Cap Gemini - Registration Document 2016

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CAPGEMINI: PEOPLE, CORPORATE SOCIAL RESPONSIBILITY (CSR) AND BUSINESS ETHICS

3.1 Our approach

Ethics & compliance program in 2016

the Ethics & Compliance program within their geographic regions (GC-ECO) for their jurisdictions. They ensure implementation of and liaise with the CECO. General Counsels also serve as Ethics & Compliance Officers policies: the Blue Book Group fundamental principles, guidelines and effectively and maintain unity across operations worldwide. each employee and company service or department to work created in 1989. It provides a common reference tool, enabling confidential Blue Book, so-called because of its color, was policies that govern our daily operations. The Company essential to have a set of common guidelines, procedures and In our largely decentralized and entrepreneurial organization, it is The Blue Book contains: principles; objectives, Values, Code of Business Ethics and collaboration Group fundamental principles: its mission, expertise, main ◗ activities; risk management, pricing and contracting rules in presales ◗ insurance rules and guidelines; financial management, merger, acquisition, disposal and ◗ human resources policies; ◗ management guidelines; marketing, communications, Group knowledge and IT ◗ selection; and procurement policies, including ethical purchasing and supplier environmental and community policies. ◗ regularly and is available to all employees on the Group’s intranet. of our Internal Audit process. The Group Blue Book is updated Assessment of compliance with these guidelines is an integral part complying with national legal requirements and specificities. standards that all entities are required to implement, while These policies, procedures and guidelines comprise the reference Our business ethics They rank amongst the most important of all our strategic among Serge Kampf’s most precious bequests to the Group. CEO, Paul Hermelin, our seven core Values and our ethics are As re-emphasized in March 2016 by the Group Chairman and performance. today, this reputation is an essential asset to our economic shaped the Capgemini Group’s reputation in the market, and dimensions. Our longstanding commitment to our Values has and maintain this reputation and, in so doing, to further strengthen The Group launched its Ethics & Compliance program to protect our competitive advantage. The objectives of the program are to: and fosters ethical behavior; develop a sustainable ethical culture, which reinforces integrity ◗ as well as internal policies applicable in Group companies; and strengthen knowledge and awareness of laws and regulations, ◗ avoiding ethics and compliance breaches. implement initiatives aimed at reinforcing prevention and ◗ Group governance and organization; ◗ authorization and approval processes; ◗ sales and production rules and guidelines; ◗

Our Code of Business Ethics

with all former IGATE employees in February 2016. ethical culture, is now available in fourteen languages. It has the Our Code of Business Ethics, which encapsulates the Group’s community. It has been updated in January 2016 and was shared Directors, the Group Executive Committee and the Vice-President collective and individual support of the members of the Board of particular, employees are expected to commit to: core Values and to the principles expressed in this Code. In Capgemini expects all Group employees to adhere to the seven respecting applicable laws and regulations; of a safe, inclusive work environment; applying health and safety rules and contributing to the creation ◗ acting responsibly in the marketplace, complying with applicable ◗ avoiding conflicts of interest and insider trading, and providing competition laws and regulations and anti-corruption provisions, business partners; building honest, clear relationships with clients, suppliers and ◗ and of any third parties with whom we work; maintaining the security and integrity of the assets of the Group which we operate; and supporting the communities and respecting the environments in ◗ refusing the use of forced labor and child labor. At the end of 2016, more than 170,000 employees had taken the Code of Business Ethics e-learning module, which is available in employees at year-end 2016. nine languages. This represents close to 88% of the Group’s the e-learning module on the Code. principles set out in the Code of Business Ethics and to complete All new hires are expected to undertake to comply with the Anti-Corruption Policy of corruption. At the end of 2016, more than 171,000 employees languages, outlining its commitment to zero tolerance for any form In 2011, the Group released a policy, available in twelve employees at year-end 2016. six languages. This represents approximately 89% of the Group’s had followed the related e-learning module, available in Group Competition Laws Policy employees had followed the related e-learning module, available in violate competition laws. At the end of 2016, more than 162,000 to help employees to identify and avoid situations that could In 2012, the Group released a policy, available in nine languages, employees at year-end 2016. five languages. This represents more than 80% of the Group’s New employees are expected to comply with the principles set modules. Competition Laws Policy, and to complete the related e-learning out in the Group Anti-Corruption Policy and in the Group accurate commercial and financial information; Specific policies

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Registration Document 2016 — Capgemini