Worldline - 2020 Universal Registration Document


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

and the Customer Services (CS) Divisions. The Group has also developed a Fraud Detection & Reaction (FD&R) application that allows the detection of fraud in near real time based on a data analysis application. Furthermore, the Group’s risk mitigation process has been enhanced with additional features to better manage residual risks, such as geo-blocking, real time blocking, fall back de-activation and back-up systems; Competition in Business: a policy stipulates the main rules ● of fair competition to adhere to through meetings with potential and known competitors. Worldline treats its customers, suppliers, partners and intermediaries with respect and shall not take unfair advantage nor practice discriminatory conditions. Consequently, Worldline refuses that its employees or third parties when assisting the Company in developing business, take part in an agreement, understanding or concerted practice which would contravene the applicable laws and regulations concerning anti-competitive practices; Anti-bribery and Anti-corruption policy (regarding gifts ● or benefits): To protect Worldline from any disproportionate gift or benefit given or received by a Worldline employee, a policy was implemented in 2013, aiming to screen gifts, invitations and other benefits of which Worldline would be provider or recipient. As participant to the United Nations Global Compact, Worldline subscribes to anti-bribery principles in “all its forms, including extortion and bribery”. The policy has been updated in 2020 and enhances the compliance focus overall including guidelines on donations and sponsoring, on forbidding contributions made or received for political purposes which could damage Worldline’s reputation, provision of money, gifts, entertainment or hospitality or anything else to any government of public officials or their close associates. The purpose of the latest update was also to include a section devoted to fraud. In fact, fraud is not the object anymore of a stand-alone policy and is integrated within the ABAC one; The Dawn Raids & Inspection policy: this Group policy ● provides a list of rules and procedures to be followed in the event of inspection by local authorities; Preventing tax evasion: ● Tax compliance: Worldline aims to comply with tax laws, ● rules, and regulations in the countries where the Group operates. In this respect, the Group pays the right amount of tax in the countries where it generates profits and value is created. This behaviour is achieved in accordance with domestic and international rules and standards as well as applying the OECD principles to transactions within the Group. Hence, the cross-border intercompany transactions within the Group are based on the arm’s length principle and are documented in each country according to the local and international transfer pricing rules, and disclosed to the local authorities whenever required, Tax risk management: Given the complexity of the ● international tax environment, a certain degree of tax risk and uncertainty is inherent in the Group’s business activities, due to challenges in the application of local

laws and regulations, errors when completing tax returns and regular audits by the tax authorities. However, the Group is committed to disclose all relevant facts and circumstances to the tax authorities. Where disagreements over the interpretation of tax laws arise, the Group works proactively to seek to resolve all issues by agreement, where possible, and reach acceptable and sustainable solutions in order to lower its exposure to risks. Moreover, Worldline manages the tax-related matters with integrity, do not enter into aggressive or artificial tax planning scheme disconnected from its actual operations and seeks to mitigate the risk level regarding its operations by ensuring a strong care is applied in relation to all processes which could affect compliance with its tax obligations. The risks are identified and managed locally by local tax managers or local CFO, with the support of external advisors in the event of uncertainty or complexity. They provide a regular report to the Group Tax Director who supervises and monitors the tax risks management in order to find the best solution to mitigate them, Tax function: Worldline’s tax strategy is approved by the ● Group Chief Financial Officer, member of the Executive Committee, who delegates its executive management – i.e. definition, monitoring and supervision – to the Group Tax Director. Local tax managers – who report to the Group Tax Director – have the responsibility to liaise with local finance & business teams as well as external advisors in order to ensure the correct application of the tax strategy and compliance with applicable national and international tax laws. The tax department is organised around a corporate team and local internal or external specialists working closely with the operations, aiming to support the business in the development of the operations and to ensure the Group competitiveness. As such, it seeks to minimise double taxation, ensure compliance with applicable tax laws and regulations, minimise tax exposure, benefit from 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. Moreover, the Group complies with its reporting obligations, in particular as regards the Country by Country Report (CbCR), which is prepared and filed according to the French tax law and the international guidelines, Regarding the country by country reporting [GRI 207-4] ● it has not been carried out this year but it will be in the future. For more information regarding Ingenico’s related policies, please consult Chapter 3.1 of its extra-financial performance declaration.


Universal Registration Document 2020

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