ICAPE Group Supplier Ethics Policy
ICAPE Group has a strong commitment to integrity and social responsability. Our group is committedto ensuring business is conducted in a way that promotes ethical behavior and legal compliance.
ICAPE Group and/or its affiliated entities worldwide (ICAPE & CIPEM) are committed to the highest
standards of business integrity and ethical compliance in their dealings with suppliers. All ouremployees and partners work hard to create and foster an environment that values integrity,openness and mutual respect.
Compliance with legal and ethical standards is the responsibility of everyone in the supply chain
ecosystem at every level. All ICAPE Group Suppliers and employees are expected to conduct
themselves with the highest standards of honesty, fairness, and personal integrity, with adherence toall applicable laws.

1. Local regulatory compliance

ICAPE Group asks each of our suppliers to respect the laws of their province or country. No current
industry practice can be opposed to this request. ICAPE Group will favor all companies doing better,in ethical terms, than the minimum set up by the laws and regulations of their country. These laws,policies and regulations include:• Equal employment• Anti-discrimination and harassment• Human rights• Anti-corruption and bribery• Conflicts of interest• Health and safety• Environment• Confidentiality• Codes of business conduct

2. Anti-corruption policy

Corruption violates clients'trust, threatens economic and social development, and hurts fair trade. Allforms of corruption, such as bribery, extortion, and embezzlement, are strictly prohibited. We ask
each of our suppliers not to try to attempt to bribe any of our employees or customers. We ask all ouremployees not to develop a financial or any other relationship that could involve a financial benefit
or other personal or competing interest. We also ask them not to be involved in any activities whichmight create a contlict of interest between themselves, ICAPE Group and its customers.
Our suppliers are committed to promoting this policy with their own suppliers, customers andemployees. They understand that this is the only way to build a strong, sustainable and fair business
partnership.
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3. Labor laws
ICAPE Group suppliers must comply with th e labor laws and regulations of th eir own country.
Supplier shall ensure that no underage labor has been used in the production or distribution of theirgoods or services. Employees must not be younger than the minimum employment age establishedby the respective country or local jurisdiction. All employee working hours must be in compliancewith all applicable laws and regulations. ICAPE Group suppliers must have a system in place to verify
and accurately record payroll, deductions and th e h ours worked by legally auth orized employees.
Suppliers must comply with all applicable wage and compensation requirements as defined underapplicable labor laws.

4. Environment protection
Suppliers undertake to respect th e environmental regulations of th eir country in order to protect
nature and neigh boring populations. For PCB-related activities, and wh enever necessary, they
confirm that they have a professional wastewater treatment plant, respecting the level of discharges
authorized by local and national authorities for their activity. Suppliers understand that copper andsome oth er metals h ave a negative impact on th e environment if th ey are released withouttreatment.

5. Human rights protection
Forced or prison labor are in no way allowed. All conditions of employment must be based on theindividual's ability and not on other personal characteristics or beliefs. ICAPE Group will not accept
any company that discriminates on the basis of race, color, sex, national origin, sexual orientation,religion, disability or any oth er similar factor. Suppliers must respect employees' righ t to decide
whether or not to join a group, provided that these groups are legal in their own country. Suppliersmust not hinder compliance with these laws.
Only workers legally entitled to work may be employed by suppliers. The legal status of all workers
sh ould be ch ecked by examining original identification documents (not ph otocopies) beforeal­lowing th em to start working. ICAPE Group will not work with suppliers wh o h arass,through disciplinary mental or physical practices, their employees.

6. Safety compliance
ICAPE Group suppliers must provide adequate processes, mach ines, storage and procedures toensure th eir employees h ave a safe and h ealth y work environment. Suppliers are committed tomaking every effort to improve th eir facilities and work procedures to ach ieve th is safety goal.
Suppliers must also have all the necessary medical facilities and fire-fighting equipment in their fieldof activity to protect their workers. They also undertake to closely control all shipments to ensure thatno illegal substances or products are introduced into our sh ipments. (such as drugs, explosives,
bio-risk substances and/ or any other contraband products).
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7. Fair living conditions
Suppliers who provide and are responsible for the housing and food of their employees must ensurea safe, healthy and reasonable environment for this purpose. lCAPE Group will not work with compa­
nies that do not respect a minimum of rules, such as the number of people in a room, the eliminationof water, the disposition of toilets, etc.

8. Confidentiality & Intellectual Property Rights, Privacy, and Data Protection
ICAPE Group suppliers are required to respect the reasonable privacy and confidentiality
expectations of our customers, and appropriately protect all data that may come into theirpossession because of their relationship with ICAPE Group.They agree to comply with all restrictive
rules relating to non-disclosure agreements signed by ICAPE with its clients. They agree not to dis­close any information to third parties without the agreement of ICAPE and its customers. Theywill protect all the information of the company ICAPE and the customers, by using them only in an
appropriate way in the exercise of their functions. This includes data relating to ICAPE Group, ICAPEGroup employees, customers, and partners, and entails compliance with ICAPE Group's instructions
and privacy, data protection, and security laws and regulations when personal, confidential,proprietary, or other sensitive information is collected, stored, processed, transmitted, or shared.

9. Fairness & Equity
Our suppliers understand that only fairness, honesty and respect in our relationships with ourpartners will lead us all to success. This is why they commit to respect such a code of conduct in orderto properly deal with our customers, their suppliers and their partners. They understand that this is
the only way to create equitable and long-term partnerships in the business world.

10. Right of inspection at suppliers
Our suppliers agree to give ICAPE Group access to their factories to verify that they comply with therules of the code of ethics set by ICAPE Group and signed by these suppliers.
Our inspections may be unannounced and may be performed by a third party if necessary and at therequest of our end customers. During these inspections, we will have the right to talk to employees
without the presence of a factory manager and tak e pictures of non-compliant situations, ifnecessary. Retaliation against employees who report abnormal situations will not be tolerated
and will be severely condemned. ICAPE Group will not work with suppliers who do not respectthese principles.

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By accepting this ethics Policy, our suppliers agree to do their best and progress with us to best meet
all these requirements. Suppliers are responsible for ensuring that any employee, subcontractor,agent, or other third party assigned to provide services to ICAPE Group, as permitted by agreementwith ICAPE Group, acts consistently with this Policy.
ICAPE Group will conduct regular unannounced audits and we will communicate the results and therating to the management of the plant concerned. ICAPE Group undertakes to keep the results ofthese audits strictly confidential between the supplier and the management of ICAPE Group.
We agree not to disclose to anyone or to any third party the detailed results of our audits.
ICAPE Group will require a corrective action plan for suppliers if a serious non-compliance isdiscovered. If the supplier does not agree within a reasonable time to correct all suchnon-conformities, then ICAPE Group may have to decide to terminate its activities with the supplierin question.
Through this ethics Policy, we intend to:- Protect the reputation of our customers and ours
- Conform to the values of developing countries- Allow customers to differentiate responsible companies like ICAPE Group from those whose
financial obj ectives surpass ethical laws whatever the costs may be for the environment andmankind.

We hope that each supplier will understand how important it is to have a strong commitment tointegrity and social responsability in order to lead the way towards a real sustainable development.
There is no long term success without accountability and ethics. Respecting this ethics policy will
enable our suppliers, our customers, our employees and ICAPE Group to achieve real and lasting
global sucess.

Alex KONG A SIOU
Quality & Engineering Director

Yann DUIGOU
CEO, ICAPE GroupNathan MARTIN
Group Purchasing Director

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