Exclusive Networks // Sustainability Report 2022
Risks and opportunities Risk factors
Risk related to corruption (business ethics) ESG
Criticality level: ■ ■ ■
Risk description
Risk management
In accordance with the requirements of the Law on the Prevention of Corruption and the Transparency of Economic Life and Public Procedures (known as the “Sapin 2” Law), Risks & compliance has set up a compliance programme and has a dedicated team, made up of specialised lawyers and local advisers (brought together in a network of Ethic Champions ). The following are the main actions carried out in 2022: update of anti-corruption procedures and reinforcement of the Group’s commitments: updated in 2022, the Code of Conduct defines and illustrates the types of behaviours to be adopted and prohibited in terms of preventing and fighting corruption and influence peddling. In this respect, the Group is committed to zero tolerance of corruption and influence peddling; launch of the update of the corruption risk assessment legal entities of the Group and the corresponding definition of specific corrective plans; launch of a third party onboarding tool integrity review system with a gradual roll-out planned until the end of 2023 (“My TrustedPartner”); continuation of the employee training and awareness-raising programme to ensure that employees are familiar with the procedures, particularly in the functions most exposed to this risk; an internal and external alert system, available to employees and stakeholders, also helps to counter this risk. Appropriate disciplinary measures are taken in consultation with the Human Resources Department and Executive Management when necessary; a regular internal audit plan. The Internal Audit department is responsible for the evaluation of the measures implemented. This department ensures that compliance related incidents are identified and addressed. For more information on the Group’s preventive measures regarding corruption, see sections 6.1 “Governance and organisation” and 6.2 “Ethics, prevention and anti-corruption” in Chapter 6.
Exclusive Networks operates in a complex and evolving legal and regulatory environment. The Group is subject to various national legislations, as well as to international standards. This is the case, in particular, for anti-corruption and money laundering regulations. In this respect, Exclusive Networks has identified two main corruption risks due to its geographical location and its relationships with partners and stakeholders: the expansion of its activities in countries where the corruption perception index is high according to the ranking established by Transparency International, particularly in Asia and Africa; the Group’s model, which is based on a network of partners made up of resellers and distributors, represents an additional risk for the Group, because it is responsible for the activities carried out on its behalf. Non-compliance with the law, as well as unethical behaviour, could expose Exclusive Networks Group and/or its employees to investigations, administrative or judicial proceedings, criminal or civil sanctions and additional penalties (such as exclusion from government contracts). These investigations or possible convictions could also have financial, reputational, operational and/or legal consequences for the Group.
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Exclusive Networks
Sustainability Report 2022
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