DISTRIBUTOR
CODE OFCONDUCT
Edito
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The Roquette Distributor Code of Conduct sets forth the minimum
requirements and expectations with respect to compliance with laws
and acceptable business conduct for Roquette’s distributors.
The requirements and expectations set forth in this Code apply to all
Roquette distributors, regardless of where the distributor is based ordoes business. The distributor also shall comply with applicable local
laws, directives and regulations.
Distributors are also encouraged to introduce policies, standards,procedures or codes that are stricter than these requirements andexpectations.
We at Roquette understand that our success is not based solely on
quality products, but also on premier customer experience, businessintegrity, compliance and responsible conduct. These principles are
expected not only from our employees, but also from our Distributors.
By committing to following these principles together, Roquette and its
Distributors will ensure they share the same ethical values andprofessionalism, which are the first key step to a long-term
relationship and sustainable growth.

Gaëtan FauvarqueHead of Global Distribution

2Preamble
This Distributor Code of Conduct is based on the Universal
Declaration of Human Rights, the principles of the United Nations
Global Compact and the conventions of the International Labor
Organization (ILO), the principles laid down by the Ethical Trading
Initiative (ETI) as well as Roquette's Code of Conduct1. It does notserve as a substitute for the various regulations, standards and current
applicable laws in the different countries.
Roquette is at the forefront of compliance in all countries where theRoquette group operates. Roquette is committed to abiding by the UK
Modern Slavery Act of 2015 and other similar national laws andregulations.
Distributors commit to respect these regulations, standards and laws
in the countries where they carry out their activity or/and as applicable.
When a Distributor performs services for a Roquette entity, it commits toabide by this Distributor Code of Conduct, and to guarantee thatthese, or equivalent principles, are known and followed by their own
subcontractors. This is the first step of the approval process before any
business relationship with a Roquette entity can be started.

1 Available on www.roquette.com

3Our Values
An organization's culture lies inits core values. Values that describe
who we are, how we engage with
our stakeholders, and how wecontribute to our society.

We are a family-owned company guided by a strong sense ofpurpose. We are authentic people, we stay true to our commitments
and we act with transparency.
Our values are the foundation of our success and essential to achieving
our mission to better feed people and treat patients while taking care of
the planet.
Roquette’s story is a human and family adventure that began almosta century ago. Since then, thousands of men and women, driven by aunique vision, have committed themselves to provide people with thefood, nutrition and health they need according to their lifestyle choices,
their age, where they live and what they do.
All over the world, talents from different origins, skills andbackgrounds have come together at Roquette to unlock the potentialof nature and contribute to building a healthier future.

4At Roquette, we embody our 4 values in everything we do.
We base our culture on:

Authenticity: We are genuine people, we are true to ourcommitments and act honestly and responsibly.
Excellence: We are a group of committed people; every day we dobetter and go further to meet customers and consumers expectations.
Forward-looking: We rely on our family heritage and long-term vision
to constantly explore, collaborate, and innovate. This is crucial tocontinuously address and anticipate our customers’ needs.
Well-being: We improve well-being by enhancing everyday products,
while taking care of resources, territories, and communities. We arecommitted to fostering an easy and enjoyable working environmentand customer experience.
Our consumers and customers trust us for doing business withhonesty and integrity. Trust is one of our greatest assets and requires
the highest standards of behavior every day.
5Table of contents●

Human Rights, Labor, and Safety and Health at Work●

Food Fraud Prevention●

Environment and Sustainability●

Product Quality and Safety●

Free Competition●

Corruption, Fraud and Conflict of Interest●

Prohibition of Money-Laundering●

Customs and Security Authorities●

Trade Restrictions and International Sanctions●Confidentiality●

IT Security, Privacy and Data Protection●

Computer Network Threats●Checks and Application●Reporting concerns

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HUMAN RIGHTS, LABOR & SAFETY & HEALTH AT
WORKDistributors shall prohibit forcedlabor and child labor incompliance with, among others, thefundamental ILO conventions.

Distributors must combat all types of abuse, violence,
discrimination or harassment, in particular discrimination tied to color,
race, sex, sexual orientation, age, ethical affiliation, origin, family
situation, religion, disability or any other characteristic that is protectedby law, and promote equal opportunity among employees.
Distributors must respect freedom of association and the right tocollective bargaining for employees, in compliance with applicablelaws and international standards.
Distributors shall provide working and remuneration conditions thatare dignified and in compliance with applicable laws and internationalstandards.
Distributors shall provide a work environment that promotes health,safety and security.
It is imperative for Distributors to abide by the Roquette rules forhygiene, health and safety during all interventions at Group sites assuch rules are provided to them.
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FOOD FRAUD PREVENTION
Distributors in the food or feed activityshould carry out a risk assessment of
their activity, implement a feed/foodfraud policy and ensure this policy isproperly implemented by themselves,
within their group, or by theirsubcontractors.

ENVIRONMENT AND SUSTAINABILITY
Distributors’ adoption ofsustainable practices plays acritical role for Roquette andRoquette supports and encourages
sustainability among its Distributors.

Applicable environmental laws and regulations shall be implemented
by Distributors and the adoption of global standard such as ISO 14001
is encouraged. Also, Energy reduction plans are encouraged as wellas activities that contribute to i) the growth and development of theinternational and local communities, ii) ensuring precious global
resources such as water and agricultural products for future
generations.
Distributors should limit as much as possible the impact of their activities
on the environment for instance by reducing or recycling waste asmuch as possible or reducing greenhouse gas emissions.
8PRODUCT QUALITY AND SAFETY
Distributors must follow high quality
and product safety standards.
Products, ingredients and services
delivered shall meet specifications asagreed by both a Roquette entity andDistributors and comply with allapplicable laws and regulations.

Roquette expects Distributors to report immediately any concerns they
may have regarding product safety or quality.

FREE COMPETITION
It is imperative for Distributors to comply
with rules related to free competition.
Distributors must commit to competition
based on price, quality and services,and only seek competitive, advantage
through lawful means.
Roquette believes in free and open competition and fully adheres tothe antitrust and competition laws in every country where we dobusiness. Distributors shall not misrepresent the characteristics ofRoquette products or services, act dishonestly, or engage in any otherunfair or anticompetitive practices. Distributors should avoid creatingeven the appearance of improper conduct. Distributors are required tocomply with all applicable antitrust and competition laws and regulations.

9Robust and fair competition practices include:• Bidding independently from competitors;• Not discussing bidding practices with competitors;• Not entering into agreements, coordinated practices, orunderstandings that could restrict competition;• Not exchanging sensitive information with competitors (including
pricing, costs, production data, market data, sales territories,
distribution channels, customer lists, or other non-public businessinformation);• Only gathering information about competitors using means that areethical and legal;• Not exchanging sensitive information between the Distributor andRoquette (including pricing per client);• Only using permitted information in compliance with the General
Distribution Agreement and in accordance with the Confidentiality
requirements described below (page 13).

CORRUPTION,
INTERESTFRAUDAND

CONFLICTOF

Roquette has a zero-tolerance policy
with respect to corruption and fraud.
Distributors must prevent and reject
all types of corruption, including
extortion and kickbacks. Infringementof the laws related to corruption,extortion, conflicts of interest and fraud
may lead to commercial, financial,administrative or penal sanctions.
10Distributors shall not directly or indirectly offer or receive gifts,
invitations or other advantages beyond a reasonable limit and incompliance with legal limits. These advantages must in no way influence
or appear to influence a decision. Invitations and other advantages areprohibited during a call for tender.

Symbolic advertising gifts may be accepted once a year.
Monetary gifts (cash, checks, transfers, etc.) are strictly prohibited.
In case of doubt concerning the reasonable value of a gift or invitation,
its acceptance will be subject to agreement by the Roquette AccountManager.

Conflicts of interest: When a Distributor has a direct or indirect
personal interest or personal relationship with an employee or ashareholder of a Roquette entity, a member of the Roquette it should
inform by the Roquette Account Manager.

PROHIBITION OF MONEY-LAUNDERING
Money-laundering can occur
where an action is taken to mask
the true origin of money orassets that are connected tocriminal activity.

Roquette requires its Distributors to commit to taking all appropriate
measures to prevent their operations from being used in relation tomoney-laundering activities.
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CUSTOMS AND SECURITY AUTHORITIESDistributors are required to comply
with applicable customs laws,
including those relating to imports andthe ban on transshipment ofmerchandise to the importing country.

TRADE RESTRICTIONS AND INTERNATIONALSANCTIONSOur Distributors must respect
international trade restrictions
and sanctions, taking into
account any changes in thesemeasures, as well as all laws
and regulations concerning
export controls.

The Distributor shall promptly notify Roquette if it becomes aware of
any actual or potential breach of any international trade restrictions
and sanctions concerning any of Roquette’s products.
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CONFIDENTIALITY

Roquette may send you document withdifferent classification: PUBLIC,ROQUETTE RESTRICTED or
ROQUETTE CONFIDENTIAL.
Any document coming from Roquettewith no marking has to be considered
as a ROQUETTE RESTRICTED
document.

Please consider for each classification the following security
requirements:
For PUBLIC classification:•Do not remove or change the mention of the classification.

For ROQUETTE RESTRICTED classification:•Do not remove or change the mention of the classification and thenumber of each page.

•Only those, individuals or groups, internal or external, who “need toknow” can have access to ROQUETTE RESTRICTED information.

•Anomalies during transport (loss/disclosure) must be reported toRoquette immediately.

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•No specific protection is required on printing, copy and sharing
ROQUETTE RESTRICTED.
However, care should always be taken to use ROQUETTE
RESTRICTED information appropriately, according to the "need toknow" principle.

•Enclose ROQUETTE RESTRICTED document in office cabinet ismandatory.

•For destruction, crosscut shredder is mandatory for printed
documents. Destruction has to be done by the distributors (nosubcontractors).

For ROQUETTE CONFIDENTIAL classification:•Do not remove or change the mention of the classification, thenumber for each page, the name and the position of the people
mentioned in the document (Annex of the document).

•Only those, individuals or groups, internal or external, who “need toknow”, can have access to ROQUETTE CONFIDENTIAL
information. The list of people, individuals or groups, internal orexternal who have access to ROQUETTE CONFIDENTIAL
information is defined in an annex attached to the document.

•

Transport/Transmission of printed ROQUETTE CONFIDENTIAL
information must be avoided as much as possible.

•Transport/Transmission of digital ROQUETTE CONFIDENTIAL
information on an external storage must be avoided as much aspossible. When the transport is required, an encrypted support ismandatory.

•Transport/Transmission of physical ROQUETTE CONFIDENTIAL
information cannot go through untracked delivery methods. Internalmail and regular postal services are not tracked delivery methods.
14•Anomalies during transport (loss / disclosure) must be reported toRoquette without any delay.

•Copying or printing ROQUETTE CONFIDENTIAL document isallowed only by Roquette.

•Sharing ROQUETTE CONFIDENTIAL information is submitted toneed to know principle. It must be allowed by Roquette who willconsequently update the Annex.

•Printing a ROQUETTE CONFIDENTIAL document must be doneon a color printer.

•For storage, enclose in a key-locked wardrobe or in a safe in asecure location is mandatory.

•Printed ROQUETTE CONFIDENTIAL information should not be
stored off-Roquette facilities unless the user is specificallyauthorized to do so by Roquette.

•Any printed ROQUETTE CONFIDENTIAL document has to be sent
back to Roquette after use. Roquette will ensure the destruction.

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IT SECURITY, PRIVACY AND DATA PROTECTION

Distributors must comply with theirobligations under applicable dataprotection laws, associated regulatory
requirements and policies on the right toprivacy and information security at
Roquette when personal data is collected,
stored, processed, used or transferred.

In case of doubt, Distributors should contact either their own Data
Protection Officer (DPO) or Roquette’s DPO at dpo@roquette.com .
To exercise your rights as a data subject, you can use this form
available on www.roquette.com/Data-Protection .
In case of data breach, suppliers should fill in this form.

COMPUTER NETWORK THREATSDistributors should implement
measures in order to protect theircomputer networks against
security threats.

16CHECKS AND APPLICATION
Awareness, formal acceptance and respectof the Distributor Code of Conduct arepart of i) the criteria for evaluating andreferencing Roquette Distributors, and ii)
their contractual obligations.
Roquette may carry out checks or audits
of Distributors, either directly or throughan organism delegated by the company,
which Distributors agree with.

REPORTING CONCERNS
If Distributors are aware orsuspect behaviors that arecontrary to the principles listed
in this code, the same should bebrought to Roquette’s attention by
notifying the Roquette AccountManager or using SpeakUp®.

https://roquette.speakup.report/en-GB/RoquetteSpeakUpline/home
A Distributors working with a Roquette entity accepts
that failing to comply with this Distributor Code of Conduct
is a sufficient ground for Roquette to end
any commercial relationship with this Distributor.

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