Eurazeo / 2018 Registration document

EURAZEO’S CORPORATE SOCIAL RESPONSIBILITY Non-Financial Performance Statement

ETHICS 2.2.4 Risk prevention and compliance with internal procedures is the responsibility of everyone within the organization. The internal control system is therefore based on an environment that promotes honest and ethical behavior, particularly through the communication of a certain number of essential principles, values and practices. Eurazeo has a Code of conduct that defines the values and principles that must guide the behavior of its employees and the stakeholders with which Eurazeo has a relationship. In particular, the code covers

certain commercial practices (notably the amount of gifts received from outside), the management of conflicts of interest, the confidentiality of information, respect for persons and private life, data protection, the use of Company assets and the prevention of corruption and influence peddling. Each employee formally undertakes to comply with this code. Two issues are covered in greater detail in the following sections: anti-corruption and the fight against tax evasion.

Anti-corruption 2.2.4.1

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Description of the potential ares of risk or opportunities

OBJECTIVES

RISK FACTORS

RISK ASSESSMENT METHODS Risk assessment by documenting a specific • corruption mapping Country risk assessment in relation to Transparency • International’s Corruption Perceptions Index Assessment of integrity for third parties and • the nature of the business relationship with them

Comply with national and international anti-corruption laws Unfamiliarity with applicable laws and regulations • Low awareness among employees exposed to • corruption risk Country where a third party is domiciled and country • where the relationship is established; typology of the third party and nature of the business relationship Business sector/third parties/location of targets • Adopt an ethical approach in Eurazeo's third-party business and relationships RISK MANAGEMENT Formalization and roll-out of a Code of conduct • Set-up of a prevention system (mapping, third party assessment, whistleblowing mechanism, training) •

OBJECTIVES

OPPORTUNITY FACTORS

Guide the behavior of each stakeholder with which Eurazeo has a relationship • Support portfolio companies in strengthening their anti-corruption system •

Improve transparency in business affairs

a third-party assessment process prior to starting up a new • relationship or continuing an existing business relationship. These assessments are conducted in proportion to the third-party risk profile and the nature of the relationship. This process is designed to classify the nature of the relationship and assess third-party integrity by distributing questionnaires, using a reputation analysis tool, and, where necessary, through extensive due diligences performed by external experts; an internal whistleblowing mechanism which, while keeping the • whistleblower’s identity strictly confidential, is designed to signal conduct or situations that may represent a crime, offense, serious or obvious breach of the law or a regulation, serious damage for the general interest, or violations of the Eurazeo Code of conduct; an anti-corruption training program which enables Eurazeo • employees to better grasp the regulatory environment and adopt the key procedures and tools of the prevention system. In addition, employees formally renew every year their individual commitment to act in accordance with the values and principles of the Code of conduct.

Policy applied at Eurazeo level Eurazeo had adopted a “zero tolerance” approach vis-a-vis active or passive corruption and influence peddling. Eurazeo prohibits all forms of corruption in the conduct of its activities and has pledged to comply with the international anti-corruption agreements. This is particularly the case for anti-corruption laws in those countries where it has business operations (specifically, in France, law no. 2016-1691 of December 9, 2016, known as the Sapin II law). This commitment applies to all employees. The Eurazeo Code of conduct, updated in 2018 and available on the Eurazeo website, is the basis of the corruption prevention system built around the eight pillars defined by the French Sapin II Law. By way of illustration, this prevention system includes: a risk mapping which identifies and prioritizes corruption risks in • relation to their occurrence and impact. It is used to define the corruption prevention system in proportion to the Company’s specific issues;

Eurazeo

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2018 Registration Document