Compliance Program

CEDI Europe is committed to the highest standards of openness, probity and personal accountability. We share Compliance Program standards we adopted in January 2012. An external Compliance officer was appointed to ensure adherence to regulated corporate and business ethics.

1.Corporate ethics

We wish to be a responsible partner in society, demonstrating integrity and honesty towards its customers, employees, manufacturers, agents, competitors, shareholders and others who are affected by our activities. In conducting our business, we will comply with the highest ethical standards and a commitment to compliance with the law and policy.

2.Business ethics

2.1.Anti- corruption

We shall conduct our business in compliance with applicable laws and regulations. Corruption can include offering, promising, or giving a payment or other advantage to a public official or a private client as undue consideration to influence selection procedures or other government or company decisions. We will not (attempt to) influence such decisions by means of illegal payments, bribes, kickbacks or other illegal methods. Any demands for or offers of a bribe shall be rejected. Further specific arrangements are laid down in our anti corruption policy.

2.2.Records of transactions

Records of transactions should be maintained in an accurate, complete and transparent manner in accordance with our accounting principles. No unrecorded funds or assets should be established or maintained. Discounts on sales are administered and documented in the same on which they are based.

2.3.Conflict of Interest

All staff shall refrain from any activity that could conflict with their responsibilities to our company, and they shall not seek personal benefits for themselves or others through their position

2.4. Child labour

We will not use child labour or any other form of forced or compulsory labour. The minimum age for admission to employment or work shall not be less than the age of completion of compulsory schooling as set by national law and, in any case, shall not be less than 15 years.

2.5. Our services

The safety, quality and integrity of our services are the basis for our sustainable development.

2.6.Innovation

We are committed to providing services and solutions aimed at creating optimal value for customers. We focus on the continuous improvement and innovation of our services to meet the needs of our customers.

3.Observance of the Code

We consider it essential that we all understand and comply with the contents and the purpose of the Code, in order to foster collective responsibility in achieving our business goals.

4.Monitoring

Our external compliance officer will monitor the daily operation of this policy. Should you require additional information on our Compliance Program, please contact:

Edwin J. Weller, compliance officer,

Tel: +31 (0) 6 22901218

weller@collectievecomplianceofficer .nl

www.collectievecomplianceofficer.nl

CEDI Europe b.v. expects all partners (customers, clients, manufacturers, distributors etc.) to adhere to our principles on Compliance.