ANTIN // 2021 Universal Registration Document
SUSTAINABILITY
Responsible company approach
4.4.6 Upholding the highest business ethics and corporate governance standards Description Antin aims to uphold the highest business ethics and corporate governance standards across operations by instating independent Board members, maintaining internal control measures, and ensuring employee awareness on business ethics topics. Risks and opportunities Corporate governance Maintaining good corporate governance helps to prevent financial and accounting problems, compliance issues, civil and criminal liability and, in extreme cases, business failure. This is all the more material following Antin’s initial public offering (IPO) and given the more stringent regulation on disclosure, governance, and accounting it is now subject to. Poor corporate governance practices could harm Antin's reputation, jeopardise its social license to operate, and trigger stakeholder backlash. Business ethics Antin maintains business relationships with a wide range of stakeholders. It is also subject to various business ethics-related regulations. Implementing proper business ethics procedures is therefore key to avoiding criminal liabilities or business opportunity losses, upholding Antin's reputation and its social license to operate, and maintaining stakeholder trust. Personal data protection A subset of good business practice is safeguarding personal data. As a company based in France, Antin is subject to small- and medium-sized enterprise (SME) requirements of the European Union (EU) General Data Protection Regulation (GDPR). Failure to comply with these personal data protection requirements could result in fines or negative reputational impact. Beyond regulatory concerns, major sensitive data security breaches could lead to operational disruptions and/ or lawsuits, and could adversely impact Antin’s reputation, its social license to operate, and stakeholder trust. Policy and strategy Corporate governance Since going public, Antin has instated four independent members on its Board of Directors. Please refer to Section 2 "Corporate Governance" of this Universal Registration Document for more detailed information on Antin's good governance practices.
Business ethics To maintain transparency and ensure ethical conduct and good business standards, Antin’s skilled internal compliance team manages a robust compliance programme, which includes maintaining a Group compliance policy, a Group Whistleblowing Policy, and a Group Code of Ethics, in addition to Codes of Ethics and policies particular to each office’s specific local regulations and requirements. To ensure employee awareness and knowledge of business ethics, Antin requires all new hires to sign its compliance policy, and the compliance team regularly conducts Group-wide trainings as well as ad hoc workshops on business ethics issues as they arise. Going forward, Antin will continue to maintain its compliance programme as outlined above to ensure high business ethics standards. Personal data protection Antin is fully compliant with the EU GDPR requirements applying to a company of its size and regularly updates its policies across the Board to remain so. GDPR compl iance is handled by both Ant in’s IT and Compliance teams. Antin maintains necessary data access and management procedures, such as an individual’s right to be forgotten, right to be informed, and right to rectification, as well as further mechanisms such as a Data Protection Policy, a Written Information Security Policy (WISP), breach notification templates, an incident response plan, and a data retention policy. Antin additionally provides employee trainings on cybersecurity. Antin’s Compliance and IT teams will continue to maintain these policies and procedures in compliance with the GDPR, with regular verification and updates. Performance
4
Corporate governance
57 % Independent Board members
Business ethics
94 % ✔ Employees trained on business ethics-related topics (1)
(1) Employees on a leave of absence when training was provided were unable to attend
✔ Limited assurance provided by statutory auditors
101 ANTIN INFRASTRUCTURE PARTNERS S.A. - UNIVERSAL REGISTRATION DOCUMENT 2021
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