1. PROFESSIONAL OBLIGATIONS, RULES, PRINCIPLES

1.1 ESOMAR Code
All Ipsos Companies, and all Ipsos employees, are required to conduct business under the terms of the ICC/ESOMAR International Code of Marketing and Research Practice. It is the duty of Directors within each country to familiarise themselves with the Code and ensure that their company operates within the spirit and the letter of the Code.

While ESOMAR is a society of individuals, the management of Ipsos has entered into an agreement to be corporately bound by the Code, which provides safeguards for the public, research institutes and clients. We are permitted to include the following in our promotional literature: 'Adherents to the ICC/ESOMAR Code of Marketing and Social Research Practice.' Further information is contained in the annual ESOMAR Directory.

If in an individual country there are additional national requirements laid down by legislation or by the local professional association, these requirements take precedence when carrying out research in that country. Note that the Code states 'This precedence applies to all research in that country even when it is carried out by researchers or clients based elsewhere.' If there is any doubt about the legality of procedures used, or requested by clients, these should be notified in writing to the Ipsos Management Board, together with any supporting documentation; the Ipsos Management Board will then decide on policy and on the subsequent communication with ESOMAR.
Ipsos Companies also subscribe to various professional bodies to improve the quality of our product and the standing and understanding of market research among the general public. For example, we support the trade organizations SYNTEC in France, BMRA in the UK, BVM and ADM in Germany, AISM in Italy, AEDEMO in Spain, CEISD in Argentina, CASRO in the U.S. and PMRS and CAMRO in Canada.

While ESOMAR is a society of individuals, the management of Ipsos has entered into an agreement to be corporately bound by the Code, which provides safeguards for the public, research institutes and clients. We are permitted to include the following in our promotional literature: 'Adherents to the ICC/ESOMAR Code of Marketing and Social Research Practice.' Further information is contained in the annual ESOMAR Directory.
If in an individual country there are additional national requirements laid down by legislation or by the local professional association, these requirements take precedence when carrying out research in that country. Note that the Code states 'This precedence applies to all research in that country even when it is carried out by researchers or clients based elsewhere.' If there is any doubt about the legality of procedures used, or requested by clients, these should be notified in writing to the Ipsos Management Board, together with any supporting documentation; the Ipsos Management Board will then decide on policy and on the subsequent communication with ESOMAR.
Ipsos Companies also subscribe to various professional bodies to improve the quality of our product and the standing and understanding of market research among the general public. For example, we support the trade organizations SYNTEC in France, BMRA in the UK, BVM and ADM in Germany, AISM in Italy, AEDEMO in Spain, CEISD in Argentina, CASRO in the U.S. and PMRS and CAMRO in Canada.

1.2 Confidentiality
Every employee of Ipsos is required to read the ICC/ ESOMAR Code of Practice and sign a confidentiality agreement, which incorporates the basic protections offered to clients and respondents under the Code.
Additionally many clients, including major international corporations such as P&G and Coca Cola, require their research contractors to sign specific confidentiality agreements which go beyond the basic protections, and which, once signed, are enforceable by law. Where such agreements have been signed, these must be lodged with the Legal Affairs Officer. It is the responsibility of the signatory to ensure that all employees working for these clients are aware of the constraints imposed. Basically these constraints are that no information about any client, any non-proprietary Ipsos survey, or any technique or methodology introduced to us by a client, may be passed outside our organisation without specific written permission from that client.

The international scope of our business and the complexities of different legal systems means that we may be vulnerable under laws prevailing in countries other than our own, and extreme caution must be exercised at all times.
Employees also have a duty of confidentiality towards the Ipsos group: this duty is also embodied in the confidentiality agreement we all sign. Specifically no unpublished information about sources of business, clients, technology, financial performance and investment policies may be revealed to any third party without specific permission of the local Chairman or the Ipsos group Chief Executive Officers, as appropriate. Breaches of confidentiality constitute necessary and sufficient reason for dismissal.

1.3 Data Protection
Data Protection regulation currently is not harmonised across the countries where Ipsos is active. In the interests of market research in general, and our specific mandate to conduct international research, Ipsos endorses the intention to provide protection to the individual to:
. Collect data only for specified, explicit and legitimate purposes
. Implement the principle of fairness, so that the collection of data is as transparent as possible, giving individuals the option of whether they provide the information or not
. Uphold the rights of individual respondents to access data they have provided, to know the origin of that data, to have inaccurate data rectified, and the right to withhold permission to have their data processed
. Not to process sensitive data (ethnic or racial origin, political or religious beliefs, trade union affiliation, health and sex) unless an over-riding important public interest can be demonstrated, and safeguards provided, only with the explicit consent of the individual concerned. In each national market our companies are subject to national laws, but because of data transfer between States we must all abide by the above set of principles.

2. WORKING AT IPSOS

Market research is a service industry, and, as employers in any service business, our most valuable assets are the people who work for us. We want all our staff and our representatives to be highly trained, well motivated and flexible people. We want our people to take pride in their work. We want our people to work in a successful organisation and to share
in the results of our success.
Ipsos believes that the best way to motivate and to achieve flexibility is to empower people. This means that we aim to set the minimum of rules which will provide the framework within which people can operate efficiently, will motivate people to reach their own maximum potential and carry out the actions the Group requires.
We aim to provide a healthy and ethical work environment for all our employees. Accordingly we adhere to the following principles and practices, subject to local statutes.

2.1 Equal Opportunities Policy
Ipsos is committed to the policy of equal treatment of all employees and applicants, and requires all employees, of whatever level or authority, to abide by this general principle together with the requirements of the Codes of Practice issued by the relevant public bodies within each of the countries in which we are established.
We will not tolerate discrimination by treating any individual less favourable than others on grounds of sex, colour, race, religion, sexual orientation, ethnic or national origin, handicaps, or membership or non-membership of a trade union or other association.

2.2 Environmental policy
Ipsos is committed to progressive improvements in our environmental performance. While we are becoming steadily less reliant on paper - based surveys, we encourage all our subsidiaries to re-cycle computer paper, questionnaires and other materials, where local facilities are available. Survey respondents return all materials to our local offices so that they can be disposed of with minimal environmental impact.
We encourage our subsidiaries to participate in environmental audits so as to identify the environmental impact of our operations and seek areas in which our performance can be improved. We share information regarding best practices between our companies.
We welcome suggestions from our employees on ways of protecting the environment and its resources.
Specifically we look for co-operation in the introduction of energy saving and anti-pollution measures. We prefer to use suppliers who subscribe to environmental protection.

2.3 Health and Safety Policy
It is our duty, so far as is reasonably practicable, to ensure the health, safety and welfare of all our employees, and our representatives, at their place of work and when they are working on our behalf outside the office. In each Ipsos establishment we supply first aid kits, instructions on what to do in emergencies, maintain equipment and designate fire officers.
It is the duty of all employees to take reasonable care for the health and safety of themselves and of other persons who may be affected by their acts or omissions at work.
We are committed to providing and maintaining working environments that are safe and without risks to health, including arrangements for the welfare of employees while at work. We abide by employee health and safety regulations such as OSHA in the US, EU Directives such as on 'the minimum health and safety requirements for work with display screen equipment,' covering minimum visual and postural standards, in Europe and other applicable local, national or international equivalents. Please refer to your employer for further details on the prevailing regulations.

2.4 Working in a listed company
Every Ipsos employee has to be aware of the particular restrictions implied by Ipsos being a listed company. In addition to applicable legislation, the following are some basic principles regarding the circulation of information and the general behaviour in a listed company.

Who is authorised to talk and comment on the Ipsos group information?
All the information included in the Annual Reports is public and registered by the Commission des Opérations de Bourse (the French Securities and Exchange Commission). However only the following persons are authorised to talk to the financial community, to the media and generally speaking to anyone outside the company in relation to Group strategic and financial affairs: the Co-Presidents, the Group Communication Director and the Group CFO.

What kind of information is strictly confidential?
Any financial information, which is not included in the Annual Reports or in our quarterly financial press release, is strictly confidential. The same goes for all major events (acquisition of new companies, major contracts with clients…) that have not been released through an official press release by the Ipsos Group Communication department.

What about trading in Ipsos shares?
Insider trading could be charged with penalties under applicable legislation (including by the Commission des Opérations de Bourse and French courts): to remain on the safe side we recommend that you do not trade in Ipsos shares three weeks before and one week after the announcement of the quarterly financial information or the release of information on major events. These dates are posted on the Ipsos.com website under "Shareholder Calendar."

2.5 Related Party Transactions
While transactions on behalf of Ipsos or one of its subsidiaries with relatives or friends are not necessarily blameworthy, every Ipsos executive or employee shall refrain from deciding on any such transaction and refer the decision, in writing, to its immediate superior who shall ensure that the transaction, in its principle and in its terms, is fair, at arm's length, not questionable and in the best interest of Ipsos. In all cases the country manager shall be informed in writing. The Group Legal Affairs Officer shall also be informed in writing for any significant transaction.
These rules cover inter alia the hiring of a relative or friend, and the subcontracting of work to, the purchasing of any service or product from, or the entering into any agreement with a relative, a friend, or a company in which the executive, one of its relative or friend is employed and/or holds any interest. Relatives include children, parents, spouses, brothers and sisters and other family or family inlaw members.
More generally, in any situation where the decision maker could face, or be perceived as facing, a conflict between personal interests and the interests of Ipsos delegated to him/her (including the interests of Ipsos' clients he/she serves) this procedure should be followed.

2.6 Employment Policy

2.6.1 Contract of Employment
All Ipsos employees have a written Contract of Employment or employment letter, which, inter alia specifies the Ipsos Company, which is their employer.
Ipsos employees are of course protected by the legislation prevailing in the country in which they are employed; in addition Ipsos people have the right to personally appeal to the most senior Ipsos Director in their country if they have not received satisfaction through the normal management channels, and feel their working conditions are unacceptable or their terms of employment have been breached.

2.6.2 Training
Every employee is given internal training in the skills required for the particular job, which they are to perform. The time devoted to training, and the period over which this takes place, varies depending on the practices prevailing in different countries, the skill levels required for given jobs and an individual's previous experience. In some cases, such as the training of interviewers, mandatory procedures are laid down by national professional organisations.
A gradual harmonisation of training procedures and standards is being implemented across Ipsos, with the principal objective of providing similar high standards of client service wherever Ipsos companies or products are marketed.
Policies of internal promotion and opportunities for skill transfers are actively pursued within all Ipsos companies.

2.6.3 Inter-company Work Opportunities
In the interest of employees and Ipsos, Ipsos offers opportunities for employees in one country to gain work experience in Ipsos companies elsewhere. Transfers can be of various durations. They are subject to approval by management of the country of residence and the host country, and dependent on basic language skills of the host country.

2.7 Grievance and Disciplinary Procedure
Each Ipsos entity abides by applicable regulations in their jurisdiction and follows fair procedures in dealing with disciplinary, dismissal and grievance issues.