Gifts & Hospitality

Gifts & Hospitality Policy First publication : November 2015 Current publication : January 2022 Version : 2 Document type : Policy Scope : Global

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

Gifts & Hospitality Policy – External Version 3 Business C ourtesies – a ny thing of value, such as Gifts , E ntertainment or H ospitality , directly or indirectly offered to or received by third parties (customers, suppliers, partners, etc.) . Business C ourtesies may include, but isn’t limited to: o Marketing material – any kind of branded element and material used to promote a company , its product or its services (business cards, letterhead, flyers, brochures, booklets, thank you cards, catalogues, postcards, USB drives, pens, mugs, tote bags ... ). o Gift – a ny tangible or intangible benefit given or received without the expectation of payment or any thi ng in return ( e.g. loans, prizes, transportation, use of another company ’ s vehicles, use of vacation facilities, stocks or other securities, participation in stock offerings, home improvements, tickets , gift certificates , etc . ) . o E n tertainment – a ny form of hospitality, promotional spending , cultural or sports activities, events, occasional business meals or drinks where Schneider Electric employee and third - party employee are present . If Schneider Electric employee is not present during the activity , such activity is considered as a gift . o Hospitality P ackage – any reception and entertainmen t for existing/potential partners, distributors, customers or other third - party to participate in S chneider Electric - organized events or third - party events for marketing, promotional or advertising purposes (e.g. Innovation Summit) or to perform a Factory Acceptance Test. Public O fficial ( also called G overnment O fficial) : o a nyone holding a legislative, administrative or judicial position ; o a ny elected official or employee of a government, ministry, public agency, political party, state - owned enterprise, or other government institution ;  for the purposes of this Policy, a state - owned enterprise , is a legal entity created by a government to take part in commercial activities on its behalf or with a specific purpose defined by law. If needed, please rely on local legislation for other definitions applicable to your jurisdict ion. o a ny official or agent of a public international organization (e.g. the United Nations Organization, the World Trade Organization...) . 2.1. P rinciple s for all Business C ourtesie s In line with our Anti - corruption policy, Schneider Electric employees must assess compliance of a Business C ourtes y before offering or accepting them , by using the 6 “Gold en ” principles : Principles Description Examples of a llowed B usiness C ourtesies Examples of f orbidden B usiness C ourtesies 1. Regulatory Compliant Must comply with local and international laws and Allowed by receiver’s country of residence / country of origin and recipient’s company . In some countries B usiness C ourtesy for public officials are 1. Definitions 2. Acceptability assessment – Key P rinciples

Gifts & Hospitality Policy – External Version 4 regulations , and recipient’s internal rules. prohibited. See Appendix if not forbidden. 2. Legitimate Business Purpose Must have a legitimate business reason , i.e. any purpose that is principally designed to promot e , demonstrat e or expla in products or services . Should benefit only the recipient and not be extended to friends, life partners or family members. - T he team in charge of a client’s project host ing a meeting with a client’s representative to discuss next steps. At the end of the meeting, the team organizes a cocktail reception at SE’s office. - Inviting a customer represen ta tive for a site visit to demonstrate a solution which is present only in this location - paying for an expensive dinner in a fancy restaurant with a customer representative - paying for travel cost for the customer representative and his/her family - invit ing for a site visit in a touristic location to obtain an advantage in a tender 3. Frequency acceptable Should be offered to or received occasionally ( from the same person ) . - T he team offers some goodies and branded pens to the clients participating in an innovation workshop at Schneider. - M eeting with a vendor on a monthly basis for a project update and then inviting him/her for a working lunch T ravelling with customers to a conference and paying for their meal in restaurants for all 7 days of travel . (see principle 4 below for reasonable value) 4. Reasonable in value and nature Never accept /offer a Business C ourtesy that could not be offered /accepted in return because of its value and/or nature. What is reasonable in value and nature : • No c ash or cash equivalent (gift vouchers, shares or anything redeemable to cash) regardless of the amount • No g ifts or e ntertainment valued over 250 EUR (per gift/per person ) • H ospitality Package s with minimum 80% agenda dedicated to business related activities • No u se of personal funds; • No B usiness C ourtesy personally benefiting the recipient; • Any gift in the form of a commitment - Brand materials - A site visit agenda which has 6 hours training/business meeting and 1 hour sightseeing tour TIPS: Schneider’s catalog of SE products that employees can choose from to offer to third parties is available here: https://www.se - branded.com/Index - Adult entertainment, i.e., nightclub - type entertainment wit h an overtly sexual content . - Factory acceptance test travel to a touristic location where the test takes 2 days and other 3 are allocated for pleasure - Commitment to hire a public official’s relative in exchange of a deal

Gifts & Hospitality Policy – External Version 5 5. F ree from undue influence Business C ourtesy should be appropriate to the giver and the beneficiary positions and circumstances. It should therefore never be offered to influence a decision in favor of the given counterpart y or be solicited or creating an obligation on the recipient to give something in return Pay attention to appearances. Even the only appearance of such a situation might create inappropriate judgement . Providing a small souvenir for national holiday and other customary occasion which does not oblige the recipient (e.g. bar of chocolate, postcard, flowers ) (see principle 4 above for reasonable value and nature ) - a B usiness C ourtesy given in secret and/or undocumented. - invitation to travel given to/received from a supplier/customer during a tender process or contract negotiation/renewal given to influence decision maker . - a small, unlawful sum of money given directly or indirectly, to someone to perform routine functions or speed up admini strative formalities which the person is required to provide ( also called “facilitation payment ” ) . 6. P roperly approved and recorded Business C ourtesies must be properly approved (see Section 3 - Approval process) and recorded as such in the accounting documents. 2. 2 . Additional principle s for Hospitality Packages Specific attention should be given to Hospitality packages due to a high cost and potential risk of misuse of such incentives. See below requirements for such travel: Certain c ountries ban Business C ourtesies to public officials (including hospitality packages), See A ppendix for a list of those countries . In countries that allow Hospitality Packages to clients who are Public Officials (e.g. employees of state - owned companies) - such as travel to see a solution prior to a tender or conduct factory acceptance tests abroad after delivery of the project - it is required to clearly state the conditions for the travel by following requirements: ▪ S end an official invitation to the Public Official stating the r ea son for travel and what exactly the Hospitality Package will contain (i.e. what will be paid and what will be not paid by Schneider Electric) ▪ I nform the third party that, in the end, the costs will be charged on the project costs ▪ O btain a confirmation from the third party that the Hospitality Package is in line with ✓ local legislation and ✓ their internal policies . ▪ T he Public Official should arrive to the location maximum 1 day before the event and leave maximum 1 day after - no extra stay is allowed . Allowed Forbidden • Lodging: Hotel Accommodations must be aligned with Schneider Electric’s local Travel p olicies in terms of standing and costs (price per room for a hotel in the Country where the Hospitality Package is given or received) . No 5 - star hotels are allowed for pu blic officials • Transportation (airfare, train, taxi) : Travel class m u st be alighted with local Travel policies • Meal (in line with local thresholds for hospitality ) • Some entertainment activities are possible but should be limited to 20% maximum of agenda’s time • Third - party events’ participation fees • Other travel related expenses (e.g. visa’s cost) • Travel and travel - related expenses for relatives , spouses and other guests • Personal expenses • First - class air travel or private jets expenses • Per diem paym ents* __________________ * Per diems or daily allowances are specific amount of money that an organization gives to cover living expenses when travelling on the employer's business.

Gifts & Hospitality Policy – External Version 6 Before accepting or offering a Business C ourtesy , Schneider Electric employees must review their local charts of approval and received necessary pre - approval if needed. Business C ourtesies offered by Schneider are entered without delay in its accounting document s. They are precisely and clearly identified in the accounts and are unequivocally worded (e.g. equivocal wording: miscellaneous expenses, other, expense reports without receipt, etc .). “I don’t know the value of the Business C ourtesy ...” If you are given a Business C ourtesy in a face - to - face setting, and you are unable to immediately ascertain wh at its value is and if you need pre - approval or not , you may seek approval for such Business C ourtesy upon your return to the office following the process described in section 3 . If approval is not given, you must make immediate arrangements for its return, explaining politely why you are unable to accept it. “But it would be impolite to refuse...” Employees may encounter situations where they feel social pressure to accept a Business C ourtesy that goes beyond Schneider Electric ’s Gifts & Hospitality policy , and do not wish to offend the donor. In such case, employees have to decide on the spur of th e moment and must use their judgment. In practice, a polite refusal, by referring to Schneider Electric ’s internal policy, may well be understood. “Surely there is no problem with a seasonal gift...” Similar dilemmas can apply to seasonal gift - giving, for example at Christmas , Ramadan or during the New Year period. Schneider’s polic y applies all year round. As such, employees need to ensure that they do not offer or accept anything that does not align with this policy during such seasonal periods by respecting the rules defined in this policy. What about Innovation Summits related Hospitality Package? Global guidelines are set up specifically for Innovation Summits, which may include specific rules for related Hospitality Packages, validated in advance by Group Compliance Team. Such rules may include local review by Compliance Officers: to do so, the Hospitality Package must be approv ed as defined in Section 3. 3. Approval Process 4. Accounting Controls 5. Common Dilemmas

Gifts & Hospitality Policy – External Version 7 “But he’s a personal friend of mine!” In some cases, it may turn out that a business partner is a personal friend, or they may become a friend as a result of a long professional relationship. Even so, the same principles apply. In the event that a personal relationship entails frequent exchan ges of Business C ourtesies , said relationship should be registered in Schneider’s conflict of interest regis ter as a potential conflict of interest. The conflict of interest regist er is accessible through Schneider’s intranet page. Please read the Conflict of Interest Policy if needed. Use your common sense and always ask yourself whether this is something you would want to see on the front of the newspaper or testify to in court. If in doubt about any aspect of this Policy (in particular when a Business C ourtesy has no face value or the face value is in a different currency), employees should seek advice from their line manager or contact their Regional Compliance Officer. Their contact information is available on Schneider’s Ethics & Compliance intranet page. 6. In case of doubt