Exclusive Networks // Sustainability Report 2022

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

 by the Risks & Compliance Department, when a new Chief Financial Officer or Country Manager is onboarded. Training courses organised by the Risks & Compliance department are adapted to the functions of the participants (marketing, finance, Executive Management or Ethics Champions) whenever possible. The courses organised by the Ethics Champions are usually for all employees in the region, based on the training materials prepared by the Risks & Compliance department.

Communication, awareness and training actions Since 2015, compliance training has been provided several times a year:  by the Risks & Compliance department, during seminars organised face-to-face with the participation of the Group’s Chief Executive Officer at the beginning of the year, and more occasionally during the year, during face-to-face or online meetings;  by the Ethics Champions, directly with their local teams, after having themselves been trained by the Risks & Compliance Department;

Action

2022 results

Train our employees to Ethics and combating corruption 45 training sessions organised

13 Onboarding* sessions conducted with the Internal Control department One Ethics Champions training course

* Onboardin g: integration process of new Financial Directors or Country Managers. The Exclusive Networks Group has set itself the objective that 100% of its employees will have certified (1) the Code of Conduct by 2025. [GRI 205-2-e]/SDG 16.5

This system supplements other reporting channels, such as the line manager, the Human Resources Department, the Legal Department, etc. All reports are treated confidentially under the supervision of the Group’s Ethics Officer, ensuring that there are no sanctions or retaliatory measures for any person who makes a report in good faith. This principle is guaranteed by the Group and reaffirmed in the whistleblowing procedure.

Whistleblowing system In accordance with the whistleblowing procedure, employees are invited to notify the Group of any facts that may violate the principles of the Code of Conduct, particularly in the case of corruption. To this end, the Exclusive Networks Group has set up a whistleblowing system in all the countries where it operates, allowing each employee and external persons to send a report in a confidential and secure manner, accessible from the Group’s websites.

Action

2022 results

Establish a procedure and system for collecting and handling alerts, enabling employees and third parties to report situations that are contrary to the Code of Conduct or that may constitute a crime, offence or harm to the general interest.

62% of employees certified in the whistleblowing procedure* Four alerts received on the platform, three of which were admissible

* Certified: refers to employees who have acknowledged receipt of the procedure and have passed the comprehension test. All alerts are internal, and no alerts from external stakeholders have been received.

[GRI 2-26]

1 Certified: refers to employees who have acknowledged receipt of the procedure and have passed the comprehension test.

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Exclusive Networks

Sustainability Report 2022

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