Worldline - Registration Document 2016

Corporate and social responsibility report Annex III - Being an ethical and fair good player in business

Response Process and confirmed as a critical concern. All case investigated at Group level through the Non-Compliance Officer, who will report to the Group Executive Committee any Response Team is reported to the Group Chief Compliance Any case which is investigated by the Non-Compliance governance matters as far as compliance is concerned are Document. described in Chapter 4.5 Risk management in this Registration through this process [GRI 102-34]. In 2016, no cases deemed critical were reported at global level export control laws, and fraud in general. bribery, corruption, and violations of competition laws and and as an affiliate of the Atos group, Worldline has implemented As a signatory of the United Nations Global Compact since 2010, several internal policies to prevent compliance risks such as specific piece of software, the Business Partner Tool): their before the beginning of any business relationship (using a Worldline in developing/retaining its business are screened Any intermediaries, consortium partners or consultants assisting is screened by the Legal, Compliance and Contract disproportion regarding the compensation, the business partner are verified beforehand. In case of risk of corruption/insolvency/ behavior and knowledge of ethics are essential criteria which To protect Worldline from any disproportionate gift or benefit provider or recipient. Management can carry out checks in case gifts, invitations and other benefits of which Worldline is a gifts and benefits was implemented in 2013, aiming to screen given or received by a Worldline employee, a policy concerning of identified risk. Atos group’s policy), which defines roles and responsibilities of Worldline has also rolled out an anti-fraud policy (as part of the approval by the Finance department. Management department, which recommends or not the faith to line management or, if applicable, to the competent measure against workers who report illegal practices in good prohibits Worldline from any discriminatory or disciplinary the management and support function in preventing fraud, and Worldline’s General Counsel is responsible for internal Group Compliance Team of Atos in coordination with raised by an employee or assumed by an internal control, the public authorities. If an allegation of fraud/non-compliance is investigations. competitors. to be adhered to by meetings with potential and known A roundtable policy, stipulates the main rules of fair competition clear processes to mitigate risks. Thanks to these measures, the prohibitions related to Export Control Regulations, and providing An Export Control policy, explaining the main principles and suppliers related to corruption. regulations in 2016. It received no complaints from clients or non-monetary sanctions for non-compliance with laws and Group was not subject to any penalties or any major [GRI 102-17] Policies to prevent compliance risks A.4.1.1.3

compliance matters processed by the Group Operational Group’s compliance approach, by rolling out and monitoring Steering Committees (bottom-up). compliance related reporting to the Group Compliance Compliance Committee (top down) and by improving Team: initiated and implemented by the Group Legal Compliance governance framework by way of several concrete measures Additionally, Atos recently enhanced the compliance of the Group Compliance Team; local leadership of compliance matters under the guidance the General Counsels of Atos, aiming to strengthening the Creation of a Global Legal Compliance Board involving all ● composed of compliance KPIs, aiming to improve the Development of country compliance dashboards, ● reporting to the Group Compliance Steering Committee, programs within the GBU Compliance Committees; and the monitoring of the effectiveness of the compliance clarification of the ambit of responsibilities and duties; Improve the role of the compliance function including the ● key compliance topics; program through presentations and trainings on a variety of compliance culture by greater visibility of the compliance Enhance compliance leadership and the overall Group ● Committee. to the Group Compliance Program to the Group Executive Communication on the milestones and realizations related ● A.4.1.1.2 will launch the Non-Compliance Response process [GRI 102-33]. the Head of Internal Audit (both within Worldline and Atos), who to be reported to the Head of Legal and Compliance and/or to Any suspected non-compliance detected within the Company is event of breaches of the Code of Ethics, and/or infringements of (defined in the Group’s anti-fraud policy) to be followed in the The Non-Compliance Response process is an internal process Compliancemonitoring actions in a measureable and consistent manner, in case of investigate report and take decisions, such as remediation the applicable laws and regulations. This process defines how to non-compliance behaviors.

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Worldline 2016 Registration Document