Richemont

Corporate Social Responsibility Guidelines
As a member of the global community, Richemont strives to act as a responsible corporate
citizen. It prides itself on maintaining high standards of integrity and honesty in carrying out
its business activities and expects the support of its managers, its employees, suppliers andassociates in pursuing these goals.

The Richemont Corporate Social Responsibility Guidelines have been adopted by the Boardof Compagnie Financière Richemont SA on 23 March 2005, and revised on
15 November 2007.

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Richemont Corporate Social Responsibility Guidelines
Table of Contents
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Responsibility towards customers
Product design and quality
Staff training and customer service
Availability and choice
After-sales service
Combating counterfeit products

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Responsibility towards employees
Employment & labour rights
RewardHealth & safety
Equal opportunities & respect at work
Employee participation
Fair dealing
Compliance and reportingoooResponsibility towards the community
Charitable involvement
Sponsorship activities
Fostering new talent

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Responsibility towards the environment
Facilities and operations
Product stewardship
Precautionary approach
Application and compliance

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Responsibility towards and obligations of business partners
Labour relationships and employment practices
Responsible environmental management
Industry specific issues
Ethical business principles
Supplier of the supplier
Application and compliance

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Responsibility towards shareholders
Principles of corporate governanceTransparency in financial reporting
Proactive investor information policy
Code of conduct for share dealings

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Detailed guidelines in each of these areas are set out in the following sections of thisdocument.
Note that the terms ‘Richemont’ and ‘the Group’ are used interchangeably throughout thisdocument.
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Richemont Corporate Social Responsibility Guidelines
Part 1
Responsibility towards customers
Richemont “Maisons” are committed to excellence, ensuring that their heritage,
individuality, traditional values and commitment to quality are conveyed to their customers
through their products and services. In pursuing these goals, the Group, will seek to act withintegrity and fairness towards its customers.
1. Product design and quality
Richemont Maisons are committed to creativity and innovation. Maisons must ensure that
this is done in line with the brand’s identity and core values, thus maintaining the intrinsic
worth of the brands over time. Richemont aspires to ensure that all products shall be of thehighest possible quality.
2. Staff training and customer service
Richemont seeks to ensure that its retail customers, whether buying from a company owned
boutique, a franchisee or from a retail partner, receive the highest standards of customer
service and care. The Group will therefore provide all its employees and dealers withappropriate training to ensure customer-focused service that reflects the Group’s and each
Maison’s image.
Employees shall be made aware of the need to treat all retail customers and potential
customers fairly, avoiding discrimination
3. Availability and choice
Each Maison has established an appropriate strategy governing the distribution of its productto wholesale and retail customers.
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Through its extensive international distribution infrastructure that includes a network ofwholesale and retail outlets, the Group seeks to offer, within the limits of production thebest possible availability of its products across the globe.

4. After-sales service
Richemont seeks to provide its customers with high levels of service, whether in terms of
repairs under guarantee, routine servicing or ad hoc repairs. Richemont will continue its
efforts to ensure that there is a strong after-sales service organisation equipped to provide
customers with a level of service and care which is commensurate with the quality of the
products being sold and which meets customer expectations.
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Maisons shall ensure that the terms of guarantees provided by the company or under theterms of local legislation in the countries in which they operate are honoured.

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•All after-sales service work shall be effected using materials of a quality equivalent tothose used in the original product. Clear information regarding cost quotations and thetime required for the repair process will be communicated to the customer, if requested.

5. Combating counterfeit products
Counterfeit products can lead to dilution and confusion in the market, undermine the valueof legitimate products bought by the Group’s clients and can result in the purchaser being
deceived. Richemont is committed to taking appropriate action when it becomes aware of the
production and distribution of counterfeit products.
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Product designs will be closely safeguarded. Wherever practical, products shall carry
unique identifiers which will facilitate product tracking.

•Maisons’ trademarks, designs, creations and technical innovations shall, as far aspractically possible, be protected by trademark, patent, copyright and other appropriate
intellectual property laws. The Intellectual Property Department will monitor andendeavour to protect the Group’s assets in this area.

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The Group Intellectual Property Department will work to detect and combat the
manufacture and sale of counterfeit and infringing products and will collaborate as
required with international organisations, law enforcement agencies and other companies
in order to minimise the impact of infringement and counterfeiting.

4Richemont Corporate Social Responsibility Guidelines
Part 2
Responsibility towards employees
Fair dealing together with ethical conduct towards the Group’s employees is central toRichemont's reputation and to its ongoing success. To this end, Richemont seeks to comply
with all applicable laws and regulation and with the ethical principles set out below.
1. Employment and labour rights
Richemont is committed to adopting fair and ethical labour practices. Employee conditions
and terms of service will comply with national laws and applicable industry standards.
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Richemont will not tolerate uncivil or degrading treatment of employees and is opposed
to all forms of abuse, physical punishment, forced labour and child labour whether in its
own operations or those of its suppliers or partners.

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Richemont will seek to provide appropriate mechanisms through which the rights andwell being of its employees may be protected and they may learn and develop their skills.

2. Reward
Richemont is a global enterprise and the means by which it rewards its employees will
inevitably vary according to local law, practice and market pressures. Irrespective of thisnational diversity, Richemont strives to acknowledge the value that each employee brings to
its business and to provide rewards on a fair and ethical basis and in line with a common
framework.
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Wages and benefits will meet or exceed minimum national legal standards and should
generally be in line with or exceed industry benchmarks.

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The Group seeks to provide adequate post-retirement benefits in line with local
legislation and general good practice within its businesses and in the countries in which it
operates.

3. Health and safety
Richemont acknowledges its responsibility for the health, safety and general well being of its
employees in the performance of their duties. Richemont seeks to provide and maintainsystems and places of work, which are in line with applicable safety and health standards.
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Richemont will endeavour to provide support and assistance in the resolution of work
related problems.

•Richemont will undertake regular risk assessments of its work places. Where
appropriate, Richemont will consult with employees on health and safety issues.

54. Equal opportunities and respect at work
Richemont is an equal opportunities employer and has a policy of offering equal treatment toall applicants and employees. Employment is provided and decisions concerning terms andconditions of employment, performance appraisals and promotions are made on the basis of
aptitude, ability, contribution to Richemont's success and commercially appropriate factors
permitted to be considered under local laws.
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Richemont does not discriminate in the recruitment, training, promotion, appraisal,compensation or termination of its employees on grounds of race, national origin,religion, disability, gender, sexual orientation or on any other illegal ground.

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Each employee is under a moral and, as applicable, legal duty not to discriminate on suchgrounds and any allegation of a breach of this duty will be investigated. Discrimination
by an employee will result in appropriate disciplinary action, which, subject to applicablelaw, may include the summary dismissal of the individual concerned.

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Richemont will not tolerate conduct, which creates an offensive, intimidating or hostileenvironment for others. Harassment is unacceptable within the Richemont environment
and will be investigated and dealt with in an appropriate manner.

5. Employee participation
Richemont maintains an open and responsive view of the activities of employee
representatives and respects the rights of employees to participate in trade unions of theirchoosing and to collective representation.
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Richemont recognises employee representatives and aims to provide them withreasonable opportunity to conduct their functions within the workplace.

6. Fair dealing
Richemont is opposed to all forms of corruption and bribery. Its employees, suppliers andassociates are prohibited from offering, making or receiving any unauthorised or unorthodox
payments or other inducements which compromise the making of objective and fair businessdecisions•

Richemont encourages its employees to report any irregular approaches that an employee
suspects are aimed at soliciting business from the Group.

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Business entertainment and hospitality must be of a type recognised to be appropriate forthe level at which the employee works and for the country concerned.

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Richemont employees shall not offer payments or inducements to third parties in order tosecure business from them.

67. Compliance and reporting
Richemont encourages employees to identify and raise potential ethical and legal issues
before they lead to problems, to seek management advice on the application of ethicalpolicies and these Guidelines when in doubt and to report violations of such policies these
Guidelines and applicable laws and regulations promptly. Richemont will take action toinvestigate and address any violations.
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Richemont has established a reporting mechanism to give employees the opportunity toflag illegal acts and/or conduct that is not in compliance with the Richemont Code ofBusiness Ethics and the Corporate Social Responsibility Guidelines. Any irregular
activity they prefer not to transmit to local Management or Human Resources may be
conveyed directly to the Head of Internal Audit at "whistle.blowing@richemont.com".
To enable a prompt assessment and the implementation of appropriate corrective action,
the informant may not report anonymously. Nevertheless, protection and confidentiality
are guaranteed by the independence of the Internal Audit function.

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To the extent practicable and permitted by local law, Richemont will respect privacy andmaintain the confidentiality of employee reports of possible violations for an employee
reporting a possible violation. No one will be subject to retaliation or discrimination
because they have in good faith reported suspected violations.

7Richemont Corporate Social Responsibility Guidelines
Part 3
Responsibility towards the community
Richemont seeks to contribute to promoting the health, welfare and sustainable economic
development of the wider community in which our Maisons operate. The Group also
believes in the importance of supporting its employees in their individual and collective
efforts towards improving society.
1. Charitable involvement
Richemont acknowledges its responsibility towards the community by participating in and/or
donating to charitable organisations.
•Globally, Richemont supports Laureus Sport for Good, a charity established to help
underprivileged individuals around the world through the medium of sport. Richemontcompanies around the world are encouraged to support the Laureus concept, throughboth financial involvement and support for the charity in terms of making resources andstaff time available.

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Maisons have the freedom to donate to any officially recognized charitable organisation
which supports a valid cause. Representatives of the Maisons should seek to ensure thatsignificant donations are put to good use, have access to the financial statements of thecharity concerned and verify that funds are used to benefit legitimate projects and are notabsorbed in administration of the charity.

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Richemont Maisons and operating companies may only make contributions to politicalparties or similar organisations to the extent permitted by local law with the priorapproval of the Chairman’s Committee. Any such contributions shall be fully andtransparently disclosed in both the Group’s internal reporting and in the statutory
reporting of the entity involved in accordance with local legal and regulatory
requirements.

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Richemont employees should be given the opportunity, where feasible, to voluntarily
donate money to their chosen charity by way of payroll deductions.

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Employees should be encouraged to volunteer their time to support charitable causes.
Where appropriate, the Group will endeavour, wherever practicable, to allow employees
reasonable time, whether compensated or not, to become involved in projects which
support the community and/or charitable causes.

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2. Sponsorship activities
Sponsoring aims by nature to associate a company with an international or local event,through a financial participation.
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Individually, Richemont Maisons support various initiatives, which are seen to be linked
to the values of the Maison. It is important that the choice of activity for sponsorship besuited to the image and the profile of the clientele of the Maison in question.

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Maisons should avoid involvement in sponsoring, potentially hazardous activities or
activities which are not compatible with the values of the Group or the Maison itself.

3. Fostering new talentRichemont seeks both to develop and perpetuate know-how, technical skills and a spirit ofexcellence amongst its employees. This is especially important for the traditions ofcraftsmanship that are involved in the creation of the Group’s products.
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Group companies will operate formal apprenticeship programmes both independently
and under the auspices of the relevant government agencies and trade associations.

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Richemont acknowledges its responsibility for fostering new talent by offering
opportunities for staff to benefit from the experience of more senior employees
throughout the organisation.

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The Group will invest in the education of future potential employees and provides themwith learning opportunities, for example through the Richemont School of Design in
Milan and through the development of special partnerships with international design andcraft schools.

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Through its cultural initiatives, the Group supports young artists in a range of disciplines,
fostering creativity and new talent.

4. Responsible citizen
Richemont recognises its responsibilities to its shareholders to optimise over the long term
its profitability and return to shareholders within the constraints imposed by laws,
regulations and good corporate conduct. It also recognises its obligations to the communities
in which it operates. The Group will pay all taxes due in compliance with prevailing fiscal
rules and regulations.

9Richemont Corporate Social Responsibility Guidelines
Part 4
Responsibility towards the environment
As a member of the global community, Richemont seeks to act as a responsible corporate
citizen carrying out its business activities in a manner which is consistent with the protectionof the environment.
In this regard Richemont has developed a model Environmental Code of Conduct(the “Environmental Code”), which confirms the Group’s commitment to environmental
stewardship and elaborates in detail the principles and practices that will be followed inorder to promote responsible environmental management. The Environmental Code has beendrafted taking into account the principles inherent in these Guidelines. The Environmental
Code may be adapted, with the approval of the Group Corporate Social Responsibility(“CSR”) Committee, to reflect the activities of specific Maisons or entities in the Group.
1. Operations•

Richemont will ensure that its operations are in compliance with local environmental
legislation, norms and regulations and executed in harmony with the environmental
surroundings.

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Richemont will monitor, as appropriate, both pollution and the consumption of water,energy, oil, natural resources and other materials used in its operations with a view toimproving their usage and minimising waste.

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Richemont will comply with international and local regulations related to the
procurement, import, usage and export of raw materials issued from endangered orprotected species.

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Richemont adheres to the principles of the “World Diamond Council Resolution on
Industry Self-regulation” supporting the Kimberley Process and the system of written
warranties established by the industry.

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Richemont will seek to require its suppliers of gold to provide, wherever feasible,
assurance that gold has been mined in a manner that does not inflict environmental
damage or violate human rights.

2. Product stewardship•

Richemont Maisons will seek to minimise the impact of their manufacturing activities
and delivery processes on the environment.

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3. Precautionary approach•

Richemont will endeavour to respect the preservation of ecosystems and the conservationof scarce resources.

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The Group will manufacture products in a manner consistent with prevailing bestpractices in order to prevent any adverse impact on health, safety or the environment.

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For its major manufacturing entities, Richemont will develop and maintain emergency
preparedness plans in conjunction with the relevant emergency services and authorities.

4. Application and Compliance•

A member of management at each of the Group’s manufacturing facilities will beassigned responsibility for the implementation of environmentally responsible practices.

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Richemont reserves the right, subject to applicable law, to terminate employment orbusiness relationships with any employee, supplier or business partner who violates theGroup’s guidelines relative to environmentally responsible management.

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Richemont has established a reporting mechanism to give employees the opportunity toflag illegal acts and/or conduct that is not in compliance with the Richemont Code ofBusiness Ethics and the Corporate Social Responsibility Guidelines. Any irregular
activity they prefer not to transmit to local Management or Human Resources may be
conveyed directly to the Head of Internal Audit at "whistle.blowing@richemont.com".
To enable a prompt assessment and the implementation of appropriate corrective action,
the informant may not report anonymously. Nevertheless, protection and confidentiality
are guaranteed by the independence of the Internal Audit function.

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Richemont Corporate Social Responsibility Guidelines
Part 5
Responsibility towards and obligations of business partners
Richemont and its Maisons’ relationships with all business partners - suppliers, subcontractors and business allies are based on sound business practices and mutual trust. The
relationship should be dynamic in nature and mutually rewarding. In the spirit of setting up
and disclosing its policies towards its business partners, Richemont has issued a Model
Supplier Code of Conduct (the “Model Supplier Code”) applicable to all its business partners
throughout the Group. The Model Supplier Code has been drafted taking into account the
principles inherent in these Guidelines and elaborates in detail how Richemont expects its
suppliers to adhere to responsible business practices. The Model Supplier Code may be
adapted, with the approval of the Group CSR Committee, to reflect the operations andrequirements of specific Maisons or entities in the Group.
1. Labour relationships and employment practices•

Richemont expects its suppliers to adopt and apply fair and ethical labour practices
respecting fundamental rights of their employees based on the conventions of theInternational Labour Organisation (ILO). These include no forced employment, freedomof association, healthy and safe working conditions, no child labour, fair wages,
reasonable working hours, no discrimination and no physical maltreatment.

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Suppliers are expected to comply with relevant legislation and industry standards of thecountries in which they operate.

2. Responsible environmental management•

Suppliers are expected to comply with local and international legislation and regulations
as well as with the principles outlined in the Richemont “Environmental Code”.

3. Industry specific issues•

Suppliers are expected to comply with specific international and local regulations
relating to the industry in which they operate, for example “CITES”, relating to the
procurement, import, usage and export of raw materials from endangered or protected
species and the “World Diamond Council Resolution on Industry self-regulation” which
supports the Kimberly Process to promote responsible procurement of conflict freediamonds. Further specific information for each industry is given in the Model Supplier
Code.

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4. Ethical business principles•

Suppliers are expected to act according to a “spirit of trust” regarding ethical businessprinciples related to trade secrets, respect for intellectual property, sincerity, truthfulness
and transparency, which will contribute to credible, fair, stable and sustainable business
relationships with Richemont and its Maisons.

•Materials and parts used in the manufacture of the Group’s products will be sourced from
responsible business partners, who can assure the Group’s quality standards. In the caseof raw materials such as precious metals and gemstones, in particular, care shall be taken
to seek to ensure that supplies are sourced only from acceptable sources, recognising theneed to adhere to international standards of best practice in avoiding the exploitation ofworkers, abuse of the environment and avoiding support for unlawful regimes or trading
practices.

5. Supplier of the supplier•Richemont encourages suppliers to extend, communicate and apply the principles
contained in the Model Supplier Code to their employees, suppliers, sub-contractors andother third parties with whom they do business.

6. Application and compliance•As part of the procurement process and the selection of the suppliers, potential partners
will be required to confirm their compliance with the provisions of the Model Supplier
Code of the Maison or Group company with whom they will do business.

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Richemont reserves the right to terminate its business relationships with any supplier orbusiness partner who violates the Group’s principles outlined in these guidelines.

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Richemont provides a formal reporting mechanism to ensure compliance with these
Guidelines, which is detailed in the Model Supplier Code. This procedure allows forwhistle blowing through a direct contact with senior management to ensure assessmentof the problem and appropriate corrective action, as required.

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Richemont Corporate Social Responsibility Guidelines
Part 6
Responsibility towards shareholders
Richemont is committed to maintaining a high standard of corporate governance andsubscribes to the principles laid down in the Swiss Code of Best Practice for Corporate
Governance.
Richemont believe it is imperative that business entities maintain the trust of theirshareholders and the investment community generally. Failure to comply with the generally
accepted principles of corporate governance could result in the investing community
discounting the Group’s shares to those of its peers who meet those standards. Conversely,
aspiring to high standards in this area and providing full and understandable disclosures of
the Group’s position in key areas, should result in benefits to all stakeholders.
The Group’s Corporate Governance Regulations, which have been distributed to senior
executives, sets out the standards that shall be applied.
1. Principles of corporate governance•

Shareholders are encouraged to attend and vote at the Annual General Meeting ofCompagnie Financière Richemont SA (‘CFR’).

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The board of CFR is composed principally of non-executive directors with a broad
experience of international business and finance whose role is to oversee management
and control the strategic direction of the Group.

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The board of CFR has established Audit, Compensation and Nomination committees toundertake specific responsibilities and oversee management’s roles in those areas.

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Management and employees throughout the Group are charged with ensuring that theGroup’s activities are conducted in a manner that does not prejudice the Group’s
reputation in terms of corporate governance generally.

2. Transparency in financial reporting
The Group seeks to achieve high standards of financial reporting.
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The annual and interim financial statements of the Group have been prepared inaccordance with Swiss Generally Accepted Accounting Principles up to the financial
year ended 31 March 2005; the Group adopted International Financial ReportingStandards in its financial year ending on 31 March 2006.

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•The financial statements of the Group and the financial statements of all entities within
the Group are audited by independent public accountants. In terms of the consolidated
financial statements, the independent accountants report to the Audit Committee, theBoard and, ultimately, the shareholders of CFR.

•Management and employees throughout the Group must ensure that financial
information presented in respect of the entities for which they are responsible is complete
and accurate.

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All employees must recognise the importance of ensuring the completeness and accuracyof the information contained in financial reports for Group purposes, for local statutory
purposes and for tax and other regulatory filings.

3. Proactive investor information policy
The Group has established a separate Investor Relations function, whose responsibility it is
to maintain an open and balanced dialogue with the investment community generally.
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All investors must be treated equitably with no individual investor, analyst or group
being afforded preferential treatment or access to information, which is not available tothe market as a whole.

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The Group will seek to avoid the release of price sensitive information to individual
investors or analysts. In the event of an erroneous or accidental release of suchinformation, appropriate steps will be taken to inform the wider investment community
without delay.

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The Group will seek to respond in a fair and accurate manner to appropriate media
inquiries.

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Unless specifically authorised, executives will not make statements relating to theGroup’s financial affairs (or which may be interpreted as relating to the affairs of theGroup) to the financial community generally and the press, in particular.

4. Code of Conduct for Dealings in Securities
To avoid the accidental or intentional misuse of price-sensitive information that has not been
made available to the investing community generally, the Group has implemented a Code of
Conduct for Dealings in Securities (the “Dealings Code”), which has been distributed to allmembers of management and other employees who may, from time to time, have access toprice sensitive information concerning the Group.
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In addition to complying with the Dealings Code, there is an overriding obligation onrecipients of the Dealings Code to exercise their own judgement in determining whether
it is or is not appropriate for them to be dealing in the Group’s securities at any time.

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Recipients of the Dealings Code and parties, closely linked to them are banned fromtrading in the Group’s own securities whilst in possession of price-sensitive information.

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The Dealings Code establishes closed periods during which the recipients are notpermitted to deal in the Group’s own securities, regardless of whether or not they are inpossession of price-sensitive information.

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The Dealings Code requires that its recipients obtain appropriate clearance from senior
management before dealing in the Group’s securities (other than in respect of theexercise of stock options) and imposes reporting obligations on its recipients.

These Guidelines are statements of policies for individual and business conduct and do not,in any way constitute an employment contract or an assurance of continued employment orother obligation legally binding on Richemont16