Anti - Corruption Policy – Version 3 – September 2021 8 Internal During the review of specific contracts inherited from a company just acquired, you learn that some “privileges” were granted several years ago by the company to its clients to maintain the relationship, such as regular invitations to sports events for the management and their families, and annual event with entertainment activities were planned, hosted and paid by the company. You must report that to your Compliance Officer. Even if the company is a joint venture in which Schneider Electric has only shares, we must ensure compliance with laws and regulations and promote our Trust Charter and Anticorruption Policy . You must ensure that : • You comply strictly with the Business Agent Policy before contracting with any Business Agent as well as through the whole contractual relation; • You conduct due diligence on third parties in accordance with our internal processes and have them approved by the relevant managers; • You never engage in a relationship with a third party who refuses a clear commitment to fight against corruption; 2.2.4 Mergers and acquisitions Acquiring a company or company shares or proceeding to a merger with another company may represent some risk for Schneider Electric. Once an acquisition is consummated, we may be held liable for wrongdoings occurring before the acquisition or the merger. You must ensure that : • You comply with internal procedures of due diligence related to M&A operations; • You ensure full compliance with Post - Merger Integration process, especially regarding implementation of our Trust Charter and our Anticorruption Policy . • You report to your Compliance Officer any suspicions of violation of either our Anticorruption Policy and of anticorruption laws and regulations. A supplier approaches you to inform you that he has relatives working for some potential clients to which Schneider Electric will submit an offer and he proposes to liaise with such relatives asking them to do a favor for Schneider Electric. He suggests being paid for this “assistance” by issuing an invoice for “other costs” linked to its supplying agreement. You must refuse the proposal and report to your Compliance Officer. “Other costs” allocation requested by a contractor is considered as a red flag.
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