Code of Conduct for
Out-of-Home display
July 2022

ContentsI

Message from the Executive Board

IIIntroduction

III Code of Conduct – purpose and scope
1. Purpose
2. Scope

IV Responsibility principles
VPublication and application
1. Publication procedure
1.1. Publication and Code of Conduct compliance commitment – customers
1.2. Publication and Code of Conduct compliance commitment – JCDecaux employees
2. Approval procedure for advertising campaigns
2.1. Local Advertisement Display Committee or equivalent procedure
2.2. Regulatory and ethical monitoring of content23

I

Message from theExecutive BoardJCDecaux occupies a unique role in cities across the world, responsible for the installation and marketingof nearly one million of advertising displays in public spaces each day. Out-of-Home advertising is partof the community, giving JCDecaux a special responsibility for the quality of our advertising sites,from their design, operation and maintenance to the advertising content – to ensure we meet theexpectations of our clients, partners and the public.
Quality and service has been at the heart of our business, ever since Jean-Claude Decaux founded
our company in 1964. Building upon his vision, our business has the strongest commitment to ethicaland responsible advertising – part of our ambition to be the leader in Out-of-Home advertising and atrailblazer in responsible communications. We comply with all the local laws and regulations everywhere
we operate, but we also go further, introducing our own Code of Conduct for Out-Of-Home Display(«Code of Conduct») in line with the values of our founder.
Our Code of Conduct is global in scale and sets out clear principles, based upon our Company values.
It includes guidelines for how the Code should be communicated and monitored in each region as wellas the expertise and responsibility required in each location.

IIIntroduction

As the number one company in Out-of-Home advertising worldwide, JCDecaux provides communities
and transport partners with valuable amenities and services paid for by advertising. We take greatcare to design, install and maintain our Street Furniture so that it is useful and aesthetically pleasing,enhancing life in cities for people. Part of the community, our advertising sites enable our partners
and stakeholders to communicate with the public when they are out and about, creating economic andsocial value everywhere we operate.
Jean-Claude Decaux’s pioneering concept of services funded by advertising has been recognised for
its excellence across the world. Today, the sustainable business model he created continues to deliver
improvements in urban living, at no cost to local taxpayers in more than 80 countries, across everycontinent. Our media reaches people in thousands of major cities (with over 10,000 inhabitants), in
more than 150 airports and across hundreds of transport networks for metros, buses, trains and trams.
The Group’s values of quality, innovation and passion continue to define how we work across our threeenvironments: Street Furniture, Transport and Billboard Advertising.
Our advertising networks are seen on a daily basis by hundreds of millions of people across the globe,
creating a public platform on a scale and of a quality that is unequalled. We are proud of the trust
placed in us by our customers and partners as we collaborate with them in a virtuous development
model that serves people and the environment. As a responsible company and a world leader in Outof-Home, JCDecaux continues to build upon the vision of our founder, putting service and sustainability
at the centre of our business.
In our business practices, JCDecaux has always upheld core values relating to our employees,
advertising clients, stakeholders and suppliers – key to our good reputation and the trust of ourpartners. We comply with the rules and regulations of the public authorities in our markets around theworld and go further, setting ourselves even higher standards, as part of our vision for the role of media
in our society. As a consequence, JCDecaux has been committed over the long-term to upholding
the universal values of the following declarations: the United Nations’ (UN) Universal Declaration of
Human Rights (UDHR) adopted on 10/12/1948, the Convention on the Rights of the Child adopted on
20/11/1989, the Convention for the Protection of Human Rights and Fundamental Freedoms of theEuropean Council adopted on 04/11/1950 and the Charter of Fundamental Rights of the EuropeanUnion (EU) adopted on 07/12/2000.

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Such principles include:- freedom of expression- freedom of trade and industry- respect for human dignity and rights- respect for gender equality- rejection of racism, anti-Semitism and any or all discrimination based on membership of an ethnic
group or cultural community, gender, sexual orientation and identity, philosophical and/or religious
beliefs- respect for child and teenage audiences- rejection of violence and incitement to any unlawful act or act that endangers people’s health andsafety- respect for decency, honesty and truthfulness.

III

JCDecaux’s Code of Conduct sets the standard for our Group’s display policy for advertising campaigns
carried on our networks, in line with our values and these principles.
At a time of great change, the need for ethics and responsibility is more pressing than ever.
Faced with climate change, businesses are changing their production processes to move towards a low
carbon economy with sustainable growth. At the same time, consumers increasingly value experiencesthat have service and sustainability at their heart. As this environmental transition continues, Out-ofHome has an ever greater duty to ensure that advertising communication about products and services
carried on our media is responsible and ethical.
Environmental and sustainability-based criteria is of increasing importance to our advertisingclients and stakeholders when it comes to choosing their media partners. JCDecaux’s extra-financial
performance has been recognised globally (CDP, MSCI, FTSE4Good) and the Group is well positioned
as a socially responsible company that is playing our part in the climate change transition.
From a local and global perspective, our partners and clients expect to see ethical and responsible
advertising on Out-of-Home, a view that is perfectly aligned with our long-term vision and with the UN’s
Sustainable Development Goals (SDGs). We have been working for a long time with our key advertisingpartners to raise awareness of the role that their brands can play in terms of their environmental
impact. We are using our in-house and third-party expertise and our role as an intermediary between
brands and local authorities to champion «Brand Urbanism» which is a collaborative initiative thatseeks to leave a positive and sustained impact on regions and communities.
As we look towards a more sustainable future, JCDecaux’s teams across the globe will continue to play
an increasingly important part in shaping the responsible and ethical platform of Out-of-Home and thepowerful and public platform of our worldwide communication channel.

Code of Conduct –purpose and scope

1. PURPOSEJCDecaux’s Code of Conduct sets out a framework for the content that we choose to accept on
our advertising sites and applies to JCDecaux SA (French Public Limited Company) and all Group
companies.
The Code was developed by JCDecaux and draws upon a number of existing codes including: theInternational Chamber of Commerce (ICC) Advertising and Marketing Communications Code andfollows recommendations provided by the International Council for Advertising Self-Regulation (ICAS)
and regional and national authorities including the European Advertising Standards Alliance (EASA)
and the French Professional Advertising Regulation Authority (ARPP).

2. SCOPE
This Code applies to all advertising/communication media. This includes posters, digital screens,banners and ambient media as well as all visual formats (PDF and JPG), digital content (mp4 format)
and social networks, whether for commercial, promotional or non-monetary purposes, in all countries
where JCDecaux operates.
The Code sets out the minimum guidance to be respected, in line with our values. The Code is intended
to supplement any local laws and regulations which we comply with in each market.
If a local law or regulation means that a local JCDecaux business can not comply with a principle as
it is outlined in the Code, the JCDecaux business, must as far as possible try to adapt or localise theprinciple so that it is consistent with the laws of the relevant authority.

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Decency
Advertising must not include any visual presentation that goes against the established or commonly
accepted norms in the country and culture concerned.

Trust
Advertising must not abuse consumer trust or exploit consumers lack of experience or knowledge.

Honest and Truthful
Advertising must prohibit any directly or indirectly misleading statement or visual presentation. Thisapplies to content that is ambiguous or overstated.

IV

Responsibility
principles

Negative campaigns
Advertising must not discredit an organisation, profession, individual, group of individuals or a productin an unfair way.

Image rights

Social responsibility

Advertising must not represent a person without their prior consent.

Advertising must respect human dignity and must not encourage or condone any form of discrimination,and in particular in terms of ethnic or national origin, religion, gender, age, disability, gender identity
and/or sexual orientation.
Advertising must not reduce human beings to objects. Advertising must also not endorse the idea thata person is inferior because of their gender, origin, membership of a social group, sexual orientation
and/or identity or any other criterion of discrimination. More specifically, advertising must not reduce a
person’s societal role and responsibilities.
Advertising must not promote direct or indirect feelings or behaviours of exclusion, intolerance orsexism.
Advertising must not exploit fear, unless and exclusively on justifiable grounds.
Advertising must not incite or endorse any unlawful or improper behaviour.
Advertising must not visually present or describe practices and/or situations that are dangerous oragainst health and safety, unless justified on educational or social grounds.
Advertising must be truthful and honest and must not allow any statement or visual representation that
may spark irrational fears. All forms of exploitation and superstition must be strictly prohibited.
Advertising must not include any displays or acts of violence, whether direct or suggested, uness it
is justifiable in the context of the product or service advertised. Inciting violence – whether moral or
physical – is strictly prohibited.

Intellectual property rights
Advertising must not use other company or organisation names, logos and/or brands without outlining
a specific reason. Advertising must also not take unfair advantage of other companies’/organisations’
reputation or of the prestige associated with other advertising campaigns.
Advertising must not include any imitation of the layout, text, slogan, visual presentation, music, etc.,
featured in other advertising campaigns which could mislead the consumer.

Children and young teenagers
Advertising must not capitalise on the credulity, loyalty, vulnerability or lack of experience of children
and young teenagers.
Advertising must not minimise the level of skill and/or age required to use a product.
Advertising must not contain any statement or visual presentation that may cause psychological, moral
or physical harm to children and young teenagers. Advertising must also not lead them into situations
or activities that pose a serious risk to their health, psychological wellbeing or safety.
Advertising must not suggest a physical, social or psychological advantage over other children throughowning or not owning a product or service.
Advertising must not undermine the authority, responsibility, judgement or tastes of parents. Advertisingmust acknowledge commonly accepted social and cultural values in country where it is displayed.

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dreamEnvironmental conduct
Advertising must not appear to endorse or encourage actions and practices that are unlawful and/or
harmful to the environment.

Sustainable developmentAdvertising that makes use of the general idea of sustainable development or that presents material thatis inconsistent with sustainability objectives must comply with the following principles: truthfulness andhonesty, objectivity and trustworthiness:
1. Truthfulness and honesty: advertising must not deceive the general public regarding the true nature of theadvertiser’s activities and/or the characteristics of their products and services.
2. Objectivity: advertising must reflect the proportional nature of its message, when it is promoting
sustainable development and the true nature of the advertiser’s initiatives in this regard.
3. Truthfulness: advertising must not communicate the exclusive nature of an advertiser’s initiative when it iscomparable with those led by other advertisers.
Advertising must not appear to endorse working conditions which violate social and human rights.

V

5. Publication
and application

1. PUBLICATION PROCEDURE
1.1. Publication and Code of Conduct compliance commitment – customers
JCDecaux is committed to promoting these values with all its stakeholders. This includes primarily
companies in which JCDecaux has a majority ownership interest or a joint control; its advertising customersand partners and media agencies.
The Code is referenced in the General Terms and Conditions of Sale and/or Conditions of Service ofJCDecaux Group business units to commit advertisers to fully comply with the terms.
As is the case for all documentation relevant to the JCDecaux Group standard (Code of Ethics, International
Charter of Fundamental Social Values, Supplier Code of Conduct), this Code is available to access anddownload on the Group’s public websites.

1.2. Publication and Code of Conduct compliance commitment – JCDecaux employees
All JCDecaux’s employees are required to comply with the content of this Code (that is available on thelocal intranet of each of the Group’s subsidiaries). The Marketing, Sales and Community Relations teams
and local authority members responsible for ethical advertising must be made aware of this Code and theneed to comply with it.

2. APPROVAL PROCEDURE FOR ADVERTISING CAMPAIGNSThe approval of campaigns must use the following recommendations which have been developed to ensure
a consistent and clear process for how JCDecaux reviews advertising creative that we receive from media
agencies and advertisers.
Local communities that are responsible for ethical advertising within the JCDecaux Group must base theirapproach on a factual assessment. It is critical that decisions are made on a local basis, but also in a waythat is consistent and that follows the Group’s shared principles outlined in this Code and with reference toa clearly identified and formally defined procedure.

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2.1. Local Advertisement Display Committee or equivalent procedure
To ensure compliance with this Code, each country has established a Local Advertisement Display
Committee that comprises people from across the business, including when possible: public affairs, legal,sales, marketing, sustainable development and communications departments.
Each Local Advertisement Display Committee must prioritise a way of working that works best for them interms of efficiency and effectiveness.
Each Advertisement Display Committee must set up a local filing system to record campaigns that havebeen refused, accepted, or accepted with amendments, noting the details. Committees must regularly
report their activities following the procedures defined elsewhere.

2.2. Regulatory and ethical monitoring of content
The Local Advertisement Display Committee must identify and be aware of any restricted or sensitive
categories in their market, this may include: alcohol, smoking, gambling, food, products with restricted
access for children, political advertising and image of people.
Before accepting an advertising/communication contract with an advertiser/partner, the creative must bereviewed before printing or publication. Its content must be assessed to make sure it complies with any local
regulations and the principles outlined in this Code.
When managing a request for a campaign that falls into an identified sensitive category, the Local
Advertisement Display Committee must set a deadline for the receipt of final creative visuals and/orcampaign proposals, giving enough time for a compliance check or a prior opinion. The Committee mustensure that the content in question (visuals, proposals, contextual explanations etc.) are sent by the local
sales department to all members of the Advertisement Display Committee for a reasoned assessment.
This will result in one of the following outcomes:- approval.
- approval subject to conditions. The decision to display/publish the campaign that is under review must be
decided by the local sales department.
- refusal. Under such circumstances, only the local executive management team may make a reasoned
decision to override the decision not to display/publish the campaign.

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Code of Conduct
for Out-of-Home display
July 2022