LEGRAND_REGISTRATION_DOCUMENT_2017

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CORPORATE SOCIAL RESPONSIBILITY (CSR)

Acting ethically towards Society

2017 achievement: In 2017, a further 593 people received training via the Group’s e-learning in business ethics, in addition to the 2,284 people trained in 2014 and 2016. This gives a total of 2,877 people, against a cumulative target of 2,200 at the end of 2017 (these 2,877 employees are added to the 2,500 employees who received training prior to 2014). As a result of this training, the achievement rate for this priority is 131%. Since 2015, the Group’s subsidiaries have also arranged local training – in addition to the online courses offered by the Group – to make the process of training in business ethics even more efficient.

Training covers compliance in general, its challenges and forms, and the applicable legal requirements. It also highlights the commitment made by General Management and its application through the compliance program, and summarizes the Group’s rules of conduct and best practices, the behaviors to be adopted, the role and responsibilities of each person when faced with corruption or fraud, and the applicable sanctions where appropriate. The content of the training is tailored to the type of corruption risk, the duties performed, and the geographical region concerned. It is revised regularly, as and when the risk map is updated. Training is organized via an e-learning platform by a recognized service provider or on the basis of classroom or online training modules developed by the Group in the language of the employees concerned. In 2017, 593 people successfully completed the e-learning course on anti-corruption organized by the Group. A further 10,000 employees were trained in compliance locally (usually face to face). R 4.3.1.2 VERIFYING THE APPLICATION OF THE GROUP’S COMPLIANCE PROGRAM Group priority 2014-2018 To cover 100% of Group sales through a compliance program monitoring scheme. Key performance indicator: the rate of implementation of the compliance program. Annual targets:

2014 2015 2016

2017

2018

Target achievement rate*

273% 198% 152% 131%

*

Calculated against annual targets.

Communication and training In order to raise awareness of the behaviors to be adopted and to avoid improper internal and external solicitation, a specific communication and training plan is implemented locally by the Group’s various entities. The communication plan addresses the Group’s commitments concerning the prevention and detection of corruption and fraud, the various aspects of the compliance program, and the risk training policy. It conveys the Group’s position as set out in the various guides and charters. The information and materials are translated into official local language(s) to facilitate their comprehension and adoption by local teams in the various countries. Communication tools (practical guides, presentations, risk assessment questionnaires) are available on the Group intranet for employees and Compliance Officers to facilitate their work in the field of business ethics. Some of these guides can be found on the website at www.legrand.com . Each year, the Group provides training for exposed staff in charge of at-risk processes: Companymanagers, Country heads, Departments and SBUs, Chief Financial Officers and other people dealing with third parties (sales, purchasing, etc.). They are the main contributors to the prevention and detection of corruption and fraud. It is therefore necessary that they clearly identify the behaviors to be adopted and their roles and responsibilities when faced with situations of non-compliance. They must encourage the broad dissemination of the commitments made by General Management, ensure that their staff embrace these, and establish a common knowledge base. In addition to and regardless of their risk exposure, the Group educates all its employees on the rules of compliance. The Group’s different areas set up their own training adapted to their particular environment and risks.

2014 2015 2016

2017

2018

Rate of implementation of the compliance program to be achieved for subsidiaries: W the most exposed and the most significant

70% 90% 90% 100% 100%

W others

50% 70% 80% 90% 100%

2017 achievement: At the end of 2017, implementation rates for the compliance program were 87% for the Group’s eight largest countries and 81% for all other reporting areas. The Group integrated the regulatory framework of the Sapin II Law into its controls at the end of 2017. This strengthened the requirement over all key stages of implementation of the program and, in particular, highlighted the need for documentary evidence of the actual implementation of these practices, leading to underperformance against the initial target set. Deployment and monitoring will continue over the next few years to confirm that the compliance program is being implemented on schedule.

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REGISTRATION DOCUMENT 2017 - LEGRAND