RUBIS_REGISTRATION_DOCUMENT_2017

CORPORATE SOCIAL RESPONSIBILITY (CSR) 5 Societal information

5.3 SOCIETAL INFORMATION

The Group has drawn up a list of the values and rules that it considers essential, and on which it has built its success. These internal

principles, rooted in its strong corporate culture, encourage employees to become involved in the social and economic fabric

surrounding them, by adopting responsible and supportive behavior.

5.3.1 RUBIS’ ETHICS POLICY

• compliance with rules regarding health and safety conditions at work, as well as those pertaining to environmental protection; • respect for people, including fundamental rights and human dignity, protection of privacy, as well as the fight against discrimination and harassment; • prevention of conflicts of interest; • management of relationships with external service providers; • requirements in terms of the reliability, transparency and auditability of accounting and financial information; • protection of the Group’s image and reputation; • fight against corruption, fraud, misappropriation of funds and money laundering. In each of these fields, Rubis details the overall principles to be adhered to by employees in performing their duties. The Group also ensures that its human resources policy complies, in all countries where it operates, with the principles relating to Human Rights at work listed in

Rubis’ ethics policy covers a range of measures, both governing employees’ behavior and subcontractors’ and suppliers’ behavior. It is reflected in the Group’s commitments to its employees, such as the setting up of health and safety protection systems within subsidiaries. 5.3.1.1 FAIR PRACTICES Rubis has developed an ethical framework shared by all of the Group’s subsidiaries, as well as a policy in the fight against corruption and fraud. The Compliance and CSR Department within the Rubis Corporate Secretariat is the point of contact for subsidiaries and employees when it comes to ethical issues. Rubis’ Code of Ethics TheCode of Ethics (available at www.rubis.fr), drawn up in 2015, lays down the values that Rubis considers fundamental: • compliance with all applicable laws and regulations wherever theGroupoperates; • comp liance w i t h compe t i t ion, confidentiality and insider trading rules, as well as with specific laws relating to war and/or embargo zones;

the International Labour Organization’s fundamental conventions, in relation to: • freedom of association and collective bargaining; • elimination of discrimination in respect of employment and occupation; • elimination of forcedor compulsory labor; • abolition of child labor. Policy against corruption In line with its values and current legislation, and as a result of its presence in an increasing number of countries, in 2015, Rubis formalized the Group’s commitment to fighting corruption in all its forms within its Code of Ethics . TheCode lays down the basic rules governing the decisions taken by all Group employees. This commitment is reflected in the gradual implementation of an anti- corruption program currently comprising the following measures: • a guide to applying the anti-corruption policy that supplements the Code of Ethics. It aims to help those Senior Managers and employees who are most exposed, to identify at-risk situations and to adopt practical preventive measures. The guide lists prohibited practices, notably facilitation payments, and specifies the rules applicable to regulated practices, particularly in relation to gifts and invitations, third-party relations and sponsorship. This guide offers examples and makes practical recommendations; • third-party assessment guidelines to help operating staff to identify third parties liable to present a risk, to perform due diligence and to deal with third parties on a case-by-case basis;

2017 Registration Document I RUBIS

ANYTHING THAT HASN’T BEEN AUTHORIZED IS STRICTLY FORBIDDEN.

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