PSA - 2019 Universal Registration Document

DECLARATION ON EXTRA-FINANCIAL PERFORMANCE Societal commitment to sustainable development

In 2018, a comprehensive anticorruption programme including elaborationof a Group risk mapping, validated by the Executive Committee,roll out of this Code in all countries,implementationof the whistleblowingsystem,trainingof around17,700 people,a new screeningtool for furtherenhancementof Due Diligenceprocessof partners, etc.are beingrolledout (see 6of CSRReport).Due to the co-determination requirements,negotiationswiththeOpel/Vauxhall GermanyWorksCouncilcauseda delayof the Anti-corruption code of conductroll out for this unit as well as anti-corruptiontraining campaignlaunch.Uponobtainingthe approval,the Anti-corruption Codeand the trainingcampaignweresuccessfully launchedin 2019. 4,073 OVGermany employees took the training. In July 2019,the new Due Diligencepolicywas announcedand the implementation wastartedin all the Group’s locations worldwide. A set of preciseeducationalinternalcontrolprocedureswhichdeal with the major themes of business ethics and compliance (anti-corruption,compliancewith competition law, Data Privacy, exportcontrol)are availablefor the differentdepartments.As part of its internal control measures,the Group’sstructuringprocesses are assessed to ensure that they incorporate, in particular, the principles intended to prevent corruption: segregation of tasks, doubleor triple validation,propertreatmentof conflictsof interest, verificationof partnerintegrity, declaration of gifts, etc. In 2010, the Group createdan Ethics and ComplianceCommittee, which reports to the Executive Committee.It is chaired by the GroupGeneralSecretaryandbringstogethertheDirectorof Human Resources,the Head of ProtectionAudit and Risk Departmentand the Chief Legal Officer.If a case of non-complianceposes a major risk to the Company,this committeealerts the ManagingBoard, which then decides whether to inform the Supervisory Board’s Finance andAudit Committee. The Ethics and ComplianceCommitteerelies on five compliance officerswho are taskedrespectivelywith ensuringcompliancewith competition law, anti-corruption law, data privacy, vehicle certificationcomplianceand exportcontrol.Ledby the Chairmanof the Ethics and ComplianceCommittee,to which they report, they have a networkof internalcontroland risk coordinators(ICRCs)to ensurethe rolloutof the complianceprogrammeof which they are tasked withverifying. The METRIC (Managementof Ethics, Risks, Internal Control and Compliance)teamoverseenby the CorporateSecretaryassiststhe Compliance Officers and supervises the ICRCs. These 23 internal control and risk coordinators (ICRC) – one representativeper departmentreporting to the Chairman of the Managing Board – are, under the leadership of their Head of department,who stays responsiblefor ethicsand compliancein his department,ICRCs are tasked with ensuringdeployment,creating and monitoringthe corruptionrisk mappingand the relatedaction plans, and for ensuring compliance of the operations. They are supportedby the Fraud DetectionManagers,who are responsible for fraud risk mapping (including external fraud), analysing deficiencies, adapting corrective and prevention measures and leadingactionplans to fight againstfraud.The anti-fraudsystemis structured, under the control of the Ethics and Compliance Committee, around processes for prevention, detection, investigation and treatment,aswell ascontinued improvement. Group ExecutiveManagementare called to evaluate, within their sphere of activity, by means of annual METRIC (Managementof Ethics,Risks, InternalControland Compliance)reviews,the risks of fraud and their own practiceswith regardto the Company’sethics GOVERNANCE, WHISTLEBLOWING AND MONITORING SYSTEM

andcompliance.Reportingdirectlyto theirHeadof departmentand led by the networkof InternalControland Risk Coordinators,they are responsiblefor applyingthe Anti-corruptionCodeof conductin their area and for implementing suitablepreventionsystems. Finally, the Protection, Audit and Risk ManagementDepartment checks that the processeshave actually been implemented.Each year it conductsseveralComplianceaudits.Each audit of a site or subsidiary includes a section focusing on risk analysis. In 2018, Groupe PSAconsiderablystrengthenedits whistleblowing system by implementing,with the help of an external supplier, a global alert system. This provides all Group employees with a completelysecure means, to report their concerns via a website. These reportsrelate to actionsthat are contraryto law and could have animpacton theGroup’s reputation, its businessor results. The systemis designedto ensurethat proceduresare in place and efficient processing of these reports, while ensuring complete confidentiality. (consolidatedGroup,excludingFaurecia) One case of non-compliancewith competitionlaw was reportedin 2019: in July 2015, the Spanish Markets and Competition National n Commission ruled that 21 car manufacturers had exchanged sensitive commercial and strategic information. The Spanish subsidiariesof the Peugeot Espaňa Group and Citroën Espaňa were fined€15.7 millionand €14.7 millionrespectively,whileOpel Españawas €22.8 millionfined as well. The Group exercisedits right of appeal before the Spanishcourts and decidedto seize the final courtof appeal on the three files; in December 2015,the French competition authority handed n down overall fines of €672.3 millionto courier companies, of which €30.6 millionon GEFCO, for breach of competitionlaw. Groupe PSAis involved because GEFCO was a wholly-owned subsidiary at the time of the events. Both companies have appealedthis decision. The proceedings are ongoing; on 9 January 2019, the Italian CompetitionAuthority issued a n decision concerning its investigation of alleged exchange of sensitiveinformation,partly throughtrade associations,between captivefinancialcompanies.BanquePSA Finance,who operated in Italy througha branchprior to the creationof its currentjoint venture with Santander, BANCA PSA ITALIA SpA and Opel Vauxhall Finance Italy (jointly with GM Company) have been respectivelyfined €38.5 million,€6.1 millionand €10 million.BPF, BANCA PSA ITALIA SpA and Opel Vauxhall Finance Italy appealedthis decision. There wereno cases ofcorruptionreportedin 2019. Tax policyof the Automotive division Compliantwith the Code of Ethics, based on long-termobjectives and in line with its global strategy and targets, the Group’s tax policy complieswith rules of transparencyand responsibility.It is based onthe following principles: fiscal policy always complies with applicable laws and 1. regulations.It is guidedby relevantinternationalstandards(for example OECD Guidelines).Groupe PSAaims to comply with the spirit as well as the letter of the law. Tax filings and paymentsas well as book-keepingand tax reportingare carried out in compliancewith all local regulations in the countries where theGroupoperates; RESULTS IN 2019

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GROUPE PSA - 2019 UNIVERSAL REGISTRATION DOCUMENT