Compagnie des Alpes // 2020 Universal Registration Document

4 STATEMENT OF NON-FINANCIAL PERFORMANCE Societal challenges

4.4.3 COMPLIANCE AND ETHICS Compagnie des Alpes makes compliance and ethics a core part of its business practices. The Group’s compliance and ethics approach has been entrusted to the Group’s Head of Legal Affairs and Compliance, appointed as Group Ethics Officer by the Chairman and Chief Executive Officer. The role of the ethics officer is to: l implement procedures that promote compliance not only with applicable regulations but also with high standards of professional conduct and ethics; l promote among all employees the principles and best practices that are part of the Group’s ongoing desire to respect our stakeholders such as our employees, shareholders, customers, partners and of course the public authorities; l make every effort to ensure that we conduct our business in a legal, responsible, transparent and ethical manner. The Ethics Officer may be consulted by any employee on issues concerning compliance and ethics and may be required to assist employees in their decision-making. 4.4.3.1 Preventing fraud, money-laundering and the financing of terrorism To encourage best ethical practices, the Group has drafted and distributed an Ethics Charter which is a guide for professional conduct, an IT system resources usage charter, and procedures to combat money laundering and the financing of terrorism. At subsidiaries, these codes of conduct are backed up, where appropriate, by formal undertakings by the management, training courses, and clauses in employment contracts. Compliance with the law, Group policies and the proper functioning of processes are ensured by the application of internal controls, the separation of duties and regular internal audits. Since 2013, the formalisation of the Group’s internal control procedures has strengthened the application of best practices and employees’ vigilance to fraud (see section 2.8 “Internal control procedures” in Chapter 2 “Risk factors”). 4.4.3.2 Combating corruption To prevent the risk of corruption, the Group has stepped up its efforts mentioned above and introduced a corruption prevention plan which meets the requirements of Law n° 2016-1691 of 9 December 2016 on transparency, anti-corruption and economic modernisation, known as the “Sapin 2” law. Although the Group does operate in countries exposed to corruption risks (Transparency International index < 50), there are fewer than five employees based permanently in these countries and the consultancy contracts which relate directly to them represent less than 0.25% of the Group’s revenue. Following the completion of the Group’s corruption risk mapping by the Risk Management Department, the following documents were prepared, at the request of the Group Legal Department, with the assistance of the Risk Management Department, the Finance Department and the Internal Audit and Internal Control Department: l Anti-Corruption Code of Conduct, based on the standard Middlenext Code which the Company helped to draw up as part of a working group, and supplemented by practical examples relating to the Group’s business activities;

l gifts, invitations and donations policy, giving employees clear guidelines on the circumstances under which they can receive or give gifts and/or invitations and setting out the conditions for donating to associations and/or patronage; l whistleblowing procedure, available to all Group employees and also non-employees, stipulating how to raise the alarm via a specialist provider’s secure whistleblowing platform, the protection offered to the person raising the alarm, etc. The Group’s Head of Legal Affairs and Compliance has been appointed as the contact person within the meaning of Article 4 II of Decree No. 2017-564 of 19 April 2017; l audit procedures for members of the Finance Department, to ensure the books, ledgers and accounts are not used to conceal corruption or trading in influence. The Chairman and Chief Executive Officer has communicated widely on these procedures and on the topic in general to all employees. The Group entities’ legal representatives are responsible for circulating them to all of their staff and ensuring they are applied. In addition, the Human Resources Department and the Group Legal Department have rolled out: l an e-learning platform. The training, which includes examples directly relevant to the Group’s business activities, has been rolled out to French-speaking permanent employees, for whom the training is mandatory; l face-to-face training by a specialist lawyer for the Executive Committee and the 340 employees most exposed to the risk, which covered 82% of the employees identified. Since then, 40 additional employees have been added to the list of exposed employees. 4.4.3.3 Human rights and promotion and compliance with the stipulations of the Basic International Labour Organization Conventions The Group recognises the guiding principles of the UN’s Universal Declaration of Human Rights and, in the course of its business activities, promotes respect for the fundamental rights (respect for human rights and the international labour standards). The companies of the CDA Group are committed to abide by the International Labour Organization (ILO) declaration relative to the fundamental rights and principles at work, bearing in mind that the ILO directives are fully incorporated into the labour laws of most countries in which the CDA Group operates. However, we do not consider the risk related to human rights as a specific risk. First, most of the sites we operate in the Ski areas and Leisure parks are located in Europe, where the risk of violation of human rights is low. Second, in terms of our purchases, an analysis conducted in 2018 as part of a socioeconomic study (see 4.4.1.1) revealed that around 97% of the purchases made by the sites covered were from tier-1 suppliers based in France or, more widely, in Europe. Very few of the products we buy for sale at the sites (“Retail” purchases) are bought from suppliers based in Asia. These products are therefore more exposed to a risk relating to fundamental rights at work. Since 2011, product compliance audits have been conducted at the factories of our main suppliers in South-East Asia (cf. §4.4.2.1), specifically those that produce toys and crockery. These audits are

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Compagnie des Alpes I 2020 Universal registration document