Compagnie des Alpes // 2021 Universal Registration Document

4 STATEMENT OF NON-FINANCIAL PERFORMANCE Societal challenges

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 no. 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, Insurance and Crisis 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, 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 purchases are potentially more at risk in terms of respect for fundamental rights at work. Since 2011, product compliance audits have been conducted at the factories of our main suppliers in South-East Asia (see 4.4.2.1), specifically those that produce toys and crockery. These audits are also carried out on the basis of labour criteria (child labour, forced labour, discrimination, working hours, compensation, health and safety, etc.). With low purchasing volumes, the risk analysis for Tier 1 plants (finished products) was based from 2019 on the consolidation of social audit reports also conducted by third parties according to recognised ethical guidelines. The results of the audits obtained to date (around fifty labour audit reports, without being completely exhaustive) show that the labour criteria are met. Work is continuing to complete the necessary information. For non-retail purchases, the Group makes every effort to impose strict contractual clauses on our suppliers and these clauses will be reinforced when necessary. 4.4.3.4 Societal supply chain performance The Group has adopted a pilot Purchasing policy which lays down the key principles which apply to each of its entities. As part of this local commitment, the CDA Group gives priority to recognised local suppliers, who share the same values in terms of risk prevention and respect for the environment. Where appropriate, contracts include environmental protection clauses and a prevention plan, possibly with a prevention- safety-environment guide. A large number of sites incorporate an

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Compagnie des Alpes I 2021 Universal registration document