2021 Universal Registration Document

4 CORPORATE RESPONSIBILITY

Engaging our stakeholders to meet their needs better

companies as part of the integration of these companies within the Group and with respect to its procedures and systems. The vigilance plan consists of four parts: A mapping of risks to identify, analyse and prioritise the risks p relating to the duty of vigilance; Risk mitigation and prevention plans; p A system for the receipt of reports relating to the existence of p risks or the occurrence of risk events; A system to monitor the measures implemented and assess their p effectiveness. RISK MAPPING EXERCISE 4.7.1. The mapping of risks relating to the duty of vigilance draws on the Group’s overall risk mapping exercise as well as the Group’s main corporate responsibility challenges. The methodology used for the mapping of risks relating to the duty of vigilance is similar to that used for the Group’s general risk mapping exercise. The risk areas listed below were analysed and prioritised in line with their severity and likelihood of occurrence in the context of the Group’s business activities and those of its suppliers and subcontractors:

Human rights and fundamental freedoms: diversity and equal p opportunity, freedom of association and the right to collective bargaining, protection of personal data, respect for the rights of local communities, preventing child labour and forced labour within the supply chain; Health and safety: right to safe and healthy working conditions p (e.g. access to buildings, sanitation, safety and security of business travel), prevention of occupational illnesses, healthcare benefits and workplace prevention measures for the Group and its supply chain; Environment: GHG emissions, treatment of polluting waste, air p and soil pollution, depletion of raw materials, soil erosion and degradation, degradation of ecosystems and biodiversity in the supply chain. RISK MITIGATION AND PREVENTION PLANS 4.7.2. The continuous improvement approach adopted in line with the Group’s corporate responsibility policy put in place several years ago focuses on the various issues targeted by the French duty of vigilance law. The cross-reference table indicates the corresponding sections of the Corporate Responsibility Report that describe the risk mitigation and prevention plans put in place. The relevant information is set out in sections 2 and 4 (pages 107 and 135). The relevant information is set out in section 2.8, “Health, safety and working conditions” (pages 118 to 119). The relevant information is set out in section 3, “Environmental responsibility: Carbon-neutral trajectory - Net-zero emissions by 2028” (pages 120 - 134). The relevant information is set out in section 4.3., “Suppliers and partners” (pages 140 to 141). subsidiaries, along with those of its main suppliers, are carried out at the level of the departments concerned. Each department with oversight for issues involving the duty of vigilance is responsible for monitoring the risks identified in the mapping of risks relating to the duty of vigilance. All of these departments are involved in the identification and implementation of reasonable and appropriate vigilance measures for their respective areas of responsibility. They report on their monitoring activities at the Group’s steering committee meetings and twice a year to the Corporate Responsibility and Sustainable Development Committee. The risk mitigation and prevention measures put in place with regard to the duty of vigilance are reviewed as part of the Group’s internal control procedures and are the focus of a consolidated report drawn up each year by the Internal Control Department and presented to Executive Management. Mitigation plans and preventive measures

Area

Category

Risks relating to the Group’s business activities

Human rights and fundamental freedoms

Health and safety

Environment

Risks relating to the business activities of the Group’s suppliers

Responsible purchasing

Sopra Steria’s policies, actions and results in respect of the workforce and human rights, business ethics, the environment and responsible purchasing are assessed annually by EcoVadis. Since this label was created in 2020, Sopra Steria has achieved the highest possible rating of Platinum. The Group has also been among the top 1% for the past three years. WHISTLEBLOWING PROCEDURE 4.7.3. Sopra Steria has put in place a whistleblowing procedure for receiving reports in connection with its duty of care. This procedure is set out in section 4.4.1. “Whistleblowing procedure” (page 142).

SYSTEM TO MONITOR THE MEASURES 4.7.4. IMPLEMENTED AND ASSESS THEIR EFFECTIVENESS

For risks relating to the duty of vigilance, the procedures for the regular assessment of the Group’s business activities and those of its

149

SOPRA STERIA UNIVERSAL REGISTRATION DOCUMENT 2021