Universal Registration Document 2021

RISKS, LITIGATION, AND CONTROLS INTERNAL CONTROL

Code of Ethics Created in 1999 and last updated in 2020, the Code of Ethics establishes the foundation of the Group’s core values and requires all employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. The Code of Ethics details the specific rules to guide employees in their day-to-day activities. It is translated in 5 languages (English, French, Spanish, Portuguese and Polish). All employees were required to individually acknowledge the Code of Ethics during 2021. Technicolor has also updated several additional key policies including a Whistleblower Policy, Anticorruption Policy and Manual, and Ethical Sourcing Policy. Indeed, Technicolor is committed to uncompromising integrity in all of our actions. A reputation for integrity benefits Technicolor in countless large and small ways – we are a trusted advisor and service provider to our customers, a dependable collaborator for our business partners, a valuable member of our communities, and a reliable long-term investment for our shareholders. Ethical behavior and observance of laws are two main ingredients in building our reputation for uncompromising integrity. The Group also created an Ethics Compliance Committee in 2006, which reports to the Audit Committee and is currently composed of six members representing different functions such as People & Talent, CSR, Internal Audit, Compliance and business divisions. This Committee is governed by its own charter (last updated in 2021). The Ethics Compliance Committee is responsible for all ethical issues related to Technicolor’s activities. This includes implementing any new policies if needed, training on existing policies, and investigating any and all reports of unethical behavior. It meets at least four times per year and more frequently when required. Over the last several years, the Group has deployed many ethics training programs. Several training sessions were launched to educate employees on various ethical rules and obligations, including bribery, competition, and fraud. Financial Ethics Charter To reinforce awareness of the ethical dimension of finance activities, Technicolor has published an Ethics Charter specific to Finance personnel and activities. It is an extension of the Company’s Code of Ethics, which applies to all employees. First published in December 2005, the Financial Ethics Charter is sponsored by the Chief Financial Officer and sent out bi-annually to the full Finance organization for review and personal acceptance. This policy promotes the following rules: acting honestly and with integrity and avoiding conflicts of interest, providing accurate, complete and objective information, compliance with all rules and regulations, public and private, to which the Group is subject, acting in good faith without misrepresenting material facts or allowing one’s judgment to be unduly influenced, respecting confidentiality of information, sharing and maintaining appropriate knowledge and skills, promoting ethical behavior in one’s environment, using and controlling responsibly assets under one’s supervisions and reporting known or suspected violations of the charter. A copy of the Code of Ethics and the Financial Ethics Charter, as well as the other policies are available on the Company’s website at www.technicolor.com or upon request to the Company.

INTERNAL CONTROL METHODOLOGY The internal control methodology is based on three pillars:

a risk-based approach which starts from the Group Risk Management • program (see paragraph below “Risk Management”) and allows internal control to deploy its methodology on the main Group risks. In 2021, despite the unexpected events of the pandemic (Covid-19), the risk and control referential was revisited and updated together with the evolution of risks; along with a clear classification distinction on Tier 1 and Tier 2 risks; a self-assessment on controls implementation by the most significant • entities, totaling the vast majority of the Group scope according to the relevant indicators (Revenue, contribution to EBITDA and other financial and non-financial indicators function of each nature of risk). In 2021, about 269 control owners were designated to perform a self-assessment on 2,679 controls over 56 financial and non-financial processes; an independent testing managed by Internal Audit covering close to • 20% of the self-assessed controls. This testing aims at providing assurance that the Technicolor internal control framework is effective. Independent testers are composed of Internal Auditors and internally trained guest testers on the testing exercise. The internal control team ensures a continuous monitoring of the internal control campaign, through key performance indicators such as self-assessment and independent testing completion rates, deficiency rates ( i.e. , by division and by process), and risk severity classification of reported deficiencies. The internal control team communicates frequently with the internal control communities, ensuring training on the approach and the tools to be used. Quarterly updates on the program are made to the Audit Committee. The management community is involved in the deficiency remediation and takes an active role in the implementation of corrective actions raised during the internal control campaign. Deficiencies with high, medium, and low severity are monitored and followed-up by Internal Auditors until their full remediation. General control 3.2.2 environment THE ETHICAL VALUES AND PRINCIPLES OF CONDUCT FOR THE GROUP’S MANAGERS AND EMPLOYEES [102-16] [102-17] [103-1 Anti-corruption] [103-2 Anti-corruption] [103-3 Anti-corruption] [205-1] [205-2] [412-1] [412-2] The values and principles of conduct for the Group’s managers and employees are defined in two of the Group’s three principal internal documents: the Group’s Code of Ethics, the Financial Ethics Charter, and the Anti-bribery and Anti-corruption Policy.

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TECHNICOLOR UNIVERSAL REGISTRATION DOCUMENT 2021