Anti - Corruption Policy – Version 3 – September 2021 5 Internal In this Policy , “Bribery” and “Corruption” are used as synonyms. Form: direct (directly by the company, its officers, directors or employees) or indirect (through an intermediary, business agent, partner....) Recipient/giver: our Anticorruption Policy applies to both private and public sectors, including but not limited to state - owned companies, government representatives and any other public officials. How to recognize risky situations? ("Red flags") Beyond a direct request to pay a bribe there are many situations that may represent a red flag and therefore specific caution is needed and enhanced diligence may be necessary to avoid or mitigate risks. Such red flags are but not limited to: • Use of a business agent or an intermediary; • Specific third party required or recommended by the client, without any legal basis; • Undocumented or insufficiently documented service; • Abnormally high fees or commissions; • Repetitive and / or disproportionate hospitality (meals, trips, etc.); • Unusual payment terms or cash payments; • Project to acquire or merge with a company located in a country at risk regarding corruption and which often interacts with public customers; • A potential business partner who refuses any reference to our Trust Charter and related policies in the consortium or joint - venture agreement A customer demands, for the final signature of a contract, the payment of a commission, in the form of a consulting service delivered by a third company imposed by the customer.  You must inform immediately your manager and your Compliance Officer. The procurement officer of a client requests a small compensation to increase our chance to win a bid Schneider Electric is participating.  You must refuse this kickback, defined as a type of bribe involving the payment of something of value to a recipient as compensation or reward for providing favorable treatment to another party.