Worldline - 2020 Universal Registration Document

EXTRA-FINANCIAL STATEMENT OF PERFORMANCE Ensuring business ethics within our value chain

Ethics & value chain risk Responsible procurement & due diligence

Worldline action plan Related

Main monitoring KPIs

Risk description

opportunities

Worldline’s ability to work with suppliers and subcontractors to uphold its CSR values and standards is key to ensure (i) the respect of Human rights standard as well as labour law ones and, (ii) the environmental norms throughout the entire value chain (duty of vigilance) This risk will be enhanced with the Ingenico’s integration. Furthermore, considering Ingenico’s activities in the assembling of terminals, it will be utmost crucial to increase the traceability of the supply chain in order to avoid any conflict minerals and other controversial substances Key topic: relationship with suppliers and subcontractors

Worldline is engaged in a continuous dialogue 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).

WL 17 Supplier ● screening: Percentage of

in the value chain For more details, refer to this document, Sections D.4.4 and F.

strategic suppliers evaluated by EcoVadis Proportion of spending on local suppliers

GRI 204-1 ●

D

Secure compliance with laws and regulations [GRI 102-17] D.4.2 [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] [GRI 207-2 Tax governance, control and risk management]

Worldline culture of compliance D.4.2.1

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 organised for all the Group employees to share knowledge on this key document (refer to this document, Section D.3.4.1.1). The Code of Ethics introduces the right of any Group employee to disclose behaviours 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). Line management, the Group Chief Compliance Officer, Human Resources 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. All alerts that reveal fraudulent behaviour, significant lapses or material shortcomings in internal controls can result in corrective measures and/or disciplinary measures and/or legal action. Anonymous reports will be considered, except if not permitted by local laws.

Worldline Code of Ethics as D.4.2.1.1

the backbone of the Company’s ethics and policies [GRI 102-16] [GRI 102-17] [GRI 207-2 Tax governance, control and risk management]

Worldline’s Code of Ethics was reviewed, updated and approved by the CEO in 2020. 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. The Code of Ethics makes a direct reference to Worldline Corporate Values, establishing ethical practices as the backbone of Worldline’s business strategy: Innovation, Excellence, Cooperation and Empowerment. 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

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