Code of conduct distribution

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.

This Code of Conduct is distributed to the Board Members, employees, consultants, contractors, and third parties authorized to act on behalf of the Group and its Operating Companies. All the listed recipients are required to read and understand the Code of Conduct and to conform to its contents.

The Code of Conduct is published with adequate prominence in the corporate intranet and in the websites of the Group and of the Operating companies in their respective local languages. Hard copies of the Code of Conduct shall be distributed to all current and future employees. Additional copies may be requested from the Human Resources Department or the Compliance Office of PVM Group BV.

Revisions and updates of the Code of Conduct are defined and approved by the Board of Directors of PVM Group BV.

For proper understanding of this Code of Conduct across the Group, the Group shall develop a communication program to ensure that the Code is explained and distributed to all employees of all the Group Operating Companies and Corporate Functions.

November 2013