Responsible Purchasing Charter

Introduction

Beyond the obligation to comply with a constantly evolving normative and regulatory framework, ESI
aims to reaffirm and strengthen its commitment to act ethically and responsibly. The group strives topromote its values both within its organization and wherever it develops activities.
Therefore, the group has developed a charter to support its suppliers so that they comply withlegislation on corporate social responsibility (social, environmental, and ethical), whether national,European, or international.
Suppliers are required to ensure that all their own subcontractors, suppliers and partners working on
behalf of the group comply with the charter.

Definition
ESI Group is the parent company of a multinational group. To refer to all the entities in this group, theterm ESI will be used.

Objective
The purpose of this charter is to describe ESI's expectations in terms of Ethics and Compliance withrespect to third parties (hereinafter referred to as the "Partners") and to offer them advice on how toact in our many areas of operation. The guidelines and standards contained in the chartercomplement ESI's sustainability requirements for its suppliers (i.e., the sustainability criteria includedin the supplier evaluation form). This charter is a guide to ethical business practices that will ensure
fruitful and sustainable collaboration.

Application
This Charter shall enter into force from July 2024.

ESI Adresse :Symbiose 2, 10, avenue Aristide Briand, 92220 Bagneux.

Contents
Part 1: Human rights and working conditions ......................................................................................... 4
1- The fight against discrimination and the promotion of equal opportunities. ................................ 4
2- The elimination of forced and compulsory labour .......................................................................... 4
3- The elimination of child labour ....................................................................................................... 44- Occupational safety and health ...................................................................................................... 4
5- Wages, rest and decent working conditions ................................................................................... 5
6- The promotion of social dialogue.................................................................................................... 5
Part 2 - Business Conduct Ethics and Governance .................................................................................. 5
1-Data confidentiality .......................................................................................................................... 5
2- The fight against corruption ............................................................................................................ 5
3- Compliance with competitive practices .......................................................................................... 64- Compliance with economic sanctions ............................................................................................. 65 Establishing a lasting and balanced relationship with suppliers ...................................................... 6Part 3 - Environmental Liability ............................................................................................................... 6
Part 4 - Supplier Membership ................................................................................................................. 71-Implementation and continuous improvement............................................................................... 72-Signature .......................................................................................................................................... 8

Part 1: Human Rights and Working Conditions
ESI respects the Universal Declaration of Human Rights, supplemented in Europe by the Charter ofFundamental Rights of the European Union, the European Convention on Human Rights and recognizes
all these rights to its stakeholders (employees, customers, etc.). ESI expects the same from hissuppliers.
ESI suppliers must ensure compliance with the fundamental conventions and protocols of theInternational Labor Organization.

1- The fight against discrimination and the promotion of equal opportunities.
Discrimination consists of favoring or disfavoring an individual because of some of his or her
characteristics or personal choices.
Suppliers must ensure that no distinction, exclusion, or preference is based on color, sex, age,language, religion, sexual orientation, or identity, national or social origin, opinion, or disability or any
other form of discrimination recognized by local or international law.
It must pay particular attention to discrimination in terms of access to employment and career paths(access to training, promotion, termination of contract, retirement, etc.). This vigilance must cover all
forms of discrimination, whether direct or indirect.

2- The elimination of forced and compulsory labor
ESI strongly condemns modern slavery in any form (human trafficking, withholding of identity papers,violence and threats, debt bondage, etc.).
Suppliers undertake to respect the same level of requirement.

3- The elimination of child labor
Suppliers must ensure the non-use of child labor.
The International Convention on the Rights of the Child defines a child as any person under the ageof 18 unless the age of majority is reached earlier under applicable law.
For ESI, a child is considered to be a child if she/he has not yet reached the age of completion ofcompulsory schooling, or the minimum age required to work in the country where she or he lives andmay not be lower in all circumstances than 16 years.
In any event, Suppliers must ensure that all employees under the age of 18 shall not perform any
work that could be dangerous or harmful to them (health, safety, morality of the child).

4- Occupational safety and health:
Suppliers must ensure that their employees work in a safe and healthy environment, just as ESI does.
Suppliers are encouraged to identify the risks associated with their activities and to take measures toprevent accidents and injuries and to ensure healthy, safe, and dignified working conditions andenvironment for their own staff.
This includes the dissemination of appropriate safety information, the transmission of which must bereinforced in the event of dangerous situations.

All of the supplier’s employees have the right to benefit from a health and social protection system inaccordance with the local legislation in force.

5- Salary, rest, and decent working conditions
Suppliers must undertake to comply with the rules in force concerning the right to the payment of adecent and regular salary, to rest and to legal benefits, rights conferred on any employee.
This includes the respect of a maximum number of weekly working hours and respect for the weekly
rest period.
Employees of suppliers must be paid at least the minimum wage and benefit, where appropriate, forovertime worked in accordance with local laws and regulations.
In general, ESI reaffirms that the well-being of the employee must be taken into by suppliers, which
implies decent employment conditions.

6- The promotion of social dialogue
Suppliers must ensure freedom of expression, freedom of association and the right to collective
bargaining are respected.

Part 2 - Ethics of Business Conduct and Governance
1- Data privacy
Suppliers must not, under any circumstances, use any proprietary or confidential information they may
have received in the course of their business relations with ESI, unless the latter has given its priorconsent.
Sensitive information includes all intellectual property rights and privileged information.
Suppliers may not use sensitive information to perform, directly or through a third party, transactionsin the Group's listed securities or to guide the negotiation of contracts with third parties.
Suppliers must deploy a secure IT system to prevent digital attacks or potential data leaks.
Individuals have the right to the protection of their personal data. The processing of personal data by
Suppliers must be carried out in accordance with the General Data Protection Regulation (GDPR), anyother laws and regulations that may exist locally and the contractual provisions described in generalconditions of purchase; https://www.esi-group.com/fr/general-purchasing-conditions

2- The fight against corruption"Corruption is a conduct/behaviuor by which a person (public official or private person) requests oraccepts directly or through an intermediary a gift, offer or promise, presents or benefits of any kindwith a view to carrying out, delaying, or failing to perform an act directly or indirectly within the scopeof his or her duties in order to obtain or maintain a commercial or financial advantage, or to influencean administrative decision.".
ESI strongly condemns any form of corruption, extortion or money laundering and applies a “tolerancezero” in this regard.

In particular, suppliers agree not pay bribes or engage in any act of corruption (including throughfacilitating payments, excessive gifts and hospitality, or donations) in their business relations with theircustomers, suppliers, members of the administration or any other related person.
Suppliers and their subcontractors must comply with applicable laws, guidelines and regulations thatset forth obligations to combat corruption, influence peddling, conflicts of interest, money launderingor any other practice that constitutes corruption, in particular the Sapin II Act, the UL Bribery Act andthe Foreign Corruption Act. For non-taxable persons, processes appropriate to their size and risk
should be put in place with a view to preventing any act of corruption during its activities, including
the implementation of transparent management and the keeping of accounts in accordance with theapplicable rules and provisions.

3- Compliance with competitive practices
Suppliers undertake to compete in a healthy and fair manner on the market, recpecting the law laws
and regulations on competition. They must refrain from participating in any anti-competitive practicewhatever its form (illegal cartel, in particular on prices, abuse of a dominant position, etc.).

4- Compliance with economic sanctions
Suppliers undertake to respect and follow the regulations on economic sanctions including the control
of exports, imports, embargoes, and other restrictions (taxes, quotas, credit freezes, etc.).
As part of the business relationship, suppliers must guarantee that they will declare any sanctions towhich they are or would be subject.

5 Establishing a lasting and balanced relationship with suppliers
ESI wishes to place the business partnership with its suppliers in a sustainable value chain thatpromotes a balanced relationship.
ESI ensures to participate in the development of the territories in which it is established and wishes
that its suppliers will do the same. To that end, they must:• Create an ecosystem relationships that contributes to their development while ensuring thatexchanges with established local stakeholders and the territorial impacts of their activities are properlymanaged.
• Seek to develop economic activity close to their area of influence.

Part 3 - Environmental Responsibility
ESI seeks to reduce its environmental impact by taking into account the sustainability of its action.
Within the frame of its environmental performance improvement initiatives, ESI expects suppliers tointegrate environmental issues into their activities to offer environmentally friendly products andservices.
Suppliers must ensure that their practices allow:• The sustainable and rational use of energy and natural resources (water, raw materials, etc.).
• The promotion of eco-design.

• The implementation of logistics processes to reduce their production of greenhouse gases.

Part 4 - Supplier Adherence
1-Implementation and continuous improvement
This Charter is an integral part of the Purchasing Processes, and is generally aimed at companies orentities with a large purchasing volume or strategic importance in the ESI’s value chain.
Suppliers undertake to implement all the means necessary to ensure compliance with the principles
set out and to relay these provisions to their own suppliers, including in countries that are notsignatories to the conventions of the International Labor Organization where they would have to work.
ESI reserves the right to conduct audits or evaluations for the purpose of supplier qualification and in
the event that any practices inconsistent with the principles supported in this Charter are detected.
ESI reserves the right to ask the supplier to implement corrective actions.

2-Signature
We hereby confirm:• That we have received and acknowledge of ESI's Responsible Purchasing Charter.
• That we are committed to the implementation of these principles and that their non-compliance
may be considered as a breach of our obligations, which could lead, depending on the seriousness of
this non-compliance, to the termination of commercial relations.
• That we will therefore inform all our direct suppliers and encourage them to follow theseprinciples.

Company Name: ................................................................................. ..........
Done at: ... ................................ ...... . . .............
Date: …………………………………………………………………………………………………………………………………………… .. .….
Authorized Signatory:
Name: ................................................ ................ .. .
Title:... ................................................................ ....................................................
Signature and stamp of the company:

If you have any questions, you can contact us via the following email address:
csr.esigroup@esi-group.com

Useful links:
General terms and conditions of purchase of ESIESI Ethical CharterDeclaration of Human Rights• Freedom of Association and Protection of the Right to Organize Convention, 1948 (No. 87);
• Right to Organize and Collective Bargaining Convention, 1949 (No. 98);
• Forced labor Convention, 1930 (No. 29) (and its 2014 Protocol);• Equal Remuneration Convention, 1951 (No. 100);• Discrimination (Employment and Occupation) Convention, 1958 (No. 111);• Abolition of Forced Labor Convention, 1957 (No. 105);• Minimum Age Convention, 1973 (No. 138);• Worst Forms of Child labor Convention, 1999 (No. 182).