Atos - Registration Document 2016

D Corporate Responsibility D.4

Ethical excellence inAtos’ sphere of influence

Ethical excellence inAtos’ sphere of influence D.4

Ethical excellence within the entire group

D.4.1

Compliance

D.4.1.1

[G4-DMA-Anti-corruption] and [G4-DMA-Compliance]

Tone from the Top

Policies, processes and Internal controls to prevent non-compliance risk

approved the Compliance Strategy plan to be deployed in all Atos Business Units on December 7, 2016. of Atos on 2015, the Group Compliance Steering Committee, composed of Group Executive Committee members and key Directors, focuses on strategies and priorities of Atos Compliance program, as defined by the Group Legal Compliance Team. It Having received mandate from the Group Executive Committee monitoring compliance matters into the local operations. Compliance Committees at Business Unit level ensure a consistent approach to Compliance at Atos, by rolling-out and Group Legal Compliance Team: Atos enhanced the compliance governance framework by way of several concrete measures initiated and implemented by the Group Legal Compliance Team; creation of a Global Legal Compliance Board involving all the • General Counsels of Atos, aiming to strengthening the local leadership of compliance matters under the guidance of the development of Country Compliance Dashboards, composed • of compliance KPIs, aiming to improve the reporting to the Group Compliance Steering Committee, and the monitoring of the effectiveness of the compliance program within the Business Units Compliance Committees. highest level of Atos Group (detailed information on the Code of Ethics in section G.6.2). The Code has been attached to all employment contracts concluded as from January 1, 2011. Atos Code of Ethics which introduces Atos’ commitment to comply with highest standards of business integrity, business ethics and latest regulations, was approved by Atos Group Board of Directors, demonstrating promotion of ethical excellence at the highly respected external professionals, has been created with the mission to strategize on the role of ethics generally, and particularly within Atos’ operations. The Ethics Committee is sponsored by the Group Chief Compliance Officer, the Group Since 2012, an Ethics Committee, composed of independent and Human Resources Director and the Global Legal Compliance team. In revising the Code of Ethics, this Committee was consulted and several recommendations were incorporated into the new Code of Ethics, deployed in 2015 and 2016. Code of Ethics

[G4-56], [G4-57] and [G4-58]

Participant since 2010 to the UN Global Compact, Atos has implemented several internal policies:

AP11 Contributions Policy; • AP16 Dawn raids Policy; • AP19 Export Control Policy; • AP20 Anti Fraud Policy; • AP35 Competition in business; • AP36 Roundtable Policy; • AP38 Business Partners Policy. •

corruption, in support of Atos’s Code of Ethics principles relating to business integrity [G4-SO5] . Atos has implemented several measures to prevent bribery and developing and retaining its business are subject to a due diligence and validation process supported by an automated tool, the Business Partner Tool (BPT). The BPT collects the Atos Business Partners, including agents, intermediaries, • consortium partners and consultants assisting Atos in will be rejected by the BPT. matches with any of the main international sanction lists, it addition, Atos strictly complies with international sanction laws and regulations and in the event a business partner process by the Business Unit Head of Sales for low-risk business partners to complex approval processes by the Group CFO and Group General Counsel, in addition to the Business Unit management, for high risk business partners. In various elements necessary for the assignment of a risk assessment to the business partner, as well as the requisite validation process. The level of risk assessment will identify the appropriate validation process, involving a simple approval In addition, the AP11 Atos Contribution Policy further • enhances the compliance efforts relating to bribery and corruption. The Policy prevents Atos’ employees from accepting or offering any disproportionate gift, invitation, hospitality package or any other similar contribution. When in doubt, an employee is required to seek approval from management.

Trusted partner for your Digital Journey

86