Measures to prevent and combat 5.3. corruption The Sopra Steria Group is committed to having measures in place to safeguard against risks arising from exposure to corruption and influence peddling. These measures help protect the Group’s reputation and maintain the trust of its internal and external partners and stakeholders. To this end, the Group applies a zero-tolerance policy with respect to corruption and influence peddling. The Group’s approach to preventing and combating corruption is based on the principles laid down in the United Nations Global Compact and on compliance with local legislation and regulations prohibiting corruption. In particular, the following measures are in place: A high degree of executive involvement in the p implementation and monitoring of the Group’s programme to prevent corruption and influence peddling. This firm commitment takes shape in particular through the Group’s specific Code of conduct covering these issues, the direct oversight of the programme at the Internal Control Department’s steering meetings, informational meetings for senior managers and regular communications campaigns targeting all Group employees; A Group-wide organisational structure in charge of p managing, monitoring and controlling the framework, through a network of Compliance Officers, who have responsibility for compliance and risk management issues within each entity; A specific risk-mapping exercise for bribery and influence p peddling risks , carried out at the same intervals and applying the same methodology used for the overall risk mapping exercise, and shared with the affected staff; A specific Code of conduct for the prevention of p corruption and influence peddling , including a foreword by the Chairman of the Board of Directors and the Chief Executive Officer and illustrated with real-world examples, as a supplement to the Code of Ethics. This Code of conduct has been translated into 10 languages and covers all Group entities; A disciplinary regime based on the Code of conduct p enforceable against all employees since its inclusion in the Group’s internal rules and regulations, or through any other mechanism in force at Group entities; Specific, formal procedures , allowing in particular for the p implementation of the associated first- and second-level controls, in order to respond to situations identified as potentially exposed to risk. For example: Policy on hospitality; policy on gifts; procedures relating to conflicts of interest; procedure for client events; procedure relating to export operations, which continued its rollout during the year; A strict procedure for assessing third parties , including p clients, suppliers and subcontractors. In this regard, the Group has formalised and rolled out a new purchasing procedure and expanded its suppliers’ charter to cover all new regulations, and more specifically regulations relating to the Sapin II Law and the duty of vigilance; A Group training programme aimed at raising awareness p among all employees, using a practical and accessible approach, and training those segments of the workforce considered as the most exposed in light of the results of the risk mapping exercise for bribery and influence-peddling risks. This programme is based on the following:
An e-learning module for all staff , which was rolled out on • a phased basis starting in December 2018 and is available in five languages. It is easily accessible via the website of Sopra Steria’s training organisation. The module includes several interactive sections, six of which consist of one or more videos and real-life situations, covering the following themes: legal framework, hospitality and gifts, public officials, conflicts of interest, intermediaries, sponsoring and patronage, facilitation payments and whistleblowing system. At 31 December 2020, 92% of Group staff had completed this e-learning module. In 2021, the e-learning module will be refreshed to reflect updated procedures; Classroom training for those considered the most at risk: • managers, sales staff, procurement staff, etc. The objectives of this training are to familiarise staff with Group rules and procedures for preventing and combating corruption and influence peddling, enable them to identify key contacts within the Group and equip them with an understanding of best practice through role play exercises based on real-world international examples; Strengthened control and audit procedures : The specific p controls are covered in the procedures developed under the programme for the prevention of corruption and influence peddling and may be either ongoing or periodic. In addition to the first-level controls carried out in the form of self-checks by the employees concerned and by line managers, controls are mainly performed, depending on the area involved, by the functional departments concerned (Finance Department, Internal Control Department, Industrial Department, Legal Department, Human Resources Department). The procedures are also assessed by the Internal Audit Department when auditing the Group’s subsidiaries and/or divisions, by running through some 30 specific checks, and during specific compliance audits as part of the internal audit programme; A whistleblowing system incorporating French legal p requirements laid down in the Sapin II Law and duty of vigilance legislation. This system has been rolled out to all Group entities. It is also accessible to the Group’s external stakeholders, and in particular its clients, suppliers and other business partners, via the Ethics and Compliance page of the Group’s website at www.soprasteria.com. To the best of the company’s knowledge at the time of writing this Universal Registration Document, neither Sopra Steria, nor its subsidiaries nor any member of an administrative or management body have been found guilty of corruption or influence peddling at any time in the last five years. Tax regulations and transparency 5.4. - Fight against tax evasion In tax matters, Sopra Steria Group is committed to complying with the tax laws and regulations applicable in all of the countries in which it is present. Sopra Steria acts in line with its values and ethical principles of integrity, commitment and accountability. Accordingly, the Group pays its taxes and duties in the countries where its operations are located and where value is created. This approach is pursued in accordance with international guidelines and standards, such as those of the OECD, particularly in relation to transfer pricing for cross-border transactions between Group companies. In this respect, the Group does not engage in tax evasion or any other practice contrary to its ethical standards.