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BOU

R

BON

Su

pp

lier Code of Conduct

B-POL-01.00

2

8

Revision 01. Original date:

22

September

2

011. Revision date:

2

3 September

2

011.

Policy prepared by: Vice President Purchase and Supply Chain. Approved by: COMEX. Validated by: Corporate Quality Director.

2

/

2

BOURBON expects its Suppliers to avoid any relationship, influence, or activity that might impair

BOURBON’s employees’ ability to make objective and fair decisions. Conflict of interest laws and

regulations

must be abided by fully and carefully.

B

u

s

ine

ss

Courte

s

ie

s

to

BOU

R

BON

Em

p

loyee

s

Although an employee may not use his or her position within BOURBON to obtain business courtesies, it is

permissible to accept unsolicited meals, refreshments, entertainment, and other business courtesies on an

occasional basis, provided that courtesies:

Foster goodwill and successful business relations.

Are not lavish or extravagant under the circumstances.

Do not recur on a frequent basis or reflect a pattern or appearance of a pattern of frequent

acceptance of courtesies from the same entities or persons.

The employee accepting the courtesies must feel comfortable about discussing the courtesies with his or her

manager or co-worker, or about public disclosure of the courtesies.

Giving Gift

s

BOURBON employees are not permitted to accept compensation, funds or monetary incentives in any form

or amount, or any tangible gift (including tickets to sporting, recreational, or other events) that has a market

value of

2

00 Euros or more, from any entity, representatives of any entity, or any person doing or seeking to

do business with BOURBON, without the approval of his/her supervisor. BOURBON expects its suppliers not

to offer any favour including free goods or services or job or sales opportunity to a BOURBON employee in

order to facilitate the supplier’s business with BOURBON.

Community Eng

a

gement

Suppliers are encouraged to foster the social and economic development and to contribute to the

sustainability of the communities in which they operate.

Protection of

I

ntellectu

a

l Pro

p

erty

Suppliers must respect intellectual property rights and safeguard customer information. Transfer of

technology and expertise must be done in a manner that protects intellectual property rights BOURBON

IV

.

Ma

n

a

gement

Suppliers are expected to establish a management system designed to ensure continuous improvement

regarding Corporate Social Responsibility performance. Suppliers should peruse this Code and ensure that

their employees are familiar with its content.

We encourage our suppliers to inform us of any actions taken to improve their Corporate Social

Responsibility practices and send any suggestions.

Christian Lefèvre

Chief Executive Officer

Gaël Bodénès

Chief Operating Officer

Laurent Renard

Chief Financial Officer

36