Worldline - 2020 Universal Registration Document

D

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

In 2019, the Group Chief Compliance Officer reviewed the internal Compliance alert process in order to: Reinforce the governance of any internal investigation; ● Enhance collaboration between global function and local ● teams; Provide clear guidelines on how to conduct an internal ● investigation, report and take decisions, such as remediation actions in a measureable and consistent manner, in case of non-compliant behaviours. Any case subject to the Group Compliance Alert Process is reported to the Group Chief Compliance Officer, who will report to the Audit Risk and Compliance Committee any case investigated and confirmed as a critical concern at Group level. All governance matters as far as compliance is concerned are described in Chapter F. Risk Factors in this document. The Compliance Alerts Policy gives an overview on how the Group acts on prevention, detection and reaction of compliance breaches including as well the protection of the person raising the alert. Roles and responsibilities are clearly set and guidelines on confidentiality and information management included. In 2020, 4 alerts have been reported highlighting breaches with Worldline’s Code of Ethics. All alerts have been investigated and actions have been taken as suitable in the given contexts. Three of the alerts were related to behavioural findings and one related to theft, all at different geographies. The treatment of the alerts has been completed through the engagement and mediation of the human resources department.

All of these four complaints have been deemed admissible. Among these, two of them have been closed and the second two are under investigation. Building and maintaining a strong D.4.2.1.2 culture of compliance [GRI 205-2] 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 2020 a comprehensive and mandatory online training on the Group’s compliance programme. 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 2020, 89% of Worldline employees completed the programme [GRI 205-2] . Additionally, to ensure a deeper understanding of the specific risks related to corruption, top management and exposed functions must attend every second year or the ETO 2 S (specific mandatory training relating to Code of Ethics for top managers) or the specific training on the fight against corruption, for 2020 newly created within the Company Thus, in 2019, 82.4% of Worldline’s management and critical employees completed the ETO 2 S. In 2020 73% completed the anti-corruption training. Due to restricted resources in the context of Covid-19, e-learnings have been issued quite late in 2020, which impacts the% of completion. For more information regarding the Code of Ethics of Ingenico, please consult Chapter 3.1 of its extra-financial performance declaration. 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 defence, within the three lines of defence model used in Worldline. 2016 2017 2018 2019 2020

Indicators

2014

2015

Percentage of employees trained in Code of Ethics Elearning

50% 71% 82% 95% 95% 95% 96%

Worldline’s compliance D.4.2.2 governance [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; ●

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Universal Registration Document 2020