QUADIENT - 2019 Universal Registration Document

NON-FINANCIAL PERFORMANCE STATEMENT Social, societal and environmental information

5.1.5

ACTING ETHICALLY AND RESPONSIBLY

Quadient expects each of its employees to act with honesty and integrity, and to comply with applicable laws, rules and regulations governing all aspects of the business including research, development, manufacturing, marketing, sales and distribution of products and associated services and solutions. Beyond the regulatory obligations, Quadient has defined the ethical standards that the Company wishes to encourage internally among its employees and, as part of its dialogue with all of its external stakeholders. Promote a culture of integrity and ethical conduct through Quadient's compliance program THE CODE OF ETHICS Designed to promote ethical behavior among employees and external stakeholders, Quadient's Code of Ethics sets the framework for its requirements and practices, a framework on which it relies to make its decisions and carry out its activities. It covers a broad range of topics that the Company sees as crucial: Human Rights, Employees (health & safety at work, diversity, fairness and respect, employee development, open dialogue, and representative bodies), Business Ethics (anti-trust laws and fair competition, corruption, political engagement, communication), Business Relationships (customers and partners), Company assets and third parties (protection of the Company assets, confidential information and data protection, respect for intellectual property rights), Citizenship and responsible engagement (environmental protection and societal commitment). Quadient asks every employee, regardless of their role, function or entity, to follow the Code of Ethics when working for or representing Quadient. It also expects and encourages its business partners and suppliers to act in a way that is consistent with this Code. To facilitate the internal distribution, the Code is available in the following languages: French, English, Dutch, German, Italian, Spanish and Czech. Each entity makes the Code available to its employees on their regional Intranet or by distributing a printed version. It is also available on the new corporate website: https://www.quadient.com/about-us/corporate-responsibility. In accordance with its Code of Ethics, Quadient complies with the anti-corruption laws of the countries in which it operates and has a zero-tolerance policy for corrupt practices, including in particular giving or accepting bribes, either by an employee or a third party acting on behalf of the Company. Quadient rejects all forms of corruption and prohibits demanding, accepting, offering or giving bribes, gifts or other benefits, either directly or indirectly. It also raises awareness and provides training to its employees on the prevention of fraud and corruption. The Board of directors of Quadient has 11 independent members, the majority of whom are independent. PREVENTION OF AND FIGHT AGAINST FRAUD AND CORRUPTION

The Board’s rules of procedures and the establishment of a Conflict of interest policy and a fraud prevention procedure in 2012 minimize the risk of abuse and misdeeds. In addition, the managers concerned are required to sign an annual conflict of interest form for internal controls. ANTI-TRUST LAWS AND FAIR COMPETITION Quadient does not tolerate anti-competitive practices, including price fixing, the rigging of tenders and responses to tenders, or sharing customers, markets or territories. Accordingly, Quadient forbids its employees from entering into any agreement with competitors intended to restrict the nature or quantity of products and services offered, as well as any agreement with suppliers or other partners to obstruct fair competition or the exchange of information with competitors regarding corporate strategy on products or pricing. WHISTLE-BLOWING PROCEDURES Quadient has implemented a corporate whistleblowing procedure to facilitate the reporting of any possible breach of its Code of Ethics. Different escalation channels are available to raise concerns. Employees are encouraged to report through the management line first. However, if an employee considers that informing their direct line manager could cause difficulties (for example, if the direct line manager was involved in the alleged misconduct) or that the alert notified may not be properly followed-up, they may directly contact one of the following departments: HR, Compliance, Legal or Internal Audit. To complement this process, a comprehensive and confidential reporting tool Quadient Ethics line will be launched in May 2020. This solution, hosted and operated by a third party provider NAVEX Global will assist employees in signaling fraud, abuse, and other misconduct in the workplace, through a form online or a hotline, available 24 hours a day, 365 days a year. All escalated or identified ethic breaches will be analyzed by the Ethics & Compliance committee composed of the Chief People Officer, General Counsel, Director of internal control and Director of CSR & Compliance. HUMAN RIGHTS Quadient runs its business in accordance with the fundamental principles outlined in the United Nations Universal Declaration of Human Rights and conventions of the International Labour Organization. The Company strongly condemns modern slavery and the trafficking of human beings, all forms of illegal, forced or compulsory labor, in particular child labor, discrimination in respect of employment and occupation, restriction of freedom of association and the right to collective bargaining. Quadient supports these principles in its Code of Ethics, its position on labor relations, hiring practices and its relationships with partners, suppliers and customers. The Company ensures that its operations comply with its Code of Ethics through its procedures and internal control systems including regular operating reviews, risk management, internal audits and supplier assessments.

5

109

UNIVERSAL REGISTRATION DOCUMENT 2019