TELEPERFORMANCE_Registration_document_2017

RISKS AND CONTROL

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2.3 Internal control and risk management procedures

before being signed, such that risks are limited and drawn to the attention of management. Major litigation or litigation risks are monitored directly or coordinated by the Group Chief Legal Officer, who is assisted by a local network of lawyers. With respect to the protection of personal data, the Group applies a global policy in order to ensure that personal data is collected, processed and transferred within the Group in accordance with applicable legislation. Since 2013, the Group’s Legal Department has implemented a system to monitor and manage the legal affairs and legal teams of its subsidiaries and holdings throughout the world. IT and security procedures The Group has streamlined its security technology to reflect best market practices and to introduce the technology required contractually by its clients or pursuant to applicable regulations. This technology aims to reduce the introduction of malware, protect personal data and detect and prevent intrusions. All personal data is collected and processed in accordance with applicable laws and the Group’s Global Essential Compliance and Security Policies (GECSP) applicable at each Teleperformance site, specifically designed to prevent potential acts of fraud or breaches of security standards. The third-party certifications requested by clients and obtained by Group subsidiaries also serve as a guarantee that the application of strict control procedures will be verified in order to ensure compliance with security and/or quality standards and processes. The Group has a large, global operational team composed of specially trained IT, compliance and security experts tasked with identifying and assessing security risks and resolving and remedying security issues. This team implements comprehensive anti-fraud programs for the duration of business relations with Group clients and their customers. These programs focus on technological innovation, such as rapid detection of fraud and secure exchange of identifiable personal information between the caller and the customer. The Group’s Global Essential Compliance and Security Policies also include physical security procedures in our contact centers.

Sales procedures To manage its sales processes, Teleperformance has created a set of best practices to follow in order to standardize the approach to managing requests for proposals. Key international RFPs are handled directly by specialized staff. Decentralized procedures Local internal control procedures are decentralized at the individual subsidiary level, where the management team is responsible for their implementation to prevent risks and comply with local legislation. The team also ensures that these procedures operate smoothly, in accordance with instructions given by senior management, which are reviewed at the meetings of each subsidiary’s Board of Directors or equivalent body. Group senior management The Executive Committee monitors the internal control system to ensure that the system is relevant and suited to the Group’s objectives. The Committee incorporates the Group’s support functions and linguistic regions management and is supervised by the Board of Directors. This includes regular reviews on the part of management and supervisory staff. It falls within the scope of their day-to- day activities and ensures that each organizational process is consistent with the Group’s vision and strategy. The role of internal audit In 2017, audit assignments were carried out in Group subsidiaries by the Internal Audit Departments of the three main divisions (Finance, Legalb&bCompliance and Operations), according to the annual audit plan and priorities set by management during the year. These audits focused primarily on the control procedures implemented at local level. As part of its work, the Internal Audit team defines action plans with each subsidiary’s management, under the supervision of Group management, to ensure that internal control procedures are continually improved. 2.3.3.6 Oversight of the internal control system

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