NATIONAL CODE OF CONDUCT

NATIONAL CODE OF CONDUCT PUBLIC-PRIVATE PARTNERSHIP TO PREVENT THE DIVERSION OF PRECURSOR CHEMICALS AND EQUIPMENT THAT COULD BE USED FOR THE ILLICIT MANUFACTURE OF DRUGS RESTRICTED DISTRIBUTION For CNAs and relevant operators only

NATIONAL CODE OF CONDUCT PUBLIC-PRIVATE PARTNERSHIP TO PREVENT THE DIVERSION OF PRECURSOR CHEMICALS AND EQUIPMENT THAT COULD BE USED FOR THE ILLICIT MANUFACTURE OF DRUGS 1. PURPOSE Growth in new synthetic drugs and criminal organisations increasingly frequent use of illicit drug manufacturing methods using non-scheduled chemical products have made closer monitoring of precursor chemicals a key element of action to counter illicit drugs trafficking. The purpose of this national code of conduct is to contribute to action to counter the illicit manufacture of drugs by identifying suspicious transactions and notifying them to the National Mission for the Control of Chemical Precursors (MNCPC). It is part of a balanced partnership approach developed jointly by the MNCPC and the following trade organisations whose contact details are listed in Appendix 1: UIC (Association of Chemical Industries) UFCC (French Chemical Trade Union) PRODAROM (National Association of Fragrance Manufacturers) SNIAA (National Federation of Food Flavouring Industries) AFIPA (French Pharmaceutical Industry Association for Responsible Self-Medication) SIMV (French Association for the Animal Health Industry) LEEM (Union of Medicinal Product Firms) and any other trade organisation that would like to be associated with it. This national code of conduct is designed to help companies/establishments involved in the production, use, trade and the entire supply chain of substances, equipment and materials liable to be used for the illicit manufacture of narcotic drugs to: - Facilitate obtaining licences, registrations and other authorisations provided for by the regulations on drug precursors; - Monitor all chemical substances and equipment that could be diverted for the illicit manufacture of drugs; - Familiarise their staff with the issues relating to drug precursors; - Develop their vigilance at all stages of the supply chain (including transporters, customs representatives and all other service providers); - Make operational use of the alerts sent out by the MNCPC. RESTRICTED DISTRIBUTION For CNAs and relevant operators only 2/10

This national code of conduct is also designed to: - Scale up cooperation and information exchanges between companies and the authorities; - Facilitate the evaluation of measures adopted by companies subsequent to MNCPC inspections on the sites concerned. Lastly, the appearance and growing use of substances called drug pre-precursors and new psychoactive substances (NPS) have made it imperative to step up the public-private partnership given that only the companies themselves are aware of all the particularities of their products and are therefore able to detect an unusual use of these products. This national code of conduct should extend active monitoring to all chemical products, not just scheduled precursors, and should consequently scale up the collection of suspicious transaction reports. 2. SCOPE The national code of conduct applies to: - All chemical substances that the companies/establishments suspect of being illicitly used, particularly: All the chemical precursors listed in the European regulations on drug precursors; these substances are ranked under four categories (see the European regulations concerned and the list of substances on the MNCPC website); Non-scheduled substances identified as having been used as substitutes in the illicit manufacture of drugs; these substances, defined in Article 2 b) of Regulation (EC) No. 273/2004 of the European Parliament and of the Council of 11 February 2004 and Article 2 b) of Regulation No. 111/2005 of the Council of 22 December 2005, are under special monitoring; Any other substance that might be identified by the operators or notified by the MNCPC; - Equipment that could be diverted for the illicit manufacture of drugs. 3. COMMITMENT BY THE COMPANIES/ESTABLISHMENTS 3. a. The key role of the responsible officer in the company/establishment The company/establishment concerned nominates a contact point responsible for drug precursors and, where appropriate, a deputy. The company/establishment concerned clearly defines the duties, role and powers of this responsible officer and any deputy nominated. It notifies all this information to the MNCPC along with the charter of commitment to this national code of conduct (see Appendix 5). In addition to his or her responsibilities in terms of implementing the regulations on precursors (licence and registration applications, annual declarations, etc.), the responsible officer plays a key role in the monitoring system: s/he, under a best efforts obligation, is tasked with all matters relating to the monitoring of precursors, equipment and materials concerned by this national code of conduct. S/he ensures close liaison between the company/establishment and the MNCPC. RESTRICTED DISTRIBUTION For CNAs and relevant operators only 3/10

The responsible officer ensures that: - The staff concerned are regularly familiarised with the issues (see Appendix Sheet 2), - In-house monitoring and diligence procedures have been set up and are effectively conducted by these staff (see Appendix Sheet 3), - Any suspicious or manifestly unusual order is immediately notified to the MNCPC (see Appendix Sheet 4). To properly carry out his or her assignments, the responsible officer must have the skills, the hierarchical level and/or the authority required in the company/establishment to put in place the monitoring procedures and collect information. Particular attention should be paid to the choice of all the service providers used by the company/establishment, especially any other third-party operator to the company/establishment involved in the supply chain through to the stage of the destruction of the substances (e.g. customs representatives, transporters, logisticians, chemical product destruction companies and, more generally, all external service providers). Any change in status or any replacement of the responsible officer or his or her deputy must be notified to the MNCPC within 10 working days pursuant to Implementing Regulation (EU) 2015/1013 on drug precursors. Any change of company/establishment address must be notified to the MNCPC within 10 working days pursuant to Implementing Regulation (EU) 2015/1013 on drug precursors. 3. b. Incorporation of the National Code of Conduct into the company/establishment management systems A charter of commitment to the national code of conduct is proposed to the operators (see Appendix Sheet 4). Each company/establishment signatory to this charter of commitment to the national code of conduct undertakes to implement the measures contained in this national code of conduct. It ensures that the procedures described in this national code of conduct are incorporated into the company/establishment s in-house management rules. The responsible officer is tasked with setting up and supervising these measures in his or her company/establishment. Each company/establishment signatory to the charter of commitment to this national code of conduct undertakes to set up a procedure to immediately notify the responsible officer in the event of a suspicious contact or unusual transaction. 4. COMMITMENT BY THE MNCPC 4. a. The role of assistance and advice to operators The MNCPC, in association with the trade federations, undertakes to: - Provide assistance and advice on the implementation of the regulations (awareness raising actions, website, brochures, on-site visits, provision of examples of procedures to be set up in the company/establishment, etc.); - Provide support and hotline assistance (by telephone/e-mail) on all questions relating to precursors; - Circulate regular information on diversion trends and new regulatory measures (newsletter); RESTRICTED DISTRIBUTION For CNAs and relevant operators only 4/10

- Provide immediate information in the event of an alert (send e-mail alert); - Communicate all useful information to facilitate the identification of risk transactions; - Respect trade secrecy and keep suspicious transaction reports anonymous; - Provide systematic feedback on action taken on a suspicious transaction report as soon as possible and within six months at the latest. In addition, the MNCPC provides operators with a certain number of tools to improve access to information, including: - A regularly updated website: http://www.entreprises.gouv.fr/precurseurs-chimiques-drogues - A secure website ( TELESCOPE ) for responsible officers to file annual declarations online, consult a range of restricted access documents (European and international guidelines, etc.), and access the online training module developed by the European Commission ( e-learning course on drug precursors ); https://telescope.finances.gouv.fr/telescope - An MNCPC presentation brochure (including its limited distribution version, which includes the list of products on the European Union voluntary monitoring list); - A summary of the regulations; - A quarterly newsletter. 4. b. The continuous search for simplification The MNCPC undertakes to constantly seek to streamline procedures and reduce the administrative burden, at national and international level, while maintaining an optimal level of substance monitoring and action to counter the diversion of substances. The MNCPC undertakes to systematically consult operators, via their federations, on national, European and international regulatory developments. In addition, the MNCPC commits to implementing the following streamlining measures in the near future: - Align regulations on precursor chemicals with customs authorised economic operator (OEA) status to streamline licence/registration procedures; - Online the sending of export authorisation applications and eventually, depending on the possibilities with partner administrations, computerise export procedures. RESTRICTED DISTRIBUTION For CNAs and relevant operators only 5/10

5. SIGNATORIES TO THE NATIONAL CODE OF CONDUCT The MNCPC and the trade organisations signatory to this document shall ensure that it is disseminated and shall facilitate its enforcement and monitoring. To this end, the signatory parties shall meet as often as required to regularly update its content. Paris, 8 February 2016 Hervé Mathevet Jean Pelin Gilles Richard Philippe Massé Head of MNCPC Director General of UIC Director General of UFCC President of PRODAROM Eric Angelini President of SNIAA Daphné Lecomte- Somaggio Delegate General of AFIPA Jean-Louis Hunault President of SIMV Fabrice Meillier pp Director General of LEEM RESTRICTED DISTRIBUTION For CNAs and relevant operators only 6/10

APPENDIX SHEET 1: Contact details of the signatories to this national code of conduct MNCPC - Mission Nationale de Contrôle des Précurseurs Chimiques Direction Générale des Entreprises Ministère de l Economie, de l Industrie et du Numérique 67, rue Barbès BP 80001 94201 Ivry-sur-Seine Cedex, France Tel: +33 (0)1 79 84 34 00 e-mail: mncpc@finances.gouv.fr website: http://www.entreprises.gouv.fr/precurseurs-chimiques-drogues UIC Union des Industries Chimiques Immeuble Le Diamant A 14 rue de la République - 92800 Puteaux, France Tel: +33 (0)1 46 53 11 00 e-mail: uicgeneral@uic.fr website: http://www.uic.fr UFCC Union Française du Commerce Chimique Immeuble Le Diamant A 14 rue de la République - 92800 Puteaux, France Tel: +33 (0)1 46 53 10 64 e-mail: ufcc@ufcc.fr website: http://www.ufcc.fr PRODAROM - Syndicat National des Fabricants de Produits Aromatiques Villa Margherite 48 avenue Riou Blanquet BP 21017-06131 Grasse Cedex, France Tel: +33 (0)4 92 42 34 80 e-mail: info@prodarom.fr website: http://www.prodarom.fr RESTRICTED DISTRIBUTION For CNAs and relevant operators only 7/10

SNIAA - Syndicat National des Industries Aromatiques Alimentaires Immeuble Le Diamant A 14 rue de la République - 92800 Puteaux, France Tel: +33 (0)1 46 53 10 10 e-mail: contact@sniaa.org website: http://www.sniaa.org AFIPA - Association Française de l Industrie Pharmaceutique pour une Automédication Responsable 8 rue Saint-Saëns 75015 Paris, France Tel: +33 (0)1 56 77 16 16 e-mail: afipa@afipa.org website: http://www.afipa.org SIMV - Syndicat de l Industrie du Médicament et Réactif Vétérinaires 11 rue des Messageries / 50 rue de Paradis 75010 Paris, France Tel: +33 (0)1 53 34 43 43 e-mail: contact@simv.org website: http://www.simv.org LEEM Les Entreprises du Médicament 58 Boulevard Gouvion-Saint Cyr - 75017 Paris, France Tel: +33 (0)1 45 03 88 88 e-mail: website: http://www.leem.org RESTRICTED DISTRIBUTION For CNAs and relevant operators only 8/10

APPENDIX SHEET 5: Charter of commitment to implement and enforce a national code of conduct to prevent the diversion of precursor chemicals and equipment that could be used for the illicit production of drugs Company/establishment. undertakes to implement and enforce the provisions contained in the national code of conduct to set up a surveillance system for precursor chemicals and equipment that could be diverted for the illicit production of drugs. Mr/Mrs/Ms., in his or her capacity as..., is tasked with setting up and supervising these measures. S/he will act as the responsible officer for the National Mission for the Control of Chemical Precursors (MNCPC). S/he will keep in regular contact with the MNCPC, in particular notifying the MNCPC immediately of any suspicious or unusual transactions. Mr/Mrs/Ms will be deputised, where appropriate, by Mr/Mrs/Ms. Company/establishment. will incorporate the vigilance measures specified in the national code of conduct into its internal management rules and will notify them to the MNCPC within three months of signing this charter. The MNCPC undertakes to communicate all useful information to facilitate the identification of risk transactions. It will provide information on action taken with respect to investigations that may be launched on the basis of suspicious transaction reports. The MNCPC will organise awareness raising actions to which it will invite company/establishment.. Company/Establishment Head Mr/Mrs/Ms. Head of the MNCPC Responsible Officer Deputy Mr Hervé Mathevet. Mr/Mrs/Ms. Mr/Mrs/Ms RESTRICTED DISTRIBUTION For CNAs and relevant operators only 9/10

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