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]

The Dawn Raids policy: this Group policy provides a list of ● rules and procedures to be followed in the event of

of the Company’s interests. This function is carried out by the Strategy department reporting directly to the CEO of Worldline. The strategy of influence managed by the Public and Regulatory Affairs department aims to: Anticipate regulatory changes and react to public ● decisions; Directly promote the expertise of the Company; ● Orchestrate the workflow of information among the ● Company on the key topics; Enhance the Company’ image by generating positive ● opinions and commitment. Worldline does not make monetary contributions to candidates for elected office, political parties or Election Committee in any country. Moreover, in its Anti-Bribery and Anti-Corruption Policy, Worldline prohibits the provision of money, gifts, entertainment or anything else to any government or public officials and/or family members or persons known to be close associates of government and public officials (“Officials”) for the purpose of influencing such officials in order to obtain or retain business or a business or commercial advantage, or otherwise in relation to decisions that may be seen as beneficial to Worldline’s business interests. Worldline’s current strategy of influence tackles in priorities the following topics: Digital single market strategy: engage in the public debate ● for topics that are relevant for payment service providers; Payment/cybersecurity/cloud/data localization: input in the ● upcoming legislation on cybersecurity for Financial Services, as payments are likely to be an important aspect of this new legislation; Paytech/fintech in API world: develop and publicly ● communicate a view on the impact of the API regime under PSD2 and the workable solutions in this area; Topics as they emerge: the list of key topics can be ● amended over time as new topics of relevance arise. Regarding the Company’s association memberships, a global assessment has been initiated in 2019 in order to rationalize the number of its representations. Worldline is deploying different tools to monitor this new activity and thus increase transparency and coherence of its actions relating to public and regulatory affairs.

inspection by local authorities. Policy to prevent tax evasion:

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Tax compliance: Worldline is committed to full ● compliance with tax law and practice in countries where the Group operates. In this respect, the Company pays taxes in the jurisdictions where business activities generate profits and value is created. This behavior is achieved in accordance with domestic and international rules and standards as well as applying the OECD principles to transactions within the Group. Tax risk management: Worldline seeks to reduce the ● level of tax risk arising from its operations by ensuring that a strong care is applied in relation to all processes which could affect compliance with its tax obligations. The Group takes benefit of available tax incentives, reliefs and exemptions in line with tax legislation and the business of the Group. Tax transparency: In order to prevent any case of tax ● avoidance, where tax law is subject to interpretation, the Group may take a written opinion so as to support the decision-making process or may engage transparent discussions with tax authorities to secure alignment on interpretation of tax rules. Monetary contributions as part of D.4.3.2 our public and regulatory affairs The payment industry must organize itself in order to assert and promote its interests. Worldline's positioning in Europe now implies organizing and structuring the following missions, from strategy to operational implementation: regulatory and political monitoring, interest representation and lobbying. The multiplication of Worldline representations can alter the scope of the Company’s messages, or even harm its interests. Moreover, future European projects imply that from now on Worldline must be able to share its vision and ambitions at the highest level of political and financial authorities, both locally and at the European level. In this context, Worldline’s general management has decided to appoint a Head of Public and Regulatory Affairs in order to set up an internal organisation that will structure this promotion

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Universal Registration Document 2019