Exclusive Networks // Sustainability Report 2022

Ethics, fair practices, compliance and security Compliance governance and organisation

Furthermore, in response to Article R. 225-105 of the French Commercial Code and for the 2022 financial year:  the Exclusive Networks Group’s strategic orientations in terms of social, societal and environmental responsibility are defined by the Board of Directors, upon the proposal of the Executive Committee. Implementation is carried out locally at the country level.  the Exclusive Networks Group has no provisions or guarantees for environmental risk;  the resources allocated by the Group to the prevention of environmental risks and pollution are not significant.

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Ethics, fair practices, compliance and security

6.1

Compliance governance and organisation

In the conduct of its business, the Exclusive Networks Group promotes a culture of integrity and compliance, based on respect and adaptation to new standards and applicable legislation, both in France and in the

countries where it carries out its activities and where its employees operate. A dedicated organization has been in place since 2013 to develop and manage the compliance programme.

Governance and organisation of compliance

Corporate

Local

Management

• Board of Directors – Audit and Risk Committee • Executive Committee • Regional Risk Committee The management team works closely with all the Group’s functions to validate orientations and action priorities. It ensures the development and monitoring of the programme.

• Country Managers Are in charge of the deployment and respect of the compliance programme in their legal entities.

• Risks & Compliance Department • General Counsel & Group Compliance Officer • VP Risks and Compliance • Risks and Compliance Director • APAC Risks and Compliance Manager • Risks & Compliance Analyst Oversees the design of the compliance programme and leads and coordinates its implementation across the Group’s business processes and subsidiaries.

• Ethics Champions Work with the Risks &

Compliance Department on the implementation and proper understanding of the compliance programme.

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Exclusive Networks

Sustainability Report 2022

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