AFD - Universal Registration Document 2020

STATEMENT OF NON-FINANCIAL PERFORMANCE 2 Fair practices

The AFD Group implements a programme to prevent and combat corruption and influence peddling within its organisation, in conformity with the “Sapin Ǿ II” Act, which became applicable in December Ǿ 2016. The Group adopted an anti-corruption code of conduct (1) clarifying the expected and prohibited behaviour of Group employees regarding the prevention and fight against corruption and influence peddling in performing their duties. The Group adopted a professional whistle-blowing system open to internal employees and external or temporary service providers working for the Group. It also mapped the risks of corruption and influence peddling, integrated into the mapping of operational risks. With regard to service providers and suppliers, in 2020 the Group developed a risk classification matrix to assess the corruption risks of the suppliers with which the AFD Group worked in 2019. The objective of this matrix is to determine the gross risk (low, medium, high) presented by these suppliers resulting from a rating based on two axes: the financial impact of the supplier and the corruption risk index of the country where the supplier is registered. The Group is also developing a procedure to enable it to identify and assess the risk of corruption associated with suppliers, at the entry point and throughout the business relationship with them. This procedure will come into force in 2021. In 2021, the Group will also adopt a charter as part of its relations with its suppliers, aimed at specifying the commitments expected from them and any subcontractors, notably in terms of ethics and the fight against corruption. Controls on the merits of transactions (such as the absence of accounting entries likely to conceal acts of corruption or influence peddling) were implemented in 2020. They will be completed and reinforced in 2021. E-learning training modules on the prevention of corruption and influence peddling and the AFD Group’s anti-corruption code of conduct will be rolled out in 2021 among AFD Group employees. This anti-corruption and influence peddling compliance programme applies not only to AFD as an industrial and commercial State public undertaking but also to its subsidiaries Proparco, Sogefom and Fisea. 2.7.2 Checks made during a project’s life cycle In accordance with banking regulations, prior to beginning a project, the counterparty and any appropriate shareholders are researched in depth in order to identify the beneficial owner. Persons subject to political exposure are also identified. As part of the monitoring of project execution, the methods for reimbursing and receiving amounts of any kind, in particular dividends, and for settlement of equity investments (transfer of equity investments) are closely monitored, because they can reveal fraudulent practices. At the time of the examination, and then throughout the life of the projects, the Group provides its employees with a filtering tool which consolidates information such as the financial

and commercial sanctions adopted by France, the European Union, the United States, the United Kingdom and the UN. Such screening is also included in the processing chain for payments issued by AFD’s Financial Department. The objective is to ensure that no counterparts, person concerned by checks, supplier and successful tenderer to a tender financed by AFD, is the subject of financial sanctions or is involved in sectors subject to an embargo, which the Group is required to implement. It should be noted that when reports of prohibited practices are reported in connection with the implementation of projects, they are processed, since the end of 2018, by a dedicated function within the Compliance Department. The Investigation Function’s main task is investigating, in a professional and objective manner, the reports made to it by AFD Group employees (called Suspicions) or by third parties (called Allegations) concerning prohibited practices, namely acts of corruption, fraud, anti- competitive practices, money laundering and terrorist financing. 2.7.3 Checks carried out as part of the foreign public procurement Ǿ process Public procurement for contracts financed in foreign States by the AFD Group undergo specific checks ensuring that the various stages of the procurement process unfold under the required conditions of integrity, transparency, fairness and efficiency. These checks are published through the issuance of a notice of no objection (NNO) and are carried out ex-ante at specific stages of the public procurement process. In certain cases and after AFD’s approval, an ex-post control may also be exercised for certain procurement processes. In addition to these controls, AFD imposes exclusion criteria (2) for project management, in addition to those existing in local legislation. Thus, a contract cannot be financed by AFD if the successful tenderer is in one of the cases of exclusion or ineligibility specified in the Directives for the award of contracts financed by AFD in foreign States. As part of the response to the Covid-19 crisis, and in particular the “Health in Common” initiative, a specific accelerated procedure was put in place for emergency supply contracts, associated with a standard application for simplified quotation (in French, English and Spanish), in order to promote a rapid response capacity. Another type of response to the Covid-19 crisis: a comprehensive e-learning training course on contracting for project owners was launched in June Ǿ 2020. In preparation before the health crisis, this support made it possible to propose an alternative while the crisis prevented the training missions planned for project owners/ Internally, training has also been adapted so that it can be delivered remotely and a large number of courses have been maintained (in a lighter format in certain cases), making it easier for branch employees to participate, an opportunity which is the same for other sectors (see above, section on “Skills development, employability and training).

(1) https://www.afd.fr/fr/lutte-contre-la-corruption (2) See Guidelines for the award of contracts financed by AFD in foreign countries - October Ǿ 2019: https://www.afd.fr/fr/ressources/directives-pour-la- passation-des-marches-finances-par-l-afd-dans-les-etats-etrangers

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2020 UNIVERSAL REGISTRATION DOCUMENT