EURAZEO_REGISTRATION_DOCUMENT_2017

2 Societal information

EURAZEO’S CORPORATE SOCIAL RESPONSIBILITY

For example, the MK Direct group established a code of business conduct in 2017. It sets out the group’s ethical commitments and the commitments expected from its business partners, such as respect for human rights, the fight against corruption and respect for the environment. In its purchasing conditions, Orolia reiterates the principles set out in its code of business conduct and asks its business partners to comply with this document. It has also incorporated environmental and ethical issues into the questionnaire sent to new suppliers. Evaluation and monitoring procedures Eurazeo conducts regular monitoring of the progress of responsible procurement policies via several channels. As part of its CSR strategy, Eurazeo encourages its investments to: include CSR issues on the agenda of the meetings of the • Supervisory Board or Board of Directors at least once a year. Eurazeo’s presence on these bodies ensures regular monitoring of these issues. 11 companies adopted this measure in 2017; set up an Audit Committee, allowing regular monitoring of risk • management at the level of the Supervisory Board or Board of Directors. Two companies adopted this measure in 2017, and 11 have an Audit Committee; adopt the 18 indicators dedicated to responsible purchasing in the • context of CSR reporting, which serve to monitor the adoption of procedures within investments. This reporting is then the subject of a comprehensive report to the management of each company. Each company is responsible for evaluating its supplier portfolio. Eurazeo provides the tools to implement this policy and encourages participating companies to send questionnaires to and/or conduct audits of their priority suppliers. In 2017, four investments conducted audits or sent questionnaires to their suppliers. Dessange International launched its Positive Sourcing approach for natural raw materials for the Phytodess range in 2015. It has resulted in the creation of a Positive Sourcing charter assessing potential “supplier risk” in respect of CSR, and the adoption of a supplier questionnaire so as to incorporate CSR criteria into the selection and evaluation of suppliers producing ingredients used in product formulation. In 2017, the Positive Sourcing initiative continued, with the evaluation of 77% of sectors, the signing of the Positive Sourcing charter by 75% of the suppliers included in the program and the audit of the sandalwood sector in Australia. In 2017, Vignal Lighting Group worked on the drafting of a supplier CSR self-assessment questionnaire, which will be released in 2018. It ushers in the inclusion of environmental and social criteria when selecting new suppliers. FAIR TRADE PRACTICES 2.5.4 Actions taken in the fight against corruption Rolling out best practice in the field of ethics is a commitment under Eurazeo’s responsible shareholder policy. It is part of a process aimed at developing a robust and exemplary governance model. In this process of continual improvement, Eurazeo encourages its investments to implement best practice in the detection and prevention of fraud and corruption.

Eurazeo has prepared a guide to anti-fraud and anti-corruption best practice. It provides a reference framework, and aims to help its investments build a culture of integrity by training staff on the ethical conduct expected of them. It also serves as a methodological tool in the implementation of anti-fraud mechanisms. The prevention of corruption is described in detail in Section 3.4.1.3, p. 190. The Code of Ethics addresses Eurazeo’s commitment to employees (respect for people, privacy, declaration of conflicts of interest, political and charitable activities, lobbying, fight against corruption and money laundering, etc.), but also with regard to its business partners, shareholders and investments. It also identifies the various issues and situations that employees and stakeholders are liable to face, indicating the procedure to follow when identifying risk situations and whom to contact. The Code of Ethics has been signed by all Eurazeo employees; it is available to all stakeholders on the www.eurazeo.com website. As part of the European Union’s Solvency II directive covering the insurance sector, AssurCopro has implemented a charter and an anti-money laundering procedure. AssurCopro has also developed a procedure for complaints and alerts from its customers. Fintrax carries out its operations in accordance with the group’s business ethics policy, the fight against corruption and the fight against money laundering. Mandatory training in these policies is being deployed. In 2016, Orolia published its Code of Ethics, which covers its commitments in the fight against corruption and in favor of human rights. Orolia has strengthened its zero-tolerance policy in respect of corruption and fraud, and undertaken to act professionally, fairly and with integrity in all of its business dealings. Measures in favor of the health and safety of consumers and customers At Léon de Bruxelles , mussel suppliers are certified in accordance with a framework specific to the group, built on the basis of a quality management system and detailed specifications. A specialized provider conducts hygiene audits in each restaurant at least four times a year. The process includes sampling of products within restaurants. Internal audits designed to verify compliance with indoor and cooking processes are included in these procedures. Hygiene training is also provided in restaurants and in the Léon de Bruxelles training school. Action taken in favor of human rights Eurazeo ’s code of business conduct commits the Group’s business partners to respect for human rights in the employment relationship. Partners undertake to promote, respect and enforce human rights in the context of their professional activities. They must ensure that the working conditions of their employees comply with applicable local and international laws. In particular, business partners must undertake to prohibit child labor, forced labor or slavery, to pay fair compensation, to establish decent working hours, to ensure the absence of discrimination, harassment and inhuman treatment, to protect health and to ensure health and safety in the workplace. Fintrax conducts most of its business in countries with low risk of human rights abuses. It has nevertheless adopted a policy to ensure compliance with UK law against modern slavery in its operations around the world. The requirements under this regulation apply to Fintrax’s entire supply chain.

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2017 Registration document

Eurazeo