Gifts & Hospitality Policy – External Version 2 Policy name: Gifts & Hospitality Policy Purpose: This policy sets forth the mandatory compliance rules and processes regarding giving and receiving business courtesies by all Schneider Electric employees. As such, it details the principles set forth in the Trust Charter . Schneider Electric (the Company) h as a zero - tolerance policy against any form of corruption. The Company does recognize that providing and receiving b usiness c ourtesies (as defined in this Policy) such as gifts, entertainment and hospitality packages is common practice to develop and maintain positive and constructive business relation ships. In different geographical locations, this practice can vary significantly, depending on local laws and specific customs. Irrespective of that, some business courtesies may create improper influence and conflicts of interest and , in some instances, such incentives may be or be perceived by regulatory bodies as corrupt practices to obtain undue advantage ( ex. a deal, inside information, advantageous contractual terms , etc . ) . Th e Policy does not apply to : • b usiness c ourtesies offered by Schneider Electric internally to its own employees and • donations , gran t s (see Philanthropy policy ) or sponsorship activities (see Sponsorship policy ) . The Policy compl e ments Schneider’s existing rules, including those contained in: - The Global Travel Policy - The Anti - Corruption Policy Audience: The Policy applies to all Schneider Electric employees and in all Schneider Electric’s affiliates when giving and receiving business courtesies . Content: 1. Definitions 2. Acceptability assessment – Key Principles 3. Approval Process 4. A ccounting C ontrols 5 . Common D ilemmas 6 . In case of doubt Confidentiality Status: Public Local adaptation authorization: Not possible Document Owner: Audrey Morin, Group Compliance Director Document Reviewer s : Nicolas Vlieghe , SVP Chief C ompliance Officer Peter Wexler, SVP Chief Legal Officer Chris Leong, EVP Chief Marketing Officer Karen Clarke, SVP Global Effectiveness Julie Ashton - Howorth, Chief Accounting Officer Pierre Lormeau, Fraud Examination Team Director Document Approver: Hervé Coureil, EVP Chief Governance Officer and Secretary General