Atos - Registration Document 2016

G Corporate governance and capital G.6 Code and charts [G4-15] et [G4-56]

Protection of Atos assets – Fraud G.6.2.4

The assets owned by Atos which consist in material such as used only for conducting Atos business and pursuant to the law hardware, or intellectual property rights or financial equity are

quality, reliable and relevant, translating exactly the activities of and rules defined by the Group: reporting must be of high the Company.

Duty to act in Good Faith, Protection of confidentiality and privileged information G.6.2.5

Atos to its clients and misappropriating the use of Atos services and assets for personal benefit. rules in order to prevent insider trading and misconduct. In addition, Atos ensures that in their decisions and actions, Atos employees Atos protects both its own confidential information and that provided by its customers, suppliers or partners. Moreover, Atos sets up act in good faith, such as refraining from acting in an inappropriate manner of any kind, including disparaging the services provided by

Alert system – employees’ rights and duties on G.6.2.6

regulation or one of the principles set out in the Code of Ethics immediate superior or to his/her GBU General Counsel or to the has been or is about to be breached, a right to report to his/her done in accordance with the regulations applicable in the country Group Head of Compliance, his/her concerns. This reporting is be Atos has established for any employee who believes that a law, in which he/she is employed. The employee who raises the alert is assured complete confidentiality in relation to the alert. The employee shall not be subject to any penalty or retaliatory measure or discrimination, provided that he/she acted in good

relating to the alert prove inaccurate or no action is faith and without the intention to cause harm, even if the events be assured, on his/her request, by mobility within the Group. subsequently taken. If necessary, the employee’s protection may material shortcomings in internal controls result in corrective All alerts that reveal fraudulent behavior, significant lapses or Anonymous reports are not considered, except if permitted by measures and/or disciplinary measures and/or legal action. local laws.

Other applicable provisions

G.6.3

comply with these rules regarding delegation of authority, Group governs the activities of each employee, who must The Code of Ethics’ principles are not the only mandatory established by the different departments and adopted by the provisions applicable within Atos. A standard of policies

mandatory contractual clauses for client and supplier contracts, the selection of potential employees and their training or the requirements. selection process for business partners, among other

Privileged Information and insider trading

G.6.4

securities, the Company aims at providing its investors and In order to ensure market transparency and integrity in Atos SE on its activities and performance. The Company requires all shareholders, under conditions that are equal for all, information

information to follow the insider trading rules and regulations senior managers or employees having access to critical

that can be found in the Prevention guide.

Insider trading

market regulation or legal violation which are liable to criminal, The use or disclosure of inside information constitutes a stock Market Authority) and civil proceedings. Accordingly, no regulatory ( Autorité des Marchés Financiers , the French Financial

deal in Atos SE securities when he or she is in possession of any employee may disclose any inside information to third parties or inside information.

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