SOMFY - Annual Financial Report 2020

03 NON-FINANCIAL STATEMENT

2. Policies

3. Initiatives

Fight against tax evasion Somfy undertakes to observe the spirit and the letter of the law in all countries in which it does business. It wants a frank and transparent relationship with all tax authorities, seeks to clarify all uncertainties and resolve all disputes in due course. It considers that it pays its fair share of taxes in those countries in which it operates. Anti-competition The Group’s compliance with rules governing competition is a priority. This compliance undertaking is reaffirmed in the Competition Law Charter currently going through the approval process, in order to strengthen the Group’s culture and in this way help to create long-term value. Intellectual property rights Somfy respects the intellectual property rights of third parties, in the same way it expects its rights to be respected.

The Group undertakes to pursue the following actions in its drive for tax transparency and to combat tax evasion: participate in compulsory reporting such as the – Country-by-Country reporting for France; monitor that intragroup transactions comply with arm’s – length principles and OECD actions on base erosion and profit shifting (BEPS). The Group has undertaken a major campaign to raise awareness amongst the employees concerned of compliance issues in the field of competition law by giving them dedicated training. The Group is pursuing its policy by working to implement a more extensive compliance programme in order to provide employees with the tools required to be more proactive. The process of developing a new product covers analyses of freedom to use patents at each stage of this development. A qualified patent team (three European legal representatives) is dedicated to this analysis and issues documents showing the associated risks. Launches of products are therefore based on designs specific to Somfy that are rights free. The vast majority of product names are covered by registered trademarks. The process of creating these names includes a preliminary search of availability conducted by a specialist team (two intellectual property lawyers).

4. Results and KPIs Ethics

The indicator used to monitor the performance of the ethics mechanism is the number of ethics alerts reported to the Ethics Committee, which was seven in 2020 (against twelve in 2018 and nine in 2019). This lower number led us increase our communication efforts in 2021 in relation to the existence of the reporting mechanism. Out of the seven reports received, six were admissible and five were closed at 31 December 2020. Anti-corruption Several indicators are monitored, notably those relating to anti-corruption training: in 2020, 261 additional employees completed the e-learning anti-corruption course within Somfy Activités SA, mainly made up of – new joiners and people who were absent during the previous initiatives in 2019; all the Group’s entities which had not received a roll-out in 2019 did so in 2020, representing an additional 1,346 people who – completed this same module in their native language, meaning all employees concerned in the workforce at the dates of the local campaigns; in 2020, 162 additional people, considered to be more exposed to the risk of corruption received face-to-face training, representing – a total of 826 people since the start of the roll-out of the anti-corruption programme, plus 195 Directors who are members of the various Management Committees; as of 31 December 2020, neither Somfy nor any of its subsidiaries had been found guilty of or were under investigation in relation to – corruption.

II. PRIVACY AND PERSONAL DATA

Somfy’s data protection policy was the subject of co-creation workshops with some Somfy France users in 2019 and 2020 and resulted in a prototype of an interactive control and personal data protection interface which should be rolled out across the Consumer sites from 2021. An Information System Security policy was formally set out and rolled out in order to structure governance and define each person’s role in the security of Somfy’s IT system. This policy is overseen on a cross-company basis by the Group Chief Information Security Officer (CISO), and covers all information assets, including IT, industrial and products.

1. Description of the risk

The protection of user and employee data is one of the key elements of the Group’s Sustainable Development policy. Since 2018, Somfy has been engaged in ensuring the Group is in compliance with the General Data Protection Regulation (GDPR). 2. Policies The Group has rolled out a policy to protect internal data worldwide in order to ensure an equivalent level of protection for all employees wherever they are located.

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SOMFY – ANNUAL FINANCIAL REPORT 2020