Tarkett : Anticorruption Code of Conduct

September 2021

Anticorruption

Code of Conduct

Summary

Message from the Chairman of the Management Board	03
1	Objective and scope of application
of the Anticorruption Code of Conduct	04
2 Essential concepts	07

• Definition of an act of corruption

• Active/passive corruption

• Public/private corruption

• Direct/indirect corruption

• The meaning of "bribe"

• The meaning of "undue commission" fee

• The meaning of "extortion"

• The meaning of "conflict of interest"

• The meaning of "influence peddling"

3	Preventing and fighting corruption:
	Tarkett's internal rules	12
3.1. Prohibited practices	13

1. Illegal payments
2. Facilitation payments
3. Political contributions

3.2.	Supervised practices	15
	3.2.1.	Gifts and invitations
	3.2.2.	Donations to charities and sponsorship
	3.2.3.	Discounts, rebates and price reductions
	3.2.4.	Interest representation and lobbying
3.3.	Required practices	21
	3.3.1.	Required practices internally
	3.3.2.	Required practices with our business partners
	3.3.3.	Required practices in public and private tenders
	3.3.4.	Required merger and acquisition practices
3.4.	DISCIPLINARY SANCTIONS	25

4	Reporting violations	26
4.1.	Whistleblowing systems	27
4.2.	Others contacts	28

Appendix

Appendix 1 : Recommendations from the French Anticorruption Agency - Definitions	29
Appendix 2	: Anti-Bribery and Corruption Clause (all business partners except at risk
	intermediaries)	30
Appendix 3	: Anti-Bribery and Corruption Clause (at risk intermediaries)	31
Appendix 4	: Annual declaration of at risk intermediaries	33
Appendix 5	: Alert signals	34

ANTICORRUPTION CODE OF CONDUCT - SEPTEMBER 20, 2021 2

FABRICE BARTHÉLEMY

Chief Executive Officer

MESSAGE FROM THE CHAIRMAN OF THE MANAGEMENT BOARD

Dear colleagues,

As employees of Tarkett, we all have a role to play in maintaining our high standards for ethics and integrity and protecting one of our most important assets: our reputation as an ethically sound company.

At Tarkett, we are committed to conducting business with the utmost integrity and full transparency; we will not tolerate any form of bribery or corruption.

Our Corruption Prevention Program provides a framework to define our expectations across Tarkett globally. For the Program to be successful, we need each of us to be sure that our behavior is guided by our company values and our commitment to ethical business practices every day.

This new Tarkett Anticorruption Code of Conduct is the cornerstone of the Corruption Prevention Program.

It provides detailed examples of corruption and bribery, making it easier for us to understand, identify and prevent corrupt behavior. It also defines clear guidelines on how we expect you to behave to comply with rules and regulations and how you can avoid inappropriate situations.

This is a business critical issue. We expect every Tarkett employee to read the Tarkett Anticorruption Code of Conduct carefully, and ensure that he or she understands how to detect and avoid corrupt situations.

On behalf of the whole Executive Committee and Management Board, thank you for your leadership and dedication in ensuring Tarkett maintains the highest standards of respect, integrity and ethical practices worldwide.

Fabrice Barthélemy

Chief Executive Officer

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1	Objective and scope
of application
of the Anticorruption

Code of Conduct

1	As a signatory to the United Nations Global Compact, Tarkett will not tolerate corruption in any form, and
actively supports all initiatives in the fight against it.

Tarkett's commitment: Tarkett is committed to conducting all of its activities with legality, integrity and transparency, as well as to developing and maintaining specific policies, procedures and internal controls to prevent and detect corruption and influence peddling. The Anticorruption Code of Conduct is one of the tools in the Tarkett compliance program dedicated to the prevention and fight against corruption and influence peddling (hereinafter the "Anticorruption Compliance Program").

Objective of the Anticorruption Code of Conduct: the Anticorruption Code of Conduct aims to guide all Tarkett employees in their daily activities, by providing knowledge of required practices and by explaining how to act in compliance with these practices.

Conflict with other regulations or practices: as Tarkett is a global group, its employees carry out their activities in many countries where the culture and regulations regarding the prevention and fight against corruption may be more or less restrictive. Tarkett considers, however, that the rules set out in the Anticorruption Code of Conduct represent good business ethical practices that transcend national boundaries. Should local regulations be less restrictive than the provisions in this code, the Anticorruption Code of Conduct shall prevail. If local regulations however are more restrictive than the provisions in this Code, the more restrictive local regulations shall prevail.

Conflict with other internal rules: the Anticorruption Code of Conduct supersedes and replaces all earlier versions of the Tarkett Anticorruption Policy, whether in electronic or paper format. While the Anticorruption Code of Conduct is translated into several languages1, in the event of doubt over the construction of any one provision, the original French version shall prevail.

Human Resources: the Anticorruption Code of Conduct applies in a mandatory and consistent manner to all Tarkett Group entities2, unless local laws impose more restrictive requirements.

For the French entities of Tarkett Group, the Anticorruption Code of Conduct has been

incorporated into the Internal Rules of Tarkett, Tarkett France (in La Défense and Sedan)

and FieldTurf Tarkett, and has been submitted for opinion to the CHSCT and Works Councils

of the above-mentioned entities on 23 May 2018 and 12 June 2018 (Tarkett France in La Défense), 20 June 2018 and 26 July 2018 (Tarkett France in Sedan) and 6 & 8 August 2018 (FieldTurf Tarkett). The Code, together with the said opinions, were forwarded to the Labor Inspectorate (Inspection du Travail) on 11 May 2018 (Tarkett), 15 June 2018 (Tarkett France La Défense), 20 September 2018 (Tarkett France Sedan) and 12 September 2018

(FieldTurf Tarkett). For Tarkett Group entities located abroad, the Anticorruption Code of Conduct shall be communicated to all employees of the concerned entities, and will apply to all activities conducted by them.

1 The Anticorruption Code of Conduct is accessible into the following 17 languages:German, English, Chinese (simplified), Danish, Spanish (EU), Finnish, French, Italian, Dutch, Norwegian, Polish, Portuguese (Brazilian), Russian, Serbian, Swedish, Turkish and Ukrainian.

2 Thus, any reference to "Tarkett" must be understood as any entity of the Tarkett Group, irrespective of its location.

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