PSA_GROUP_REGISTRATION_DOCUMENT_2017

DECLARATION ON EXTRA-FINANCIAL PERFORMANCE Corporate sustainable Development Commitment

Ethical practices – anti-corruption DPEF.37 2.3.4.

GOVERNANCE, WHISTLEBLOWING AND MONITORING SYSTEM In 2010, the Group created an Ethics and Compliance Committee , which reports to the Executive Committee. It is chaired by the Group General Secretary and brings together the Head of human resources, the Head of Audit and Risk Management and the Chief Legal Officer. If a case of non-compliance poses a major risk to the Company, this Committee alerts the Managing Board, which then decides whether to inform the Supervisory Board’s Finance and Audit Committee. Since 2017, the Ethics and Compliance Committee relies on five compliance officers who are tasked respectively with ensuring compliance with competition law, anti-corruption law, data privacy, vehicle certification compliance and export control. Led by the Chairman of the Ethics and Compliance Committee, to which they report, they have a network of internal control and risk officers (ICRMs) to ensure the rollout of the compliance programme of which they are tasked with verifying. In 2017, in the desire for convergence with Opel’s organisation and methods, the compliance officers teamed up to work on each theme, one officer from Opel and one from PCD taking the role of leader or deputy. The METRIC (Management of Ethics, Risks, Internal Control and Compliance) team overseen by the Corporate Secretary assists the Compliance Officers and supervises the ICRMs. The 23 internal control and risk officers (one representative per department reporting to the Chairman of the Managing Board) are, under the leadership of their Head of department, who is responsible for ethics and compliance in their department, tasked with ensuring deployment, creating and monitoring the corruption risk mapping and the related action plans, and for ensuring compliance of the operations. They are supported by the Fraud Detection Managers, who are responsible for fraud risk mapping (including external fraud), analysing deficiencies, adapting corrective and prevention measures and leading action plans to fight against fraud. The anti-fraud system is structured, under the control of the Ethics and Compliance Committee, around processes for prevention, detection, investigation and treatment, as well as continued improvement. Finally, the relay network of the Ethics and Compliance Committee is completed by the country Chief Ethics Officers, who are from HR or legal counsels, so that the system can be adapted to the specific legal sanctions of each country. Group Executive Management are called to evaluate, within their sphere of activity, by means of annual METRIC (Management of Ethics, Risks, Internal Control and Compliance) reviews, the risks of fraud and their own practices with regard to the Company’s ethics and compliance. Reporting directly to their Head of department and led by the network of Internal Control and Risk Officers, they are responsible for applying the Anti-corruption Code of Ethics in their area and for implementing suitable prevention systems. Finally, the Protection, Audit and Risk Management Department checks that the processes have actually been implemented. Each year it conducts several Compliance audits (for example, compliance with competition laws in 2016 and 2017, export control in 2017, and audit of the corruption compliance programme in 2018, etc.) Each audit of a site or subsidiary includes a section focusing on risk analysis. In total, for 2017, about 103 managers (not including auditors), dispersed across the Group’s functions, establishments and geographical areas, ensure optimum networking of the Group and are specifically tasked with alerting and informing the Ethics Committee in the event of fraud and monitoring the implemented action plans.

The Group’s history has engendered a corporate culture based on respect and responsibility. This ethical outlook is formalised through policies, signing of agreements (Global Framework Agreement) and adhering to international standards (Global Compact). Groupe PSA reaffirms its ambition to be the industry benchmark for responsible development. This ambition implies compliance by leaders and all employees with shared ethical rules of conduct. THE GROUP’S ETHICS POLICY AND ITS REFERENCE DOCUMENTS The Group ethics and compliance organisation policy is set out in its Code of Ethics, organised around the following requirements: respect for the law, respect for people and the environment, respect for customers and respect for the Company. The Code of Ethics includes detailed information regarding the prohibition of anti-competitive practices and corruption, the prevention of conflicts of interest, gifts and non-interference with political activities. The Code is expanded and includes a foreword on the formal commitment made by the Group’s executive managers, which has been signed by the Executive Committee. It was slightly updated in 2017. The Code is accompanied by an illustrative document “Daily ethics”, an operational guide comprising examples of situations that might occur in respect to each rule. These documents are available on the Group’s intranet and internet site. They form part of the new employee documents given to all new staff. The anti-corruption guide was updated and redistributed in 2016, in anticipation of the Anti-corruption Code of Ethics. In 2017, Groupe PSA adopted an anti-corruption Code of Ethics annexed to the internal rules and applicable to all employees. The Code sets out the Group’s zero tolerance policy with regard to corruption in all its forms: active corruption, passive corruption, direct or indirect, influence peddling, corruption in public or private organisations, facilitating payments, favouritism, extortion, collision with a supplier, client or partner, money laundering, misappropriation of funds, excessive gifts or advantages, given or received, which may compromise the impartiality of a supplier, customer or partner. This Code was the subject of a consultation with employee representatives on 26 June 2017. It includes examples and scenarios and reaffirms Groupe PSA’s sanction policy in this regard. A set of precise educational internal control procedures which deal with the major themes of business ethics and compliance (anti-corruption, compliance with competition law, Data Privacy, export control) are available for the different departments. As part of its internal control measures, the Group’s structuring processes are assessed to ensure that they incorporate, in particular, the principles intended to prevent corruption: segregation of tasks, double or triple validation, proper treatment of conflicts of interest, verification of partner integrity, declaration of gifts, etc. In addition to this general system and the Group’s reference documents, other procedures have been introduced in certain corporate departments or subsidiaries depending on the identified risks or particular legislation. In the United Kingdom the conflict of interest and anti-bribery policy was enhanced and updated.

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GROUPE PSA - 2017 REGISTRATION DOCUMENT