SOMFY - Annual Financial Report 2020

03 NON-FINANCIAL STATEMENT

2. Policies

3. Initiatives

Ethics Since 2015, Somfy has had a Code of Ethics which is a point of reference for employees in relation to individual and collective behaviour, and a framework for everyday actions, enabling them to embody the Group’s values. This Code is a common and unifying document, which guides every employee in their decision-making; it is also a tool to promote dialogue between employees so that ethics is an open matter understood by all. It is systematically provided to employee on joining the Group and is available on the Group’s website and intranet in 23 languages.

The Audit Committee and the Management Board provide strong support to the Ethics Committee and oversee the ethics function. The Ethics Committee helps to ensure there is a collective approach to ethics and that the principles described are applied. It is made up of four members appointed by the Management Board. It relies on a network of Ethics officers to oversee local communication and close coordination, ensuring the solution’s effectiveness. Managers are responsible for the roll-out and application of the Code of Ethics within their scope, including in relation to new arrivals. Every employee must understand and apply the principles set out in the Group’s Code of Ethics. Employees are also encouraged to report any concerns relating to ethical principles or behaviour to their manager, their local Ethics officer, or the Ethics Committee. A whistleblowing mechanism has been in place since 2015 allowing the confidential and secure reporting of any behaviour that contravenes the Code of Ethics, so that it can be considered and handled in compliance with the applicable legal and regulatory provisions. Included in the anti-corruption compliance programme, this whistleblowing mechanism also allows Somfy to meet the requirements of law n°2016-1691 of 9 December 2016 on transparency, the fight against corruption and the modernisation of the economy, known as the “Sapin 2” law. A specific procedure has been formally set out in 23 languages to present this system and the conditions of its use. Lastly, Somfy is also a member of the Business Ethics Group, an organisation that has set itself the task of promoting ethics and compliance in the management and governance of French companies. The Group has formally set out mapping dedicated to the analysis of corruption related risks in each of its geographic regions, in accordance with its activities. The Group decided to adopt the Middlenext Anti-Corruption Code of Conduct, designed to provide guidance for behaviour in business. Somfy supplemented the Code with several appendices in order to provide practical advice, examples and links to other procedures. E-learning was rolled out to all the Group’s employees (excluding manual workers and equity-accounted entities) in 22 languages. Face-to-face training was introduced for employees considered to be the most exposed. The roll-out of local training continued in 2020, although the timing was disrupted by the health situation. The whistleblowing mechanism introduced in 2015 to escalate non-ethical behaviours (as mentioned above) was extended to meet the requirements of the “Sapin 2” law. Accounting controls were implemented to detect potential fraudulent acts. A digitalised solution to ensure atypical transactions are kept under control on an ongoing basis is currently being purchased. Procedures are currently being rolled out to assess third parties with whom the Group already works, and prior to any new relationship. A screening solution was purchased in 2019 and implemented in 2020. Cash flows form an integral part of the tests of the internal audit programme and are verified during each assignment within a subsidiary. The Group is involved in the fight against money laundering by working with reliable and strong banking partners, who use procedures to verify financial flows and their origins.

Fight against corruption In addition to the Group’s Ethics Code and following the enactment of the law on transparency, the fight against corruption and the modernisation of the economy, Somfy has set out its anti-corruption policy, available on the Group’s website, and implemented an anti-corruption programme.

Combatting money laundering The Group’s Treasury Charter expressly states that payments and receipts made in cash are not permitted, except in exceptional cases in complete compliance with applicable local regulations and/or the Group’s rules.

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SOMFY – ANNUAL FINANCIAL REPORT 2020