Code of Ethics

We believe that profit is the reward for serving society well, not the principle aim regardless of the consequences. To deliver these aims we need to maintain a relationship of trust with all of our stakeholders.

Therefore, our key value is to “Do the right thing” for society, the environment, the company, each other and for our customers.

We will comply with all laws and regulations applicable to our business, and beyond this, to act in an honest and ethical manner at all times.

Ethics must be at the core of managing our daily activities. We build together the trust of our stakeholders, which is a major value creation lever for the Company. This ethical ambition is embedded in the principles set out in the present Charter. No development or performance objective should therefore be set within the Company if implementation leads to any infringement of these principles. Although our Company draws strength from its operational excellence, it is also recognised by all of its partners and customers for its very high level of reliability and responsibility. It is therefore down to each and every one of us to live up to the trust that is placed on us, by making ethics an absolute priority every day.

For Employees, Contractors, Interns and Volunteers

Act in accordance with laws and regulations

In all circumstances, all Company employees must observe national and local regulations, as well as rules of professional ethics for their activities, and the Company’s ethics and compliance policies.

Behave honestly and promote a culture of integrity

Honesty and integrity must govern both business and interpersonal relationships, and everyday professional practices. It is essential for every individual to act in an upright manner in all circumstances and promote a culture of honesty and integrity. Based on this principle, the Company attaches the utmost importance to exemplary behaviour from its employees. In choosing its employees, Juice is careful to maintain high requirements regarding honesty and respect for human rights.

As a consequence, Juice encourages reporting of ethical incidents, and no employee may be sanctioned neither for using a reporting measure for these incidents, selflessly and in good faith, nor for refusing to carry out an act which they believe goes against the Company’s ethical principles.

Honour commitments

For the Company and the quality of our relationships. This includes the execution of contracts. In particular, this requires that we honour the commitments made and that we do not make any commitment that the Company cannot keep. Every time one of the Company’s employees communicates with their contacts, they do so in good faith, in a constructive spirit, in respect of everyone’s interests, and caring about providing sincere information. The principle of transparency does not prevent employees respecting business secrecy, within the framework of the applicable laws.

Juice expects its employees to respect the principles laid out in the present Charter and offers in return the necessary protection when they are challenged or jeopardised, provided that they have acted in good faith in the course of their duties.

Respect others

Convinced that a sustainable company is a company that unites economic development and human progress, Juice attaches the utmost importance to the values of tolerance and respect for others, to which all employees must adhere in the course of their professional activities, and which govern Juice’s relationship with them. Respect for others implies treating everyone fairly, by giving equal importance to everyone. It requires reciprocity: everyone has rights they can exercise, but also duties to fulfil, towards others, their entity, the Company and society as a whole. In particular, this principle covers respecting, in all circumstances, the rights of persons, their dignity and their singularity, and respecting different cultures. It also applies to material and immaterial goods belonging to others, and more generally to the preservation of heritage and the environment.

It guides the Company’s policy for gender equality, respect for private life, promoting diversity and fighting all forms of discrimination, protecting health and safety at work, and in particular preventing and sanctioning all situations of harassment. It underlies all of Juice’s internal and external policies and must even inspire the mode of conflict resolution. Tolerance, which is manifested in kindness and openness to others, rules out any form of extremist behaviour.

Application of Juice’s Ethics charter

THE ETHICS CHARTER AND ITS 4 PRINCIPLES APPLY:

To all of Juice’s employees.

Juice expects its employees to act in accordance with the Company’s ethical principles, in all circumstances, and whatever their jobs, level of responsibility and contacts.

A healthy working environment contributes to the successful operation of the Company and to employee well-being. The Company therefore pays great attention to quality of life at work. Respect and trust must guide relationships between employees and dialogue with social partners.

Everyone, from board members to employees, has the responsibility never to act in any way which might raise the slightest doubt a about Juice’s ethics.

The fundamental ethical principles must be promoted by the directors.

Juice directors and managers are the primary promoters of the Juice Ethics charter and its everyday application among employees and stakeholders. While managers must verify that their employees are familiar with their ethical and legal obligations, it is even more important that they should make sure that practices reflect those obligations.

To Juice’s customers and stakeholders Juice applies its ethical principles to its relationships with all parties, particularly customers, investors, partners, suppliers, service providers and subcontractors (including intermediaries or business consultants) or non-governmental organisations (NGOs). Juice promotes these principles among all of its stakeholders.

Regarding customers, Juice pays utmost attention to their satisfaction, based on quality products and services, an open dialogue, procedural transparency, honouring commitments, and respecting rules of competition.

In their dealing with all stakeholders in the market, Juice’s employees behave loyally, and show fairness and impartiality in negotiations. They ensure that the ethical concerns of partners, suppliers, service providers and subcontractors are compatible with those of Juice and bring Juice’s Ethics charter to their attention.

Juice requires its contracts with partners, suppliers, service providers and subcontractors to include a clause stipulating compliance with Juice’s commitments in the areas of human rights and fighting corruption, on the part of both the parties and their own partners. Juice looks into the integrity and the reputation of its partners, suppliers, service providers and subcontractors.

To society as a whole Juice applies its ethical principles wherever it is present. It conducts its business in accordance with internationally recognised human rights.

Juice is socially responsible and committed to respecting the environment and cultural diversity and minimising its ecological impact in the communities where it operates. It communicates openly about its achievements and its challenges in this area and cooperates with environmental and humanitarian non-governmental organisations (NGOs).

Governance

Juice’s ethical commitment is promoted at the highest level of Juice: the Board of Directors has equipped Juice with structures for this purpose.

The Juice Board of Directors monitors respect of the individual and collective values underlying Juice’s action, and of the rules of conduct to be followed by every employee. It ensures that Juice has adequate means to apply these values and rules. The Board of Directors monitors the proper implementation of the Company’s ethical commitments, follows up on identified failures, and ensures that they are adequately dealt with. The Juice Board of Directors helps to integrate ethics into Juice’s vision, strategy, management and practices. It proposes reference texts for ethics and compliance, supervises their implementation, leads training initiatives, receives reports on ethical incidents and contributes to the necessary control activities.

Leaders have a special responsibility for:

• Demonstrating ethical behaviour by example.
• Ensuring that all employees understand these Guidelines.
• Stressing the need for commitment to these Guidelines.
• Maintaining a workplace environment that encourages the discussion of ethical issues without fear of reprisal.
• Supporting any ethics investigations when called upon.
• Communicating the expectation that Juice’s contractors, vendors and agents comply with these Guidelines.

All employees are responsible for:

• Knowing, understanding, and complying with these Guidelines.
• Contributing to a workplace environment that is conducive to upholding these Guidelines.
• Seeking help from a line manager or a Director when the proper course of action is unclear or unknown to them.
• Being sensitive to behaviour by other employees, vendors, contractors or agents that is illegal or unethical.
• Reporting violations of these Guidelines.
• Learning the basic legal and regulatory requirements that pertain to their jobs.

Violations:

Depending on the nature and severity of the violation, Juice will take appropriate disciplinary action to resolve the situation up to and including termination. Additionally, Juice may seek to prosecute employees, former employees and non-employees who violate the law in their role as Juice employees, vendors, contractors or agents of Juice.

Ethical Guidelines

Workplace Issues

Juice is a diverse company. Respect for the differences in backgrounds, experiences, perspectives, and talent that each individual employee brings to a team is a fundamental value. Each employee has responsibility for creating and sustaining a pleasant, secure, and productive working environment. Employees are expected to work in harmony with their colleagues throughout Juice and must always treat each other with fairness, dignity, and respect. Employees should strive to communicate ideas and concerns in an honest and clear manner. They should make sure that criticisms are both direct and constructive and accept candid feedback from others in the same spirit. Developing an ability to resolve problems and work effectively as team members is an important and ongoing challenge. Juice is committed to a work environment that respects the rights and cultural differences of all employees and one that is free of behaviour that may offend a fellow employee’s dignity.

Equal Employment Opportunity and Anti-Harassment

As part of Juice’s commitment to a quality workplace, it is Juice’s policy and practice to make all employment decisions, including recruiting, hiring, training, promotions or other employment of employees or the awarding of subcontracts without regard to race, colour, religion, national origin, sex, age, physical or mental disability, sexual orientation or any other protected status. Juice believes that a work environment that reflects diversity and is free of discrimination, harassment, intimidation, and retaliation will result in a productive and efficient workforce. In carrying out this commitment to equal opportunity, Juice prohibits harassment or discrimination on the basis of any of these protected statuses. Employees who feel they are the victims of unlawful harassment or discrimination must contact their line manager or a Director immediately. All complaints or allegations of discrimination will be investigated. Confidentiality will be maintained to the maximum extent practical, and retaliation against individuals who report complaints will not be tolerated.

Client Relationships

Juice employees are expected to always engage with clients in a straightforward, trustworthy, and honest manner. Clients should know that they can depend not only on Juice products and services, but on Juice’s word and corporate character. Juice takes pride in its integrity.

Juice Assets

Juice employees have a responsibility to protect the company’s assets and ensure their efficient use. Theft, carelessness, and unnecessary waste have a direct impact on the Company’s profitability and, ultimately, on all employees’ jobs. Supplies and equipment purchased by Juice are intended to be used for Juice business purposes only. Everyone involved in operating equipment bears a responsibility for understanding its proper use and maintaining it in good condition. Juice employees are expected to report situations (e.g., damage, theft, or unauthorised use) to a Director.

Proprietary Information

Information is a key corporate asset. A critical factor in Juice’s success is the maintenance of strict security and confidentiality with regard to Juice, client, and prospect data and proprietary information. The importance of maintaining the confidentiality of client information and of Juice’s proprietary technology and trade secrets cannot be overstated. Employees who have access to proprietary and confidential information must take precautions to keep it confidential. An employee’s obligation to protect Juice’s confidential information continues even after he/she leaves the Company.

Respect for Health and Safety

Juice encourages all employees, vendors and customers to report safety concerns in a timely manner to maintain a safe, healthy environment. In addition, workplace violence or the threat of violence is unacceptable and should be reported to a manager or Director immediately. Employees who engage in violence or threats of violence will be subject to disciplinary action, up to and including termination and in some cases criminal prosecution.

Conflicts of Interest

A conflict of interest is a situation in which a person, such as a Juice employee, has a private or personal interest sufficient to influence (or appear to influence) the objective exercise of his or her responsibilities as an Juice employee. These conflicts may include the following areas:

Personal Conflict of Interest:

Personal conflicts of interest arise when actions occur that are influenced or are perceived to be influenced by a desire for personal gain to the detriment of Juice or fellow employees. The gain could be for the benefit of the employee, a relative, or another third party.

Business Conflict of Interest:

A business conflict of interest arises when an employee’s actions are influenced or are perceived to be influenced by the outside business activities of the employee, a relative, or another third party.
Juice employees are expected to avoid all conflicts of interest and not place themselves in situations that might force them to choose between personal, business or financial interests and the interests of Juice. The following basic principles will guide an employee’s conduct:

• When fulfilling Juice responsibilities or otherwise acting in any capacity as a Juice employee, employees must always act in the best interests of Juice.
• Employees must never allow personal business or financial interests to compromise or appear to compromise their loyalty and dedication to the best interests of Juice.
• Employees must disclose potential conflicts, seek advice from their Leader, and err on the side of caution.

Juice reserves the right to determine when an employee’s activities conflict with its best interests and to take whatever action is necessary to resolve the situation.

Purchasing and Vendor Relationships

Juice selects vendors fairly on the basis of price, quality, performance, and suitability of their product or service for the overall benefit of Juice. To this end, employees involved in or influencing purchasing decisions must:

• Always follow the applicable purchasing policies regarding travel, office supplies, computer equipment, etc.
• Never accept a bribe or kickback.
• Disclose to your Leader any potential conflict of interest that may arise when the employee or the employee’s relative or close friend may have a personal stake in a company that supplies or seeks to supply goods or services to Juice.
• Never use personal relationships to improperly influence dealings with a client, vendor, or potential client or vendor.
• Always follow the Receipt of Employment-Related Gifts policy found in these Guidelines.
• During a Request For Proposal (RFP) or similar process, never accept any gifts or favours from any vendor.

Fair and Ethical Sales Practices

Juice employees are held to the highest standards of integrity and business ethics. Decisions must be based on the best interests of Juice and our customers and not deceive, defraud or misrepresent facts. This conduct is essential at all times and is important to the success of Juice. No employee must ever allow a misguided sense of company loyalty lead to disobeying the laws of those countries in which Juice operates. Employees must conduct business in a fair and honest manner with our customers, competitors and vendors. Therefore, the following guidelines should be followed:

• Employees must engage in sales practices that meet customer needs, not just those that meet sales or compensation goals.
• Employees must communicate honestly and truthfully and make the terms of sale clear, accurate and easy to find.
• Employees must ensure confidentiality, integrity, and accuracy of customer records and transactions.

Employees must not make promises or make commitments that can’t be kept.
Not only are ethical sales practices important to the success of Juice, our honesty and integrity while dealing with customers can be regulated by the U.S. Federal Trade Commission and state attorney general’s as well as applicable enforcement agencies in other countries.