LEGRAND_REGISTRATION_DOCUMENT_2017

CORPORATE SOCIAL RESPONSIBILITY (CSR)

Acting ethically towards Society

business ethics and submitting policies proposed as part of the compliance program to him for approval. The Group’s business ethics approach therefore closely involves head office departments, which thus contribute to strengthening the established rules and to developing awareness, training and monitoring activities. 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. Risk is managed by the Group Audit and Internal Control Department. The Fraud and Alerts Committee deals with cases of non- compliance under the supervision of the Group Compliance Officer. Group subsidiaries locally implement the rules defined and adapt them according to local laws and regulations. The Country Chief Financial Officers have been named as Country Compliance Officers and ensure that all entities within their scope implement the program. Group compliance program The Group’s compliance program covers all aspects of business ethics: 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. This program is organized around five stages: 1. A strong commitment from the Group’s General Management, echoed by local divisions by signing 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. 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). Audits are performed to identify inappropriate practices. These might, for example, concern registers of guests and expenses, purchasing processes, or agreements with business partners.

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 local deployment of the program’s actions, thus ensuring that the right messages are conveyed within the organization. This letter is published on the local intranet of each subsidiary and department or SBU. The ethical business rules that the Group applies do not stop at its subsidiaries: they also apply to its 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. The Group’s compliance guide sets out the rules and obligations to be observed by all Group employees. The General Management has affirmed its strong commitment to business ethics by signing the Global Compact and by adhering to the main universal principles and the international reference documents, including: the Universal Declaration of Human Rights and additional compacts; the United Nations Sustainable Development Goals; the guiding principles of the OECD on the fight against bribery of foreign public officials in international business transactions; the guiding principles of the OECD for multinational companies; the United Nations Convention against Corruption; transnational or national legislation and regulations on competition and anti-corruption. Organization of business ethics within the Group Business ethics is the responsibility of the Group Legal and Compliance Department. The Group Executive VP Legal Affairs also acts as Group Compliance Officer. Her role is to limit the risks of non-compliance by defining a framework designed to enforce the rules and regulations on business ethics. The Group has set up a compliance program 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 (please refer to section 4.3.1.2 of this Registration Document). The program is coordinated by the Group Compliance Committee. This multi-disciplinary internal committee brings together the managers of head office departments (HR, Group Purchasing, Group Operations, Finance, Export and Strategy) and meets quarterly. Its two main tasks consist of defining core areas of concern, and monitoring the results of these actions. 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. She has direct access to the Group CEO, advising him on matters relating to

04

83

REGISTRATION DOCUMENT 2017 - LEGRAND