Exclusive Networks // Sustainability Report 2022

Risks and opportunities Internal control and risk management

2.2.5

Internal control and risk management environment

Group’s activities, its environment and risks, and will be enriched with the feedback received from employees and its application by the Group and the countries. This Country Manual is available in the Finance and Risks & Compliance sections of the Group’s intranet. Code of conduct The Group’s ethical principles are set out in the Code of Conduct, which contains the Group’s commitments and rules of conduct towards its main stakeholders, namely employees, vendors, business partners, the environment and civil society. This Code of Conduct must be signed by all Exclusive Networks Group employees, on an electronic platform, after they have answered an electronic questionnaire as part of a training course. Group ethical principles Honesty and integrity, fairness of commercial practices, data confidentiality, professional behaviour, professional skills and added value, social respect, environmental care. Delegation of authority Delegation of authority matrices, specific to each region, define the authorisations required to enter into transactions and to carry out the Group’s key activities. These delegation of authority matrices defined, depending on the issues at stake, three levels of decisions corresponding to the three levels of the Group’s organisation (local at entity level, regional and at Group level) according to the nature, the strategic issue and the amount of the impact at stake.

The internal control and risk management system is based on a decentralised organisation with a clear definition of responsibilities, notably through job descriptions, delegations of authority and widely communicated policies and procedures. It includes principles and values governing the behaviour and ethics of all the Group’s employees, presented in a set of rules and procedures. Rules and procedures of the Group Country Manual The Internal Control department has drawn up a collection of internal control guidelines and procedures called the Country Manual, which was distributed to all employees in July 2022. This Country Manual is applicable at all levels within the Group. Each Country Manager is responsible for ensuring that it is properly applied and distributed. The Country Manual defines the main principles and fundamental rules on which the Group’s activities are based, and specifies the Group’s expectations and requirements with regard to processes and controls (including their formalisation) for each of the key cycles, particularly in the following areas:  the Group’s fundamental principles, governance and organisation;  rules and guidelines for the sales, purchasing, import/export, inventory and logistics, treasury, fixed assets, tax etc.;  guidelines for the Group’s human resources, marketing, communication and IT management. The Country Manual was developed jointly by the Internal Control department and each of the relevant departments, with input from financial managers and directors at both local and regional levels. It will be updated periodically to take account of changes in the

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Exclusive Networks

Sustainability Report 2022

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