technicolor - 2018 Registration document

DISCLOSURE ON EXTRA-FINANCIAL PERFORMANCE

FAIRNESS OF BUSINESS PRACTICES

FAIRNESS OF BUSINESS PRACTICES 5.7 GRI [103-1 Anti-corruption] [103-2 Anti-corruption] [103-3 Anti-corruption]

[103-1 Anti-competitive behavior] [103-2 Anti-competitive behavior] [103-3 Anti-competitive behavior] [103-1 Socioeconomic compliance] [103-2 Socioeconomic compliance] [103-3 Socioeconomic compliance]

Competition rules and anti-bribery 5.7.1 GRI [205-1] [205-2] Following regulatory evolutions, especially the Sapin II Law adopted on December 9, 2016, the Group performed an in-depth review of its Code of Ethics so as to be in compliance with the new regulatory requirements and business practices. Compliance with competition rules and prevention of bribery and corruption, together with more general business ethics rules, are at the core of our Code of Ethics. Our overall approach regarding these two aspects are presented in section 3.3.2 Code of Ethics and Financial Ethics Charter. The Antibribery policy has been reshuffled and a manual has been developed to present practical cases. The Travel and Customer Entertainment policy has also been updated to harmonize processes across businesses. The Third Party policy covering our relationship and engagement with agents, consultants, advisors among others, has been reviewed and communicated to sales and legal teams, in specific training. The sales agent template contract has been updated to streamline it and to take into account new anti-bribery requirements. Tax evasion 5.7.2 The Group operates in many countries around the world. Our strategy is to pay the right amount of tax in the jurisdictions in which we operate, as dictated by local requirements. We pay corporate income taxes, stamp duties, employment and other taxes. We also collect and pay employee income taxes, and indirect taxes such as import duties and VAT. The taxes we pay and collect form a significant part of our economic TAX PLANNING We engage in efficient tax planning that supports our business activities and reflects commercial and economic substance. We adhere to relevant tax laws and disclosure requirements in every jurisdiction in which we operate and seek to minimize the risk of uncertainty or disputes. Acquisitions, Group’s reorganizations and simplifications are driven by commercial factors as opposed to tax savings. We conduct transactions between Group’s companies on an arm’s-length basis and in accordance with current OECD guidelines. Technicolor will take into account the underlying policy objectives of relevant tax laws and will comply with current practices. Where tax contribution to the countries in which we operate. Our tax strategy accords with the following principles:

E-learning training targeting all employees categories has been delivered as well as on-site training for specific employees categories such as sales team, legal team or specific countries. Technicolor top management has shown its engagement by issuing several communication to all employees regarding anti-bribery practices, and by requiring regular updates on the anti-bribery program at the Audit Committee of the Company's Board of Directors. A risk mapping exercise was performed which involved among others, controlling and sourcing teams, business leaders and specific managers, in order to identify priorities areas for anti-bribery purpose. A subsequent screening of our third parties (customers, vendors, partners) has been done with the support of an external assessment (Lexis Diligence). Pertaining to these policies, any employee may report anonymously any suspected breach of competition rules or anti-bribery rules, and more broadly any breach of the Code of Ethics, through the whistleblowing portal (phone, email) in the countries where Technicolor is active.

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incentives and exemptions are implemented to encourage investment, employment and economic development, we aim to apply these in the manner intended to minimize the tax cost of conducting our business. We do not use artificial arrangements to generate a tax advantage.

The Group does not have an overall target effective tax rate.

TAX RISK Our tax policies aim to ensure that we identify tax risks and take actions to address them. Tax risk is considered as part of our management process and is overseen by the Company's Board of Directors. To prevent any tax risk, a worldwide tax guideline is sent annually to all the Group’s finance team to prevent, identify and mitigate the occurrence of risks. The Group has a dedicated tax team with the necessary experience and skill set, which works with the Group’s businesses to provide the required tax advice and guidance. Our controls and governance ensure that tax risks that could affect our business plans, shareholder value and reputation are identified and addressed by the finance and tax departments.

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TECHNICOLOR REGISTRATION DOCUMENT 2018