Sustainability Report - FY 2023

Corporate culture and business conduct policies Transparency and the fight against tax evasion

Managing the compliance programme Audits are regularly conducted jointly by the Group’s internal audit department. They carry out tests and interviews to identify risky practices or any deviations observed as well as corrective actions to be taken.

The Exclusive Networks group has set itself the objective of having all countries subject to an audit including an anti-corruption component at least every 5 years, with the net margin of the entities covered by the audit plan representing 30% of the Group’s net margin.

Key monitoring indicators

2022

2023

Number of entities covered by an audit with an anti-corruption component

Monitoring, follow-up and evaluation of the implementation of the Group’s

14

13

Number of proven cases of identified corruption

0

0

Number of employees dismissed or disciplined for corruption

0

0

compliance programme

Number of convictions for corruption against the Exclusive Networks group, or one of its subsidiaries

0

0

8.3

Transparency and the fight against tax evasion

Organisation of the tax function The Exclusive Networks group’s tax department is organised around a central team, integrated into the Group’s Finance Department, which relies on local finance teams and external advisors to ensure that the Group pays taxes due in the jurisdictions in which it operates and that risks are identified, assessed and controlled. The tax department’s mission is to ensure compliance with applicable local and international tax laws and regulations, to minimise tax exposure by managing tax risk, to limit double taxation and to benefit from the tax incentives or concessions to which the Group is entitled. Compliance, Transparency and Fiscal Accountability The Exclusive Networks group has offices in 47 countries. Due to the global and cross-border nature of its distribution business and the complexity of the international tax environment, the Group faces uncertainties and tax risks inherent in its business.

This is due to the multiplicity and complexity of tax regulations, both local and international (including transfer pricing rules and principles governing the application of withholding taxes), and their interpretation in each country. In this global and complex environment, the Exclusive Networks group aims to comply with all applicable tax rules and regulations in the countries where it operates, ensuring that the right amount of tax is paid in the jurisdictions where it generates profits and value. As such, Exclusive Networks is committed to complying with local and international rules, including the “OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations”. Exclusive Networks handles tax-related matters with integrity and does not engage in any artificial tax schemes. In addition, each of the Group’s locations abroad aims to expand the Group’s activities by ensuring a local presence when operational and commercial needs require it.

65

Exclusive Networks SA

2023 Sustainability Report