Violations to the code of conduct and disciplinary measures

Our Group’s reputation for being an honest, fair and capable firm with which to do business is one of our most valuable assets we are determined to preserve.

Compliance with the Code of Conduct

Compliance with the Code of Conduct is to be considered an essen- tial part of the contractual obligations undertaken by our employees, temporary workers, independent contractors, and other parties doing business with the Group. The Management of Group’s Operating Companies and of the Corporate Functions is responsible for ensuring that all employe- es understand and meet the Groups’ expectations. Therefore, the Management must make sure that the commitments stated in the Code of Conduct are implemented in all the Business Units and Corporate functions.

Reporting Violations

For an effective enforcement of the Code of Conduct, the Company expects anyone who becomes aware of a case of non-compliance with the Code within the Group to report the violation. For an effective enforcement of the Code of Conduct, the Company expects anyone who becomes aware of a case of non-compliance with the Code within the Group to report the violation. All employees should report any violation or suspected violation to their direct manager/supervisor or, in cases when this may be inef- fective or inappropriate, they should contact the Human Resources Department and/or the General Manager and/or the Managing Director of their company, or directly the Compliance Office / Officer (Compliance Office) of their Company or, in absence of it, the Compliance Officer of PVM Group B.V.

• Mr. Harsh Arora-Director- Legal & Internal Audit, South Asia
• Ms. Ritu Kochhar–Director-HR
• Mr. P S Surana-External Director on Board, PVMI

Their contact details are When a violation report is submitted to the informant’s manager/supervi- sor or to the Human Resources Department or to the General Manager and/or Managing Director or to the Compliance Office, the Management of the Company involved shall immediately conduct investigations and, if necessary, apply the appropriate disciplinary measures. The Compliance Office is a body appointed by the Board of Directors of the Operating Company and vested with initiative and control powers. The Compliance Office shall verify the reported information promptly and carefully, and, if it is found accurate, shall submit the case to the appropria- te Manager/Function responsible for applying any disciplinary measure or terminating the offender’s employment contract. The Compliance Office may summon and interview the informant and any other parties involved, in consultation with the Management of the Company involved (General Manager and/or Managing Director), if appropriate. Third Parties shall address their notice of violation directly to the Compliance Office of PVM Group B.V. Reports to the Compliance Office of PVM Group B.V. should be made in writing and sent to either of the following addresses:

• Compliance Office, c/o Perfetti Van Melle Group B.V., Stationsplein ZW 997, Tristar 3, 1117 CE Schiphol – Oost.
• complianceoffice@nl.pvmgrp.com

The Group shall make sure that no one who reports an actual or attemp- ted violation to the Code of Conduct is subject to any form of retaliation, illicit conditioning, harassment or discrimination at the workplace, as a consequence of his/her reporting a violation of the Code or of any internal procedure. Any form of reprisal against persons who, in good faith, report violations of the Code of Conduct, constitutes a violation of this Code as well. Accusing other employees of a violation with the conscious knowledge that the accusation is false is also a violation of the Code of Conduct.

Diciplinary Measures

Violations to the principles stated in the Code of Conduct and in the Company’s internal procedures compromise the trust between the Group and any person(s) who commits the violation (including managers, employees, consultants, contractors, customers, suppliers, business or financial partners). Once a violation is ascertained, firm and immediate actions shall be taken against the offender(s), through appropriate and proportionate disciplinary measures in accordance with applicable laws and regulations. When the violation constitutes a criminal offense, such measures shall be applied in addition to and regardless of the initiation of a criminal prosecution. Disciplinary measures applied for violations of the Code of Conduct are adopted by the Company in accordance with applicable regulations and employment contracts stipulated at the national or company level. Such measures may include termination of employment. To safeguard its image and protect its assets, the Group shall not entertain relations of any nature with parties who do not intend to act in strict compliance with applicable regulations, and/or who refuse to conform their behavior to the values and principles stated in the Code of Conduct.