Sustainability Report - FY 2023

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

Updating and centralising the corruption risk map The Group’s activities and processes are subject to regular risk analyses, which aim to provide appropriate and proportionate remediation solutions to detect and prevent these risks. In 2022, Exclusive Networks undertook the complete overhaul of its specific mapping dedicated to corruption risks, in accordance with the recommendations of the supervisory authorities. This project, which was of major scope, covered all of the Group’s operating companies. Based on all of the Group’s functions and with the support of an independent consulting firm, the methodology has been designed taking into account the recommendations of the Agence Française Anticorruption and best practices according to international standards. This project made it possible to map the corruption risks of each of its subsidiary companies carrying out an operational activity.

The updating of this mapping has led to the updating of the scope of the risks considered and the associated action plan. The results of this work and the consolidated remediation plans at Group level were presented to the Executive Committee and the Audit and Risks Committee on 28 April 2023. During this update and consolidation, the Compliance Department was able to observe that some entities had underestimated risks. The entity concerned was then asked to review its risk mapping as part of its remediation plan. The re-execution was coordinated by the Risk & Compliance Department, which provided in-person training on bribery and corruption risks to all of the entity’s employees. In addition, the risk scoring workshop was conducted in person, unlike the previous year when the scoring workshops were conducted remotely.

Key monitoring indicators

2022

2023

Carry out the re-execution of the corruption risk mapping in accordance with the remediation plan established in 2022

Number of entities for which risk mapping has been rerun

59

8

Number of local employees involved in the risk assessment

463

63

Creating an On-site Visit Programme In 2023, the Risk and Compliance Department inaugurated a new “On-site Visit” programme to ensure the effective deployment of the anti-corruption

and Ethics Champion, deepening understanding of the risks specific to each area;  monitoring the implementation of the programme, which involves in-depth discussions during which the practical application of the procedures is examined in detail. In some cases, examples of implementation can be requested as an indication, thus facilitating the identification of good practices or areas for improvement. Each visit concludes with an email highlighting the best practices identified as well as areas in need of improvement.

programme at the local level. The visit programme includes:

 face-to-face training for all employees, with Groups of up to 20 participants. The topics covered are aimed at strengthening the understanding and awareness of risks within the organisation;  targeted interviews with key functions such as Country Manager, Human Resources, Marketing, Sales, Finance,

Key monitoring indicators

2023

Establish a site visit schedule

Number of entities visited

9*

* The 9 entities visited cover the following regions where the Group operates: Europe, Asia, Middle East.

62

Exclusive Networks SA

2023 Sustainability Report

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