Universal Registration Document 2021

DISCLOSURE ON EXTRA-FINANCIAL PERFORMANCE FAIRNESS OF BUSINESS PRACTICES

Besides the traditional objective of Content & IP protection, the Connected Home products have a key role to play in Privacy protection, and defense against massive scale cyberattacks. Physically positioned at the border between the private sphere of the end-user, and the Internet operators’ networks, the Technicolor Customer Premise Equipment (CPE) need to achieve best-in-class protection to contribute to global security and privacy efforts, and to provide security added value to our customers.

Protection Authority (CNIL). Technicolor Data Control Organization (DCO) is in place worldwide, to support compliance to Technicolor Privacy Policy and the General Data Protection Regulation (GDPR). The DCO supports the DPO and works in close relation with Legal and Security teams. Even if Technicolor activity does not directly collect sensitive personal information of private customers, a privacy-by-design approach is used for Technicolor products and systems, and the DCO is involved when a Data Protection Impact Analysis seems relevant.

As a French company with headquarters in Paris, the Group has also nominated a global Data Protection Officer (DPO) to the French Data FAIRNESS OF BUSINESS PRACTICES 5.8

[102-17] [103-1 Anti-corruption] [103-2 Anti-corruption] [103-3 Anti-corruption] [103-1 Anti-competitive behavior] [103-2 Anti-competitive behavior] [103-3 Anti-competitive behavior] [103-1 Public policy] [103-2 Public policy] [103-3 Public policy] [103-1 Socioeconomic compliance] [103-2 Socioeconomic compliance] [103-3 Socioeconomic compliance]

Competition rules and anti-bribery 5.8.1 [205-1] [205-2]

Following regulatory evolutions, especially the Sapin II Law adopted on December 9, 2016, the Group has strengthened its Ethics and Compliance program so as to be in compliance with the new regulatory requirements and business practices. The anti-bribery program now includes the following: Technicolor top management has shown its engagement (i) by issuing • several communications to all employees explaining that a zero-tolerance policy against bribery is part of Technicolor’s core values and (ii) by requiring regular updates on the anti-bribery program at the Audit Committee of the Company’s Board of Directors and at the Board itself; Code of Ethics & Anti-Bribery Policy: this Code was updated in • 2020 and is now available in 5 languages so to be accessible and well understood by all Group employees. The employees are now required to confirm that they duly read it. The Anti-Bribery Policy provides practical examples showing employees how to do the right thing when faced with a dilemma. The Travel and Customer Entertainment policy has also been updated to harmonize processes across businesses; Whistleblowing Policy, updated in 2021: a Whistleblowing system is • available and enables all Technicolor employees and partners to report anything that they suspect to be unethical, illegal or unsafe, through a dedicated website or by phone; risk mapping: our risk mapping has been reviewed in 2020 to identify • new risks specific to business conduct and to re-assess all of them;

third-party assessments: the Group’s suppliers are required to respect • the Anti-bribery Policy, and the Third-Party policy covering our relationship and engagement with agents, consultants, advisors, among others, has been reviewed and communicated to sales and legal teams, in specific training. The sales agent template contract has been updated to streamline it and to take into account new anti-bribery requirements; training: specific training courses on anti-bribery are developed and • delivered within the Group to the staff categories with the highest level of exposure. Targeted E-learning training as well as on-site training for specific employee categories such as sales, legal, finance or human resource employees have been put in place. A training program to be provided to all the teams worldwide was also launched early 2022; accounting control procedures: the internal control and risk • management procedures relating to the preparation and processing of financial and accounting information form an integral part of the Group’s anti-bribery measures; internal control and audit procedures: internal and external audits are • performed on a regular basis, notably covering anti-bribery matters. Compliance with competition rules and with more general business ethics rules, are at the core of our Code of Ethics. Our overall approach regarding these two aspects are presented in section 3.2.2: “General control environment”.

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