DNFP 2020

2020 DECLARATION OF NON-FINANCIAL PERFORMANCE OF THE DESCOURS & CABAUD GROUP 34 In addition, the Company is also potentially exposed to the risk of harm to its image, the impacts of which may be measured in the short or medium term. The means of control: DESCOURS & CABAUD, through its Risk Committee, has taken great pains to implement the eight measures required by the Law: • A map of bribery risks for each sector of activity and geographical area, in the form of a document that is updated on an annual basis. This map has been produced in France on the basis of interviews with managers and front-line staff, not only from a viewpoint of actual risks encountered but also in terms of potential future risks • A DESCOURS & CABAUD Code of Conduct for the attention of employees, appended to the company’s internal regulations and established according to the provisions of Article L.1321-4 of the French Labour Code, the aim of the latter article being to provide the necessary keys in terms of conduct to be adopted or prohibited. It has been translated into all the languages of the countries in which the Group operates, and has been handed to all employees • an internal alert system allowing for the reception of employees’ reports concerning the existence of conduct or situations that go against the company’s Code of Conduct and/or are illegal. The system for transmitting such alerts and for protecting the whistle- blower concerned is defined by the Code of Conduct. An Ethical Committee receives the alert, analyses it and checks its validity, and, if appropriate, transmits it to one or more persons charged with conducting an inquiry • a training system intended for those employees who are most exposed to risks: a French e-learning module has been distributed to the entire sales force and its management team A translation of this training system for international subsidiaries is currently being completed for roll-out in 2021 • 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, top-level suppliers, and the intermediaries with whom the Group has business relations Action plans for the latter measure need to be developed and implemented. The Executive Board's commitment to these anti-bribery provisions has led the Group to adopt exemplary conduct that will not tolerate any deviation and that finds its expression in a clearly asserted motto: We are all exemplary, we are all concerned, and we are all vigilant. Key performance indicator: We maintain our intention to attain a rate of training via e-learning of at least 90% of the anti-bribery module by the entire salesforce and its management team. These e-learning training sessions are considered as “validated” on condition that a minimum rate of correct answers of 80% is obtained. If the rate of correct answers is lower, the training session is not validated and the trainee must repeat the entire course. Rate of training for the e-learning anti-bribery training course: 50% 60% 70% 80% 90% 100% 110% 2019 2020 90% 89.6% Target 90%