Compagnies des Alpes // 2019 Universal Registration Document

2 RISK FACTORS

Internal control procedures

said approval. The Charter also states the missions and prerogatives of the di ff erent Committees of the Board of Directors, particularly the Audit and Finance Committee. The Charter is available on the Group website: www.compagniedesalpes.com; l the Ethics Charter states the values and principles of the Compagnie des Alpes Group. It serves as a guide for professional behaviour, reviews the basics of investment ethics, explains the risks of con fl icts of interest, and de fi nes appropriate behaviour. It is adjusted in line with regulatory developments; l pursuant to Law No. 2016-1691 of 9 December 2016, known as the Sapin II Law, the Group has a plan for the prevention of corruption and trading in in fl uence, including an anti-corruption code of conduct and a whistleblowing procedure; l a procedure for the prevention of fraud, money-laundering and the fi nancing of terrorism; l a charter for the use of IT resources. Like the Ethics Charter, it is being gradually applied to all Group employees. Information and communication Each functional or operational department de fi nes the charters, rules and procedures that fall within its area of responsibility. These documents make up the Group Reference Documents, which are made available to all Group employees who are required to apply them. In 2019, a new document management tool, administered by the Audit and Internal Control Department, will improve employee accessibility through the Group’s Intranet. The entities of the Group are responsible for translating Group rules and procedures, into rules, procedures and operating methods adapted to their organisation, and also for communicating these to all employees concerned. Definition of control measures Since 2013, the CDA Group has embarked on a more detailed formalisation phase of its internal control system, which is gradually being deployed on all of the Group’s processes listed in the process mapping, with a priority given to processes impacting the main income statement lines (sales, purchases, etc.), the production of accounting and fi nancial information, as well as the Group’s priority risks. For each of the processes concerned, the method applied involves drawing up all or some of the following documents: l fl ow diagram: schematic description of the steps involved in the process. This fl ow diagram is a standard document at Group level; l internal control benchmark: this guide translates the general internal control targets and describes the controls to be implemented to ensure better control of each of the risks identi fi ed, at the level of each step of the process; l self-assessment questionnaire: this makes it possible to assess the extent to which operating procedures and methods comply with the internal control standard recommended by the Group. All these documents are prepared in collaboration with operational sta f f, risk experts and the operational departments concerned. Every year, the system is strengthened with the introduction of new processes that are prioritised with the help of Executive Management and the support of the Risk, Insurance and Crisis Management Department.

company and all controlled entities. This system is tailored to the nature and scope of each of the activities and is integrated into existing processes in order to empower actors as closely as possible to the processes. It primarily consists in providing the required tools and an information-sharing platform, so that each employee is fully aware of their role in the system. An Internal Control Charter speci fi es the key operating principles (roles and responsibilities, governance, methodology). It is available in the Group’s reference documents. The internal control system consists of fi ve elements: l an organisation – i.e. clearly de fi ned responsibilities, adequate IT resources and skills based on rules and procedures; l the publication of relevant information; l a risk analysis system; l proportionate control measures; l a continuous monitoring system. Group organisation The Executive Management of the CDA Group decides on: l organisation, responsibilities and the delegation of powers and/or signing authorities; l the objectives, policies and values of the Group. Group management, which is the responsibility of the Chairman and Chief Executive O ffi cer (1) , is based on a matrix organisation split between large functional and operational departments, each led by a member of the Executive Committee (Comex). There are 7 such departments: l four operational departments manage the implementation of Group strategy and are responsible for the achievement of commercial and fi nancial targets, management, and human resources and risk management at all operating entities under their responsibility: l the Ski areas Department, l the Leisure parks Department, l the Strategy, Development and Mergers & Acquisitions Department, mainly responsible for development in France and internationally, l the Distribution, New Business Lines and Innovation Department, mainly responsible for the development strategy concerning products and new business lines; l the Communications, Brand and Corporate Social Responsibility (CSR) Department, in charge of fi nancial and institutional communications, as well as brand-related and CSR issues; l the Finance, Risk, IT, and Procurement Departments, which have responsibility for the Group’s financial policy, in particular the production of accounting and fi nancial information, procurement policy, the IT master plan and risk and insurance policy; l the Legal A ff airs, Audit and Internal Control Department. Main Group charters Charters are given to all employees, setting out the Group’s values: l the Corporate Governance Charter defines the areas in which Executive Management decisions are subject to prior approval by the Board of Directors, as well as the conditions for the granting of

(1) Until 15 October 2018, the Chairman and Chief Executive Officer was assisted by a Deputy CEO.

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Compagnie des Alpes I 2019 Universal registration document