Worldline - 2019 Universal Registration Document

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

Additionally, to ensure a deeper understanding of the specific the “fight against corruption” training program developed by risks related to corruption, top management and exposed the United Nations. Thus, in 2019, 82.4% of Worldline’s functions must attend the ETO 2 S (specific mandatory training management and critical employees completed the ETO 2 S. relating to Code of Ethics for top managers) and be certified in

2019

Indicators

2014 2015 2016 2017

2018

Percentage of employees trained in Code of Ethics Elearning

50% 71% 82% 95% 95% 95%

Our compliance governance D.4.2.2 [GRI 102-34] [GRI 205-1] [GRI 205-3] [GRI 419-1] The Worldline Group Compliance Charter, as published in 2019, sets forth the principles regarding to the positioning and governance of the Compliance Function at Worldline Group. The Compliance Function assists Worldline Group to carry out its mission with integrity and in accordance with applicable legal and regulatory requirements and the highest ethical standards. Worldline Group has the following objectives related to Compliance: Preventing and mitigating of Compliance Risks; ● Embedding in all its activities Compliance with rules and ● ethical principles applicable to Worldline as well with Worldline’s Code of Ethics, Integrity policies and Compliance policies; Establishing and maintaining effective Compliance ● management and control systems, including monitoring and reporting; Promoting a culture of Compliance and integrity within ● Worldline, its business and its employees. The aim is to prevent loss of integrity, as well as financial, legal and reputational damage and also to protect each company within the Worldline Group and/or one of its employees from prosecution or sanctions due to non-compliance with rules. Worldline’s Compliance Function acts as part of the second line of defense, within the three lines of defense model used in Worldline. This three-lines-of-defense structure is in place in all countries where Worldline operates and can be defined as follows: Front line staff and management in operations and 1. support functions. Internal control and systems as well as the culture developed and implemented by these managerial units is crucial in ensuring compliance;

Risk management and Compliance Function. These 2. functions provide the oversight and the tools, systems and advice necessary to support, challenge and monitor the first line in identifying, managing and monitoring risks and ensuring compliance; Internal audit function. This function provides a level of 3. independent assurance in order that the risk, compliance management and internal control framework works as designed. Worldline’s Compliance global organization is based on 2 pillars: the Global Compliance Function headed by Worldline’s Head of Quality, Security, Risk and Compliance and the Group Head of Legal Compliance and contract management. The Head of Quality, Security, Risk and Compliance is appointed as the Group Chief Compliance Officer and reports in this role to the Deputy Chief Executive Officer with a functional reporting to the Group Head of Legal Compliance and contract management. The Group Chief Compliance Officer relies on the local compliance function to deploy compliance matters across the Group. The Group Compliance Function makes the bridge with the Legal Compliance and contract management team via a functional reporting line at management level. Furthermore the Group Compliance Function relies on the local compliance function and teams established in the Managerial Units. The outlined governance aims to achieve: An improved connection with top management focusing on ● priorities and progress of the risk based Compliance Program; A stronger involvement of the business and enhancing ● cooperation and alignment between first and second line of defense, sharing achievements and future requirements on Compliance.

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159 Universal Registration Document 2019