DNFP 2020

2020 DECLARATION OF NON-FINANCIAL PERFORMANCE OF THE DESCOURS & CABAUD GROUP 33 Fair practices and purchasing policy Companies focus by their nature on commercial performance and productivity, but must nevertheless make it a priority to guarantee fair practices both within their organisations and with regard to their partners. The concept of fair practices concerns not only the ethical conducting of a company’s transactions but also its relationship with all its stakeholders: customers, public authorities, suppliers, partners, subcontractors, competitors, etc. In the field of social responsibility, fair practices involves the way in which a Company uses its relations with different economic partners in order to help obtain positive results, without exercising power over others for the purposes of making a profit, by ensuring an exemplary approach and by encouraging the involvement of its entire sphere of influence in CSR policies. DESCOURS & CABAUD intends to guarantee the principles of integrity and honesty in relation to all its stakeholders. It is a question of ethical conduct. The requirements for regulatory compliance imposed upon the Company with the aimof moralising its practices and encouraging the secure performance of its activities have increased exponentially in recent years. This obligation of fair practices is expressed in fields of activity as varied as the fight against corruption, fair competition, the encouragement of social responsibility throughout the value chain, etc. DESCOURS & CABAUD is therefore particularly keen to respect the following requirements: • To identify the risks of bribery at the different levels of its activities (in relation to the purchasing, sales, and logistics functions, etc.) • To train its employees and to raise their awareness of situations involving corruption and conflicts of interest • To comply with the regulatory provisions in terms of competition law • To put in place initiatives to prevent any form of commercial fraud (in relation to product conformity and the transmission of corporate communications). With regard to the application of fair practices to our Group, we will concentrate on those regulations that are both the most recent ones and those that have the greatest impact upon us, namely the risk of bribery, and the introduction of the European General Data Protection Regulation. The risks linked to purchasing policy will be examined from the viewpoint of the need for vigilance and of the concentration of logistical flows. THE RISK OF BRIBERY The main objectives of what is known in France as the “Sapin 2” Law, which came into force on 1st September 2017, are to “reinforce the transparency of public decision-taking procedures, to better prevent bribery and to punish it as quickly and severely as possible”; and to “place 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. This Law naturally applies to all the DESCOURS & CABAUD Group's French subsidiaries, but also to all its subsidiaries in other countries. The risk factors and their consequences: The companies concerned by these obligations must prepare a programme of conformity with anti-bribery requirements that involves several measures. Inspection of this system is henceforth entrusted to the Agence Française Anticorruption (French Anti-Bribery Agency), which is responsible for upholding integrity and honesty in economic life. Potential financial sanctions can be imposed of up to 200,000 euros for physical persons and up to 1 million euros for corporate entities. Bearing in mind DESCOURS & CABAUD’s geographical presence and the fact that its employees are subject to the constraints of each location, and despite the multiple initiatives taken by the Company, this risk remains a permanent focus of attention, even in relation to the Group’s Declaration of Non-Financial Performance.