Worldline - 2020 Universal Registration Document

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

This three-lines-of-defence 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 organisation is based on two 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 Programme; A stronger involvement of the business and enhancing ● cooperation and alignment between first and second line of defence, sharing achievements and future requirements on Compliance. To support these objectives, exchanges are organised through the different following meeting structures.

Meeting structure

Scope

Participants & topics addressed

D

Local Compliance meetings

They cover specific compliance questions in operations for the unit. They serve in the compliance context the objective of cooperation and information sharing on a monthly basis with the business. They draft and align group-wide compliance policies and follow up on the progress of the Group Compliance Programme, with the aim to enhance compliance culture by greater visibility of the programme through trainings on a variety of key compliance topics (Anti-bribery and anti-corruption policy, etc.). This body relates compliance challenges and issues with a cross regional impact or coverage. Inputs are based on Local QSRC Committees.

Regularly organised in operations at Managerial Unit level. Participants in these Committees are representatives of first and second line of defence with a Global Business Line or Regional Business Unit scope. These meetings gather over the Worldline Group the Compliance Coordinators of the different operational units.

Local QSRC (Quality, Security, Risk & Compliance) Committees

Monthly Group Compliance Coordinators’ meetings

Group QSRC (Quality, Security, Risk & Compliance) Committee

The Committee is led by the Group Chief Compliance Officer and gathers Group operations and second line functions.

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