WORLDLINE_REGISTRATION_DOCUMENT_2017

D

Corporate Social Responsibility report Being an ethical and fair player in business

Being an ethical and fair player in business D.4

Ethical excellence withinWorldline

D.4.1

[GRI 205-2] [GRI 103-2 Socioeconomic Compliance] and [GRI 419-1]

D.4.1.1

Legal compliance

Identify compliance risks and implementation of controls to ● protect the Company from those risks; Advise the business on relevant changes and controls in the ● compliance environment; Increase awareness of all employees on compliance rules ● and risks of non-compliance through the Code of Ethics. In 2017, no significant fine for non-compliance [GRI 419-1] or claim related to corruption [GRI 205-3] was reported for Worldline. In 2017, no cases deemed critical were reported at global level through this process [GRI 102-34]. D.4.1.1.1 The implementation of compliance governance approved by the Atos group Executive Committee in 2017, and applicable to Worldline, has begun to be rolled out this same year. This governance aims to achieve the three following objectives: Even stronger connection with top management ● through the Group Compliance Steering Committee. This Committee focuses on strategies and priorities of the Compliance program, as defined by the Group Legal Compliance Team, and is led by the Atos group’s Chief Compliance Officer. Worldline is also entrusted to lead this program, which is under the responsibility of the Worldline Chief Compliance Officer; Stronger involvement of operations through the ● different operational entities within Worldline and an enhanced cross-functional approach in the Operational Compliance Committee of the Atos group: Chaired by the Group Chief Compliance Officer, the Operational Compliance Committee focuses on cross-functional compliance actions; Implementation of a global compliance approach by ● setting up GBU Compliance Committees within local operations . All local Compliance Committees were launched in 2015. In 2017, the Worldline Group continued to maintain regular GBU Compliance Committee meetings. The goal is to improve the consistency of the Group's compliance approach by rolling out and monitoring compliance matters processed with the Group Operational Compliance Committee (top down) and by improving compliance related to reporting with the Group Compliance Steering Committees (bottom-up). Compliance governance

[GRI 102-33] [GRI 102-34] [GRI 205-3] and [GRI 419-1]

In order to meet the latest ethics and compliance challenges that arise in Worldline activities throughout the world, the Company has put in place an effective compliance program, which is to a large extent based on the program developed by the Atos group. In particular, Worldline benefits from the assistance of the Atos group’s Compliance team for all compliance matters, provided via a Group Services Agreement. In April 2017, Worldline, as part of the Atos group Executive Committee, which decided to update and improve its ethics and compliance organization, presented the following similar objectives: To set up an agile Worldline compliance governance ● function to meet rapidly changing regulatory requirements as well as new activities; To enhance Worldline local entities ethics and compliance ● organization matching their operational risks and culture; To reinforce the “tone from the top” and management ● involvement in ethics and compliance matters. Following the Group’s Executive Committee and to embrace its new objectives, the Atos group compliance team has released a new global ethics & compliance policy on September 15, 2017. Pursuant to this policy, the Atos ethics and compliance global organization is managed by a global compliance department, headed by the Atos Chief Compliance Officer who reports to the Atos group’s Executive Committee, chaired by the Atos Chief Executive Officer. The Atos group’s Executive Committee is tasked with determining the direction and priorities of the ethics and compliance actions plan, allocating the necessary resources and monitoring, on a yearly basis, with a quarterly report. Themain objectives of Worldline Compliance function is to: Embed compliance with applicable laws, regulations, rules, ● professional standards and ethical principles as well as with a Code of Ethics; Establish and maintain effective compliance management ● and control systems, including monitoring and reporting;

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Worldline 2017 Registration Document