ANTI-CORRUPTION CODE OF CONDUCT

KEY ACTIONS

IN PRACTICE

DO…

DON’T…

• refer to and apply the third-party assessment and integrity process before entering into any commitment; • identify the risks arising from each relationship, and set out appropriate measures for managing such risks; • monitor the application of risk management measures and compliance with contractual clauses throughout any relationship with a third party; • report any situation of concern relating to a third party to your Compliance Officer. Q You are looking to boost the Group’s position in the Middle Eastern market. You ask a local consultant to analyse the market and market opportunities. Do they have the right skills for this role? Are they likely to harm the Group’s reputation? Will the Group be liable in respect of any third parties? A Using local consultants or intermediaries is a high-risk situation. Always apply the third-party integrity assessment process. If you are unsure of anything, contact your Compliance Officer. CASE STUDIES

• act as an intermediary in contravention of the Group’s values and principles as set out in this Code of Conduct; • call on an intermediary to influence a decision in contravention of the provisions of this Code of Conduct or of current laws and regulations; • enter into a risky business relationship or contract without first carrying out a third party integrity assessment.

Q You have identified a local company as a potential joint venture partner. Has the company every been involved in or convicted of corruption? Have its senior managers been convicted in the past? Are its shareholders under economic sanctions? A Use the third-party assessment process to answer these questions, thus protecting the Group’s reputation and interests. If you are unsure of anything, contact your Compliance Officer.

LAGARDÈRE - ANTI-CORRUPTION CODE OF CONDUCT • 9