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MANAGEMENT REPORT ANTI-CORRUPTION MEASURES

The Group's executive management team defines the Group's overall internal control principles and ensures that they are correctly applied. The Audit Committee examines the main reports related to the accounts as well as those concerning internal control. 3.8.3.6 2018 action plan The Group has made internal control part of a continuous improvement plan with the aim of enhancing the operational effectiveness of its processes for preparing and processing accounting and financial information. In line with this, the action plan drawn up for 2018 notably includes carrying out a priority review of recently-acquired subsidiaries, covering financial, organisational and operational issues.

In small-sized entities, the appropriate segregation of tasks is sometimes difficult to achieve owing to the entity's organisational structure. In such cases, specific controls are put in place, essentially in the form of increased supervision by management, which conducts an independent review of critical transactions for control and authorisation purposes.

3.8.3.5 Ongoing monitoring of the internal control process

Overseeing the internal control process is one of the primary duties of the Board of Directors and the Audit Committee as well as of the Group's support and operations departments.

3.9 ANTI-CORRUPTION MEASURES

In 2011 Assystem pledged to uphold the UN Global Compact which sets out ten universal principles covering human rights, labour, the environment and anti-corruption measures, and reaffirmed its pledge in a letter dated 16 January 2017. Within the Group, these principles are

translated into mandatory behaviours and practices, as indicated in the cross-reference table in the CSR report on page 212 and reproduced below.

Anti-corruption measures Global Compact principles

Sources

• COP 2013, 2014, 2015 and 2016 • Code of Ethics (see pages 20 and 47 of this Registration Document) • Code of Business Conduct (see pages 52 and 75 of this Registration Document)

Businesses should work against corruption in all its forms, including extortion and bribery

3.9.1 SECURITIES TRADING CODE OF CONDUCT The Board is guided in its work by its Rules of Procedure which define its modus operandi and include the Securities Trading Code of Conduct. The Board regularly reviews its Rules of Procedure in order to ensure that they are continually in compliance with the applicable laws and regulations. The latest update was carried out by the Board on 1 February 2017 in order to align the Rules with European Union Regulation no. 596/2014 dated 16 April 2014 on market abuse and its implementing legislation, which entered into force on 3 July 2016. FAIR BUSINESS PRACTICES Employing fair business practices is one of the Group's key priorities. Assystem has had a Code of Ethics since 2006 and it now also has a Code of Business Conduct which provides practical guidance on the application of the Group's ethical values by defining and describing the principles and behaviours to be followed when conducting business. The Code of Business Conduct adds to but does not replace pre-existing local policies. Its purpose is to ensure that the Group's ethical ethos is applied consistently in all countries, taking into account the differences in local business practices. 3.9.2

The Code of Business Conduct describes four specific policies:

● Policy concerning gifts and invitations:

● gifts given or accepted by executives and employees must be: – of reasonable and symbolic value, – occasional, – in compliance with the applicable laws and regulations and consistent with local practices; ● gifts given by the Group must be transparently recorded in Assystem’s accounts. ● Anti-bribery policy: executives and employees must give the following undertakings: ● not to solicit money, gifts, invitations or any other form of advantage, ● not to offer, give or promise gifts, invitations or any other form of advantage to a public official or private individual in order to obtain a benefit or preferential treatment, or to influence the completion of a transaction or the awarding of a contract, ● to obtain details of the anti-corruption rules applicable in the Group's host countries, ● to notify their superior of any dubious requests or solicitations.

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