LEGRAND_REGISTRATION_DOCUMENT_2017

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CORPORATE SOCIAL RESPONSIBILITY (CSR)

Acting ethically towards Society

Optimization of the compliance program in line with the Sapin II Law

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 the employees. The training offered by the Group, on e-learning, anti-corruption and webcasting for example, is received by the employees concerned (please refer to section 4.3.1.1.). 5. Theapproach for internal audit,implementationof actionplans in response to the risks identified and for 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, please refer to section 3.2.2.). In addition, business ethics is included in the internal audit programs. Improvements and corrective actions Cases of non-compliance are referred to the Group’s Legal and Compliance Department, as well as to Group Internal Audit by various means: audits or self-assessments of the entities, the whistleblowing mechanism for ethics and fraud, reporting lines, Compliance Officers or ethics representatives. The Group undertakes to communicate on any non-compliance. In line with this principle, the Group does not currently consider there to be any extraordinary circumstances, or governmental, legal or arbitration proceedings, that have a significant probability of materially affecting, or that have recently affected, its financial position, assets or business. Five cases of proven fraud were recorded in 2017, 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 have been systematically implemented to address the risks identified. In accordance with the Group’s governance principles, these cases have been reported to the Group Audit Committee. In 2017, 7 ethics and fraud 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 respect of which a Group subsidiary was acquitted by a trial court in June 2015. In these last two matters, no major financial or non-financial sanctions have been applied to the Group. The compliance program set up by the Group and described above is a tool aimed at preventing the occurrence of such risks.

In 2017, the Group evaluated its compliance program with regard to the requirements of the French Sapin II Law (Law no. 2016- 1691 of December 9, 2016) on the prevention of corruption and influence peddling. (i) Commitment of the General Management of the Legrand Group to preventing and detecting corruption The Group’s General Management is uncompromising when it comes to behavior that runs counter to business ethics in general, and any risk of corruption or fraud in particular: no form of corruption or fraud is tolerated. This zero-tolerance approach is the cornerstone of the policy for the prevention and detection of corruption. It signals the commitment of General Management to ensuring that behaviors are consistent with business ethics and obey strict rules. (ii) Guide to Good Business Practice This reflects the commitment of the General Management 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. It applies to all employees and is adopted wherever the Group operates, even abroad, without prejudicing the application of stricter anti-corruption laws where relevant. The Guide defines and illustrates situations and behaviors that could constitute corruption or fraud and that must be proscribed. 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. (iii) Whistleblowing mechanism Legrand has introduced a mechanism for receiving reports from its employees concerning the existence of conduct or situations contrary to the Group’s charters and guides, in addition to reports from employees and other external and occasional service providers about circumstances and risks relating to corruption and influence peddling. The Group’s whistleblowingmechanism 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. (iv) Risk mapping The Legrand Group maps its compliance risks. This provides insights into the factors that 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

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REGISTRATION DOCUMENT 2017 - LEGRAND