Sustainability Report - FY 2023

Corporate culture and business conduct policies Compliance governance and organisation

8

Corporate culture and business conduct policies

8.1

Compliance governance and organisation

In the conduct of its business, the Exclusive Networks group promotes a culture of integrity and compliance, based on compliance with and adaptation to new

standards and applicable legislation, both in France and in the countries where it operates and where its employees operate.

To deploy and manage the compliance programme, the Group relies on a dedicated organisation described below:

Governance and organisation of compliance

Corporate

Local

Management

• Board of Directors – Audit and Risks Committee • Executive Committee • Regional Risk Committee The management team works closely with all the Group’s functions to validate the programme’s orientations and action priorities. It ensures the roll-out and development of compliance measures.

• Risks & Compliance Department • General Counsel & Group Compliance Officer • Risks and Compliance Director • Regional compliance managers (EMEA, NAM, APAC, META) Oversees the design of the compliance programme and leads and coordinates its roll-out across the Group’s business processes and subsidiaries.

• Country Managers

In charge of the deployment and respect

of the compliance programme in their legal entity.

• Ethics Champions

Work with the Risks & Compliance Department on the roll-out and proper understanding of the compliance programme.

At the corporate level  The Group’s General Counsel and Chief Compliance Officer , who reports to the Group Chief Executive Officer on these matters, defines and organises the Compliance function and oversees its implementation in the Group. In particular, its mission is to bring the subject before the various governance bodies (Group Executive Committee, Audit and Risks Committee, and the Board of Directors). It shall decide freely, and independently, on any internal investigation it deems appropriate and which shall be entrusted to internal audit.  The Risk and Compliance Director , who reports to the Group’s General Counsel and Chief Compliance Officer, designs the compliance programme, first and foremost the one relating to the anti-corruption system, manages and controls the deployment, implementation and updating of the system, and leads the Compliance network within the Group, ensures regulatory monitoring as well as best practices, organises and leads Compliance training courses in the Group. The Risk and Compliance director is the point of contact for operational functions. She/he participates, if necessary, in internal or external investigations relating to the programme, or likely to be initiated in the event of the use of the internal whistleblowing system.

At the local level  The Regional Risk Committee

The Regional Risk Committee brings together the SVP of the region concerned, the Group General Counsel and Chief Compliance Officer, the Director of internal control, the Director of internal audit, the Director of Risk and Compliance, the Regional Finance Director, the Regional HR Director and the Regional Risks & Compliance Manager. In place for the Asia Pacific region since 2022, it was implemented in 2023 for the EMEA (Europe, Middle East and Africa) region. Each Regional Committee provides an opportunity for its members to discuss ongoing business, implementation of the compliance programme, audits, and any other matter relevant to the region concerned. These discussions are followed up by the stakeholders responsible for the topic when necessary.  The Country Manager They are responsible for the deployment and compliance of the compliance programme in the legal entities for which they are responsible.

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Exclusive Networks SA

2023 Sustainability Report

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