Worldline - 2019 Universal Registration Document

D

EXTRA-FINANCIAL STATEMENT OF PERFORMANCE Ensuring business ethics within our value chain [GRI 102-9] [GRI 103-3 Social compliance]

Ethics & value chain risk Risk description

Worldline action plan

Related opportunities

Main monitoring KPIs

Responsible procurement & due diligence in the value chain For more details, refer to this document, Sections D.4.4 and F.

Worldline is engaged in a continuous dialog and has defined dierent levels of commitment with its suppliers to reduce technical, social and environmental risks and ensure ethical business practices all along the value chain (notably sharing Worldline’s suppliers charter and using EcoVadis assessment).

AO 17 Supplier ●

screening: Percentage of strategic suppliers evaluated by EcoVadis GRI 204-1 Proportion of ● spending on local suppliers

Worldline’s ability to work with suppliers and subcontractors to uphold its CSR values and standards is key to avoiding unethical behavior in the value chain and to meeting the Company’s legal obligations (Duty of Vigilance). Key topic: relationship with suppliers and subcontractors

Secure compliance with laws and regulations D.4.2

[GRI 102-17] [GRI 102-33] [GRI 102-34] [GRI 103-1 Procurement Practices] [GRI 103-1 Anti-corruption] [GRI 103-1 Compliance] [GRI 419-1] [GRI 103-1 Socio-economic compliance] [GRI 205-3] [GRI 419-1] and [GRI 103-1 Procurement Practices]

Worldline culture of compliance D.4.2.1

The Code of Ethics introduces the right of any Group employee to disclose behaviors or actions deemed inconsistent with the values and principles of the Code of Ethics (refer to this document, Section D.4.2.4.4). The Compliance alert system has been established in line with the requirements of the French Data Protection Authority (CNIL). Local General Counsels, line management, the Group Chief Compliance Officer and the Group General Counsel are points of contact for any employee raising an alert, ensuring that the rights of employees, and the sender or subject of the alert, are protected accordingly. The employee who raises the alert is assured complete confidentiality in relation to the alert. The employee shall not be subjected to any penalty or retaliatory measure or discrimination, provided that he/she acted in good faith and without the intention to cause harm, even if the events relating to the alert prove inaccurate or no action is subsequently taken. If necessary, the employee's protection may be assured, on his/her request, by mobility within the Group. All alerts that reveal fraudulent behavior, significant lapses or material shortcomings in internal controls can result in corrective measures and/or disciplinary measures and/or legal action. Anonymous reports are not considered, except if permitted by local laws. The Company aims to disseminate the values and principles of integrity entailed in the Code of Ethics so that all its employees embrace them. That’s why Worldline conducted in 2019 a comprehensive and mandatory online training on the Group’s compliance program. Since, 2014, Worldline has imposed to all its new employees an e-learning on the Code of Ethics, regardless of their jobs function, country and hierarchical level. This training aims to ensure a better understanding of Worldline’s Code of Ethics and promote the adoption of fair practices on a daily basis. In 2019, 94.9% of Worldline employees completed the program [GRI 205-2]. Building and maintaining a strong D.4.2.1.2 culture of compliance [GRI 205-2]

Worldline Code of Ethics as the D.4.2.1.1

backbone of the Company’s ethics and policies [GRI 102-16] [GRI 102-17]

Worldline’s Code of Ethics was reviewed and approved by Worldline Board of Directors in 2016. Strong involvement by the Human Resources department has ensured a consistent and thorough implementation, particularly in countries requiring representatives of employee to be involved. Additionally, the Legal department of each country reviewed the content of the Code of Ethics to ensure alignment with local laws and regulations. Consequently, certain countries have adopted a slightly modified Code of Ethics, particularly with respect to issues carrying legal implications, such as national whistleblowing systems. The Code of Ethics makes a direct reference to Worldline Corporate Values, establishing ethical practices as the backbone of Worldline's business strategy: Responsibility, Trust, Sustainable competitiveness, Service quality and listening to clients, Innovation, Wellbeing@work and Excellence. These principles imply that Worldline treats its employees as well as third parties with integrity, based on merit and qualifications, prohibiting any form of discrimination. The Code of Ethics also reminds employees the need to act honestly, impartially and with integrity in their day-to-day work, and in compliance with the legal framework applicable to each country where Worldline conducts its business. To this end, the Code of Ethics has been included in the employee's employment contract since 2011. Suppliers, partners and third parties who assist Worldline in its business activities must commit to respecting the principles of the Code. Additionally, a mandatory e-learning training on the Code of Ethics is organized for all the Group employees to share knowledge on this key document (refer to this document, Section D.3.4.1.1).

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Universal Registration Document 2019