technicolor - 2018 Registration document

DISCLOSURE ON EXTRA-FINANCIAL PERFORMANCE

VIGILANCE PLAN

The presentation and report are done according to this subdivision of scope

Scope: Activities of the Group and its controlled subsidiaries

Scope: Activities of subcontractors or suppliers

1 Risk mapping Through the analysis of materiality of risks, the Group identified six macro risks translating into 22 CSR issues (see section 5.1). This analysis was performed internally in 2018 by the Ethics Compliance Committee. It included the Internal Audit, HR, Legal, CSR, IT Security departments and the business divisions. CSR inquiries received from and focus points expressed by external stakeholders to the Group were also integrated.

The methodology to assess risks is the EcoVadis Rating Framework , using country risk and industry risk (See section 5.3.1).

2 Procedures for regular assessment of the situation, with regard to risk mapping Internal controls and management of risks (see section 3.1 to 3.4). • Internal Audits and other periodic monitoring (EH&S) (see • section 5.5 and 5.2.5).

Assessment of suppliers by an external third party EcoVadis. It • covers all direct suppliers with purchasing exceeding €1 million of spending per year per business division. It represents 91.7% of spending of the Group. 55% of spending are already assessed. Physical on-site Internal Audits of critical suppliers for higher risk • country and industry. RBA (Responsible Business Alliance) audits. • Agreement with Group’s Suppliers Ethic policy as part of terms and • conditions of contract. Implementation of corrective/remediation measures in case of • violation/breaches of critical principles discovered during on site audits. Certain violations generate immediate breach of contract (see section 5.3.1). Internal physical on-site audits with finding reports available to • business division and sourcing (see section 5.3.1). Global whistleblowing procedure access progressively extended to •

3 Appropriate actions to mitigate risks or prevent serious harm Policies are described in Chapter 5 with regard to CSR issues. •

4 Warning and collection process of alerts relating to the existence or the materialization of risks Global whistleblowing procedure (phone, email, website) in place • since more than 10 years for breach of the Group’s Code of Ethics and Code business ethics. It covers harassment, discrimination and human rights topics and any breach of compliance of fraud. (see section 3.3.2).

Supplier’s employees in countries of presence. NGO and CSR agencies reports and inquiries. •

In several countries/sites, additional local procedures to collect and • investigate about harassment/discrimination complaints are in place and include protection of the complainer. 5 Monitoring the measures implemented and evaluating their effectiveness Internal control procedures (see section 3.1 to 3.4). • EHS audits and other periodic monitoring (see section 5.5 and • section 5.2.5).

5

Verification of effective implementation of corrective actions • requested to suppliers. Evolution of nature and volume of violations of Ethics conditions by • suppliers. Monitoring the evolution of EcoVadis rating of suppliers. •

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TECHNICOLOR REGISTRATION DOCUMENT 2018