QUADIENT // 2021 Universal Registration Document

4 RISK FACTORS AND INTERNAL CONTROL Internal control and internal audit framework

Procedures are made available on the Group Intranet in a dedicated internal control section, designed to improve circulation of procedures and to facilitate communication by providing information on internal control, audits, legal affairs and cash management. Every new or updated procedure is circulated electronically to the manager of each subsidiary. Each subsidiary arranges internal communication of the procedure and ensures they are implemented and applied by employees. The consistent involvement of the headquarter's management in subsidiaries’ operations through regular reviews also allows for the rapid identification of any anomalies and the efficient and timely implementation of appropriate remedial action plans. Furthermore, the internal audit department conducts cross audits to strengthen these controls. The integration of new activities and the strategic shift that the Company has made in recent years has led him to redefine its values to better reflect its organizational identity: THE GROUP’S ETHICAL PRINCIPLES Quadient believes that conducting its business in an ethical and responsible manner is essential to its sustainable growth and success. The Company's Code of Ethics sets out principles of ethics and business conduct that help each of its employee to act with integrity and ethically as well as best practices and policies that will elevate the Company's reputation. In short, this code of ethics stands as a testament for doing what the Company knows is right. It covers the following topics: Human Rights, employees, business ethics, business relationships, Quadient assets and third parties, citizenship and responsible engagement. It also includes useful recommendations for how to anchor the code of ethics in Quadient’s corporate culture and takes into account Quadient’s new “EPIC” (Empowerment, Passion, Inspiration and Community) values. Quadient asks every employee, regardless of their role, function or entity, to follow the code of ethics when working for or representing Quadient. In this respect, each employee is required to follow the dedicated training and endorse the code of ethics. In 2021, 67 of the employees received the code of ethics training and 66 have endorsed the code. The code of ethics is available on the corporate intranet (WeShare) and corporate website in the following languages: French, English, Dutch, German, Italian, Spanish, Japanese and Czech. Ethical reference framework

meets as necessary to manage any compliance issues and the whistleblowing reports received, the investigations and remedial plans. This committee advises the Executive Committee to set directions and priorities for compliance at Quadient. The Vice-President of CSR and Compliance reports on the progress of the compliance program through quarterly reports and updates to the Chief Transformation Officer, the Chief financial Officer and the CEO to the company. In 2021, these updates included improvement projects such as integrity checks on third parties, the launch of the new code of conduct for business partners, the revision of some corporate policies and the implementation of a GRC platform. APPLICATION OF THE SAPIN 2 LAW Quadient is fully committed to the fight against corruption and has made clear commitments as part of its commitment to the United Nations Global Compact. The Company applies strict principles which are enshrined in its Code of Ethics and its global policy against corruption and influence peddling. The Company's program revolves around the following themes: Code of ethics ● Annual mapping of corruption risks ● Raising awareness and training of exposed persons and ● all employees Control devices ● Accounting procedures ● Due diligence and evaluation procedure of third parties ● Disciplinary system ● Whistleblowing procedure and system ● In this context, the Company has continued to improve and strengthen its processes and tools. Therefore, in 2021, the Company has revised and supplemented its anti-corruption and bribery policy; updated the assessment of risk scenarios on corruption and bribery, implemented a procedure for knowing third parties with a particular focus on commercial distributors, but also the implementation of due diligence for suppliers and associations benefiting from donations or sponsorship actions. The Company's whistleblowing system has also been extended to all 3rd parties. Some training actions have been taken for employees who were the most exposed to these risks, as well as the legal and compliance teams. The Compliance and Internal Control and Internal Audit teams work closely to implement the controls required, such as the annual declaration of conflict of interest.

Information Systems

The key priority for the Digital organization remains the harmonization of global processes and systems, underpinned by investments in ERP, CRM & HCM. Additionally, Digital is investing in Contact Centre and eCommerce platforms, to enhance customer interactions.

ETHICS & COMPLIANCE COMMITTEE

In terms of governance, an Ethics & Compliance committee, chaired by the Vice-President of CSR and Compliance and composed of the Chief People Officer, the General Counsel and the Vice-President of Internal audit

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UNIVERSAL REGISTRATION DOCUMENT 2021