Supplier

Code of Conduct

Overview ofthe company

Dear suppliers,
SES-imagotag is a fast-growing retail technology company. The company
was founded in 1992 and is listed on the Euronext Paris Stock exchange.
The company is the world leader in IoT solutions for the physical retail sector,
serving major retailers in Europe, Asia and the Americas.
SES-imagotag’s mission is to use technology to modernize the physical retailsector. This means supporting retailers with their digital transformation to:• help them better manage and control their stores;• make them ultra-connected and efficient;• while enabling a truly omnichannel in-store shopping experience.

SES-imagotag believes in sustainable innovation that will serve our customers
and stakeholders well into the future through four shared value-creation goals:
1. Facilitate more sustainable business operations;
2. Promote positive social impact;
3. Make SES-imagotag an appealing environment for our employees, suppliers,partners and investors;
4. Apply the highest standards of governance.

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Table ofcontents

41.

Introduction to the Supplier Code of Conduct

2.

Responsibilities of SES-imagotag’s Suppliers

3.

Final Note4.

Point of Contact

Introduction to the Supplier

Code of Conduct
This Supplier Code of Conduct outlines the legaland business ethical standards to be respected bySES-imagotag and its suppliers. The Code provides
a general overview of business ethics along withthe factors SES-imagotag feels are key to ensuring
compliance with our shared social and environmental
responsibilities.
This Code also reaffirms the importance of:• complying with laws and regulations;• operating fairly and with integrity;• while creating a respectful environment.
The key principle of our procurement policy is
working with suppliers that respect applicablenational and international laws governing theprotection of human rights, the environment, labor
standards, anti‑corruption efforts, fair competitionand data privacy. All SES-imagotag suppliers are
expected to adhere to the principles in this Supplier
Code of Conduct.
SES-imagotag also encourages suppliers and partners to go beyond mere legal compliance and todraw upon best practice globally in terms of businessethics and social and environmental responsibilities.

This Supplier Code of Conduct is not intended to beexhaustive. It is instead intended to help suppliers
take the necessary steps to meet SES-imagotag’s
expectations. This may include reviewing current
performance levels and drawing up improvement
plans. Furthermore, it may be an opportunity toestablish a process of ongoing improvement withrespect to the standards outlined in this Supplier
Code of Conduct.
Furthermore, SES-imagotag urges contracted suppliers
to use this document as a guide for implementing theirown principles with their own subcontractors andsuppliers, including employment agencies.
All business activities must thus be conducted in amanner that is compatible with this Supplier Code ofConduct.

5Responsibilities ofSES-imagotag’s Suppliers
I. COMPLIANCE WITH THE
LAW AND HUMAN RIGHTS
SES-imagotag expects its suppliers to always andstrictly comply with all applicable national andinternational laws and technical standards. This includes
the UN Global Compact and other major international
conventions governing human and labor rights.

II. WORKPLACE
AND WORKINGENVIRONMENT
1. Child Labor
SES-imagotag rejects all forms of child labor.
Its commitment is aligned with the principles outlinedin the International Labor Standards on Child Labor
issued by the International Labor Organization (ILO).
This includes Convention 128 on the Minimum Age of
Employment and Convention 182 on the Worst Formsof Child Labor.
Suppliers are expected to comply with the same
standards or with local laws, whichever are more
stringent.
The minimum working age is the age of completionof compulsory schooling, but never under 15 years ofage. Young employees between the ages of 15 and18 may not be exposed to work that is likely to harm
their physical or mental health, safety or morals.

2. Forced labor and modern slavery
Suppliers may not use or benefit from any form of forcedlabor, bonded labor or labor provided involuntarily under6

the threat of penalty. This includes, but is not limited to,human trafficking, slavery or servitude, debt bondage,
forced prison labor or forced overtime. Workers should
not be forced to deposit identity papers, lodge deposits
or security payments. Suppliers may also not withhold
the identity papers of migrant workers.
Furthermore, workers are free to withdraw from theiremployment contracts in line with national laws,
without fear of retaliation or penalty.

3. Discrimination Harassment
or Abusive Behavior
Hiring and employment-related decisions must bebased on relevant and objective criteria.
Suppliers may not discriminate in hiring and in
employment practices and decisions on grounds
including but not limited to gender, race, color, ethnicity,indigenous or social origin or religion, sexual orientation,
marital status, age, disability, political or other opinion,
nationality, and union membership.
Employment-related decisions include, but are notlimited to: hiring, promotion, lay-off and relocationof workers, training and skills development, healthand safety, any policy related to working conditions
such as working hours and remuneration.
Suppliers must always treat their employees
and workers with fairness, respect and dignity,
guaranteeing equal opportunity to all. Suppliers may
not use corporal punishment, disciplinary practices
and any form of harassment, threat or abusive
behavior in the workplace. This includes, but is not
limited to: physical, sexual or psychological abuse,
exploitation or coercion.
SES-imagotag also expects its suppliers to promote
diversity and to take corrective action against any formof discrimination based on the aforementioned criteria.

4. Health and Safety
SES-imagotag expects its suppliers to provide asafe and healthy working environment for all theiremployees, contractors and other stakeholders.
Suppliers must comply with all applicable local
and national laws as well as international labor law,standards and regulations on working conditions. This
specifically relates to working hours, occupational
health and safety and social protection systems in
the event of occupational accidents and illnesses.

5. Freedom of Association and Rightto Collective Bargaining andNon-Retaliation
As set out in The International Labor Organization’s
Fundamental Conventions suppliers must recognize
and thereby not interfere with workers’:• freedom to join workers’ organizations andassociations; and• rights to collective bargaining.

They must also have obtained the necessary permits,licenses and permissions from local and nationalauthorities. Suppliers must have documented healthand safety policies and/or procedures together withappropriate safety infrastructure and equipment.

Employee representatives must not be subject
to discrimination, harassment or termination ofcontract in retaliation for exercising employee
rights, submitting grievances, participating in union
activities, or reporting suspected legal violations.

Suppliers identified as being moderate to high risk
on health and safety grounds (based on the hazards
posed by the work or locations) must take action andprovide proof of continuous improvement towards a
recognized Health and Safety management system.

6. Legal Contracts

To minimize the risk of occupational accidents,
injuries and illnesses, suppliers must:(i) provide appropriate equipment (includingpersonal protective equipment) free of charge toworkers;(ii) plan effective controls and establish safe
working procedures; and(iii) implement effective programs and systems
to ensure worker safety.
Suppliers must also provide appropriate safety
information and training to workers and set up suitablesystems to report, analyze, minimize and prevent
risks in the event of any hazardous situations. Workers
must report occupational injuries or illnesses to theirsupervisor without fear of consequences or reprisals.
Suppliers and their workers must be prepared foremergencies. This includes:• worker notification and evacuation procedures;

All workers must have legal contracts. Suppliers must
establish recognized employment relationships with
their workers that comply with best practice andall applicable laws and regulations. Suppliers must
not do anything to deny their workers their legal orcontractual rights.

7. Working Hours
Suppliers must comply with all applicable national
and international standards governing working hours.
Furthermore, besides providing weekly rest periods,
suppliers must also provide annual and national
holidays as well as any parental leave, sick/medical
leave or any other leave entitlements allowed underapplicable laws and relevant industry standards.

8. Wages and Benefits
Suppliers must comply with all applicable laws andcollective bargaining agreements on wages andbenefits. In addition to standard wages, workers
must be paid overtime at the rate specified by law
or collective bargaining agreements. They must also
receive any benefits to which they are legally entitled.
Furthermore, suppliers must ensure that their workers
receive decent, regular and adequate wages.

• emergency training;• appropriate first-aid supplies;• appropriate fire detection and suppression
equipment; and• adequate exit facilities.

7III. MITIGATING SUPPLIER’SENVIRONMENTAL IMPACT
1. Environmental Management andRegulatory Compliance
SES-imagotag is committed to respecting theenvironment across its value chain. Suppliers are
asked to support SES-imagotag in its efforts to takea precautionary approach to environmental matters.
They are also asked to apply best practice acrosstheir activities.
Suppliers must therefore comply with applicable
environmental laws and regulations.
SES-imagotag also encourages its partners to promote
greater environmental responsibility and to reduce
their environmental impact.

2. Management of Environmental
Impact and Hazardous Substances
Suppliers must systematically manage and minimize
their environmental impact with regard to, but notlimited to:• climate and energy;• water;• waste;• chemicals;• air pollution; and• biodiversity.
They must set objectives and targets to reduce
any such impact by means of updated production
practices, facility maintenance and processes, material
substitution, conservation, recycling and material reuse.
Suppliers must comply with all laws and regulations
governing the use of hazardous substances. Suppliersmust refrain from using substances that are banned
nationally or internationally (for example substancesbanned because of their risk to humans or theenvironment). Suppliers must also have appropriate
measures in place to manage, store and transport
hazardous substances.

8

IV. SOCIAL RESPONSIBILITY
AND SUSTAINABILITY
1. Conflict Minerals
The procurement of 3TG (tin, tungsten, tantalum, andgold), carries the risk of funding organizations inhigh-risk locations (the Democratic Republic of theCongo or adjoining countries). This includes potential
threats to human rights such as child labor, harshworking conditions and corruption. SES-imagotag
recognizes these risks and strives to minimize themby advocating for the responsible procurement ofminerals. It encourages its suppliers to do the same.
SES-imagotag requires selected suppliers to fill out
the Conflict Minerals Reporting Template (CMRT)
or other customized conflict mineral-related
document. This enables SES-imagotag to shortlist
the appropriate business partners and to maintaintransparency across its supply chain.
SES-imagotag’s procurement team will continue tofollow the guidelines established by the OECD forconflict-affected and high-risk areas. SES-imagotag
requires suppliers to comply with these guidelines.
SES-imagotag must also be notified of smelters/
refineries so that it can maintain transparency
across its supply chain. SES-imagotag will continue
to participate in international efforts to ensure theresponsible procurement of 3TG minerals.

2. Bribery and Corruption
Suppliers must comply with all applicableanti‑corruption laws and regulations including theU.S. Foreign Corrupt Practices Act (FCPA) and theU.K. Bribery Act 2010. This means a zero-tolerance
policy to any form of bribery, corruption, extortionand embezzlement. No supplier or their extended
supply chain may accept, authorize or offer a bribeor any other inducement (Including kickbacks,facilitation payments, excessive gifts and hospitality,grants or donations) when dealing with customers,suppliers, public officials or any other stakeholder or
any person in the public or private sector.

3. Preventing Conflicts of Interests
To ensure strong long-term business relationships,
suppliers must avoid any behavior that might hinder
trust and avoid any conflicts of interests or situations
that appear to be potential conflicts of interests,
including in its dealings with SES-imagotag.

4. Sanctions
Suppliers must comply with all applicable rules andregulations governing trade and economic sanctions,
including applicable export controls. Suppliers may
not procure or purchase products or parts, services tobe used by or sold to SES-imagotag from a party thatis subject to embargo, international sanctions or is asanctioned party. Suppliers must carry out all necessary
checks and perform appropriate due diligence todetermine that any such party is not subject to sanctions.

5. Competition Law
When performing their contract with SES-imagotag,
suppliers must comply with all applicable laws andregulations governing fair competition.
They must therefore avoid any abuse of a dominantposition, cartel pricing practices, market and client
allocation, collusion in tendering and, in general, anyother unlawful agreement designed to prevent, hinder
or distort market competition.
Suppliers are also expected to take all necessary
precautions to avoid the disclosure to third partiesof any commercially sensitive information regarding
their supply relationship with SES-imagotag.

6. Data Privacy
SES-imagotag’s suppliers must comply with all applicable local laws governing data protection and privacy.
They must at all times respect and protect their workers’ privacy and their right to their own personal data.
SES-imagotag accordingly encourages its suppliers
to adopt a dedicated data protection policy. This must
limit the collection of personal data to what is relevant
and necessary for the activity, and requiring the lawful, fair and transparent processing of such data.

8. Collaboration Through CSR SupplyChain Audits
As part of SES-imagotag’s commitment to society,its employees and the environment, SES-imagotag
requires its suppliers to behave ethically whileproviding quality goods and services at a fair price.
To maintain transparency across the supply chain,suppliers must be audited by EcoVadis or an equivalentcertified rating agency. The criteria for evaluationmust include the Environment, Labor & Human Rights,
Ethics and Sustainable Procurement.

9. Providing Evidence of Compliance
Suppliers must continuously monitor and reportcompliance with this Supplier Code of Conduct.
They must also retain the necessary documentation
to prove compliance with its provisions, relevant
standards and with applicable laws. Suppliersmust immediately notify SES-imagotag of any
non‑compliance and relevant planned correctiveactions. Suppliers must never hide any critical areasor plead ignorance of any non-compliance.

10. The Audit Process
SES-imagotag reserves the right to audit, withor without prior notice, suppliers’ compliancewith the Supplier Code of Conduct. This may bedone by SES‑imagotag staff or by organizations
appointed by SES-imagotag. Any such audit may
include facility inspections and worker interviews
or self‑assessment questionnaires (e.g., onenvironmental and/or social practices). To this end,
suppliers are expected to cooperate during suchaudits.

7. Protect Intellectual Property
Suppliers must safeguard confidential information andonly use it in an appropriate manner.
They must respect the intellectual property rights ofthird parties, including those held by SES-imagotag.
This includes copyright, patents, trade secrets,
trademarks and other proprietary information.
Suppliers must ensure compliance with relevant
contractual provisions and be vigilant regarding thescope of these commitments.

9FinalNote
The information in this Supplier Code of Conduct
helps address important areas and provides guidanceon complex day-to-day matters. Nevertheless, thisdocument cannot cover every scenario or eventuality.
It is not, therefore, a substitute for sound judgment
or sensitivity to other cultures, laws, customs
and practices. SES-imagotag therefore suggeststhat when in doubt you consult management andprofessional colleagues.
Please note that this guide will be updated in lightof any updates to SES-imagotag’s internal policies.

Point ofContact
Developingstrong,sustainableandethicalrelationships also means that SES-imagotag must
make itself available to answer queries and questions
from suppliers.
Please reach out to your procurement contact oremail ethics@ses-imagotag.com should you haveany query regarding the application of this Supplier
Code of Conduct.
The same applies should you need to report any
infringement. Furthermore, please consult theWhistleblower Policy for information on how
SES‑imagotag will support you so that you can safely
express your concerns. This includes details of whoto contact, how to make a report and how you areprotected as a whistleblower.

1055 Place Nelson Mandela
CS 6010692024 Nanterre Cedex, FranceTél. : +33 1 34 34 61 61
Fax : +33 1 55 69 78 00
www.ses-imagotag.com