Atos - Registration Document 2016

D Corporate Responsibility

D.4

Ethical excellence inAtos’ sphere of influence

usefulness in guiding the behaviors of its employees and key stakeholders. Atos is continually reviewing its compliance policies to ensure adherence to laws and regulations, as well as relevance and In addition, compliance internal controls are put in place and managed by Internal Control Team. In 2016, the Group Legal Compliance Team reviewed the compliance internal controls to improve the monitoring of our compliance program in all the Group Business Units. internal audits on specific regions, countries or activity include compliance checks Some internal audits are performed on compliance matters, and with laws and regulations were levied against the Group [G4-SO8] . No client or supplier claim related to corruption was levied against the Group [G4-SO5] . In 2016, 1 significant fine of € 160 thousand for non-compliance implement adequate remediation actions where necessary as well to understand how the risks identified are perceived within the organization. evaluation by members of the Atos Legal, Compliance and Contract Management department and relevant non-legal stakeholders (Human Resources, IT, security) of a series of legal risks (i.e. risks with a legal cause) that allows Atos entities to Atos has put in place a legal and compliance risk management process, which was fully integrated to the Enterprise Risk Management in 2016. This risk management process consists in results of the Legal risk management exercise are presented to the Audit Committee of the Group, with a clear mapping of the As integrated to the Atos Enterprise risk management, the legal risks of the Group. Risk assessment andmapping process

systems for credit, commercial and legal risks, through the Rainbow Process, which sets out defined steps and escalation procedures [G4-SO3] . In addition, the review of core compliance issues in assessing business opportunities is an important part of the overall risk assessment framework. The compliance review process of transactions is well established within Atos, similar to the review

[G4-56] Improvement of compliance awareness

e-learning is mandatory for all employees, regardless of their job, function, country and hierarchical level. achieve another step in the improvement of its compliance program. This specific training on the Code of Ethics’ principles ensures a better understanding of the Code of Ethics and promotes fair practices in the daily business activities. This Regarding training, the launch in September 2013 of specific e-learning on the Code of Ethics has made it possible for Atos to In 2016, a new version of the e-learning was elaborated and will be launched in January 2017. To complement this e-learning module on the Code of Ethics, specific classroom training sessions on the Code of Ethics are organized in some Business Units for top managers: ETO²S training (“Ethics in Tier One Organization School”) presents the responsibilities and the risks of non-compliance for Atos and the managers related to the principles of the Code of Ethics, explains the main Atos policies and processes to ensure compliance with these principles, and gives concrete examples of ethical behaviors of manager in their daily work. In 2016, 86% of employees completed the e-learning on the trainings [G4-SO4] . Code of Ethics and 642 managers were trained in classroom

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