Exclusive Networks // Sustainability Report 2022

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

This project has made it possible to map the corruption risks of each operational subsidiary. All the results are currently being consolidated and will lead to the updating of the action plan considering to the main net risks, taking into account the effectiveness of the measures already in place.

 presentation and validation with each Country Manager of the matrix and remediation plan by country (2023);  presentation and validation by the Executive Committee and the Group Audit Committee of the matrix and remediation plans consolidated at Group level (2023).

Actions

2022 results

Develop or update the corruption risk matrix for all the Group’s operating companies Involve operational managers in the identification and prevention of corruption risks and take their vision into account Involve employees from all functions and reporting levels in the working groups to get a hands-on view

59 corruption risk matrices completed

44 individual interviews conducted with Country Managers

463 employees participated in the risk assessment

[GRI 205-1-b]/SDG 16.5

ensure that third parties meet the company’s ethical requirements. The tool is accessible to all employees and allows the company to quickly identify if there are any red flags, risk of corruption or ethical misconduct. When the tool detects red flags, the third party is considered to be “at risk”: additional checks are then initiated and submitted to the Risks & Compliance department and the relevant Country Manager for validation. This new third-party integrity review is being rolled out progressively and will continue in 2023.

Third-party due diligences All third parties with whom the Exclusive Networks Group is planning to initiate or continue a business relationship are subject to a specific and appropriate onboarding process, aimed at determining the level of the potential corruption risk of each third party, and implementing the necessary mitigation measures to ensure compliance with the ethical standards of the Group. In 2022, the Group evolved the due diligence process for third parties and deployed a new dedicated tool to

Action

2022 results

Assess the integrity of third parties with whom the Group has or will have business relations [GRI 205-1-a]/SDG 16.5

4,968 third parties assessed in the integrity review tool

141 third parties with a medium or high risk formally approved the “Ethics & Code of conduct for third parties”

[GRI 205-2-c]/SDG 16.5

The Exclusive Networks Group has set itself the goal of completing 100% of the due diligence on high-risk third parties in 2023.

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Exclusive Networks

Sustainability Report 2022

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