Essilor's Code Of Conduct

Employee Code of Conduct

INTRODUCTION

The Code of Conduct expresses Essilor’s commitment to conducting business ethically. It explains what it means to act with integrity and transparency in everything we do and in accordance with our unique culture and values. As members of the Essilor family, let us follow not only the code of conduct, but its intent and spirit as well. This means we should:

• Imbibe the Code, Company policies and procedures, and laws that apply to our job.

• Follow the legal requirements of all locations where we do business.

•Always conduct yourself in accordance to the ways that are consistent with the Code, Company policies and procedures, and laws.

• Report if

Essilor’s Code of Conduct is comprised of our core business principles and values that unite all employees and forms a solid foundation for sustainable growth.

Why does Essilor have a Code?

Essilor’s code of conduct is based on the company’s core values and principles that have remained constant over time. The principles in this Code remain consistent with Essilor’s longstanding business conduct principles , its values, and our shared ethical standards for conducting business with uncompromising honesty and integrity. This Code is your guide for answering questions or solving ethical problems when the right choice may not be clear.

Essilor’s Code summarizes key compliance principles, highlights issues that can have significant legal and ethical consequences if handled improperly, and provides guidelines for appropriate action.

Who must follow the Code?

Essilor’s Code of Conduct applies to all Essilorians. Employees are expected to live the Essilor Values and Principles. Together, Essilorians ensure the continued success of Essilor Company and protect Essilor’s longstanding reputation for doing the right thing, always and everywhere.

What does the Code require me to

Donations can only be made to organizations recognized as being of public benefit. We should obtain an official receipt for the donations.

Compliance

• Code of Conduct often sets an even higher standard than what the law requires. Employees have to comply with Essilor’s Code of Conduct, in addition to the law.

• Unless prohibited by local country law, employees must promptly report all suspected violations of the law or Essilor’s Code by bringing their concerns to the attention of the company management or by reporting through the helpline

• Essilor does not tolerate retaliation of any kind for reporting a business conduct concern or cooperating with an investigation. Essilor expects such reports to be made in good faith. This does not mean you have all the facts; you should feel free to ask questions and to report any issue that causes you concern without fear of retaliation. Reports or allegations that are false or malicious, however, are not in good faith and may be grounds for discipline.

• Essilor can be held responsible for the wrongdoing of others acting on its behalf. 3M employees must not knowingly allow a business partner or a third party to engage in illegal activities and should ask questions and take steps to prevent such wrongful