Sustainability Report - FY 2023

Corporate culture and business conduct policies Export Controls

The first line of risk management is made up of the Country Managers and Export Control Champions of the Group’s main subsidiaries. The second line of risk control is provided by the Group Export Control Manager, who defines the export control strategy and associated procedures, and ensures regulatory monitoring, which is particularly critical given the geopolitical situation and the speed with which sanctions regimes are evolving. The Internal Compliance Programme:  is the bible of procedures to be followed by the Group and its subsidiaries to comply with regulations, such as the procedure for drawing up the declaration of final destination and end use;  incorporates training components;  refers to other internal procedures of the Group, such as the third-party screening system (Refer to the chapter 2 of the 2023 Universal Registration Document - Risk Factors - Screening through ‘‘My TrustedPartner’’ platform). In addition, the Group regularly conducts audits, either by the internal audit Department or by independent firms.

In 2023, the major actions evolved following the arrival of the Export Control Group Manager and the main improvement actions undertaken consisted of:  updating the Group’s Export Control policy (certification rate of 96% of the Group’s employees, including its subsidiaries);  process review (know your end-user, resellers, etc.);  the strengthening of coordination between the Export Control Champions with the implementation of regular communications and the coordination of the Export Control Champions network, its training and the systematic implementation of an export control clause in the Group’s distribution and sales contracts; and  the review of key export control points in coordination with the Group’s internal control Department. Prospects: The 2024 improvement actions identified will focus on the IT tool for screening end-users, the deployment of training modules available on the Group’s e-learning platform and the update of the Internal Compliance Programme.

67

Exclusive Networks SA

2023 Sustainability Report