Sustainability Report - FY 2023

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

Third-Party Review All third parties with whom the Exclusive Networks group intends to initiate or continue a business relationship are subject to a specific and appropriate onboarding process, aimed at determining the level of potential corruption risk posed by each third party, and implementing the necessary mitigation measures to ensure compliance with the ethical standards that the Group has set for itself. Accessible to all employees, this system makes it possible to quickly identify whether, in the absence of any negative signal, the risk is low, or conversely if a risk in terms of corruption or ethics is detected. When the tool detects negative signals, the third party concerned is considered “at risk”: additional checks are then

initiated and submitted to the validation of the Risk and Compliance Department and the Country Manager concerned. In 2023, the Group developed the process and included:  updating internal and external questionnaires to conform to evaluation best practices;  creating two new categories of third parties (payment agents and charities);  updating the approval process; and  implementing e-learning training for high-risk third parties. This third-party integrity review system is being rolled out gradually, which will continue in 2024.

The Group’s target of completing 100% of due diligence on high-risk third parties was achieved in 2023.

Key monitoring indicators

2022

2023

Number of third parties assessed in the integrity review system Number of moderate or high risk third parties who have formally endorsed the Code of Conduct*

Assessment of the integrity of third parties with whom the Group has or will enter into a business relationship

4,968

11,962

141

512

* Indicator with a target for 2025.

Communication, awareness-raising and training actions Since 2015, compliance training has been provided several times a year:  by the Risk and Compliance Department, in particular during seminars organised in person and more occasionally during the year, during face-to-face or online meetings;  by the Ethics Champions, directly with their local teams, after having themselves been trained by the Risk and Compliance Department; and  by the Risk and Compliance Department, when a new Chief Financial Officer or Country Manager is integrated. The training courses organised by the Risk and Compliance Department are adapted whenever possible to the functions of the participants (marketing, finance, General Management or Ethics Champions). The training courses organised by the Ethics Champions are most of the time common to all employees in the region, based on the training materials prepared by the Risk and Compliance Department.

In 2023, the Risk and Compliance Department executed its training plan which included the following trainings:  face-to-face training of the Executive Committee by a specialist speaker on 17 March 2023;  face-to-face training for Country Managers on 19 April 2023;  face-to-face training for employees of entities that have re-executed the corruption risk mapping exercise;  training of all employees by the entity’s Ethics Champion; and  training of Ethics Champions, including the creation of the first Ethics Champions seminar for the EMEA region.

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Exclusive Networks SA

2023 Sustainability Report