JOULES CODE OF VALUES,BEHAVIOURS AND ETHICS

THE “JOULES CODE”

Here at Joules we have a strong set of values and beliefs,

governing our employee and corporate behaviours. At the

core of our business are our values of respect, responsibility,

fairness and trust. We work hard to make sure that what we

do is right - not just for us, but also for the people we work

with, the communities we’re based in and the world around

us.

Our values define us as an organisation and are integral to

the way we do business and to how we build and manage our

relationships with our customers, colleagues, suppliers and

wider stakeholders. Demonstrating and living up to these

values by adhering to the standards set out in the Joules

Code, and related documents, is the responsibility of every

Joules employee. We continuously review these standards to

ensure they remain appropriate for our business.

This Joules Code is intended to give a high level summary

of core values and behaviours which are then underpinned

by more detailed policies and procedures, all of which are

available on the Joules intranet and accessible via the links

in this document.

The Joules Code applies to every employee of Joules,

anywhere in the world. All employees are required to read

the Joules Code and the policies referred to in it. Failure to

comply with the Code and associated policies is a serious

matter.

JOULES CODE OF VALUES, BEHAVIOURS AND E THICSTHE “JOULES CODE”

REPORTING CONCERNS

It is essential that we foster an environment where

employees feel able to speak up if they come across

something which does not feel right, without fear of reprisal.

If you have any concerns, in the first instance please discuss

this with your with your line manager. If you feel that you

cannot raise the matter with your line manager then please

speak with your head of department.

If you feel that you need to raise the matter outside of

Joules, or if you have raised a matter internally which you

feel has not been resolved, we have a whistleblowing hotline

in place, managed by an external provider. More detail is set

out in the Joules Whistleblowing Policy which is available

on the

Joules intranet.

Any price sensitive matters (i.e. matters which could impact

on Joules’ share price), or which may have implications for

• We do not accept or offer bribes or other inducements

• We do not give or accept gifts or hospitality that are

intended to influence, or appear to influence, business

decisions

• We seek to avoid conflicts of interest between employees

and Joules, and if there are conflicts we ensure these

are properly documented

• We respect confidentiality and protect personal data at

all times

• We do everything we can to protect Joules’ intellectual

property and we do not infringe the intellectual property

rights of others

• We keep IT equipment secure

• We use the internet and work email in an appropriate

manner with due consideration to how what we say

online may impact on ourselves and Joules

• We look after our colleagues and provide a supportive

and safe place to work

• We obey the law and ethical standards in all countries

in which we do business

• We treat fellow employees, customers, suppliers,

investors and other third parties fairly and honestly

• We consider our impact on the wider world with

due regard to human rights, animal welfare and the

environment

KEY PRINCIPLES

the reputational risk of the Company, should be referred

to the Chief Executive Office, CFO, Company Secretary or

General Counsel without delay.

CONTENTS

A. Our Business Behaviours and Legal Compliance

1. Bribery and Corruption

2. Fraud and Improper Payments

3. Conflicts of Interest

4. Data Protection and Privacy

5. Intellectual Property

6. Confidentiality

7. Use of Information Technology

8. Competition Law

9. Share dealing and Inside Information

10. Media and Investor Relations

B. Working Relationships

1. Equal Opportunities

2. Bullying and Harassment

3. Health and Safety

C. Our Wider Impact

1. Sourcing with Integrity

2. Human Rights

3. Animal Welfare

4. The Environment

D. Conclusion and key contacts

We do not give or accept improper payments in order to

conduct business. We operate a zero tolerance approach to

the making or receiving of bribes or corrupt payments, in any

form. This type of conduct is absolutely prohibited whether

committed by employees or anyone else acting on Joules’

behalf.

No Joules employee should get involved in any business

transactions that could result in personal benefit. This

includes using their position to obtain discounts from

contractors or suppliers unless they are agreed discounts

notified and made available to all employees. Our Employee

Anti-Bribery Policy contains more detail and training will be

provided each year.

When setting up arrangements with new suppliers or other

business partners it is important that we ensure that such

partners are aware of our stance on bribery & corruption

and agree to adhere to our principles. We have a Supplier

Anti-Bribery Policy which all of our suppliers and business

partners are required to sign up to and comply with.

Employees must also be careful when giving or receiving gifts

and hospitality from third parties. We acknowledge that this

can be a normal way of doing business, however any gifts

or hospitality must be proportionate and we have a register

which we maintain to document the gifts or hospitality we

give or receive above a certain financial value.

Our Gifts and Hospitality Policy sets this out in more detail

the online form you must complete and submit when giving

or receiving gifts or hospitality is located on the intranet.

Fraud is deemed to be gross misconduct. Fraud includes any

deliberate act to falsify, destroy or create any information,

document, record or account, or to obtain money or property

dishonestly.

Joules’ policies and procedures must be followed when

handling money, handling transactions or claiming expenses.

Please see our Expenses Policy and Card Data Security

A .OUR BUSINESS BEHAVIOURS AND LEGAL COMPLIANCE1.BRIBERY AND CORRUP TION

2.FRAUD & IMPROPER PAYMENTS

Policy for those of you who work in customer services

handling credit card payments.

We also need to protect ourselves from misappropriation

of funds and unscrupulous appeals. So, to ensure that we

properly record our charitable activity, this is all managed

via our Charitably Joules arrangements.

Conflicts of interest arise when there is opportunity for

personal gain beyond the usual rewards of employment, or

when an employee’s interests conflict with Joules’ interests.

Each employee must avoid doing anything that compromises,

or appears to compromise their judgment, or that places

or appears to place their personal interests and Joules’

interests at odds.

Conflicts of interest can arise whenever an employee holds a

significant interest in, engage in outside work for, or receive

any personal benefit or gift from any of Joules’ vendors,

suppliers, contractors, customers, or competitors. Conflicts

also arise when an employee competes with Joules or when

they are presented with an opportunity that is received

due to their position with Joules and in which Joules may

be interested. When in doubt, ask your line manager or a

director.

3.CONFLIC TS OF INTEREST

Data protection is taken very seriously at Joules and we need

to ensure that all personal data relating to our customers,

our employees and our suppliers is treated correctly and

lawfully.

Personal data means any data from which an individual can

be identified or is identifiable and includes details such as

name, postal address, email address, telephone numbers,

bank or payment card details and physical appearance such

as images captured on CCTV.

4.DATA PROTEC TION & PRIVACY

Joules is an incredibly creative place, and we generate

valuable intellectual property (IP) on a daily basis, whether

it be hand drawn prints, product designs, photographs, new

trade marks or marketing slogans or website content and

code. This IP belongs to Joules and it is important that each

and every one of us protects it carefully.

This means being careful not to disclose IP outside the

business unless this is strictly necessary and authorised,

and, where we do need to disclose it, ensuring that correct

contractual protections are in place with our partners to

clearly set out how the IP may be used and to guard against

unauthorised use.

As well as protecting our own IP we must also be considerate

of third party IP rights and ensure that we never make

unauthorised use of a third’s party’s IP. Unauthorised use

of third party IP whether it be a name, a photograph, a

design or a print can often lead to a dispute, which can be

very costly and time consuming to resolve, and potentially

embarrassing for Joules, so always think twice. If in doubt,

please speak with Joules’ legal team who will guide you.

More detail is also set out in our Intellectual Property

Guiding Principles.

5. INTELLEC TUAL PROPERT Y

All personal data must be kept secure and confidential,

only disclosed to those individuals within the business who

have a need to know it, must not be retained for longer than

necessary and must not be used for any purpose which has

not been expressly authorised in writing by the person to

whom the data relates. Further detail is contained in our

Privacy Statements and Data Management and Retention

Policy.

Any breach or suspected breach of data security must be

dealt with in accordance with our Data Breach Policy.

You will be entrusted with confidential information whilst

working at Joules. This may include, amongst other

things, financial information, details of business plans and

strategy, pricing information and information about our

commercial relationships. You are under an obligation to

keep confidential information confidential and not make use

of it except as is necessary for the proper performance of your

duties or as required by law. This obligation remains in place

both during your employment with Joules and afterwards.

Our Confidentiality Guiding Principles contain more details.

6.CONFIDENTIALIT Y

All IT equipment provided to you belongs to Joules and it is

important that it is used in an appropriate way. You must

ensure that any IT equipment given to you by Joules is kept

safe and secure and that it is not used for personal reasons

beyond that permitted in our IT Guiding Principles and

Company Mobile Phone Guiding Principles.

Please bear in mind the way that you use the internet, email

and social media may impact both on your own reputation

and that of Joules. Always think very carefully before posting

comments or pictures online, before sending personal emails

from your Joules email account and before downloading

anything from the internet.

Joules takes information security very seriously. And

protects all points of entry to our systems, both physically

and electronically,. It is every employee’s responsibility to

ensure that security policies and procedures are adhered to

without fail. With the changing electronic landscape that

we trade in today, we expect employees to be observant and

report any concerns.

Our IT Guiding Principles set out our detailed policy on such

use. It is important that you familiarise yourself with this

policy and ensure that you comply with it. Our Data Security

Breach Policy sets out how a breach or suspected breach of

data security must be dealt with.

7.USE OF INFORMATION TECHNOLOGY

The main purpose of Competition law is to maintain market

competition by regulating anti-competitive conduct by

companies, with the ultimate aim of protecting consumers.

Although Competition Law will not impact on many of you in

your day to day working life, this will impact on some of you,

particularly those of you who work in sales and marketing,

where behaviour which could be deemed price fixing must be

avoided. Any conversations with stockists or our competitors

regarding pricing or promotions must be very carefully

considered.

There are severe consequences for breaking the law with

penalties for companies including fines of up to 10% of group

turnover and personal liability including prison sentences

and fines. The Joules legal team will provide regular training

to those of you in high risk areas of the business.

8.COMPE TIT ION L AW

As shares in Joules Group Plc are publically traded on AIM

(a market of the London Stock Exchange), all employees

must be aware that it is a criminal offence for anyone to

deal in Joules’ shares whilst in possession of price-sensitive

information. Certain individuals are classed as “insiders”

with additional obligations of these people (you will be

informed in writing if you are an insider).

Joules’ Share Dealing Code sets out the detailed obligations

and the forms which insiders must completed prior to dealing

in Joules’ shares. There will be closed periods throughout

each year when insiders may not deal in Joules’ shares and

regular reminders will be sent to insiders.

As we are a public company, we must be very careful about

any information we are putting into the public domain.

Dealing with the media and investors requires a specific

set of skills, and our PR, legal and finance teams are

responsible for managing and supporting any such dealings,

particularly if it relates to the Group’s financials, corporate

announcements or legal issues. Please see our Media Policy

for more detail.

9.SHARE DEALING & INSIDE INFORMATION

10.MEDIA AND INVESTOR REL ATIONSHIPS

It is important to all at Joules than our employees are

treated fairly, in accordance with the law and best practice.

All employees are paid at least the living wage, we have no

zero-hours contracts and the vast majority of our employees

are employed on a permanent basis. The wellbeing of our

employees is important to us and we have arrangements

with the Retail Trust to provide all employees with external

support and advice when they need it.

WORKING REL ATIONSHIPSINTRO

Joules is committed to being an equal opportunities employer

and will always make decisions regarding both existing

employees and potential employees on the basis of their

qualifications and competencies without regard to race,

colour, ancestry, national origin, religion, gender, marital

status, age, sexual orientation, legally protected disability,

status in the UK for non-UK citizens, or on any other basis

protected under applicable law. Further detail is provided in

our Equality Guiding Principles.

Joules will not tolerate harassment in the workplace in any

form or in any manner including, but not limited to, sexual

harassment. Joules believes that all employees should

enjoy a work environment that is free from discrimination,

harassment, and intimidation. This applies to all employees,

applicants, contractors, visitors, or guests. Further detail is

provided in our Bullying and Harassment Guiding Principles.

Ensuring the continued health and safety of Joules employees,

contractors and customers is one of our highest priorities.

We expect all Joules employees to support us in this objective,

complying with safety rules and procedures and taking

reasonable care of their own health and safety and the health

and safety of others who may be affected by their actions

or omissions such as customers, colleagues, visitors and

suppliers. Each of us has a responsibility for safety in the

workplace and to correctly report any incidents, including

“near misses”. Further detail is provided in our Health and

Safety policy.

1.AN EQUAL OPPORTUNITIES EMPLOYER

2.BULLYING OR WORKPL ACE HARASSMENT

3.HEALTH & SAFE T Y

B

To ensure our products are of the high quality that our

customers expect from us we manufacture all over the world.

By working closely with all of our suppliers we ensure that

they not only meet our quality expectations but they also

understand, meet and embrace our strong internal values.

We have ethical standards in place, which our suppliers

comply with and undertake to ensure that their suppliers

will also comply with. This ensures that their workforce,

working conditions, material selection and management and

production processes are not just legally compliant but are

also fair, responsible and sustainable, with due regard to

human rights, animal welfare and the environment.

We have a dedicated sourcing office in Shanghai that allows

us to maintain close working relationships with our suppliers,

alongside this we have a programme to visit and audit

suppliers and work in partnership with them to deliver on our

ethical standards.

OUR WIDER IMPACT1.SOURCING WITH INTEGRIT Y

We will not tolerate any form of human rights violation

within our business or supply chain.

As a minimum we expect in our supply chain that

employment is freely chosen; freedom of association and

the right to collective bargaining are respected; working

conditions are safe and hygienic; child labour is not used;

living wages are paid; working hours are not excessive; no

discrimination is practised; regular employment is provided

and no harsh or inhumane treatment is allowed.

We publish an annual statement to set out the steps we

have taken each year to combat modern slavery and human

trafficking within our supply chain and we are committed to

continually improving our practices.

If you see or hear anything which raises any concerns in

respect of our supply chain, you must raise this immediately

with your line manager or via our whistleblowing helpline.

As a business, Joules is committed in ensuring its suppliers

source any raw materials derived from animals from sources

that adhere to best animal welfare practices. We have a

detailed Animal Welfare Policy which suppliers are required

to sign and comply with.

If you see or hear anything which raises a concern in respect

of animal welfare then please inform your line manager or

head of department.

2.HUMAN RIGHTS

3.ANIMAL WELFARE

Joules was born in the British countryside, so caring about

our environment is second nature to us. As a growing

business we are continually striving to minimise our own

environmental impact on the planet and we want to create a

culture of innovation in sustainability whether that be in our

stores and head office or throughout our supply chain and

distribution network.

4.THE ENVIRONMENT

C

We appreciate there is a lot to take in, so please take the

time to familiarise yourself with all of Joules’ policies and

procedures. Ongoing reminders and updates will be provided

across the business and more detailed training on the topics

covered by this presentation will take place during each year.

If you have any queries about specific elements, or need

assistance, please contact the Joules Legal

Team or your HR representative.

CONCLUSION

D