23 2021 DECLARAT ION OF NON-F INANCIAL PERFORMANCE DESCOURS & CABAUD The r i sk of br ibery The Sapin 2 Law sets the main objectives which consist in “reinforcing the transparency of public decisiontaking procedures, better preventing bribery and punishing it as quickly and severely as possible”; and “placing France on a par with the best international standards in the fields of transparency and of the fight against bribery.” This law includes an ambitious anti-bribery mechanism, and establishes new obligations for companies to prevent risks of bribery or the illegal protection of corporate self-interest. It applies to all international subsidiaries of the DESCOURS & CABAUD Group. Given its geographical reach, the Group pays constant attention to the application of this law. The risks incurred can reach €200k for individuals and €1m for legal entities. In addition to these financial penalties, the Group is also potentially exposed to the risk of harm to its image, whose impacts on performance may be measured in the short or medium term. In its ethics charter, the Group states the common values around which it wants to unite the actions of all its employees and the conduct that each of them must adopt with the company's customers, suppliers and partners. In addition to sharing these fundamental elements, the Group has put in place the measures required by law, including: • A corruption risk map to identify, analyse and prioritise the company's specific exposure risks. This initial mapping has been produced in France following interviews with managers, both in terms of actual risks encountered and in terms of potential risks; • An anti-corruption code of conduct, translated into the languages of the countries where the Group is present and given to all employees, which recalls the Group's commitment to a zero tolerance policy, presents the behaviours to be avoided and mentions the penalties in the case of violation; • A whistleblowing system that allows employees to report any breach or situation that is contrary to the code of conduct. It ensures the protection of whistleblowers as provided for by the Sapin 2 law. An Ethical Committee receives the alert, checks its validity, and, if appropriate, transmits it to one or more persons charged with conducting an inquiry; • A training course for the sales force and its management. After being rolled out in France in 2020, 2021 was devoted to the translation of the e-learning training course and then to the launch of its rollout, in the last quarter, in the international subsidiaries; • Internal and external accounting control procedures to ensure that the accounts do not hide corruption and influence peddling; • Procedures for assessing the situation of customers, primary suppliers and consultants in relation to the corruption risk map. RISKS AND CONSEQUENCES MEANS OF CONTROL
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