LEGRAND / 2018 Registration document

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CORPORATE SOCIAL RESPONSIBILITY AND DECLARATION OF EXTRA-FINANCIAL PERFORMANCE

ACTING ETHICALLY TOWARDS SOCIETY

could affect the Group’s business and performance, enabling it to better understand and control these risks, and to guard against the legal, human, economic and financial consequences that could result from a lack of vigilance. Its aim is to ensure that the Group’s compliance program is effective and appropriate. Compliance risk mapping is evaluated annually and updated on the basis of changes in the business or in the regulatory or economic environment. 3. Clear policies and control mechanisms: these must be applied locally and meet the Group’s requirements. They are supplemented by practical guides tailored to the local context and designed to define the Group’s rules and tools (e.g. do’s and don’ts). 4. Training and communication: a communication plan promotes the program, while the Group’s messages and tools are translated into the local language and circulated among employees. The training offered by the Group, on e-learning, anti-corruption and webcasting for example, is received by the employees concerned (see section 4.3.1.1.). 5. The approach for internal audit, the implementation of action plans in response to the risks identified, and continuous progress: each Group subsidiary undergoes a self-assessment of its internal control system which includes checks on compliance with business ethics (for more information, see section 3.2.2.). In addition, business ethics are included in the internal audit programs. Whistleblowing Legrand has introduced a mechanism for receiving alerts from its employees, and from external and occasional employees and service providers, concerning the existence of conduct or situations contrary to the Group’s charters and guides. The Group’s whistleblowing mechanism is accompanied by procedures for the protection of whistleblowers. These are designed to protect the rights of whistleblowers and, more importantly, their identity, as well as the details of the alleged events and the people implicated. Four cases of proven fraud were recorded in 2018, plus multiple attempts to commit fraud from outside the Group, all of which were foiled. None of these cases posed a significant threat to the subsidiary concerned or to the Group. Corrective action plans were implemented in all cases to address the risks identified. In accordance with the Group’s governance principles, these cases were reported to the Group Audit Committee.

In 2018, fewer than 10 ethics alerts were reported to the Group. None of these alerts represented a significant risk. They were examined and handled in accordance with Group procedures as detailed in the Charter of Fundamental Principles and on www.legrand.com . No legal action is pending against the Group for anti-competitive behavior, violations of antitrust laws or monopolistic practices. No legal action is pending against the Group for non-compliance with laws and regulations on business ethics, except for the case concerning the implementation of the UN Oil-for-Food program. In that case, the Paris Appeal Court found against Legrand SNC on February 15, 2019, overturning the first-instance judgment, and found it guilty of active bribery of a foreign public official. A suspended fine of €30,000 was also levied on Legrand SNC. The Paris Appeal Court expressly stated that this judgment would not go on the criminal record of the company, and in accordance with French law, this means that it is not prohibited from bidding on public procurement contracts. As of the date on which this reference document was filed, Legrand SNC had, as a protective measure, lodged an appeal against that judgment with the Cour de Cassation. The Group demonstrates its commitment in these areas through two priorities in its CSR roadmap: employee awareness and training, and efforts to check that its compliance program is properly implemented. R 4.3.1.1 AWARENESS AND TRAINING IN BUSINESS ETHICS Review of the 2014-2018 Group priority Train an additional 3,000 employees in business ethics (anti-corruption, fraud prevention, compliance with competition rules, conflicts of interest, etc.). Key performance indicator : the number of employees trained in business ethics during the year. Annual targets:

4

2014 2015 2016 2017

2018

Total number of employees trained in business ethics*

400 900 1,500 2,200 3,377

* Over the roadmap period and thus not taking into account employees trained previously

101

LEGRAND

REGISTRATION DOCUMENT 2018