Anti - Corruption Policy – Version 3 – September 2021 4 Internal 2. Rules of Conduct “The fight against corruption is everyone’s business.” Nicolas Vlieghe , SVP Chief Compliance Officer 2.1 General rules regarding anti - corruption policy Bribery and corruption have a tremendous cost: - For companies: this is the financial and reputational cost, accompanied by legal proceedings, prosecutions and sanctions. - For individuals: this is a “human” cost, with penalty of imprisonment. - For the business: this is a competition cost, as companies accepting/giving bribes break the fair competition rules; also, a company may be debarred from public tenders/ public funds related projects in case of corruption. - For the Society: an economic, politic and environmental cost, as bribery and corruption maintain countries in poverty, by diverting public resources from crucial priorities, such infrastructures and access to basic needs such as energy. Our Anticorruption Policy mandates that everyone comply with our internal rules, dedicated policies and procedures put in place at Group and local levels. Managers are intended to walk the talk by complying with rules, spread the right message in their teams, and support reporting of misconducts. Beyond these internal policies and procedures, our Anticorruption Policy defines a course of action to be followed in all circumstances. In case of doubts, please contact your Compliance Officer. Local legislations may be stricter or less strict than our Policy : keep in mind that the stricter rule always prevails . Any non - compliance with the Anticorruption Policy will lead to sanctions, as defined in the section 4 “Sanctions” of this Anticorruption Policy . What is corruption? What is bribery? Corruption can be defined as the abuse of entrusted power for private gain and it can take many forms, including bribery. Bribery can be defined as the offering, promising, giving, accepting or soliciting money or anything of value, to obtain an undue advantage for oneself, for another person or for the company, by ensuring that someone in the public or private sector fails to respect his or her duties. Undue advantage can take the form of gifts, loans, fees, rewards or other advantages (taxes, services, donations, favors, etc.). Nature: active (briber) or passive (bribed person) bribery.
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