LEGRAND_REGISTRATION_DOCUMENT_2017

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CORPORATE SOCIAL RESPONSIBILITY (CSR)

Acting ethically towards Society

4.3 – ACTING ETHICALLY TOWARDS SOCIETY

Social responsibility applies to all the partners with which the Legrand Group interacts. This interaction must take place with the utmost respect for ethical principles, particularly in terms of business practices and purchasing policy. As a socially responsible organization, the Group is also committed to helping as many people as possible gain sustainable access to electricity.

4.3.1 – Acting ethically

The Group’s commitments One of the basic tenets of Legrand’s social responsibility is to abide by ethical principles. This approach covers the themes of compliance with competition rules, the application of best business practices (particularly on anti-corruption), the prevention of conflicts of interest and management of fraud risks, the observation of international embargoes and sanctions, and the prevention of money laundering and terrorist financing. These themes are reflected in the four pillars of the Group’s compliance program. Concerning compliance with the competition rules, the Group prohibits formal or implicit agreements between companies, whether horizontal between directly competing companies, or vertical between players at different levels in the economic chain. Such agreements may have the effect of distorting or reducing competition. The Group also prohibits the exchange of commercially sensitive information with competitors and abuses of dominant position that could lead to the closure of the market to the arrival of new players or exclude existing competitors, to the detriment of customers and end consumers. The Group defines corruption as unlawfully or inappropriately offering an advantage in return for a favor or advantage, or to influence someone’s actions. Legrand prohibits corruption in its dealings with public authorities, customers, suppliers or other partners (by bribes, commission or illegal payments, for example). The Group is extremely attentive to other situations that might prove legal or illegal, depending on the circumstances or the local legal context, such as facilitation payments and lobbying for example. In addition, strict procedures apply to business gifts, hospitality and entertainment. Donations to charities are also regulated. The Group defines fraud as the willful use of deception by one or more members of management, individuals in charge of governance, employees or third parties to obtain an undue and/ or unlawful advantage. The notion of fraud includes various concepts: first, the misappropriation of assets by an employee and any attempt to derive a personal benefit from his or her employment at the expense of the company; second, non-

compliance with accounting standards and communication to the Group of financial data that is known to be materially false; third, failure to obey the law. Fraud is strictly prohibited within the Legrand Group. The Legrand Group does not tolerate non-compliance with the laws on export control or trade embargoes against a country or individuals,particularlyfinancial andeconomic sanctions imposed by the United Nations Security Council, the U.S. Government and the European Union. Furthermore, each Group subsidiary has a duty to monitor compliance with national regulations that may have been enacted by some countries and that impose economic, trade or financial sanctions against certain states. Lastly, Legrand is committed to enforcing anti-money laundering legislation and seeks to have reputable customers with legitimate operations, financed by lawfully obtained funds. The Group’s commitments and rules regarding business ethics are enshrined in its guidelines and charters. 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. In terms of trade relations, Legrand’s Competition Charter sets out the best practices to adopt and explains how to abide by competition rules. These documents supplement the Group’s Charter of Fundamental Principles. 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 Group demonstrates its commitment in these areas through two priorities in its CSR roadmap: employee awareness and training, and checking that its compliance program is properly implemented. 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,

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REGISTRATION DOCUMENT 2017 - LEGRAND