2021 Universal Registration Document


Engaging our stakeholders to meet their needs better

A strict procedure for assessing third parties , including p clients, suppliers and subcontractors. In this regard, the Group implements its purchasing procedure and suppliers’ charter to ensure that all new regulations, and more specifically those connected with the “Sapin II” Act and the duty of vigilance, are covered. Specific procedures are also in place to assess export clients, beneficiaries of donations, sponsorship and patronage, and acquisition targets; A Group training programme aimed at raising awareness p among all employees, using a practical and accessible approach, and training those segments of the workforce considered as the most exposed in light of the results of the risk mapping exercise for bribery and influence-peddling risks. This programme is based on the following: A mandatory e-learning course for all employees : this • course, renewed in 2021, is available in five languages. It is easily accessible via the website of Sopra Steria’s training organisation. This tailored course, designed in-house, consists of eight interactive modules (Legal framework, code of conduct and key contact points; Invitations and gifts; Conflicts of interest; Public agents; Commercial intermediaries and international sanctions; Donations, sponsorship and patronage; Facilitation payments; Whistleblowing procedure) and ends with a mandatory knowledge assessment quiz that employees must pass to successfully complete the course. At 31 December 2021, 92% of Group employees had completed this e-learning module. Dedicated training for populations considered the most • exposed: managers, sales staff, buyers, etc. Strengthened control and audit procedures : The specific p controls are covered in the procedures developed under the programme for the prevention of corruption and influence peddling and may be either ongoing or periodic. In addition to the first-level controls carried out in the form of self-checks by the employees concerned and by line managers, controls are mainly performed, depending on the area involved, by the functional departments concerned (Finance Department, Internal Control Department, Industrial Department, Legal Department, Human Resources Department). The procedures are also assessed by the Internal Audit Department when auditing the Group’s subsidiaries and/or divisions, by running through some 30 specific checks, and during specific compliance audits as part of the internal audit programme; A whistleblowing procedure as set out in section 4.4.1., p “Whistleblowing procedure” (page 142). To the best of the company’s knowledge at the time of writing this Universal Registration Document, neither Sopra Steria, nor its subsidiaries nor any member of an administrative or management body have been found guilty of corruption or influence peddling at any time in the last five years.

Monthly steering meetings unite Executive Management, Finance Department, Internal Audit Department and Internal Control Department to review compliance issues and programme progress and implementation. The Internal Control Department and the Internal Audit Department meet regularly to exchange updated information, notably concerning the audit plan and the identification of risks. Risk management and control within the Group, and the relationship with the Internal Audit Department and external auditors, are described in more detail in Section 3, “Internal control and risk management”, Chapter 2 of this Universal Registration Document (pages 45 to 49). Preventing corruption and influence peddling The Sopra Steria Group is committed to having measures in place to safeguard against risks arising from exposure to corruption and influence peddling. These measures help protect the Group’s reputation and maintain the trust of its internal and external stakeholders. To this end, the Group applies a zero-tolerance policy with respect to corruption and influence peddling. In particular, the following measures are in place: A high degree of executive involvement in the p implementation and monitoring of the Group’s programme to prevent corruption and influence peddling. This firm commitment takes shape in particular through the Group’s specific code of conduct covering these issues, the direct oversight of the programme at the Internal Control Department’s steering meetings, informational meetings for senior managers and regular communications campaigns targeting all Group employees: for example, Executive Management reiterated its commitment to all Group employees on International Anti-Corruption Day, which took place on 9 December; A Group-wide organisational structure in charge of p managing, monitoring and controlling the framework, through a network of Internal Control & Compliance Officers, who have responsibility for compliance and risk management issues within each entity; A specific mapping exercise to identify risks of corruption p and influence peddling , updated every two years or as soon as is necessary following a major Group-level event; A specific code of conduct for the prevention of p corruption and influence peddling , including a foreword by the Chairman of the Board of Directors and the Chief Executive Officer and illustrated with real-world examples, as a supplement to the Code of Ethics. This code of conduct has been translated into 10 languages and covers all Group entities; A disciplinary regime based on the code of conduct p enforceable against all employees since its inclusion in the Group’s internal rules and regulations, or through any other mechanism in force at Group entities; Specific, formal procedures , allowing in particular for the p implementation of the first- and second-level controls, in order to respond to situations identified as potentially exposed to risk. For example: policies on hospitality and gifts and procedures covering conflicts of interest, client events and export activities; BUSINESS ETHICS AND COMPLIANCE 4.4.3.



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