE OF ETHICS

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1 CAMUS GROUP CODE OF ETHICS THE LETTER OF THE PRESIDENT In an ever more global commercial context, our group must develop its activities and geographical presence with, as a consequence, a growing division of our structures across 11 cities, 6 countries and 3 continents. We should all be pleased at the cultural diversity in which we operate and the diverse nature of our activities, but it is also important that we all share the same Values. However, I see today that the recent fast changes in the Group have created a situation with less homogeneity in the culture of the company. In all the countries where we have a presence, the purpose of any company is to generate profits, and provide its shareholders and employees with stable and satisfactory revenues. But if the financial aspect is extremely important, a company is not just a Balance Sheet or an Income Statement: the company also exists through its products, its men and women, and its values. This is even more so in the case of a family owned company with a brand bearing its name. I would like here to remind you of the mission of our company: The CAMUS Group will remain a French company entirely dedicated to the development of the CAMUS brand. The vision that we have of the CAMUS brand is as follows: In the world of good living and consumption of quality products, CAMUS is the legitimate, desirable and available BRAND. The essential Values of our Group are: - Excellence - Honesty - Fulfilment of commitments - Customer Satisfaction - Commitment of the men and women working in the Group I wish for those values to be detailed and communicated, through the Code of Ethics that is given to you today. I will ask you to please conform to it rigorously and to share it with all our partners. An Ethics Committee has been created. It has for mission to ensure that all employees of the Group adhere to the Code. The committee is also available to assist you is the implementation of its principles. Thanking you in advance for the attention you will give to this future-defining document, Best Regards, Cyril CAMUS

2 PREAMBLE FIELD OF APPLICATION AND IMPLEMENTATION - The CAMUS Code of Ethics is a frame of reference intended to give CAMUS Group ( the Group ) employees, the Management the Board of Directors and its 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 enact additional rules, subject to their compliance with the principles of the Code hereafter and the approval of the Ethics Committee. All 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 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 organised overall by a form of capitalism based on the guiding principles of the WTO and the United Nations. 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, CAMUS has resolutely opted for a system of values which aims to build a cohesive Group with a view to its long term and sustainable development. Thus, the Group certifies being managed in accordance with a system of values which has been formalised into an Code of Ethics, controlling both its in-house and external relationships.

3 THE VALUES OF THE GROUP Excellence: based on the constant setting of ambitious objectives which constitute factors of continual improvement. This principle ensures the growth of the Group as well as the development of its employees. Honesty: the Group complies with the laws and regulations wherever it is present or represented. Strict morality and integrity are the basis of it rules of conduct. Respecting commitments: the Group keeps its promises to all the partners it encounters during its activities. It exercises risk management and is always responsible for its actions. Customer satisfaction: The Group s customers are at the heart of its activities ; Their satisfaction and the quality of service given to them are the essential conditions of the Group s development. Value of the Staff and Brands of the Group: the brands are an essential value, but the Group affirms that its employees are its primnary wealth; their cultural and social diversity is the guarantee of ongoing growth. The Group is constantly developping individual qualities, while offering a suitable environment for the collectivity in the work place, ensuring the cohesiveness of the Group. COMMITMENTS Based on our values we make principles of our duties and responsibilities as follows: INDIVIDUAL We must act with integrity and honesty. In the daily exercise of our professional activities, we are mindful to preserve the interests of the Group and the image of our Brands. We prohibit any social behaviour which could contravene this principle.

4 COLLECTIVE We promote a policy of human resources 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, or moral 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 the health and the safety of men and women at work are an essential obligation. Outside the company, all our customers and partners are beneficiaries of our desire for excellence and the Group s system from values. OUR CUSTOMERS They are at the heart of our activity. Their confidence is earned on a daily basis and in order to preserve it the Group, through its subsidiary companies and the whole of its distribution network, sells only products which meet the highest requirements of quality and safety. In addition to its products, the Group also delivers to its customer reliable, honest and legal information. Lastly, we guarantee our customers complete confidentiality regarding personal information with which they may entrust us. All of our commitments to our customers are respected within the applicable laws of the countries where the activity of the Group is carried out. We do not permit 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.

5 OUR PARTNERS AND SUPPLIERS Fairly and honestly, the Group builds relations with its partners and suppliers on a long term basis. We do not finance political, trade-union, cultural or charitable organisations for the sole purpose of obtaining material, commercial or personal gain, direct or indirect. 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. Lastly, the Directors and employees of the CAMUS Group must avoid any situation likely to create a conflict between their personal interests and those of the Group. Any actual or potential conflict of interest must be advised to the Ethics Committee, which will take the necessary steps to put an end to it. OUR COMPETITORS We believe in respecting the rules of the market economy, particularly where our competitors are concerned. Our behaviour is founded upon honesty and integrity; we never make defamatory remarks about our competitors. We insist on using only legal and honest means to obtain information about our competitors, in order to decide our best market strategy. PROTECTING OUR INTELLECTUAL PROPERTY The Intellectual Property of CAMUS is one of its most valuable assets. All commercial secrets, trademarks, patents, copyrights and other intangible assets must be protected by all the employees of the Group, whatever their position. For this reason, confidentiality is one of the primary obligations of all CAMUS employees Lastly, the Group undertakes to protect the Intellectual Property of third parties, and only use copyrights in strict accordance with the terms of use defined contractually.

6 RESPECTING THE ENVIRONMENT The CAMUS Group seeks the protection of the environment in all its industrial activity. 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. THE ETHICS COMMITTEE The CAMUS Group is a family-owned company managed by a President who holds, amongst others, the position of Managing Director; for this reason, he has instigated the CAMUS Code of Ethics. To carry out his wish, the President of CAMUS appoints an Ethics Committee, with the responsibility of 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 Worldwide Human Resources Code. Its prerogatives: - provide Ethics recommendations to the President of the Group - submit once a year a report to the Board of Directors - assume the Ethical coordination of all Departments, subsidiaries and representative offices of the Group in France and overseas.

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