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CODE OF CONDUCTJANUARY 2020SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

CONTENTSBusiness integrity 19Gifts and invitations 20Conflict of interest 21Fraud prevention 22Fair competition 23Supplier selection 24Environment 27Contribution to local communities 28Political contributions and lobbying 29International tradecontrol 30Preventing moneylaundering 31Accurate Reporting and Financial Integrity 32Human rights 11Bullying, harassment anddiscrimination 12Health and safety 13Protecting our image when using social media 14Privacy and cyber security 15Protection of assets 16Confidential and sensitiveinformation 17OUR STANDARDSAS A BUSINESS 18OUR STANDARDSAS A CITIZEN 26OUR STANDARDSAS AN EMPLOYER 10 Forewords of Marie-Christine Coisne-Roquette (Chairman) andPhilippe Delpech (Chief Executive Officer) 03Introduction 04Executive Committee, our Commitment 05Governance and Responsibility 06Implementation and Compliance with the Code of Conduct 07How to raise aconcern? 08Our values 09To keep in mind, Contact 35SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

SONEPAR - CODE OF CONDUCT - 202003Founded in 1969, Sonepar is an independent family-owned company which leads the global market in B-to-B distribution of electrical products, solutions and related services. Drawing on the skill and passion of its associates, every day Sonepar delivers an enhanced level of services and experiences to its customers. Sonepar’s ambition is to be “La Référence” - the standard-setter for all its stakeholders.In 2018, we created an original strategic plan called “Impact”, which is focused on the following four pillars: ➔ performance, because without profit, Sonepar cannot invest and grow; ➔ people, creating progressive programs to guide our teams into the future and through the digital transition; ➔ customers, focusing on compliance and an increasingly customer centric organization and experience; and ➔ planet, with key priorities on the environment, long-term sustainability, and society.Sonepar’s history is one of continuous adaptation to new practices and customer and product bases built on our fundamental and long-standing core values. We pride ourselves on our ability to execute. We also recognize that key attributes like integrity, honesty and trust are what make Sonepar successful. When we face diffi cult decisions during the course of our work, ethics, compliance and integrity remain our highest priorities and we demand the same from those around us. We come from many places and operational units, but are committed to shared values, rules of governance and principles of action to drive sound and sustainable growth. We believe that integrity, fairness, trust and respect should never be sacrifi ced in the pursuit of profi ts. For Sonepar, complying with legal and ethical standards is central to having a sustainable business. Our focus on compliance is a source of added value that helps to ensure our long-term growth. Our commitment is formalized in this Code of Conduct. However, it is your actions and decisions, as associates, that determine our ability to operate as an ethical group. You are the fi rst line of defense against violations of the Code of Conduct. We count on you to come forward with your concerns if you see or suspect unethical behavior by contacting your manager or Sonepar’s Legal, Risk & Compliance Network or by using our whistleblowing procedure. We thank you for your contribution to Sonepar’s success and for upholding and abiding by this Code of Conduct.We are Sonepar. We are Powered by Difference.PHILIPPE DELPECHChief Executive Offi cerMARIE-CHRISTINE COISNE-ROQUETTEChairman SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

Vanessa SANSENVP Legal and Compliance"Compliance everywhere, every day is key to continue ensuring Sonepar’s long-term success!"SONEPAR - CODE OF CONDUCT - 202004INTRODUCTIONThe Sonepar Group (“Sonepar” ) is committed to complying with the laws that govern its activities. This commitment to acting ethically and with integrity was formalized in the fi rst version of our Code of Conduct in December 2017.This revised Code of Conduct builds on the previous version by addressing regulatory developments, incorporating insights based on practical experience and drawing upon Sonepar’s corruption and influence peddling risk mapping. The Code of Conduct becomes effective as of January 2020. It will be updated from time to time.It is publicly available on Sonepar's Corporate website : www.sonepar.com.SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

05SONEPAR - CODE OF CONDUCT - 2020OUR BUSINESS PARTNERS KNOW THAT OUR COMMITMENT TO STAND AS “LA RÉFÉRENCE” IS NOT JUST A CONCEPT, IT IS PART OF WHO WE ARE AND REFLECTS OUR VISION TOBECOMPETITIVE, CREATIVE AND ETHICAL LEADERS IN OUR INDUSTRY.EXECUTIVE COMMITTEEOUR COMMITMENTPatrick SALVADORIPresident Western Europe &South AmericaJérôme MALASSIGNEChief Strategic Marketing & Sourcing Offi cer and Asia Pacifi c OperationsBenoît PEDOUSSAUTPresident FranceJérémie PROFETAChief Digital Enterprise Offi cerMatt POTHECARYChief CommunicationsOffi cer & SustainabilityStefan STEGEMANNPresident Central &NordicEuropeRob TAYLORPresident North AmericaOlivier CATHERINEGeneral CounselSara BIRASCHI ROLLANDChief HumanResources Offi cerPhilippe DELPECHChief ExecutiveOffi cerAndros NEOCLEOUSChief FinancialOffi cer"Integrity and compliance are conditions of doing business and a responsibility shared by us all."SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

SONEPAR - CODE OF CONDUCT - 202006INDIVIDUAL RESPONSIBILITIESAll associates are expected to be familiar with the Code of Conduct and its related Policies andProcedures, to comply with their principles and rules and to behave in an ethical manner inallcircumstances.Managers have additional responsibilities and play a key role in ensuring compliance, including: ➔ discussing and promoting the principles and rules set out in the Code of Conduct and its related Policies and Procedures with their teams and with business partners; ➔ establishing and maintaining a climate of trust that makes associates feel comfortable inasking questions or raising concerns; ➔ leading by example; ➔ ensuring effective implementation of the Code of Conduct and its related Policies andProcedures, and responding to questions; ➔ consulting the Legal, Risk&Compliance Network, when in doubt, and reporting andescalating concerns.GOVERNANCE AND RESPONSIBILITYCOMPLIANCE WITH SONEPAR’S CODE OF CONDUCT IS THE SHARED RESPONSIBILITYOFEACHMANAGERANDASSOCIATE THROUGHOUT SONEPAR. Assessment ofthe complianceprogram’seffectiveness• Chairman• Corporate Board• Audit Committee̼%JKGH'ZGEWVKXG1HͣEGT• Executive CommitteeImplementationof the complianceprogramStrategic decisionsand leadershipDesign and oversight of the compliance program• Gener• COMPLIANCE GOVERNANCEEXECUTIVE• Country General Management• OpCo General Management• Regional General Counsels• Country Lawyers and Compliance ChampionsREGION/COUNTRY• General Counsel• Legal, Risk & ComplianceHEADQUARTER• Internal Control• Internal AuditEVALUATIONSpecifi c governance responsibilities are identifi ed at each level of the organization with additionalexpectations defi ned for managers. The Code is intended as a reference to help guidethedecisions and actions of us all, supplemented by the advice of the Legal, Risk&Compliance Network and relevant departments.SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

07SONEPAR - CODE OF CONDUCT - 2020IMPLEMENTATION AND COMPLIANCE WITH THE CODE OF CONDUCTTO WHOM DOES THE CODE OFCONDUCT APPLY?The Code of Conduct applies across Sonepar to all associates in all operating companies worldwide, including without limitation controlled joint ventures.Where Sonepar is a minority shareholder in a joint venture, we seek to ensure that the majority shareholders and management abide by the principles of the Code of Conduct and apply equivalent standards.Sonepar expects all business partners to comply with Sonepar’s high ethical standards. In addition to the Code of Conduct, specifi c standards are defi ned in the Supplier Code of Conduct.LOCAL CODES OF CONDUCTSonepar operates in dozens of countries, each with unique legal and regulatory requirements.Sonepar has adopted this global Code of Conduct to provide an overview of the commitments, rules and processes that govern our daily global operations. In some countries, more stringent laws and regulations may apply.If this Code of Conduct conflicts with a local Sonepar code of conduct, this Code of Conduct prevails, unless the local code of conduct sets out more stringent requirements.HOW TO MAKE THE RIGHT DECISION?The Code of Conduct sets out the rules that all associates must follow and provides resources to help them in addressing questions that may arise in a variety of situations.The following chapters present summary information on each topic and defi ne what is potentially at stake as well as the DOs and DON’Ts.The Code of Conduct is designed as a guide to help associates deal with most of the situations they may face in their day-to-day business activities that might pose integrity or ethical questions. However, the Code of Conduct cannot anticipate all situations they may encounter.Making ethical decisions can seem complicated as it often involves making decisions that go beyond simply respecting a set of rules. In such situations, we are all expected to use our best judgment to make good decisions and to consult identifi ed resources for advice.WHAT HAPPENS IN CASE OFNON-COMPLIANCE WITH THECODE OF CONDUCT?Failure to respect the Code of Conduct and its related Policies and Procedures may have major adverse consequences. These consequences can be serious not only for Sonepar but also for the involved individuals and can include, among others, disciplinary sanctions, fi nes, imprisonment, and damaged reputation.All violations to the Code of Conduct or its related Policies and Procedures are treated as serious matters. Failure to comply may result in disciplinary sanctions, up to and including termination of employment, and potential legal actions against the offenders.MAKING THE RIGHT DECISIONWhen in doubt, always ask yourself the following questions:Is what I am doing legal and amIauthorized to do it?pNO, NOT SURESeek advice! YESIs it in line with the Code of Conduct and other internalpolicies or procedures?pNO, NOT SUREYESDoes this reflect well on me, my business unit and/or Sonepar?pNO, NOT SUREYESIs it the right thing to do and amIleadingby example?pNO, NOT SUREYESIf the answer to any of the above questions causes you concern, do not keep it to yourself. Speak to your manager, someone from the Legal, Risk&Compliance Network, your HR Department or other Sonepar resources. They will be able to assist you!SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

SONEPAR - CODE OF CONDUCT - 202008MORE INFORMATION• For additional details, please consult Sonepar’s Whistleblowing Procedure.• For questions about this procedure, associates may consult their manager, the General Counsel’s Offi ce at groupcompliance@sonepar.com, the Human Resources Department or Sonepar’s external third-party whistleblowing reporting system at www.sonepar.com/alert.iSONEPAR HAS ESTABLISHED A WHISTLEBLOWING PROCEDURE TO PROVIDE A WAY FOR ASSOCIATES, BUSINESS PARTNERS OR ANY THIRD PARTIES TO REPORT POSSIBLE VIOLATIONS OF THE LAW OR SONEPAR’S CODE OF CONDUCT, POLICIES AND PROCEDURES. MANAGERS, ASSOCIATES AND ANYONE CONTRACTUALLY WORKING FOR SONEPAR AREENCOURAGED TO REPORT ANY VIOLATIONS OR POSSIBLE VIOLATIONS.The whistleblowing platform is managed by a prominent third-party provider chosen by Sonepar for this service. Reports can be made 24 hours aday, in 20 different languages.The platform can be accessed via the following link: www.sonepar.com/alert.All reports made in good faith under this procedure remain confidential regardless of how they are notified.Sonepar prohibits retaliation for any whistleblower who reports in good faith a suspected oractualviolation.In most instances, an associate’s manager is the preferred option for reporting such concerns. However, if an associate is uncomfortable sharing concerns with his/her management, Human Resources, the General Counsel's Offi ce (groupcompliance@sonepar.com) and the Legal, Risk&Compliance Network are available to hear concerns.If an associate wishes to make a report without directly interacting with Sonepar’s personnel, or if the person wishing to report is outside Sonepar, a whistleblowing platform is available.HOW TO RAISE ACONCERN?SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

09SONEPAR - CODE OF CONDUCT - 2020PEOPLEThe key to business developmentPASSIONThat sustains and heightens our daily on-the-job commitmentPROFITWhich keeps us free and independentCUSTOMERSWhose lives we seek to simplify and facilitate “LA RÉFÉRENCE”This is our ambition: to be the benchmark reference for our stakeholders, including in terms of ethics and business practices SYNERGIESThat we leverage bylearning from eachother to increase oure ciencyFUTUREBecause “what counts iswhatlasts…”RESPECTThe foundation of all our relationshipsOUR VALUESAS AN INTERNATIONAL, INDEPENDENT GROUP, SONEPAR RELIES ON A SPIRIT OFLOCAL INITIATIVE ANDENTREPRENEURSHIP ON THE PART OF ITS ASSOCIATES. WE ARE A PEOPLE-CENTRIC ORGANIZATION THATEMPHASIZES EMPOWERMENT, TRUST AND ACCOUNTABILITY.Our actions as a company, and those performed by our associates on a daily basis, are guided by the values we share as an organization and that defi ne our culture:SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

SONEPAR - CODE OF CONDUCT - 202010OUR STANDARDS“Compliance, respect and fair leadership are at the core of our daily activity in our teams and towards all our associates. 48,000engaged Sonepar ambassadors show daily their commitment to such priorities.”Sara BIRASCHI ROLLAND, Chief Human Resources O cerAS AN EMPLOYERSONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

11SONEPAR - CODE OF CONDUCT - 2020MORE INFORMATION• For additional details, please consult your HR Department or the Legal, Risk&Compliance Network.• Additional information on Human Rights can be found athttps:// www.ilo.org, http://www.oecd.org/corporate/mne/ and https://www.un.org/en/universal-declaration-human-rights/iSONEPAR IS COMMITTED TO RESPECTING HUMAN RIGHTS. IN PARTICULAR, SONEPAR PROHIBITS ALLFORMS OF CHILD AND FORCED LABOR, HUMAN TRAFFICKING AND UNLAWFUL DISCRIMINATION.WE WORK TO ENSURE THAT THE CONDUCT OF ALL ASSOCIATES IS CONSISTENT WITH INTERNATIONAL STANDARDS.HUMAN RIGHTS D Tolerate any conduct that may negatively impact a person’s dignity,including child or forced labor orhuman traf cking. D Accept any conduct that may interfere with a person’s work performance, or that may create an intimidating, hostileoroffensivework environment.DON’TsWHAT YOU NEED TOKNOWSonepar promotes respect, diversity and fairness throughout its organization. It shares the principles outlined in the Universal Declaration of Human Rights, the Organization for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises and those of the International Labour Organization (ILO).The OECD Guidelines for Multinational Enterprises are recommendations addressed by governments to multinational enterprises on principles and standards for responsible business conduct in a global context.The International Labour Organization is a United Nations agency that promotes internationally recognized human and labor rights. ILO brings together employers, employee representatives and 187 Member States to set labor standards, develop policies and programs promoting decent work standards for all women and men.Forced labor is any work or service performed against a person’s will under the threat of punishment.Child labor refers to work for children under a certain age.WHAT ARE YOUR RESPONSIBILITIES? D Respect Human Rights everywhere, every day, in every circumstance. D Be aware and comply with applicable labor laws and regulations. D Promote a diverse and inclusive workplace where all associates treat each other with respect and dignity and bene t from equal opportunities.DOsWHAT IS AT STAKE?The individual development of each associate and a positive work environment are necessary conditions for the collective success of Sonepar.Millions of people are in forced labor today, and almost all countries are affected. Forced labor and child labor are closely linked and should never be tolerated in our work environment orby our business partners.SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

SONEPAR - CODE OF CONDUCT - 202012MORE INFORMATION• For additional details, please consult your HR Department orthe Legal, Risk&Compliance Network.iSONEPAR EXPECTS ALL OF US TO TREAT EACH OTHER INAPROFESSIONAL MANNER, BASED UPON MUTUAL RESPECT, TRUSTAND INDIVIDUAL DIGNITY.SONEPAR PROMOTES A WORKPLACE FREE FROM ANY FORM OF DISCRIMINATION, BULLYING OR HARASSMENT TOWARDS ASSOCIATES, CONTRACTORS OR CANDIDATES FOREMPLOYMENT.BULLYING, HARASSMENT ANDDISCRIMINATIONWHAT YOU NEED TOKNOWBullying and harassment include unwelcome verbal, visual, and physical conduct or other conduct of any kind that creates an intimidating, offensive or hostile work environment.Discrimination means treating aperson or group less favorably than another person or group due to their circumstances or personal characteristics, including but not limited to: race, ethnicity, religion, skin color, gender, nationality, age, sexual orientation, marital status, family structure, social origin, genetic information, handicap, pregnancy, military reserve or veteran status, political or philosophical views ortradeunion activities.WHAT ARE YOUR RESPONSIBILITIES? D Tolerate or ignore any form of discrimination, bullying or harassment of colleagues or anyone else with whom we have business relationships. D Make employment decisions based on an individual’s personal characteristics.DON’Ts D Create a work environment that is free from discrimination, bullying, harassment and/or retaliation. D Provide feedback in an appropriate and respectful manner. D Base employment decisions only on professional quali cations and merit.DOsWHAT IS AT STAKE?Bullying, harassment and discrimination may cause a deterioration of working conditions and may harm associates’ physical ormental health or their career.A working environment where everyone feels respected regardless oftheir unique characteristics enhances performance and drives motivation.SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

13SONEPAR - CODE OF CONDUCT - 2020MORE INFORMATION• Any questions or concerns canbedirected to the Legal, Risk&Compliance Network oryour HR Department.iPROTECTING THE HEALTH, SAFETY AND WELL-BEING OFOURASSOCIATES AND BUSINESS PARTNERS WORLDWIDEISONE OFSONEPAR’S HIGHEST PRIORITIES.HEALTH AND SAFETY D Do anything that may violate applicable health and safety rules or regulatory requirements. D Engage in activities that could endanger the health and safety of associates or third parties, whether on-site or off-site. D Fail to address malfunctioning equipment or machinery, defer equipment maintenance or inspection, or compromise on safe work methods, for any reason. D Fail to report an accident resulting in an injury, no matter how minor. D Create risks to your mental and physical well-being or that of your associates by, for example, accepting or imposing unreasonable deadlines, regularly performing or demanding longer working hours or working excessively outside normal business hours.DON’TsWHAT YOU NEED TOKNOWProtection of health and safety isadaily battle. We must never dropourguard.Health and safety in the workplace depend on all of us. We must always remain vigilant to identify risks, manage them and raise awareness in order toprevent diseases and accidents.WHAT ARE YOUR RESPONSIBILITIES? D Everywhere Sonepar op erates, ensure compliance with health and safety laws and regulations and with Sonepar’s local workplace rules. D Ensure health and safety standards are respected by everyone in your workplace. D Immediately report if you observe health and safety risks. D Intervene or stop a task without fear of retaliation if you observe an unsafe or hazardous action or condition at a work site or if there are any concerns regarding the adequate control of a health and safety risk.DOsWHAT IS AT STAKE?Protecting the health, safety and well-being of our associates and business partners isnotonly a duty, italso contributes to Sonepar’s business success.SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

SONEPAR - CODE OF CONDUCT - 202014THE EXPLOSION OF SOCIAL MEDIA HAS CHANGED THEWAYINFORMATION IS SHARED IN DAILY PERSONAL ANDPROFESSIONAL LIVES. WHILE SOCIAL MEDIA CREATES NEWOPPORTUNITIES FOR COMMUNICATION ANDCOLLABORATION, USE OF SOCIAL MEDIAALSO BRINGS ADDITIONAL RESPONSIBILITIES THAT YOUMUST KNOW ANDFOLLOW ASASSOCIATES OF SONEPAR.PROTECTING OUR IMAGE WHEN USING SOCIAL MEDIA D Respond to requests from thepublicor the media without management authorization. D Post anything negative about our competitors, suppliers or customers. D Reveal any proprietary or con dential information oforaboutSonepar or its brands. D Use your company email address forcommunicating on social mediaon non-work-related matters. D Post your work email address openly on social media forums. D Post personal details of other associates, clients or suppliers online. D Leave public comments online aboutwork-related legal matters.DON’TsWHAT YOU NEED TOKNOWSocial media includes any digital communication channels that allow individuals to create and share content and post comments: social networking sites, video and photo platforms, blogs,etc.Whether you use social media is entirely up to you. But it is important toknow that all the posts and comments you share on a social media are public– they can be seen byanyone, whether they are in your social network or not.Many of you include details of where you work on our social media and all ofyou are, to some extent, ambassadors for Sonepar and its brands when you are posting on socialmedia.WHAT ARE YOUR RESPONSIBILITIES?MORE INFORMATION• For additional details, please consult Sonepar’s Communications and Sustainable Development Department, the Legal, Risk&Compliance Network, your HR Department or your IT Department.• To help you use social media in a responsible and positive way, please refer to Sonepar’s Social Media Guidelines.i D Always distinguish between professional and personal communications. D Be clear that your opinions are your own. D Use good judgement when posting. D Get permission before you refer to or share anyone’s image. D Stop and think; if it makes you or Sonepar even the slightest bit uncomfortable, take a second look. D Keep in mind that the internet never forgets– what you post will probably stay online for decades. D Take care when discussing subjects where emotions run high and show respect for others’ opinions. D Remember that integrity is our most important asset.DOsWHAT IS AT STAKE?You are all ambassadors for Sonepar and its brandswhenyoupost on social media.What any of you communicates through social media, whether in a professional or personal capacity, can have implications for us as individuals, Sonepar and our fellow associates. Yourcommunications with the public must always be honest and straightforward, while protecting Sonepar’s reputation andcon dential information.SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

15SONEPAR - CODE OF CONDUCT - 2020SONEPAR RESPECTS THE PRIVACY OF ALL ITS ASSOCIATES, BUSINESS PARTNERS AND OTHER STAKEHOLDERS.PRIVACY AND CYBER SECURITYWHAT YOU NEED TOKNOWThe world relies on technology more than ever before. As a result, digital data creation has surged. Today, businesses and governments store and transmit data electronically. Devices and their underlying systems have vulnerabilities that, when exploited, undermine the health and objectives of an organization.Many countries in which Sonepar operates have implemented strict regulations on the collection and use of personal data such as name, date of birth, photo and email address.MORE INFORMATION• For additional details, please consult the Legal, Risk&Compliance Network ortheITDepartment.• Additional information on protection of data of all types may be found in privacy policies applicable locally.i D Disclose personal data to an unauthorized person or send sensitive documents without properprotection. D Leave personal data in a printer oron a shared server. D Share logins and passwords withanyone. D Open an attachment or click on alink if you have any doubt aboutthe sender. D Store or transfer professional documents using personal devices. D Use personal email or unapproved devices to conduct Sonepar business.DON’TsWHAT ARE YOUR RESPONSIBILITIES? D Respect the privacy of your colleagues and business partners. D Properly collect, store, process anddestroy personal data. D Only collect personal information needed for legitimate business purposes. D Take steps to keep the information secure and respect all security procedures from unauthorized access and use. D Be wary of emails you receive from unknown senders or from senders disguised as someone you know. D Immediately report any possible breach of data  les.DOsWHAT IS AT STAKE?A data breach can have a range of devastating consequences for any business. It can damage a company’s reputation through the loss oftrust by partners and other stakeholders. Non-compliance with data protection regulations and privacy laws may results in loss of revenue and legal sanctions. A strongcompany-wide commitment tocybersecurity is essential.Under its IT Security Policy, Sonepar requires that measures are in place to ensure the con dentiality of personal data, and to restrict access of this data to those users who are authorized to view or maintain it.SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

SONEPAR - CODE OF CONDUCT - 202016MORE INFORMATION• For additional details, please consult the Legal, Risk&Compliance Network.iSONEPAR ASSETS SHALL BE MANAGED WITHCAREATALL TIMES.PROTECTION OF ASSETSWHAT YOU NEED TOKNOWSonepar assets include, but are not limited to:• associates;• inventories;• goods, equipments, fi xtures andsupplies;• intangible property (examples: expertise, customer relationships, business plans, software, licenses, data, websites and domain names);• fi nancial assets such as cash, volume incentives, rebates and receivables;• confi dential, proprietary and sensitive information, including trade secrets;• brands, patents, trademarks, logos,copyrights and other intellectual property;• image and reputation.“Support” assets, such as computers, phones, tablets,etc., are reserved for professional use. D Improperly destroy or alter documents. D Let third parties enter our premises without following the applicable check in procedure. D Use company assets for a personal bene t or for a business purpose that is not consistent with Sonepar's Policies. D Use, copy, transfer or distribute proprietary information without Sonepar’s authorization. D Remove assets from Sonepar premises unless necessary to conduct Sonepar’s business activities.DON’TsWHAT ARE YOUR RESPONSIBILITIES? D Properly use and protect Sonepar assets. D Comply with security programs to safeguard Sonepar’s assets against unauthorized use or removal, as well as against loss by criminal act or breach of trust. D Protect the assets of third parties, in particular con dentiality, intellectual and industrial property rights, as well as trade secrets of others, while ensuring that those of Sonepar are also protected. D Make sure assets, including third parties’ assets entrusted to Sonepar’s care, are appropriately protected by relevant protective measures and insurance policies. D Promptly report any actual or suspected loss, misuse or theft to your manager.DOsWHAT IS AT STAKE?To run our business successfully over the long term, we must protect our tangible and intangible assets against loss, damage, theft or illicit use.SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

17SONEPAR - CODE OF CONDUCT - 2020INFORMATION IS ONE OF OUR MOST VALUABLE ASSETS. SONEPAR IS COMMITTED TO PROTECTING INFORMATION, WHETHER IT BELONGS TO US OR TO ANOTHER COMPANYORPERSON. IT IS ESSENTIAL TO OUR SUCCESS, REPUTATIONAND SUSTAINABILITY AS A COMPANY.CONFIDENTIAL AND SENSITIVEINFORMATIONWHAT YOU NEED TOKNOWConfidential information includes but is not limited to non-public information about:• strategy, costs, prices, margins andprofi ts;• markets, logistics, supply chains, sales and marketing plans, business plans, forecasts, operations andresults;• customers and vendors;• IT systems;• mergers and acquisitions;• litigation and investigation;• intellectual and proprietary property (such as patents, trademarks, trade secrets and copyrights); and• personal information regarding associates.It may be refl ected in any format or tool, such as emails, contracts, correspondence, USB keys, hard drives, computers, mobile phones, accounts, fi les,etc.MORE INFORMATION• Additional information and guidelines can be found in local policies.• For additional details, please consult the Legal, Risk&Compliance Network or your IT Department.i D Use any con dential information foryour own personal use orforthepersonal use of any otherperson or entity. D Post company information on social media, for example photos or videos of a distribution center. D Keep any con dential information on your desk when leaving the of ce. D Leave any con dential information on paper boards after a meeting.DON’TsWHAT ARE YOUR RESPONSIBILITIES? D Protect con dential information from theft, unauthorized access, improper use, disclosure or alteration. D Respect any con dentiality agreements between Sonepar andits business partners. D Enter into appropriate non-disclosure agreements or provide for speci c con dentiality clauses if you need to share con dential information with third parties. D Apply any applicable document retention policy.DOsWHAT IS AT STAKE?Our customers, suppliers and other business partners entrust us with their con dential and proprietary information, and it is critical that we handle it carefully to merit their continued con dence. The same holds true for retaining the trust ofourassociates.SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

SONEPAR - CODE OF CONDUCT - 202018AS A BUSINESSOUR STANDARDS“We are all responsible for making compliance a vital part of our business and success! The Legal, Risk & Compliance Network can assist you whenever there is any doubt about an existing situation or proposed course of action.”Olivier CATHERINE, General CounselSONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

19SONEPAR - CODE OF CONDUCT - 2020WHAT IS AT STAKE?Criminal sanctions can be harsh for both the associate(s) at fault and Sonepar.Certain countries (for example, the United States, the United Kingdom and France) have laws that allow authorities to take action against corruption committed by individuals or companies beyond such countries’ borders. Anyone who violates these rules may therefore be subject to prosecution in another country, regardless of where the individual works or resides.Other major adverse impacts on Sonepar include damage to reputation, loss of contracts, exclusion from public tenders,  nes and unavailability of insurance coverage.SONEPAR BUILDS RELATIONSHIPS BASED ON TRUST. WEAPPLYAZERO-TOLERANCE POLICY TOBRIBERY, CORRUPTION AND INFLUENCE PEDDLING IN ALL ITS FORMS. THISCODE EXTENDS TO OUR BUSINESS PARTNERS WHOWEEXPECT TO COMPLY WITHSONEPAR’SHIGHETHICALSTANDARDS.BUSINESS INTEGRITYWHAT YOU NEED TOKNOWCorruption includes offering, promising, giving, soliciting or accepting an undue advantage, whether fi nancial or non-fi nancial, directly or indirectly, to encourage or reward a person to secure business, infl uence the award of a contract or a public bid or obtain a favorable decision.Corruption generally involves at least two parties:• the party who uses its power or infl uence in exchange for an undue advantage; and• the party who offers or provides this undue advantage.A person who facilitates an act of corruption is an accomplice, and one who benefi ts from this act by receiving the undue advantage is a receiver. They are personally liable for these actions. Influence peddling is the unlawful use of one’s position or infl uence on someone’s behalf in exchange for money or favors.Corruption is deemed to exist even if:• the person who offers the undue advantage acts through a third party;• the person who receives the undue advantage is not its end-benefi ciary;• the fraudulent action and the granting of the undue advantage donot take place simultaneously (the undue advantage may be granted inadvance or at a later date);• the undue advantage is in anon-monetary form;• the benefi ciary is a public-sector employee or a private-sector employee.Corruption and infl uence peddling are illegal in virtually every country andare strictly prohibited by this CodeofConduct. Although permitted in certain jurisdictions in limited situations, facilitation payments to secure or expedite a routine or necessary procedure or action by a public offi cial to which the payer of the facilitation payment is legally entitled are prohibited within Sonepar. D Offer, promise or give any undue advantage to secure business, in uence the award of a contract ora public bid or obtain a favorable decision. D Use third parties to do something that we do not have the right to do directly. D Use personal funds to do something that we do not have the right to do. D Continue working with a business partner that fails to comply with Sonepar’s business integrity standards. D Make any facilitation payment.DON’TsWHAT ARE YOUR RESPONSIBILITIES? D Strictly adhere to Sonepar’s Anti-corruption Policy. D Conduct due diligence to check the integrity of our business partners prior to doing business withthem. D Regularly update assessments ofabusiness partner’s risk level. D Properly record all expenses in the relevant entity's accounts. D Retain appropriate records orsupporting documents. DOsMORE INFORMATION• Additional information and guidelines can be found in Sonepar’sAnti-corruption Policy.• Have questions or concerns? When indoubt, ask your manager or the Legal, Risk&Compliance Network.iNo associate will ever be disciplined for refusing to pay a bribe, regardless of its impact on sales, profi tability, project completion, or any other aspects of our business.SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

SONEPAR - CODE OF CONDUCT - 202020WHAT IS AT STAKE?If Sonepar’s business practices are considered to have been impacted by gifts orinvitations, the company and its associates may be subject tocorruption charges, lossofbusiness and reputational harm.WHILE IT MAY BE APPROPRIATE AND CUSTOMARY IN SOME INSTANCES TO OFFER OR RECEIVE GIFTS IN ORDER TO STRENGTHEN BUSINESS RELATIONSHIPS OR AS A MERE MATTER OF COURTESY, SONEPAR ASSOCIATES MUST ENSURE THEY DONOT AFFECT BUSINESS DECISION-MAKING OR IMPEDE GOODJUDGMENT.GIFTS AND INVITATIONSWHAT YOU NEED TOKNOWA gift can be a wide array of benefi ts, including material objects such as a pen, a book, a bottle of wine or box of chocolates. A gift can also be the payment of an expense, such as travel or hotel expenses.An invitation can be an offer to share an enjoyable period of time or event exclusively or partially for business purposes such as a meal atarestaurant, a show or a trip.MORE INFORMATION• Additional information and guidelines can be found in Sonepar’sAnti-corruption Policy.• Have questions or concerns? When indoubt, ask your manager or the Legal, Risk&Compliance Network.iWHAT ARE YOUR RESPONSIBILITIES?Make or receive: D Any gift or invitation in connection with a negotiation, sale or tender process. D Any gift or invitation with anexpectation of reciprocity. D Any gift in the form of cash or cash equivalent. D Any gift in the form of excessive services or other non-cash bene ts. D Lavish gifts or invitations.DON’Ts D Strictly follow Sonepar’s Anti-corruption Policy and your localgift policy. D Obtain preapproval from your supervisor if the gift or invitation exceeds the authorized threshold. D Offer gifts or invitations in good faith and only for the purpose of building or maintaining legitimate business relationships. D Only offer gifts or invitations ofreasonable value. D Report gifts or invitations in accordance with local accounting and compliance procedures.DOsA good way to assess the legitimacy of a gift or invitation is to ask the following questions:Is the frequency of such gift or invitation reasonable?pNOIf you answer NO to any of these questions, the recommendation is to abstain.Is the gift or invitation made with suffi cient transparency?pNOIs there a legitimate business justifi cation for the gift or invitation?pNOWould you or Sonepar be comfortable if the press were aware of the gift or invitation?pNOSONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

21SONEPAR - CODE OF CONDUCT - 2020SONEPAR’S HIGH STANDARDS OF INTEGRITY REQUIRE THATOURASSOCIATES ACT IN THE BEST INTERESTS OFSONEPAR ANDOUR STAKEHOLDERS. ASSOCIATES AREEXPECTED TO ALWAYS BE AWARE OF AND AVOID ANYPOTENTIAL CONFLICTSOF INTEREST.CONFLICT OF INTERESTWHAT YOU NEED TOKNOWA conflict of interest arises when an associate’s private interests interfere, may interfere, or may give the impression of interfering with his/her professional responsibilities as an associate. Common examples of confl ict of interest situations include personal workplace relationships such as hiring or supervising a closely related person, or promoting personal fi nancial interests without appropriate disclosure and approval.A conflict of interest may affect your ability to act impartially or raise doubts about your ability to fulfi ll your responsibilities objectively.WHAT ARE YOUR RESPONSIBILITIES?MORE INFORMATION• Additional information and rules canbefound in Sonepar’s Confl ict ofInterestPolicy.• Have questions or concerns? When indoubt, ask your manager or the Legal, Risk&Compliance Network.• In certain circumstances, associates maybe required to complete a “Statement of Confl ict of Interest”.i D Abuse Sonepar’s resources or use Sonepar’s name for personal gain. D Exert in uence on the employment, performance assessment or remuneration of a friend or relative. D Award a contract or in uence the award of a contract to an entity inwhich you or a close relation has aninterest. D Conceal any information onanyactual or potential con ict ofinterest.DON’Ts D Ensure that your decisions and actions are consistent with Sonepar’s interests and are not in uenced by any personal interests. D Act with transparency and objectivity while assessing situations that might represent a con ict ofinterest. D Identify and report in writing any actual or potential con ict of interest to avoid ambiguity. D Remove yourself from the decision-making process when a con ict of interest arises or may arise.DOsWHAT IS AT STAKE?A con ict of interest, in which the associate’s or a third party’s personal interests take precedence over Sonepar’s interests, can jeopardize thequality and legality of adecision oran action.The appearance or actual existence of a con ict of interest can damage Sonepar’s image, reputation and business and can create  nancial risks for Sonepar.An associate or a third party acting against Sonepar’s interests due to acon ict may be held liable, thereby risking disciplinary action.SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

SONEPAR - CODE OF CONDUCT - 202022FRAUD PREVENTIONWHAT YOU NEED TOKNOWFraud is any illegal act characterized by deceit, concealment or violation of trust.In practice, it can take many forms such as:• fraudulent fi nancial reporting, including distorted records, falsifi ed transactions, or misused accounting principles resulting in intentionally misleading fi nancial information;• misuse of funds (false invoices, manipulation of checks, falsifi cation of bank details);• theft of Sonepar’s assets (supplies, hardware, data);• falsifi cation of receipts for expense reporting (claims for fi ctitious expenses, undeclared absences);• misrepresentation of a claim to a third party (supplier, insurance company);• intentional inaccuracies in inventory counting;• forgery and counterfeits.Sonepar may also be exposed to external fraud attempts such as:• fake CEO bank transfer instructions;• fake bank accounts or reference numbers;• illegal acts by third parties against Sonepar’s interests.MORE INFORMATION• Have questions or concerns? When indoubt, ask your manager or the Legal, Risk&Compliance Network.i D Bypass a procedure simply because “everyone does it”. D Alter, falsify or misrepresent any transaction or inventory movement. D Allow any wrongdoing to continue without addressing and correcting it.DON’TsWHAT ARE YOUR RESPONSIBILITIES? D Comply with all internal procedures, including without limitation quarterly fraud reporting. D Identify sensitive assets and issues in relation to possible fraud within our businesses to help in supporting effective internal control procedures. D Increase awareness within Sonepar about fraud and its consequences.DOsWHAT IS AT STAKE?Prevention of fraud is critical not only because it can cost a great deal of money and other resources to Sonepar but also because it can harm our interests and image.Severe disciplinary, administrative, civil and criminal penalties can be imposed on any individual orcompany involved in fraudulent activities.SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

23SONEPAR - CODE OF CONDUCT - 2020MORE INFORMATION• For more information, please consult Sonepar’s Competition Policy.• You may consult your Legal Department to understand theparticular competition lawsand regulations you have tocomply with.iSONEPAR IS COMMITTED TO CONDUCTING ITS BUSINESS ACTIVITIES OPENLY AND FAIRLY, IN FULL COMPLIANCE WITH THECOMPETITION LAWS AND REGULATIONS OFTHEJURISDICTIONS IN WHICH IT DOES BUSINESS. WE MAKE CLEAR TO OUR ASSOCIATES AND BUSINESS PARTNERSTHATWETAKETHESE REGULATIONS VERYSERIOUSLY ANDEXPECT THEIRSTRICT COMPLIANCE.FAIR COMPETITION D Enter into any unlawful discussion oragreement with a competitor about prices, margins, rebates, costs, stock levels, allocation of customers, suppliers, territories, associates orcontracts. D Share information with competitors including in particular in trade associations. D Denigrate or discredit competitors in any manner.DON’TsWHAT YOU NEED TOKNOWCompetition laws promote free and fair competition for the benefi t of all business partners.These laws generally:• prohibit agreements or understandings between competitors that undermine competition;• regulate the behavior of dominant companies;• require prior review and, in some instances, clearance for mergers, acquisitions and certain other transactions, in order to prevent transactions that would substantially reduce competition.These laws are complex and vary considerably from country to country. Conduct permissible in one country can be unlawful in another.WHAT ARE YOUR RESPONSIBILITIES? D Comply with all applicable competition laws and regulations and Sonepar’s Competition Policy. D Compete fairly at all times. D Avoid formal orinformal business contacts withcompetitors.DOsWHAT IS AT STAKE?Violation of competition laws may be severely sanctioned bycompetition authorities.They can also lead to:• damage to Sonepar’s reputation;• civil lawsuits brought by potential victims of anticompetitive practices;• imprisonment or  nes;• internal disciplinary measuresbySonepar.SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

SONEPAR - CODE OF CONDUCT - 202024SONEPAR ESTABLISHES LONG-TERM RELATIONSHIPS WITH SUPPLIERS THAT ARE OPEN AND MUTUALLY SUPPORTIVE. THESEBUSINESS RELATIONSHIPS ARE BASED ON PRINCIPLES OF TRUST, FAIRNESS AND LOYALTY. SONEPAR WILL NOT ABUSE ITS MARKET POSITION IN ORDER TO GAIN PREFERENTIAL TREATMENT FROM SUPPLIERS.SUPPLIER SELECTION D Continue to work with a supplier that is repeatedly not meeting Sonepar’s expectations or not respecting the principles set out in our Supplier Code of Conduct. D Start doing business with a supplier without having conducting proper due diligence.DON’TsWHAT YOU NEED TOKNOWIt is key to ensure all players in thesupply chain act in accordance withour core commitments and principles, including:• respect for Human Rights;• prevention of harassment anddiscrimination;• protection of the environment;• operating with business integrity.Specifi c expectations of our suppliers are set forth in Sonepar’s Supplier Code of Conduct. We expect our suppliers to comply with all applicable laws and regulations, contractual obligations and Sonepar policies.WHAT ARE YOUR RESPONSIBILITIES?MORE INFORMATION• For further information, please seeSonepar’s Supplier Code ofConduct and Sonepar’s Anti-corruption Policy.• Questions about Sonepar’s purchasing practices may be directed to the local Purchasing Department or the Legal, Risk&Compliance Network.i D Treat suppliers fairly. D Avoid any con ict of interest that may undermine objective and independent decision making. D Ensure our ethical expectations are understood before any business is conducted with a supplier. D Comply with and enforce contractual obligations.DOsWHAT IS AT STAKE?If a player in the supply chain fails to act in accordance with these principles, Sonepar’sperformance, reputation and image could be seriously affected.SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

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26SONEPAR - CODE OF CONDUCT - 2020AS A CITIZENOUR STANDARDS“We must comply with and aim to exceed applicable environmental laws and regulations wherever we do business, whilst striving toreduce the overall Sonepar environmental footprint. In addition, we seek to contribute to the economic development and social well-being of communities by partnering withlocal stakeholders.” Matt POTHECARYChief Communications O cer & SustainabilitySONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

27SONEPAR - CODE OF CONDUCT - 2020WHAT IS AT STAKE?As a global leader in B-to-B distribution of electrical products, solutions and related services, Sonepar is at the heart of the energy transition.Sonepar is fully committed to placing the planet at the core of its business activities and is preparing for future energytransition challenges by promoting energy ef cient products and raising awareness on sustainability.Sonepar intends to leverage its size, logistical power and wide product range to accelerate the energy transition by focusing, in part, on selling solutions to promote energy ef ciency (heating, cooling, ventilation, air conditioning, lighting, energy management, home automation,etc.), renewable energy (solar, heat pumps, energy storage,etc.) and electric mobility.MORE INFORMATION• Questions may be directed to Sonepar’s Sustainable Development Department or the Legal, Risk&Compliance Network.iSONEPAR HAS A RESPONSIBILITY TOPROTECT THE ENVIRONMENT. SONEPARMUSTCOMPLY WITH AND STRIVE TO EXCEED ALLAPPLICABLE ENVIRONMENTAL LAWS AND REGULATIONS.ENVIRONMENT D Accept environmental practices from suppliers or other business partners thatwould not be acceptable in Sonepar’s day-to-day operations.DON’TsWHAT YOU NEED TOKNOWIn 2015, 193countries adopted the United Nations 2030 Agenda for Sustainable Development and its 17goals. They are the reference for countries and corporations to achieve a better and more sustainable future for all.Sonepar’s sustainable development strategy is aligned on these United Nation’s goals and intends to accelerate access to clean and affordable energy, climate action, quality education and responsible consumption.WHAT ARE YOUR RESPONSIBILITIES? D Always comply with environmentallaws. D Respect the environment in conducting Sonepar’s businessactivities. D Engage customers to buy more sustainable products (moreenergyef cient, recyclable, circular, lesspackaging). D Reduce plastic and paper usage. D Properly manage waste anddevelopwaste recycling. D Engage suppliers to reduce packaging, provide their CO2 product fooprint and reduce upstream freight. D Focus purchasing practices on sustainable products (more energy ef cient, recyclable, circular, less packaging). D Prioritize low CO2, low energy consumption means of transportation for commuting, professional travels, logistics and customer visits (carpooling, hybrid and electrical vehicles). D Engage customers to bundle purchases to reduce deliveries. D Reduce back orders with suppliers. D Optimize box spaces and reuse containers, when possible. D Prioritize energy ef ciency andrenewable energy technologies inbuildings. D Prioritize digital communication instead of travel, when possible.DOsSONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

SONEPAR - CODE OF CONDUCT - 202028SONEPAR IS A RESPONSIBLE STAKEHOLDER IN SOCIETY, AGOODNEIGHBOR AND A CONCERNED CITIZEN COMMITTED TOTHE COMMUNITIES IN WHICH IT CONDUCTS BUSINESS.SONEPAR ENCOURAGES ASSOCIATES TO PLAY ANACTIVEROLEIN THEIR COMMUNITY.CONTRIBUTION TO LOCAL COMMUNITIESWHAT YOU NEED TOKNOWAs a responsible corporate citizen, Sonepar contributes to the local communities in which it operates through donations, sponsorships and volunteer activities undertaken by associates.Monetary and product donations are made in local communities to support social, educational or humanitarian projects.Contributions to industry associations or fees for memberships in organizations that serve business interests are not considered donations.MORE INFORMATION• Have questions or concerns? When in doubt, ask your manager or the Legal, Risk&Compliance Network.i D Engage Sonepar in actions inconsistent with our ethical principles and/or which may damage Sonepar’s reputation. D Require associates or business partners to donate gifts or funds to philanthropic projects. D Make a donation to any entity that represents or may represent a potential con ict of interest or in uence a business decision. D Make any donation to religious groups without prior extensive due diligence and after only having obtained applicable approval.DON’TsWHAT ARE YOUR RESPONSIBILITIES? D Treat with respect members of the local communities in which Sonepar is operating. D Always be transparent when making donations or engaging in sponsorship opportunities. D Clearly identify, justify and document the recipient’s identity and the planned used of a donation. D Sponsorship contributions must have clear written objectives and must support legitimate causes that support the Sonepar brand. D Make charitable contributions only to nonpro t or nongovernmental organizations, in compliance with Sonepar policies, including local codes of conduct, applicable local laws and regulations and after having obtained applicable approval(s).DOsWHAT IS AT STAKE?In addition to ful lling our responsibilities as a corporate citizen of the communities in which we operate, contributions to local communities help to create a positive corporate image and can open new business opportunities.Any donations or sponsorships shall only be made under appropriate and legal circumstances to avoid risk of sanctions or damage to Sonepar’s reputation due toillegal or unethical behaviour.SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

29SONEPAR - CODE OF CONDUCT - 2020WHAT IS AT STAKE?Actively contributing to the public policy decision-making process is an integral part of the democratic process and a legitimate activity as it enables the views of different social interests to be taken intoaccount.In some cases, however, lobbying may constitute corruption or influence peddling if an undue advantage is offered or received in order to encourage a person of in uence to support a law, regulation and/or decision favorable to Sonepar ordetrimental to competitors.SONEPAR MAY SOMETIMES PROACTIVELY PARTICIPATE IN THEPUBLIC DECISION-MAKING PROCESS IN THE COUNTRIES INWHICH WE OPERATE. SONEPAR RESPECTS ASSOCIATES’ RIGHTS TO PARTICIPATE ASINDIVIDUALS IN POLITICAL ACTIVITIES PROVIDED THAT THEY DO NOT REPRESENT SONEPAR.POLITICAL CONTRIBUTIONS AND LOBBYING D Make any political contributions on Sonepar’s behalf, either directly or indirectly without having obtained prior applicable approval(s). D Use Sonepar’s resources to participate in any political activity. D Use your position at Sonepar tosuggest Sonepar supports orisinvolved in a political cause ororganization. D Engage in lobbying for any corrupt or illegal purposes or to improperly in uence a decision.DON’TsWHAT YOU NEED TOKNOWLobbying actions relate to activities designed to infl uence the decisions or directives of a government or public institution.Political contributions mean any contribution, whether made in cash or in kind, to support a political cause, party, candidate, action committee, campaign or offi cial.WHAT ARE YOUR RESPONSIBILITIES?MORE INFORMATION• For further information, please see Sonepar’s Anti-corruption Policy.• Have questions or concerns? When indoubt, ask your manager or the Legal, Risk&Compliance Network.i D When participating in personal political activities, do so in your name and never in the name of Sonepar. D Inform your manager if participation in a political activity may have an impact on your responsibilities to Sonepar or may create confusion and potentially lead to a con ict ofinterest. D Ensure all lobbying is done in full transparency and with honesty andintegrity. D Receive advance approval for all lobbying activities and disclose those activities to top management of your operating company and tothe Legal, Risk&Compliance Network. D Strictly respect rules on preventing corruption and on gifts and invitations.DOsSONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

SONEPAR - CODE OF CONDUCT - 202030THE SELLING OF IMPORTED OR EXPORTED PRODUCTS, MATERIALS OR TECHNOLOGIES MAY BE SUBJECT TO SPECIFIC REGULATIONS. SOME COUNTRIES ALSO IMPOSE RESTRICTIONS ON BUSINESS DEALINGS WITH CERTAIN ENTITIES AND INDIVIDUALS. SONEPAR COMPLIES WITH ALL APPLICABLE LAWS GOVERNING INTERNATIONAL TRADE.INTERNATIONAL TRADECONTROL D Enter into a business relationship prior to having conducted a proper integrity check. D Conduct business without arequiredlicense. D Turn a blind eye on exports which you have reasons to know are ultimately intended for a country orperson under sanctions.DON’TsWHAT YOU NEED TOKNOWEconomic sanctions and trade embargoes restrict activities with orinvolving certain countries, territories, business sectors, specifi c goods and blocked persons. Sonepar is committed to conducting business in compliance with all applicable trade and fi nancial sanctions imposed by the U.S. Offi ce of Foreign Assets Control (OFAC), theEuropean Union and other national or international authorities.It is therefore critical to determine if import or export control regulations apply to any particular transaction. Duediligence must be conducted toensure the foreign customer or supplier is not a blocked person, like an OFAC Specially Designated National (SDN), or is not owned, directly or indirectly, 50% or more by oneormore such blocked persons.Certain countries, such as the United States, have anti-boycott laws and regulations that prohibit their nationals and companies from complying with or supporting a country’s boycott of another country that is not approved bythe government. It is Sonepar’s policy to comply with any applicable anti-boycott laws.WHAT ARE YOUR RESPONSIBILITIES?MORE INFORMATION• For further information, please see Sonepar’s International Trade ControlPolicy.• Have questions or concerns? Whenindoubt, ask your manager or a member of the Legal, Risk&Compliance Network.i D Comply with the principles contained herein and the Sonepar’s International Trade Control Policy. D Comply with applicable import orexport control regulations. D Obtain from appropriate authorities any license required forthe importorexport of goods in aspeci c country. D Conduct an integrity check to ensure the potential business partner is not on a sanctions list. D Comply with trade control covenants contained in contracts with business partners.DO’sWHAT IS AT STAKE?The penalties for violating these requirements are severe and may include large monetary  nes, criminal prosecution. It also couldbe a breach offinancing agreements towhich Sonepar is a party.SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

31SONEPAR - CODE OF CONDUCT - 2020MORE INFORMATION• Have questions or concerns? Whenindoubt, ask your manager, yourFinance Department or the Legal,Risk&Compliance Network.iPREVENTING MONEYLAUNDERINGWHAT YOU NEED TOKNOWMoney laundering occurs when:• the proceeds of crime are hidden within legitimate business dealings;• Illegally obstained funds are transferred through the fi nancial system in an attempt to conceal their criminal origin. D Conceal payments through theuseof a third party. D Accept unusual payments.DON’TsWHAT ARE YOUR RESPONSIBILITIES? D Remain constantly vigilant. D Always conduct an integrity check (as further detailed in Sonepar’s Anti-corruption Policy) to ensure the potential business partner is not involved in or funded through illegal activities. D Promptly report any suspicions about possible impropriety. D Record all transactions properly.DOsBE CAUTIOUS!About the following situations: D transfer of funds involving highriskgeographies; D operations or activities that requirecashpayments; D use of petty cash; D unusual requests; D transactions structured tocircumvent obligations todeclareorreport transactions.WHAT IS AT STAKE?Money laundering is considered a criminal act. Depending on the countries, both Sonepar and its associates may be subject to imprisonment and nes. Almost all international companies face therisk of being exploited by individuals engaged inmoney laundering. We must remain very cautious to protect Sonepar’s reputation and avoid sanctions.SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

SONEPAR - CODE OF CONDUCT - 202032SONEPAR STRIVES TO BE A GOOD CORPORATE CITIZEN WHEREVER ITS OPERATES. THIS INCLUDES RESPECTING TAX LAWS AND ENSURINGACCURACY OFFINANCIAL REPORTING.ACCURATE REPORTING AND FINANCIAL INTEGRITY D Change the coding of any product. D Structure or record any transaction, asset, liability or reimbursement request, or engage in any other conduct in an attempt to manipulate the reported operating results, assets or liabilities, to circumvent Sonepar’s system of internal controls and related processes, or toachieve other illegitimate objectives.DON’TsWHAT YOU NEED TOKNOWIn order to ensure compliance with regulatory requirements, it is necessary to ensure that transactions and businessactivities are properly recorded.WHAT ARE YOUR RESPONSIBILITIES?MORE INFORMATION• Have questions or concerns? When in doubt, ask your manager or the Legal, Risk&Compliance Network.i D Ensure all transactions, assets and liabilities are properly and timely recorded in Sonepar’s books and accounts, in accordance with applicable accounting principles. D Ensure all transactions are authorized by management and closed in accordance with applicable laws and regulations. D Always obtain suf cient documentation to support information entered into Sonepar’s books, records and accounts. D Accurately and timely prepare taxforms. D Pay in full all local and national taxesrequired by tax laws. D Accurately report the results ofinternal control campaigns.DOsWHAT IS ATSTAKE?Accuracy is key to a successful business. Accurate and transparent reporting also helps prevent and detect fraud, comply with local accounting and reporting standards, maintain necessary business ethics arrangements and ensures Sonepar’s activities are not used to launder money from criminal activities.SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

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THIS POSTER IS DISTRIBUTED THROUGHOUT ALL ENTITIESCOMMITTEDCOMPLIANT ALL ALLVanessa SANSENVP Legal and CompliancePhilippe DELPECHChief Executive O cerENSURING COMPLIANCEREPORTING A CONCERNWe count on you to report your concerns if you see or suspect unethical behavior. Sonepar Code of Conduct and other reference documents are available at www.sonepar.comUse Sonepar’s confi dential whistleblowing system to report possible violations of thelaw or of our Code of Conduct, Policies orProcedures, orcontact groupcompliance@sonepar.comSONEPAR - CODE OF CONDUCT - 202034SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

Translations of this document may be subject to interpretation. Only the English version is authoritative.First edition: December 2017 - New edition: January 2020The Legal, Risk&Compliance Network is available to answer any questions you may have about the Code ofConduct or its related Policies and Procedures or to discuss any concerns you may have in relation thereto. You may directly contact the Group Compliance Department : groupcompliance@sonepar.comAn updated contact list for Legal, Risk&Compliance Network is available on the Sonepar intranet.Photo credits: iStock, ipopba, vm, hocus-focus, COMiCZ, Tryaging, Rawpixel, ronstik - Dominik Obertreis - Philippe Gérardin - Sébastien Millier - Sylvain Adenot Photography.AS YOU GO ABOUT YOUR DAILY ACTIVITIES, YOU MUST ALWAYS:142536Abide by the principles ofthis Code of Conduct andany local code ofconduct applicable toyour Sonepar business.Hold colleagues andbusiness partners tohighethical standards.Use common sense in your work anddecision-making.Avoid sacrifi cing your personal integrity forprofi tor personal gain.Use available Sonepar resources for guidance when you have questions.Think twice about the impact of your actions andwhat if became publicly known.35SONEPAR - CODE OF CONDUCT - 2020TO KEEP IN MINDSONEPAR - Code de conduite 2020 - EN - V1 08/11/2021

SONEPAR SAS 25, rue d’Astorg75008 Paris − FranceTel. : +33 (0)1 58 44 13 13sonepar.comAll Rights Reserved − January 2020SONEPAR - Code de conduite 2020 - EN - V1 08/11/2021