COMPLIANCE Due diligence / RISK FACTORS AND CONSEQUENCES The Act of 27 March 2017 on the duty of care of parent companies and ordering companies requires large companies to prevent any serious violation of human rights and fundamental freedoms, personal health and safety, and the environment. The scope of application includes not only the company's activity, but also its sphere of influence (subsidiaries, subcontractors and suppliers). A due diligence fault may be committed due to a nonexistent, incomplete or ineffective due diligence plan. If a company fails to respond to a formal notice, it may be required to comply, with a penalty payment, or incur civil liability for environmental, health or human rights damage. The company executives' criminal liability may also be incurred. Finally, the company may suffer from a tarnished image in the event of a proven disaster. / MEANS OF CONTROL DESCOURS & CABAUD works with approved suppliers and service providers who respect the Group's values and commitments. Through the framework contracts put in place, suppliers undertake in particular to comply with the requirements of the Charter of CSR commitments for DESCOURS & CABAUD suppliers, which will be reviewed in 2023. This charter sets out the minimum standards required in terms of respect for human rights, business ethics (primarily the fight against corruption) and reducing environmental impact. All the Group's employees, as well as new arrivals, benefit from a training programme on the prevention of corruption risks as soon as they join the Group. In 2023, DESCOURS & CABAUD continued deploying its Sustainable Procurement roadmap, which was launched in 2019 after the Group had finished mapping its risks. This policy is focused on providing transparency throughout the supply chain through greater visibility of the social, environmental and ethical performance of its suppliers and business partners. The Procurement Division is responsible for ensuring the compliance of its listed suppliers. It is committed to implementing a process for monitoring and measuring social and environmental performance, and strives to engage product and service providers with the process. In 2022, all employees within the Procurement Division (and who had been in the company back in September 2021) received trained on the issues relating to this topic from training organisation ORSYS. They have also been alerted to the actions that must be implemented through the purchasing processes. To support the deployment of its approach among its registered suppliers, and in particular for a targeted scope of suppliers identified as representing the highest level of commitment and risk for the Group, a CSR evaluation by an independent third party (EcoVadis) is required into the environmental, social, business ethics and subcontracting performance. This system, already in place in previous years, has been maintained for 2023. The results collected form an integral part of the overall supplier assessments, which enhance the level achieved but also continual progress, encouraging suppliers to take the necessary corrective action. The Group's senior management team is also committed to upholding sustainable procurement practices. Meeting payment deadlines has been identified as an important objective. DESCOURS & CABAUD has been based in Shanghai for almost 20 years and has appointed a team of 25 people to manage its supplier qualification policy in Asia. Their efforts have resulted in a CSR code of conduct that covers respect for human rights, business ethics and the reduction of environmental impacts, on-site audits carried out by a dedicated team of inspectors/auditors and by third parties, and general purchasing conditions that include CSR obligations. More specifically, since 2022, a pre-qualification visit has been carried out upstream of the commercial relationship. This pre-audit addresses CSR compliance issues and helps to validate or reject the conduct of pre-contractual negotiations with the potential supplier: 100% of accounts payable opened since 2022 and 2023 have been approved by this pre-qualification assessment. 31 DECLARATION OF NON-FINANCIAL PERFORMANCE 2023_DESCOURS & CABAUD
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