Sustainability Report - FY 2023

Corporate culture and business conduct policies Ethics, prevention and the fight against corruption

 The Ethics Champions Network The main mission of the Ethics Champions Network, made up of around 50 employees, is to deploy the

compliance programme in conjunction with the Risk and Compliance Department, and to ensure that it is properly taken into account and understood.

8.2

Ethics, prevention and the fight against corruption

A mature compliance programme Adopting and promoting honest and ethical behaviour in all its relations and with all its partners is a strong commitment of the Exclusive Networks group. This principle has led the Group to define rules of conduct in terms of ethics, intended for its employees as well as for all its business partners and stakeholders. Key date in the Group’s compliance policy

Creation of the whistleblowing hotline open to all employees and third parties

Creating an on-site visit programme of the main entities of the Group

Creation of the Risks & Compliance Department

Creation of the Ethics Champions network

2013

2014

2015 2016 2017 2018 2019 2020 2021

2022 2023

Publication of the first

Completion of the first corruption risk map

• Recasting of compliance procedures • Roll-out of a new third-party integrity review tool • Recasting of the corruption risk map

Code of Conduct

All procedures and policies are addressed individually to each employee as soon as they are hired through the Group’s e-learning platform. They give rise to an acknowledgment of receipt as well as a questionnaire to ensure that they are properly understood. In order to robustly address the risk of corruption or non compliance with internal business ethics regulations and procedures, the Exclusive Networks group regularly updates and develops its compliance programme, to take into account its corruption risk map as well as new regulatory and legal requirements. In 2023, the Group continued to update and complete its corruption risk management system on three major measures:  re-execution of the corruption risk mapping in accordance with the remediation plan;  creation of a programme for on-site visits to the Group’s entities and review of the implementation of the elements of the compliance programme;  review of the third-party onboarding system; and  training of employees and more specifically of the Executive Committee.

Through its internal policies and procedures, the Group establishes the guiding principles applicable to all its subsidiary companies, designed to provide employees with the rules of good conduct and behaviour to adopt in terms of business ethics and the fight against corruption. The compliance programme is structured as follows:

The whistleblower hotline allows all Group employees andpartners to report any behaviour that goes against these rules

3

Thematic procedures specify the rules applicable to all entities

2

The Code of Conduct forms the basis of the compliance documentation

1

Some of the policies and procedures that make up the Exclusive Networks group’s anti-bribery and corruption programme include the Code of Conduct, the Conflict of Interest policy, and the Gifts and Hospitality policy.

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Exclusive Networks SA

2023 Sustainability Report