DERICHEBOURG - Universal registration document 2019-2020

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CSR report (serving as statement of extra-financial performance) Consolidating relationships of trust with our partners

Consolidating relationships of trust with our partners 1.7

Four Group subsidiaries(DerichebourgPropreté,DerichebourgÉnergie, DerichebourgIntérimand DerichebourgAccueil) have been assessedby ECOVADIS in 2019/2020, the first collaborative platform enabling companies to monitor the sustainable development performance of their suppliers in 150 sectors and 110 countries. The average score weighted by revenue was 67%. With these scores, the Derichebourg Propreté, DerichebourgÉnergie and DerichebourgAccueil subsidiaries are in the top 4% of companies assessed in their respective business sectors. Managing CSR risks in the valucehain 1.7.1 Derichebourg Multiservices has been a signatory of the UN Global Compactsince 2013. This commitmentis an undertakingto respect the 10 universalprinciples of the Global Compact regardinghuman rights, international labor standards, the environment and combating corruption, and to support the SustainableDevelopmentGoals of the UnitedNations. Duty of vigilance The provisions relating to the duty of vigilance are set out in section 1.8. Fair trading practices Under section 3.3 “Risk Factors”, the Group provides details of the risks associatedwith the purchase of metals and the register of goods purchased (retail purchases): in particular, the risk of receiving stolen property. The Group took action, via its professional federation, to lobby government authorities to ban cash payments for such purchases in France. Since August 1, 2011, retail metal purchasesmust be paid for by crossedcheck, bank or post office transfer. This has enabled the risk of cash float theft to be reduced and made money flows from retail metal purchasestraceable. The Group drew up a corruptionrisk map under law no. 2016-1691of December 9,2016 on transparency,fighting corruptionand economic modernization, known as “Sapin 2”. This map identifies theoretical corruptionrisks, which are scored in two stages: a scoring on impact and frequency in order to obtain a mapping of p inherent risks. The types of impacts selected are reputation, marketing, legal and financial and the seriousness is assessed from low to critical. Frequency is defined by time intervals from the possible (every 3 to 10 years) to the almost certain (several times per quarter);

a scoring of the level of inherent risk management in order to p prepare a mapping of residual risks. The level of risk management representsthe level of internal control maturity in respect to a risk. It has been assessed as being exemplarywhen the risk is covered by a controlmechanismthat is appropriate,formalizedand supervised. The Group has created an Anti-CorruptionCode of Conduct, which begins with an introduction by the Chairman and Chief Executive Officer that confirms the Group’s commitments in the fight against corruptionand defines the code as a guideline for all employees in the daily exercise of their activities. It restates its binding legal status for all stakeholders: employees, corporate officers, shareholders, commercial partners. The Anti-CorruptionCode presents the different types of active and passive corruption. It states the definitions of active and passive influence peddling and illustrates the prohibited behaviors with tangibleexamples. It sets out the Group’s policy in terms of gifts received or offered, hospitality, contracts signed with intermediaries,facilitation payments, patronageand sponsoring. It alerts readers to the responsibilityof all employees and hierarchical managers by recalling the disciplinary, civil and criminal sanctions resultingfromnon-compliancewith the policy. It concludeswith the alert proceduremade available to employeesand third parties that witness acts of corruption or attempted corruption. Alerts are collected confidentiallyunder the whistle blower protection status with the assurancethat the alert will be processed.The Secretary General is appointed as the Group’s ComplianceOfficer, approved to receive these alerts via an email address “ethique@derichebourg.com” specificallycreatedfor this purpose,or by letter. A clear, adapted training program has been rolled out for the employees in question, in particular members of the Executive Committee,business directors, and sales, developmentand purchasing managers. The Group employees in question received training during the previous fiscal year. Employeeswho joined the Company after this first campaign and identified as belonging to the potentially exposed categories were trained during the 2019/2020 fiscal year. 165 of the 167 people exposed received training during the 2019/2020 period. This representsa completionrate of 98.8%. In addition, a trainingupdate for those already trained is plannedevery two years. This training will be rolled out as of the next fiscal year through an internal e-learning module currently being developed by the DerichebourgAcademy.

98.8 % rate of completed anti-corruption training courses

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