LEGRAND / 2018 Registration document

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The program has four parts: W compliance with competition rules; W efforts to combat bribery and influence peddling;

Focus: Every country director has signed a letter of commitment pledging support for the compliance program. Since June 2015, the commitment of General Management has cascaded down to the Group’s various departments and countries, which must sign a letter pledging compliance with the rules on business ethics. The letter is relayed by the countries, departments and SBUs at the highest level of their organization. Reflecting the two priorities of the CSR roadmap, the letter confirms the signatories’ commitment to training local staff and effectively implementing the rules and procedures of the Group’s compliance program. They reaffirm their deep commitment to deploying the program’s initiatives at the local level, thus ensuring that the right messages are conveyed within the organization. The ethical business rules also apply to the Group’s suppliers and subcontractors. Legrand expects them to adhere to the sustainability standards contained in its Ethical Supplier Relations Code. Compliance with these rules is a major factor in supplier selection and management. Organization of business ethics within the Group Business ethics is the responsibility of the Group Legal and Compliance Department. The Group Legal Department has a network of country Compliance Officers tasked with ensuring that the compliance program is properly implemented. The Group’s business ethics approach therefore closely involves General Management and the Group’s various departments, which thus contribute to strengthening the established rules and to developing awareness, training and monitoring activities. The Group Compliance Committee reports annually on its work to the Group Risk Committee, which in turn reports to the Audit Committee and the Board of Directors. The Group’s Compliance Officer works directly with these Committees. Risk is managed by the Group Audit and Internal Control Department. Monitoring procedures and policies associated with compliance are also fully integrated within the Group’s internal control program. Compliance risks are thus assessed according to an occurrence/impact matrix. Group Compliance Program One of the basic tenets of Legrand’s social responsibility is to abide by ethical principles. The Compliance program, set up in 2012, is based on the regulatory and legislative framework, the best practice rules defined by the Group, and an analysis of the risks relating to business ethics for the Group.

W prevention of conflicts of interest and management of fraud risks; W observation of international embargoes and sanctions and the prevention of money laundering and terrorist financing. The Group’s commitments and rules regarding business ethics are enshrined in its guidelines and charters. W The Guide to Good Business Practices illustrates how the Group views and conducts business; it sets out the values shared by the Group’s employees. It therefore reflects General Management’s commitment to unreservedly and unequivocally involving the Legrand Group in the prevention and detection of corruption and fraud. Its aim is to foster a culture of compliance. The Guide defines and illustrates situations and behaviors that could constitute corruption or fraud and that must be prohibited. Behaviors that are contrary to the commitments and principles of the Guide may lead to penalties, as defined by the Group’s internal procedures, or any other local measure. W In terms of trade relations, Legrand’s Competition Charter sets out the best practices to adopt and explains how to abide by competition rules. W These documents supplement the Group’s Charter of Fundamental Principles, which are annexed to its rules of procedure and enforceable against Group employees, which must comply with the rules they contain. The Charter of Fundamental Principles is supplemented by a system of sanctions if the rules are breached. All Group guides and charters apply to all Group employees and are adopted wherever the Group operates, even abroad, without prejudicing the application of stricter laws where relevant. All Group employees must adhere to these rules, particularly if they are in contact with the Group’s customers, suppliers or business partners. All these documents can be found at www.legrand.com . The Compliance program is organized around five stages: 1. A strong commitment from the Group’s General Management, supported by local Departments which sign a letter pledging to comply with the rules on business ethics. The program translates into local action plans based on the priorities set and a specific communication plan; the Country Compliance Officers are responsible for overseeing the program and report to the Country Compliance Committees on the achievement of targets. 2. The Group’s compliance risk analysis methodology: Legrand has identified compliance risks within the four pillars of the program, namely competition, anti-corruption, fraud and embargoes and money laundering. The risks are the subject of an annual self- assessment by the Group’s various countries and entities as part of the internal control process. The Legrand Group maps its compliance risks. This provides insights into the factors that




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