Compagnies des Alpes // 2019 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 implementation of the Group’s compliance and ethics policy has been entrusted to the Legal Director, appointed as the Group’s Ethics O ffi cer by the Chairman and Chief Executive O ffi cer, as con fi rmed by the Group’s Risk Committee. The Ethics O f ficer’s role is to establish procedures that promote compliance with applicable regulations, as well as stringent rules of ethics and professional conduct. It also involves inciting all employees to abide by the principles and good practices that uphold the Group’s constant determination to respect its stakeholders, including its employees, shareholders, customers, partners and, of course, public authorities, and to make every e ff ort to ensure that all of its business activities are conducted in a totally legal, responsible, transparent and ethical manner. The Ethics O f ficer 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 fi nancing 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 e ff orts 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 fi ve employees based permanently in these countries and the consultancy contracts which relate directly to them represent less than 0.05% 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 o ff ered to the person raising the alarm, etc. The Group Legal Director is the designated point of contact in accordance with Article 4 II of Decree n° 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 in fl uence. The Chairman and Chief Executive O ffi cer 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 sta ff and ensuring they are applied. The Human Resources Department and Group Legal Department have also worked on the introduction of: 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 identi fi ed. A plan to monitor the e ff ectiveness of the system was put in place by the Internal Audit Department in 2019. 4.4.3.3 Human rights and promotion and 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 speci fi c 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 ( cf . 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”) 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), speci fi cally compliance with the stipulations of the Basic International Labour Organization Conventions

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Compagnie des Alpes I 2019 Universal registration document