DNFP_2018_English

2018 DECLARATION OF NON-FINANCIAL PERFORMANCE OF THE DESCOURS & CABAUD GROUP 27 THE RISK OF BRIBERY Totally in linewith current regulations in theUnitedStates and the United Kingdom, the French lawmakers have put in place an ambitious anti-bribery system liable to reinforce confidence among France's trading partners. This is enshrined in the Sapin II Act, which came into force on 1 st September 2017 and which imposes new risk prevention obligations on companies concerning bribery or the illegal taking of interest. This ACt naturally applies to all DESCOURS & CABAUD's French subsidiaries and also to all its foreign subsidiaries. The risk factors, consequences and means of control: The content of these obligations is set out in a programme of several measures, which must be implemented. Inspection of this system is henceforth entrusted to the Agence Française Anticorruption (French anti-bribery agency), which is responsible for controlling integrity and maintaining high ideals in economic life. This Agency can impose fines of up to €200,000on individuals and one million euros on legal entities. In addition to these financial penalties, the company is also potentially exposed to the risk of harm to its image, the impacts of which can be measured in the short or medium term. > The means of control: DESCOURS & CABAUD has taken great pains to implement the eight measures required by law: • risk mapping by business segment and by geographical segment. A mapping of bribery risks has been produced in France on the basis of interviews with managers and front-line staff, both in terms of actual risks encountered and in terms of potential risks • a DESCOURS & CABAUD code of conduct for the attention of employees, appended to the company rule book: this provides the necessary keys in terms of required or prohibited conduct • an internal whistle-blowing procedure: this procedure, described in the code of conduct, stipulates thewhistle- blowing arrangements, arrangements for protecting a whistle-blower who reports any serious breach of the code of conduct and/or the law in general • a training plan intended for employees who are most exposed to the risks: an e-learning training module leading to qualification, which when completed measures knowledge acquisition, has been circulated to all the sales force, and will be circulated to all employees in 2019 • disciplinary measures penalising breaches of the code of conduct: they are expressly included in the latter • account auditing procedures • a system that controls and assesses the implemented measures • procedures for assessing the situation of customers and suppliers, as well as the intermediaries with whom the Group has business relations Action plans for these last three measures need to be developed and implemented. The Executive Board's commitment to these anti-bribery arrangements has led the Group to adopt exemplary conduct that does not tolerate any deviation and that finds expression in a clearly asserted motto: We are all exemplary, concerned and vigilant. We must therefore ensure that the programme has been introduced and implemented, both in France and abroad, where it has started being deployed.