Exclusive Networks // Sustainability Report 2022

Ethics, fair practices, compliance and security Ethics, prevention and anti-corruption

Through its internal policies and procedures, the Group establishes the guiding principles applicable to all its subsidiaries, intended to provide employees with the

rules of conduct and the behaviour to adopt in terms of business ethics and combating corruption. The compliance programme is structured as follows:

The whistleblower hotline allows all Group employees and partners to report any behaviour that seems to go against these rules

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Procedures specify the rules applicable to all entities

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The Code of Conduct is the framework of the compliance documentation

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The policies and procedures that make up the Exclusive Networks Group’s anti-corruption programme include the Code of Conduct, the Conflict of Interest Policy, or the Gifts and Entertainment Policy. All procedures and policies are addressed individually to each employee as soon as they are hired via the Group’s e-learning platform. Employees complete an acknowledgement of receipt and a questionnaire to ensure that they understand them. In order to strongly address the risk of corruption or non-compliance with internal business ethics rules and procedures (see Chapter 2 and section 2.3), the Exclusive Networks Group regularly updates and evolves its compliance programme, to take into account its corruption risk mapping as well as new regulatory and legal obligations. In 2022, the Exclusive Networks Group updated and completed its corruption risk management system on three major dimensions:  risk matrix;  third party due diligence;  employees’ training. [GRI 3-3-c]/SDG 16.5

Update of the corruption risk matrix The Group’s activities and processes are subject to regular risk assessment (see Chapter 2), which aims to provide appropriate and proportionate remediation solutions to detect and prevent these risks. In 2022, Exclusive Networks undertook a complete overhaul of its corruption risk matrix, in accordance with the recommendations of the supervisory authorities. This major project covers all of the Group’s operating companies. Supported by all the Group’s functions and an independent consultancy firm, the methodology was designed taking into account the recommendations of the French Anti-Corruption Agency and best practices according to international standards. This 8-month project is being carried out according to the following process:  interviews conducted first with the Country Managers and Ethics Champions, to enable the preparation of workshops for all companies, gathered by country or region;  country-specific workshops, with the participation of employees from various functions and reporting levels, each of them aiming to identify the main risks, processes and controls in place, and possible actions;  summary of the working groups and preparation, by company and then at Group level, of gross and net risk matrix and remediation plans;  kick-off with by the Executive Committee;  inventory of risks and controls in place;

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Exclusive Networks

Sustainability Report 2022

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