Atos - Registration Document 2016

D Corporate Responsibility D.4

Ethical excellence inAtos’ sphere of influence

NUMBEROF PEOPLEWHO COMPLETED THE E-LEARNINGON THE CODE OF ETHICS IN 2016 [G4-SO4]

96%

96%

100%

94%

92%

92% 93%

89%

87%

80%

69%

66%

66%

62%

60%

53%

47%

40%

20%

0%

Iberia

France

Cloud &

Central &

Germany

Worldline

Benelux & The Nordics

Corporate

Middle East & Africa

Asia Paci c

United Kingdom & Ireland

Major Events

North America

South America

Eastern Europe

Entreprise So ware

Experts Network). initiatives taken, within different channels, from highest executive body (Group Compliance Steering Committee), to all the General Counsels of the Group (Group Legal Compliance Board), and through specific expert network (Legal Compliance the different Business Units Compliance Programs with the corporate one is made possible through harmonized communication and awareness on several programs and or tool is appropriately communicated, with specific communication and training sessions: during the first semester of 2016, training sessions on the Business Partner Tool were organized for all the Business Units. In addition, full alignment of Group Legal Compliance Team ensure that new policy, procedure Through the Atos Enterprise Social Network, Group Compliance ensures an up-to-date communication channel directly with employees who can join a specific community, called “Legal Compliance Organization”, to learn about Atos policies, be informed about training sessions, receive compliance newsletter and interesting information on compliance and ethics.

Awhistleblowing procedure and internal investigations

protected accordingly. Data Protection Authority [G4-57 and G4-58] . Local General Counsels, management, and Group Compliance are points of contact for any employee raising an alert, and ensuring that the rights of employees, the sender or subject of the alert, are established in compliance with the requirements of the French suspected non-compliance with the values and principles of the Code of Ethics. The Code of Ethics alert system has been Atos Code of Ethics, as described in Section G.6.2, establishes the right of all employees to raise an alert in the event of a Any allegations of non-compliance detected within the Company are to be reported to the Head of Compliance and/or to the Group Head of Internal Audit, who will launch the Internal local teams and provides clear guidelines on how to conduct internal investigation. in 2016, to reinforce the governance of any internal investigation, enhance collaboration between global function and Investigations procedure [G4-49] . Such procedure was reviewed Such Internal Investigations are properly tracked at corporate level, and communicated to Group Executive Committee, through the annual review of internal investigations during a Group Compliance Steering Committee. For 2016, 11 alerts were reported and monitored at the Group Compliance level [G4-50] .

Trusted partner for your Digital Journey

88