Cod of Conduct

Ethical
Conduct of Suppliers
Content 9.4. Unfair Competition ............................................................ 39
9.5. Financial and Accounting Records......................................... 40
15 Audit and Termination of Contract ................................. 68

9.6. Reducing Risks of Significant Economic 16 Communication ....................................................... 70

1 1 ADEO Culture ..................................................... 03 Dependence .............................................................................. 42 16.1. Anonymity and Confidentiality ..........................................74
9.7. Mutual Efficiency................................................................. 42 16.2. Cooperation of Investigation................................................ 75
22 To whom does the ADEO’s Code of Ethical Conduct of 16.3. Protection Against Retaliation ............................................ 75
Suppliers apply? ................................................................. 06
10 10 Human Rights and Fundamental Labor Rights
3 Message from the General Director................................... 09 .................................................................................. 43 17 Term of Commitment .................................................. 76
10.1. Work Conditions ............................................................... 45
4 Introduction................................................................ 12 10.2. Working Hours................................................................... 46 Annex 1 - Woods Policy ....................................................... 78
10.3. Compensation and Benefits ................................................ 46 I.ADEO’s Commitments............................................................... 80
10.4. Elimination of All Forms of Forced Labor or II. Supplier’s Commitments ........................................................... 83
5 Fundamental Principles of the Organization ........................ 15 Similar to Slavery ........................................................................ 47 III.Policy Follow-up.......................................................................... 87
10.5. Eradication of Child Labor..................................................... 47
6 Purposes and Coverage ................................................... 18 10.6. Diversity and Inclusion ...................................................... 48 Annex 2 - ADEO’s storage and packagingpolicy
7 Compliance with the Law, Standards and Contracts............... 20 10.7. Disciplinary Practices.......................................................... 49 EN-V05.............................................................................. 90

8 Anti corruption Policy .................................................. 23 11 Occupational Health and Safety ....................................... 50 Chapter 1: Compliance with the Law.......................................... 92
11.1. Use of Alcohol and Drugs ................................................... 52
8.1. Sponsorship, Patronage and Lobby ............................................. 26 Chapter 2: Environment, Safety, Health .................................. 93
12 Environment and Sustainability........................................ 53 2.1. Component/material ...........................................................93
9 Ethics and Transparency in the Business Relationships ......... 28 2.2. Suppliers.............................................................................. 96
9.1. Gifts, Travel and Other Benefits .....................................................31 13 Quality ..................................................................... 55
9.2. Conflict of Interest............................................................... 33 14 Secrecy and Confidentiality of Information and Chapter 3: Social.............................................................. 97
9.2.1Development of Other Activities ............................................ 33 Protection of Personal Data ................................................ 58 3.1. Respect the maximum packaging weight for transport
9.2.2.Hirings.............................................................................. 34
14.1. Confidential Information ................................................... 60 t(recommended by GS1 and ECR) ................................................... 97
9.2.3. Equity Interest ................................................................... 35
14.2. Information Security ........................................................... 62 3.2. Respect the marks on the packaging of the sales unit and on
9.2.4. Professional Private Relationships ...................................... 35
14.3. Use of Social Network ....................................................... 65 the transport packaging ................................................................. 96
9.3. Abuse of Power and Harassment.......................................... 37
ADEO Culture 1 3
ADEO Culture
ADEO intends, through its 120,000 employees all over the world, “to create, support and help all
inhabtants to achieve their dreams of a better home”.
It is essential that this mission is carried out in accordance with our VALUES: HONESTY,
GENEROSITY, RESPECT TO ONE ANOTHER, PROXIMITY AND SPIRIT OF
ACHIEVEMENT that must accompany all our behaviors and decisions.

We want the HUMAN to be in the HEART of our community of Companies, which is expressed by the
“usefulness for oneself, for others and for the world”. All of them work in our community, with
interdependence between each other and with the world, aware of and responsible for their impacts:

Useful for oneself (oneself, one’s team, one’s customers, one’s company and one’s results);
Useful for others (communities, partners, Suppliers and other ADEO Companies); Useful
for the world (society and the environment).

4
ADEO Culture

This Code of Conduct represents the ADEO’s desire to apply to all of its Suppliers
the Group’s principles and Values, bringing together these three levels of usefulness
to develop genuine ethical (legal as well as moral) behavior to ensure HEALTH and
SAFETY of all people in our environments.

5
To whom does the ADEO’s Code of Ethical
Conduct of Suppliers apply? 2 6
To whom does the ADEO’s Code of Ethical Conduct of
Suppliers apply?
This Code of Ethical Conduct of Suppliers applies to all Suppliers.

“Supplier” or “Suppliers” means any legal person supplying goods and/or services to the ADEO Companies
worldwide, and any of their subcontractors and/or subsidiaries.

In this document we demonstrate our commitment and what we expect our Suppliers to fulfill with respect to
human rights, including the fight against child labor, forced labor and slavery, as well as combating
discrimination and valuing diversity.

7
To whom does the ADEO’s Code of Ethical Conduct of
Suppliers apply?
We also present our commitment to national and international ethical guidelines, which have been developed on
the basis of guidelines of the International Labor Organization (ILO), the United Nations Universal Declaration of
Human Rights and the European Convention on Human Rights, which extend to our Suppliers.

This Code of Ethical Conduct is at the disposal of our Suppliers and is intended to strengthen our relationship
and common understanding and should be put into practice in our daily business. By accepting this Code,
Suppliers acknowledge that all agreements, contracts and business relationships with ADEO Enterprises,
existing and future, will be subject to the provisions contained in this document.

Where the Code of Conduct of this Code is more stringent than local laws or practices, I, the Supplier, undertake
to comply with the provisions of this Code of Conduct.

8
Message from the
General Director 3 9
Message from the General Director
The Global Leaders of ADEO and of each of its Companies employ the Values and principles of
this Code of Conduct and ensure its good application.

In this regard, they are very engaged in awareness-raising, dissemination and respect of the
Code of Ethical Conduct with its Management Committees. The basis of our culture is our
commitment to acting with integrity.
Even when we change to meet the needs of our customers or Suppliers, we remain faithful to
the values and behaviors that have guided us in recent years.

Ignacio Sánchez Michael Reins

Leroy Merlin Obramax

10
The Code of Ethical Conduct is a daily resource that helps us make objective, fair and honest
decisions while operating in accordance with applicable law and our internal policies, processes
and procedures.

This Code of Ethical Conduct applies to the Director General, the Management Committee and
all Employees and Suppliers of the ADEO Companies in Brazil.

Thank you for your commitment to our Code of Ethical Conduct. This
means more than making ethical decisions, it shows that you care about the Company, our
reputation, our customers and the sustainability of our business.

11
Introduction 4 12
Introduction
ADEO is currently made up of 34 autonomous Companies operating in 13 countries, consolidating itself as one
of the world leaders in the DIY and home equipment sector, with more than 758 own stores and 555 units
between franchises or leased stores, divided into 13 independent brands.

ADEO employs around 120,000 employees worldwide and earned almost 22 billion Euros in 2017, serving one
and a half million customers per day worldwide!

LEROY MERLIN arrived in Brazil in 1998 bringing a new concept to the Construction Material market. With a
focus on the quality of products, customer service and services, the Company offers in its stores spacious and
pleasant environments to better receive its customers.

Specializing in Construction, Finishing, DIY, Decoration and Gardening, LEROY MERLIN sells more than 65
thousand items divided into 14 sectors: Basic Materials, Timber, Electrical, Tools, Carpets, Ceramics, Sanitary,
Plumbing, Gardening, Hardware, Organization, Painting, Decoration and Lighting. We also offer differentiated
services, such as wood and glass cutting, framing, tailor made curtains, flooring installations, home delivery, among
others.

13
LEROY MERLIN came to Brazil to stay. The Company seeks long-term and sustainable development, not
just immediate profit. Today it is the largest retailer in the construction sector in the country and its market
share has been growing steadily.

OBRAMAX came to Brazil in 2015 to service civil construction professionals and small resellers of
construction materials; it is Brazil’s first wholesale-retail of construction materials. Its mission is to be the
reliable partner of pragmatic end-users and professionals, ensuring a saving of time, energy and money in the
conduction of its small and medium-sized residential, commercial and residential construction, renovation,
installation and maintenance projects.

14
Fundamental Principles of
the Organization 5 15
Mission
• Proximity
We want to give everyone the opportunity to improve their home..
We seek closeness between people and products, customers and the
reality of the store. Empathy, customized relationship and service
Values provision.

• Honesty • Simplicity
Our key words: transparency, integrity, ethics, authenticity, We are always available and we seek simplicity when
reliability. communicating, learning and teaching..

• Generosity • Coherence
We seek to develop self-esteem and team spirit. We share the ADEO Companies value clarity: they practice what they preach and
Knowledge, the Ability and the Possession. speak their minds.

• Respect to one another • Spirit of achievement

Humanism, listening, consideration, adaptation to the place and We are persevering, we have initiative and dynamism, seeking to
respect for differences. overcome obstacles and evolve always.

16
Philosophy
The true foundation of the Company is based on the philosophy of sharing:

Sharing the knowledge: is translated by the learning capacity of each Sharing the possession: the companies believe in teamwork and privilege
Employee who acquires knowledge and practices behaviors that allows them collective victories. The Employees are interested in the results of their
to grow personally and professionally. store, as well as those of the Company, in the short and medium term. This
dynamic sharing policy promotes a steady progress and teamwork and
gradually spreads to the largest number of branded companies.

Sharing the ability: is translated by the responsibility, the autonomy of its

Employees and the communication of its opinion on the future desired by Sharing the will: a state of mind, a positive attitude, a motivation and a will
the Company. that contributes to the achievement of results.

17
 Purposes and
Comprehensiveness 6
18
Purposes and Comprehensiveness
This Code of Ethical Conduct covers all Suppliers, as well as their affiliated and controlled Companies and its
purpose is to clarify what we mean by ethical conduct in business relations with the Companies that provide
us with products and services.

Likewise, we expect our Suppliers to extend these criteria throughout their value chain, that is, customers,
Suppliers of raw materials and service providers, directly or indirectly, linked to the Company’s activities.

Therefore, it is up to us jointly, ADEO Companies and Suppliers, to ensure that these behaviors are always
complied with and respected.

19
Compliance with the Law,
Standards and Contracts 7
20
Compliance with the Law, Standards and Contracts
Compliance with laws, regulations and contracts is the basis of our reputation and our ethical
values and principles.

Laws
The relationship of the ADEO Companies with all their Suppliers is based on compliance with
the legislation in force in the countries where the Company operates. In cases where the local
legislation in force is less comprehensive than the French legislation, international standards
shall prevail.

Contracts and Internal Regulations

The Suppliers of ADEO Companies shall always ensure compliance with the contractual
obligations established by the Company, presented in the processes, procedures and/or policies
published by the Company.

21
Agreements, Treaties and Conventions

We know and act on the basis of international pacts, agreements, treaties and conventions of our
branch of activity, such as the United Nations Universal Declaration of Human Rights,
Principles of the Global Compact, as well as the laws from the International Labor Organization
(ILO).

Granting of Powers

If it is necessary to grant powers to a Supplier for the exercise of any operation, this shall be
mandatorily performed by means of an instrument of mandate with a fixed term, with an
express indication of the specific purpose and object, as well as, prohibition of substitution.

In the event that the Suppliers exceed the powers granted in the mandate, they will be subject to
liability under the current law, without prejudice to termination of the contract, as well as
verification of losses and damages applicable in concrete cases.

22
Anti - Corruption
Policy 8
23
Anti Corruption Policy
The Grupo ADEO Companies are committed to the fight against corruption
and have rigid internal controls to ensure full compliance with the laws of the
countries where they are present.

It is totally prohibited for our Employees and Suppliers to give or receive any
advantage (financial or otherwise) in exchange for actions that are contrary to the
interests of the ADEO Group and the locallaw.

24
It is forbidden to pay any facilitation (in cash or gift) to a collaborator of
a Supplier or public agency - in exchange for some advantage, such as
speeding up the execution of a service in progress, as well as:

Offering, paying, promising, transferring or authorizing payments in cash or gifts, directly or

indirectly by or for Employees of ADEO Companies;

Promoting, offering or giving, directly or indirectly, an undue advantage to a public agent, or

persons related to them;

Falsifying documents, trademarks or products;

Hiding incidents (accidents and/or near misses);

Performing or being involved in illegal activities or conduct such as tax evasion, smuggling,
bribery, among others;

Hindering the activity of investigation or inspection by organs, entities or public agents, or

intervening in its action.

25
8.1. Sponsorship, Patronage andLobby:
The patronage and sponsorship operations of the ADEO Companies can be a means of
promoting our image and supporting the implementation of various social actions. In
order to ensure that resources actually have the intended destination and therefore do
not constitute acts of corruption, they must be previously authorized by the responsible
area, following objective and transparent criteria for selecting the beneficiaries and
coherence between the ADEO Companies’ Values and the destination of the resources.

The Lobby, also known as the practice of influencing representatives of public

authorities or political parties with decision-making power,especially as to the approval
and/or modification of a law or a regulatory act, is not permitted by Brazilian law.

26
In practice
1| I am a Supplier of one of the ADEO Companies and I service part of the decoration products range.
My company carries out some social work with the local community and we support a non-profit
association that carries out a project with the elderly on a monthly basis. The association is in need of a
renovation to meet the accessibility standards of its facilities.

May I contact the ADEO Companies for sponsorship?

YES: There is no prohibition that a request for sponsorship is addressed by an Employee, Supplier or
Customer, however, it is necessary to respect the Company’s rules for the selection of incentive
projects / social actions and entities/ associations and purpose of resource allocation, as well as comply
with the Company’s budgetary and/or fiscal incentive limits permitted by law, as well as ensure that
the sponsorship does not influence or give the appearance of influencing a business decision to make
future purchases with that Supplier.

27
Ethics and Transparency in
the Business Relationships 9 28
Ethics and Transparency in the Business Relationships
Ethics guides our behavior as an organization. It is important to act ethically and transparently both in internal processes and
when dealing with external situations. The same logic applies to our Suppliers, who must be ethical and transparent both in
their internal procedures, and in relations with the ADEO Companies and with their other partners.

The selection and contracting of our Suppliers follows technical and professional criteria that ensure that the relationship of the
ADEO Companies with them is free from favors and privileges, based on fair commercial practices in relation to quality, price,
agreed terms and services rendered, as well as compliance with the laws and regulations in force and compliance with the
Company’s internal processes, policies and procedures.

This way, we have as good practice the execution of competition processes and the application of the due diligence process of
our Suppliers.

Any Supplier, or intermediary, must go through the process of verification and the application of the due
diligence process and as a result, these Companies should not be included in any list of international economic
sanctions, guaranteeing ADEO’s security.

29
In practice
1| By participating in acompetition process for one of theADEO
Companies, I identify that the Code of Ethical Conduct for Suppliers
has points and obligations that I disagreewith.

Do I have the possibility to veto these clauses in our negotiation?

NO: The ADEO’s Code of Ethical Conduct represents our Values.

Therefore, unless the Supplier refuses to accept them because their company
also has a Compliance Program and its own Code of Conduct or internal anti-
corruption policies, strong commitments to Ethics, Human Rights, and the
Preservation of the Environment , and that these are not incompatible with
our Values, it will not be possible to do business with this Supplier.

30
9.1. Gifts, Travel and Other Benefits

The ADEO Companies do not admit that their Suppliers offer any type of advantage to
Employees and/or their relatives, until the third degree.

Lodging, travel, meals, transportation and events related to the activities carried out in
the professional scope may be borne by our Suppliers, provided that they are approved
by the Leader, and in no case is the concession linked to the requirement of any
consideration or favor.

Courtesies may be received as promotional gifts (pens, calendars, pen drives or edible
and drinking gifts (panettone, chocolates, wines, etc.) provided they are not of
significant value and are used exclusively in the work environment.

31
In practice
1| | I would like to invite my new ADEO Group customer to meet the
new facilities in my factory together with other new customers. My
guests will have no cost, we will pay all expenses! It will be a pleasureto
welcome them, without anyinterest!

Can ADEO Companies’ Employees accept this invitation?

YES: The general rule is that wemust refuse any travel paid by a service
provider, supplier or customer, provided that professional relevance is
justified, unless it is not possible for the Company to pay for its expenses
directly and provided it has been agreed in advance with the Leader.

32
9.2. Conflict of Interest
Business relationships must follow specific standards and appropriate ethical conduct, avoiding
situations of conflict of interest and/or any relationships that interfere with the full exercise of
business.

Aconflict of interest will occur when our judgment may be influenced or appear to have been
influenced by the possibility of personal benefit.

9.2.1. Development of Other Activities

It is forbidden, in any case, that the Employees of the ADEO Companies provide autonomous
services to our Suppliers, even in a later time than the working hours.

33
9.2.2. Hirings
ADEO Companies strive to prevent personal relationships from interfering with
professional performance or constitutingharassment.
Therefore, companies of relatives of any Group ADEO Employees can not be hired by them or
their area.
Any type of private, usual relationship between Suppliers and Employees of ADEO Companies
must be communicated, such as, for example, kinship relations between Employees and/or
partners of the Supplier and/or Company employees directly involved inthe negotiation
process.

In addition, according to contractual premises, during the period of validity of these and after
six months of its closure, ADEO Companies and their Suppliers are not allowed to hire
Employees of the parties involved.

34
9.2.3. Equity Interest
Employees of the ADEO Companies are prohibited from participating incompanies that
provide them with products and/or services, which may have adecisive influence on the
contracting process.

9.2.4. Professional Private Relationships

Business relationships between Employees and Suppliers of ADEO Companies will not beallowed
when their activity is directly linked to the Employee’srole in the Company.

35
In practice
1| I work in the commercial area of an air conditioning maintenance
service company that intends to become an ADEO Supplier for the
business unit where my cousin also works and is responsiblefor
contracting.

Is there a conflict of interest in thissituation?

YES: Howeverthis should not prevent your cousin’s business unit from
contracting your company,as long as it participates in the competition processon
equal terms with other suppliers, offers a quality service and has a complete price.
You and your cousin must inform your respective superiors / Leaders of the
situation and neither of you should participate in the decision making, which
should be done under objective and professional criteria byother employees, free
of interests.

36
9.3. Abuse of Power and Harassment
The ADEO Companies do not allow coercive commercial practices or any type of harassment,
such as moral, sexual, racial, political and religious.

Suppliers of ADEO Companies must treat all of their employees with respect and dignity, and
corporal punishment, physical, sexual, psychological or verbal abuse or harassment, as well as the
application of fines for disciplinary measures are not allowed.

37
In practice
1| A colleague of my company reported feeling embarrassed by the comments
madeby asupervisor of one of theADEO Companies becauseof his origin, saying
that where he was born, people have no education and that he has no capacity to
carry out the tasks designatedfor him.

Isto é discriminação? O que devo fazer?

YES: It is imperative that you immediately inform the person responsible for
your contract with the ADEO Company, who will contact the Relevant HR so that
it will provide the necessary support for the determination and even referral for
disciplinary sanctions under the Code of Ethical Conduct of Employees.
You may, alternatively, record the fact on our Ethics Listening Channel.

38
9.4. Unfair Competition
Suppliers of ADEO Companies shall conduct their business in a manner
consistent with principles of fair competition and in accordance with all
applicable antitrust laws. We condemn, among others, the following practices:

Fail to comply with tax, labor, environmental or any other legal regulations;

Formation of trusts and/or cartels;

Tarnish the image of the competitors;

Practice fraud and/or industrial espionage.

39
9.5. Financial and Accounting Records
We maintain strict internal controls to evaluate and manage the risks of our activities,
Employees and our reputation, as well as to ensure that the books, financial and accounting
records of operations carried out by ADEO Companies (*)/(**) are not used to hide the
practice of acts of corruption, money laundering or influence peddling. All financial and
accounting information is confidential.

Therefore, wemake sure that the contract chain is respected when making a payment.
Accordingly, it is the same company that signs the commercial contract/proposal with any of
the ADEO Companies, issues the invoice and holds the bank account in which the payment
transfer will be made. All such operations must take place in the same country, except for
operations with International Suppliers.

(*) By determination of the Central Bank of Brazil, the payments to be remitted abroad are classified as foreign
exchange operations, and the registration of operations at the Federal Revenue for the importation of products is
mandatory. (**) The issuance of an invoice for services
in the case of Non-Reseller Suppliers operations is mandatory.

40
In practice
1| DDuring the performance of a service by my company, the execution values exceeded the initial estimate, however, the ADEO Company Employee
responsible for the monitoring of the services, aware of the fact, advisedus not to present the details or any additions made and assured us that he
“owouldtake care” of justifying to their Leader the increase of the price and, in exchange, “wewould have no problems to receive our part”.

Can I issue the invoice this way?

NO: Payments must be made according to the contracted budget. The amounts involved should not be subject to significant variations that are not justified.
Remember that wework with transparency, so the additional services not only must be broken downin the invoice, but the consistent justification of the contracted
price variation must be submitted for validation of the Leader and subsequent authorization of payment to the FinanceDepartment.
By omitting such information, you are in violation of the ADEO Business Values. Remember that Honesty can be translated by transparent business practices and
trust. Furthermore, it is the duty of all to care for the practice of ethical conduct. The Employee’s guidance clearly intends to involve them in a situation that will allow
them to, in some way, unduly gain personal advantages! You may use our Ethics Listening Channel to record our Employee misconduct.

41
9.6. Reducing Risks of Significant Economic Dependence
The ADEO Companies make sure that their Suppliers are not in a state of significant economic
dependence, which could jeopardize their activity and the social function of the company,
noting, for example, the lack of sequential invoices.

9.7. Mutual Efficiency

The ADEO Companies undertake to establish a relationship of mutual efficiency with their
Suppliers, especially by continuously improving their order advance practices, in order to limit
the risk of a sudden change in order volumes to Suppliers.

42
 Human Rights and
Fundamental Labor Rights 10
43
10. 10. Human Rights and Fundamental Labor Rights

The ADEO Companies are committed to respect for human rights and implementation and
strengthening of practices and procedures are based on national and international instruments,
including the Universal Declaration of Human Rights, the ILO Declaration on Fundamental
Principles and Rights at Work and the United Nations Guiding Principles on Business and
Human Rights.

We expect our Suppliers to conduct their business in a waythat demonstrates their commitment
to respect for human rights, in accordance with the principles to follow.

44
10.1. Work Conditions
The ADEO Companies consider it absolutely essential to preserve the health and physical
integrity of their Employees, as well as to promote the quality of life in the work environment,
and it is the duty of all to guarantee healthy environments and safe and healthy work
conditions, according to the legislation in force on Occupational Safety and Health.

Therefore, our Suppliers must provide at least decent working conditions, always seeking the
reduction of unhealthy and dangerous environments for their employees. The working hours,
remuneration and benefits, and compliance with health and safety standards must observe the
current legislation.

45
10.2. oring Hours
Our Suppliers shall ensure that the work performed by their employees is in accordance with the current lawsand
mandatory standards of the Collective Labor Agreement of the region of their work unit regarding the number of
hours anddaysworked,including requirementsfor intervals.
In the event of a conflict betweenthe Code of Ethical Conduct and the CollectiveLabor Convention, the provisions
providedfor underthe legislationin forceshallprevail..

10.3. Compensation and Benefits

Suppliers of the ADEO Companies shall remunerate their employees according to the applicable laws and
regulations and submit the employment contracts and proof of payment of labor charges, whenever
requested..

In places where no minimum wage is defined, at least the basic salary of the market category must be paid.
They must also ensure that their employees are compensated for overtime at legally required rates and that
they receive all legal and/or insurance benefits provided for by applicable legislation and regulations.

46
10.4. Elimination of All Forms of Forced Labor or
Similar to Slavery
The ADEO Companies do not use and neither do they admit that any of their Suppliers use any type of
slave labor or any other form of involuntary or forced labor, including work under confinement, slavery or
imprisonment.

10.5. Eradication of Child Labor

The use of child labor by Suppliers of ADEO Companies is absolutely prohibited. Child labor is
understood as any form of work performed by children and adolescents, under the legal minimum
age allowed for work that violates the Child and Adolescent Statute and otherapplicable provisions.

47
10.6. Diversity and Inclusion
ADEO Companies adhere fully to international laws and agreements that address discriminatory treatment. Our Suppliers will ensure that
your employees do not suffer any harassment or discrimination.

In practice
1 | My company will develop a project within some stores of the ADEO Companies. In the selection process, weidentified
some highly qualified professionals for the job, but with notorious union activity, and others with controversial political
opinions, disclosed in their social networks.

Should I hire them anyway?

YES: If the professionals are technically qualified, they must be hired.

The personal preferences of our Employees should not be obstacles to their hiring. Any form of discrimination based on origin, sex,
family status, marital status, pregnancy, physical characteristics, illness, disability, sexual orientation, age, social class, political,
partisan and philosophical opinions, trade union activities, belonging or not, truly or allegedly, to an ethnic group, nation or religion
should be vehemently prohibited and repressed.

48
10.7. Disciplinary Practices
Our Suppliers should treat all their employees with respect and dignity.
Threats, corporal punishment or any other forms of physical, sexual,
psychological and verbal abuse, or any form of harassment or
discrimination shall not be tolerated, nor shall fines be imposed as
disciplinary measures.

49
Occupational Health
and Safety 11
50
11. Occupational Health and Safety
The ADEO Companies consider it absolutely essential to preserve the health, quality of life and
physical integrity of its Employees, customers and Suppliers, as well as the promotion of quality of
life in the Company’s work environment. These premises also apply to our Suppliers.
WhenengagedinabusinessrelationshipwithADEOCompanies,

o the Supplier must:

Meet the requirements of labor and social security legislation, as well as collective labor
agreements;
Provide health and safety conditions in the work environment, following the applicable laws
and the rules and procedures of the ADEO Companies listed in the contract;

Seek to mobilize its employees and propose initiatives related to health and safety.

51
11.1. Use of Alcohol and Drugs
The possession, offer or use of illegal drugs or being under the influence of these drugs or
alcohol during the working/ service provision hours within the facilities of ADEO Companies is
prohibited and will not be tolerated.

Suppliers shall ensure that their employees and/or service providers allocated to the ADEO
companies comply with such rules, including with regard to participation in events of the
Companies that allow the consumption of alcoholic beverage, when the consumption of
alcoholic beverages will be allowed for those employees/ service providers who have the
minimum age allowed by local law and in moderation.

52
Environment and
sustainability 12
53
12. Environment and Sustainability
It is imperative that our Suppliers comply with all applicable environmental laws and regulations. In this
sense, Suppliers shall:
Commit to comply with the environmental legislation applicable to their activities;
Ensure the maintenance of the necessary environmental licenses within their units;
To make the correct collection and disposal of the residues derived from their operation;
Limit consumption of non-renewable natural resources;
Give preference to raw materials from renewable/recyclable sources and that the conditions of extraction
respect local populations and ecosystems;
Be aware of the environmental aspects and impacts caused by their activities, and plan the control actions
necessary and sufficient to keep them under control;
Prefer multimodal transport in order to reduce CO2 emissions;
Comply with the ADEO policy on wood (Annex 1);
Comply with the ADEO policy on dangerous substances.
(The provisions of this chapter apply preponderantly to Reseller Suppliers;
To Non-Resell Suppliers, the applicability will be analyzed on a case by case basis).
54
Quality 13 55
13. Quality
Quality is understood as a high level of product safety and compliance, as well as a high
level of satisfaction in use, through the product life cycle.

To make our Quality strategy a success, weshare our vision of Quality with the
intention of converging with our Suppliers, an inseparable and fundamental part of our
ecosystem.

56
In this context, the ADEO Companies Apply a Quality Assurance
Approach to:
Implement, with the Supplier, the necessary conditions to guarantee the total quality of the
products purchased, throughout their life cycle;
Challenge and empower the Supplier to control its quality process and its approach to
continuous improvement;
Structure and organize the Quality management and its administration among the ADEO
Companies and the Supplier;
Develop proactive and innovative suggestions with the Supplier, especially regarding the use of
the products.

(The provisions of this chapter apply exclusively to Reseller Suppliers).

57
 Secrecy and Confidentiality of
Information and Protection of
personal Data 14
58
14. Secrecy and Confidentiality of Information and
Protection of Personal Data

In addition to regulatory restrictions and penalties, the protection of our confidential

information aswell asthe personal data of our Clients and Employees is essential and is an
integral part of our policies and should always be guided by an ethicalapproach.

When obtaining access to any type of information listed as confidential in this Code
of Conduct, our Suppliers must be committed to our guidelines set forth in
confidentiality clauses.

59
14.1. Confidential Information
There shall be considered as confidential and strategic information for
ADEO Companies:

Technical and commercial product data;

Goals, tactics, and business and marketing strategies;
Annual budgets;
Short-, medium-and long-term planning;

Volume and purchasing conditions;

60
Survey results;

Statistical, financial, accounting and operational data;

Information on commercial agreement entered into between the ADEO Companies and
their partners;
Evaluations, analyzes, interpretations and other results of the ADEO Companies;

Any data related to the ADEO Companies’ customers;

Confidential and strategic information may only be disclosed by the partners with the
prior written consent of the ADEO Companies.

Access to the foregoing confidential information does not give rise to any rights to
trademarks, patents, trade secrets or other intellectual property rights in any way
whatsoever of the ADEO Companies.

61
14.2. Information Security
For ADEO Companies, information is a valuable asset. Information is understood as all
technical and technological knowledge (publications, reports and other confidential
information) which ensure the quality
of our services.

62
It is hereby established that our suppliers must follow the
guidelines:
Be aware of and moderate in the use of computers, USB slots, internet, e-mails and
prints;
APresent to the Information Security Committee any and all personal equipment (computer
or external media) so that they can register them and check that they are suitable for use
within the work environment;
ID, passwords and badgesare of personal and non-transferable use;

Do not install and useon Company equipment, (il)legal copy of software, and do not
transmit through the ADEO Companies’ softwaresystems;

Beaware that the Company’s environment, IT systems and resources are monitored in
accordance with applicable regulatory guidelines andlegislation;

Implement technical and security measures to safeguard personaldata.

63
In practice
1| Athird party contracted by my company and allocated at one of the
ADEO Companies units requested the installation of software on a
notebook made available by the ADEO Companies to carry out an urgent
project, but the process is taking too long.

Can I request that he bring the notebook to my

company so that I can install the software, expediting service to the
request?

NO: It is prohibitedto install or use on the ADEO Companies’ equipmenta

copy of software owned by you or bt a third party, even if it is an original
software, if the equipment is contractually supplied by the ADEOCompanies.

64
14.3. Use of Social Network
The ADEO Companies are committed to a good relationship with the media and
communication vehicles and are guided by integrity and transparency. For this, it is
necessary to maintain credibility by providing information quickly, accurately and
consistently.

All replies should first and foremost protect the commercial interests and/or care for the
safety of the Company’s assets. The Marketing area must validate any type of action and/
or reply that a department or store may wish to carry out in all social channels of the
company and/or third parties on behalf of the ADEO Companies.

65
Therefore, it is the duty of the Employees and Suppliers of the
ADEO Group Companies:
To direct to the Communication area any and all customer complaints that they have
accessed or received through social media;
Do not disclose confidential information and comments of the ADEO Companies in social
media, whether in their personal or third-party profiles;
To be responsible and respectful in posts on social networks and know that any information
disclosed is the responsibility of who did it, and the ADEO Companies are totally exempt.

66
Intelectual Property
All information, technologies and intellectual property, including, but not limited to, all
creative materials, brands, slogans, programs, processes, strategies, procedures and other
documents developed or requested by aADEO Company manager or Employee belong to the
Companyand all rights the Company may have on Intellectual Property are assigned to it.

All Intellectual Property will remain with the ADEO Companies after the termination of
the relationship with any of our partners, and may be improved. To do so, they willwaive all
moral and author rights they may have over it, unless otherwise provided bycontract.

Any Collaborator or partner of ADEO Companies are prohibited from reproducing, distributing
or altering materials without the prior authorization of the manager responsible for the area.

67
Audit and Termination
of Contract 15 68
15. Audit and Termination of Contract
The ADEO Companies reserve the right to, at any time, verify that their Suppliers are complying
with the provisions of this Code and all other contractual provisions. In the event that we become
aware of any actions or conditions that breach it, we reserve the right to demand from the
Suppliers the necessary corrective measures.

ADEO Companies also reserve the right to terminate any agreement with any Supplier
that breaches this Code of Ethical Conduct by sending prior written notice.

69
Communication 16 70
16. Communication
I, the Supplier, undertake to disclose this Code of Ethical Conduct of
Suppliers to all my employees, agents, and subcontractors for immediate
application.

Consequently, asSupplier,I must undertaketo provideinformation assoon as

possible uponrequest.

71
In the event of breaches related to this “Code of Ethical
Conduct of Suppliers”, please contact us through our Ethics
Listening Channel:

72
 For Russian suppliers For Chinese suppliers

https://app.whispli.ru/adeo-suppliers-russia- https://app.whispli-adeo.cn/adeo-suppliers-
responsible-purchasing-code china-responsible-purchasing-code

For suppliers from other countries

https://app.whispli.fr/adeo-suppliers-others-responsible-purchasing-code

73
Any form of reporting to the responsible channel will follow the following guidelines:

16.1. Anonymity and Confidentiality

The ADEO Companies and those responsible for investigating complaints of breaches of this Code
of Ethical Conduct shall take all necessary precautions to maintain the confidentiality of the identity
of the alert author, as well as that of the persons mentioned by them, and undertake to carry out a
fair and thorough investigation.

In addition, it is imperative that such matters are confidential and not discussed with anyone
other than those responsible for the hearings.

74
16.2. Cooperation of Investigation
Possible offenses against the principles that govern this Code of Ethical Conduct will go through
athorough investigation process and therefore it is fundamental that all those who are part of
the analysis commit to cooperate and answer all questions in acomplete and honest manner.

16.3. Protection Against Retaliation

The ADEO Companies value the help of Employees who identify possible problems that need to
be addressed. Therefore, any adverse action such as removal, demotion, loss of benefits, threats,
harassment,discrimination or any other retaliation will also betreated asabreachof thisCode.

75
Term of Commitment 17 76
17. Term of Commitment
The ADEO Companies deliver the Code of Ethical Conduct for all its Employees and Suppliers and it is fundamental that everyone read it carefully, understand and incorporate the
practices described therein.

I, the Supplier, hereby declare that I am fully aware of all the guidelines established herein, upon the prior receipt and full knowledge of the contents of the document, which is whyI
undertake to ensure compliance in all situations and circumstances that are direct or indirectly linked to my business relations with the ADEO Companies.

I further declare that I am able to adopt, at any time, the necessary measures to remedy or, if it is not possible to do so directly, to report any violation of these rules of conduct that may be
identified by me through the Ethics Listening Channel.

The acceptance of this Code of Ethical Conduct of Suppliers will be done by means of the signature of this Term through the Portal of Suppliers and/or by a hard copy.

Company’s Name:
Representative’s Name and Position:
Signature:

On: / /

77
 Annex
Wood Policy
78
1
Annex 1 - WoodPolicy
Aware of the environmental impact of their activities, the ADEO Companies prioritized
their matters and constructed a wood policy to improve the preservation of natural
resources, local communities and biodiversity.

The ADEO Companies and their Suppliers agree to respect and ensure the application of the
wood policy through the supply chain.
It covers all products containing wood fibers purchased by the ADEO Companies (market
products or not, including packaging, paper, pallets, leaflets, etc.).

79
This policy, which applies to all ADEO Companies, refers to wood coming from responsible
sources, that is, certified by FSC or PEFC, or respecting the 6 criteria defined below:

I. ADEO’s Commitments
All Companies, depending on their starting state and local context, define their main steps and
priorities with the following common and minimum objectives:

By 2020, at ADEO, 100% of our products made from wood products will come from
responsible sources, focusing on FSC or PEFC certification;

In non-market products, ADEO Companies are also committed to reducing the footprint of
wood resources;

80
The ADEO Companies undertake to provide species of wood used in the products,
their precise origins and status (certifications, labels, etc.) upon request.

The ADEO Companies work with organizations of specialists such as (TFT, FSC,
PEFC, NEPCON, WWF, etc.).

The local supply of wood closer to the place of production and areas of consumption
is favored according to the wood policy.

81
 Our Common Steps
0% of our Companies All ADEO Companies

2014 2015 2016 2017 2018 2019 2020

Launch of the •• •1100% of Suppliers •Packaging Status 90% ofwood 100% of wood coming
ADEO Wood Mapping of involved to protect diagnosis and comingfrom from responsible
policy wood origins the ADEO Wood launch of the responsible sources
da madeira + policy wood policy for sources
icustomer •• 100% of non-
information certified tropical commercial
• KPIS wood products
• 1º status

82
II. Supplier’s Commitments
The Supplier undertakes to:

1 Respect the wood policy of the ADEO Companies

2 Provide products made from wood from responsible sources, that is: Certified by FSC or PEFC;: Certi icados por FSC ou PEFC;
Otherwise, respecting the 6 criteria below.

These 6 criteria apply to the entire life cycle of the product, from the extraction of
primary resources to the end of product life. Namely:

83
Legality of the Wood
Supplier shall ensure compliance with the applicable wood regulations applicable in the country
of sale and in the country where the wood is cut.
In addition, the Supplier implements a management system to ensure the traceability of its wood
supply and must be able to identify the traceability of incoming and outgoing wood products
throughout the supply chain, especially through the maintenance of invoices and delivery notes

Right of Local Populations

The Supplier undertakes to respect the social responsibility aspect and especially the
fundamental rights and principles of human rights.
The Supplier undertakes that the exploitation of the wood resource is not carried out in violation
of the rights of local populations, close to the forest.

84
Protection of Endangered and ProtectedSpecies
The Supplier agrees not to use the wood products listed in CITES Annex 1 and to comply strictly
with the rules for the supply of the products listed in Annexes 2 and 3. (further details: https://
www.cites.org/fra/app/index.php).
Given the specific shareholdings in tropical wood, each product listed containing tropical wood
must be certified by FSC or PEFC.

Preservation of Ecosystemsand Biodiversity

In order to preserve biodiversity, the Supplier undertakes that the wood may not come from a
protected location: as a “forest of high conservation value” or high conservation value (further details:
https://www.hcvnetwork.org).

85
Preservation of Soil and Water Integrity
The Supplier guarantees that neither soil nor water will be disturbed, in particular by
prohibiting the use of GMOs.

Low Emission of Greenhouse Gases

The Supplier undertakes to reduce GHG emissions from its activities.

86
III. Policy Follow-up:

As part of our contractual relationship, ADEO Companies will support their

Suppliers in a process of continuous improvement
Know
However, in the case where the evidence of compliance with
this wood policy is not sufficient to complete an insignificant risk of
Evaluate responsible supply following a risk analysis, the ADEO Companies shall
request the Supplier to immediately implement corrective action, especially
the possibility to perform an audit at the location, collecting samples from
the product for testing (DNA, for example). The cost of these corrective
Ensure actions shall be borne by the Supplier. In the event of failure to
comply with this request, the ADEO Companies will reconsider their
business relationship with the Supplier, and in the event of a serious breach,
they may terminate the relationship.
Measure

87
What is Responsible Wood?
The Companies of ADEO officially and publicly declare their concept of Responsible Wood in the
following terms:

“The concept of Responsible Wood encompasses all products that have wood and its derivatives
(except paper or paperboard) in its composition, raw material of which is legally exploited, without
violation of human rights and with minimum environmental impact.

Since June 2018, the Brazilian native woods used in products sold by the ADEO Companies are 100%
certified. Products made from wood from non-certified planted forests will be subjected to a robust
assessment covering the following topics: Legal Compliance; Quality management system (inspection
of the SupplyChain Control Policy); Wood supply; Risk Analysis System; Forest management analysis.

88
As of June 2019, the Suppliers of products made from planted

Wood timber shall comply with the risk analysis checklist as well as apply it to their Suppliers to
ensure compliance with the Responsible Wood concept.”

Commitment
By signing this document, the ADEO Companies and the Supplier agree to set up the necessary means
to comply with the ADEO Companies’policy points.

To achieve our goal, the Supplier agrees to communicate the information necessary to track the wood
of the product through the forest and certifies the accuracy of the information that will be entered
into an on-line platform to be informed upon signature of this document.

89
 Annex 2
ADEO’s storage and packaging policy
- EN-V05
90
Annex 2 - ADEO’s storage and packaging policy -
EN-V05
The ambition of the ADEO group in terms of packaging is to put packaging on the market that
guarantees an impact (in the environment, safety, health) as low as possible, ensuring the
protection of the products and optimizing the cost of packaging in the entire offer in supply
chains.

91
Chapter 1: Compliance With The Law

Packaging and storage shall comply with the legal requirements and standards of the countries
where the product is distributed (including European Directive 94/62 EC, especially with
regard to the testing of heavy metals) and comply with the requirements of the REACH
Regulation (No. 1907/2006, in particular Article 33). |Technical documents and proof of
compliance must be provided for the products distributed by ADEO.

92
Chapter 2: Environment, Safety, Health
The following points must be respected in relation to the components, packaging conceptand
suppliers:

2.1. Component/material
-Easy-to-recycle packaging with low safety/health impact

Preferably use material with arecycling process or, at least, arecovery process in the countries
where the products are sold..

Use more cardboard (renewable material with alarge well-known recycling industry). Use
recycled fiber board and, if itis really necessary, use virgin card for resistance purposes. The
fibers must originate from certifiedforests.

93
Limit the useof plastic material fromfossil fuels: The sorting and recycling
industries are structurally uneven or non-existent for some plastics or even in some
countries

If plastic is required, limit the use of PVC to the maximum, replacing it with
another material (such asPET for blisters, PE or PPfor bags). Limit the use of plastic
windows in cardboard boxes. Give preference to the printing of photos in the
packaging or windows without plastic sheet. If this is not possible, PET should be
used instead of PVC or, where possible, recycled plastic materials should beused.

Do not usebiomaterials (PLA, starch, sugarcane), becauseat the moment there are
problems related to the end of life of this material and there are not enough industries
to recover them.

Ban the use of metal clips and strips (even in the shippingpackage).

94
Use single-component or easy-to-separate materials (by the customer or employee in
the store/warehouse) for sorting and recycling.

Use as much paint and varnish with the least harmful substances as possible.

Reduced packaging weight (sales unit + transport packaging) without reducing the
required quality:

Adjust the size of the packaging to the size of the product.

Adjust the thickness of the materials.

Adjust the weight of the packaging (optimization should be done for the packaging of
the sales unit + transport packaging).

Study the possibility of (partial or total) dismantling of the product (optimization of

transport volume). Do not forget to include assembly instructions for the customer.

95
oStudy the possibility of (really) reusing the packaging of the sales unit.

Marks to help our customer with sorting

Add signs/logos of the material packaging to facilitate its recognition (within limits: Do not print or add a
self-adhesive label to the packaging to add the sign/logo if the package (carton or bag) has no other print
or mark).

o Print the illustrations of the ADEO multilingual sorting information with the “Triman Logo” if there
is enough space in the package.

Our goal is to have no package or packaging whenever possible. The

less, the better.

2.2. suppliers:
Favor the suppliers that manage the traceability of the raw material with certification not disputed by any
suitable and known body.

96
Chapter 3: Corporate
For working conditions (for suppliers of raw materials, transformers (printers,
vacuum packaging suppliers), packers...), see ALL the bylaws.

3.1. Respect the maximum packaging weight for transport

(recommended by GS1 and ECR)

For the packaging of transport that brings together several products: 25 kg maximum.

For exhibition or cutcase that collect several products, use a pallet if the weight exceeds 18 kg

97
3.2. Respect markings on sales and transport
packaging:
Use the ISO 780-2015 mark, especially for the stacking of pallets and fragile products. Apply the
transport mark linked to the products and countries where they aredistributed.

Use GS1 recommendations for barcodes.

For products over 8 kg or bulky products: It is recommended to place abar code on thevarious
sides of the salesunit package and use the magnification factor between 150 and 200% for the
bar code.

For products over 25 kg: It is recommended to indicate the gross weightand logo
recommending the transport by 2people.

98