Ethics Alert Procedure 21 03 6 15

Ethical whistleblowing procedure
Whistleblowing is an optional procedure to allow employees who have observed

malfunctions or irregularities within the company that pose a serious risk, to report these to
persons empowered to end them.
I. What types of breaches are covered by the whistleblowing procedure?
The procedure covers serious breaches in one or more of the following areas that
pose serious risks to the company:
- financial, accounting, and corruption issues;

- anti-competitive practices;
- workplace discrimination and harassment;
- healthcare, sanitation, and workplace safety;
- environmental protection.
II. Who may use the ethical whistleblowing procedure?
Any employee who may have knowledge of the facts in question.
III. How are breaches identified? And what should be done in case of doubt?
Determine whether there is, in fact, a breach, particularly by replying to the following
questions:
- What does the breach consist of?
- Could the situation in question violate legal provisions and/or the Group’s codes of
conduct or ethics charters?
- Did the infraction occur long ago?
- Has the problem already been remedied?
- Where did the breach occur?
- How would this situation be regarded by other persons?
- What would happen if this situation was reported in the newspapers?
Act on the basis of the identified facts and, in any case:

- Don’t ignore the presence of a problem, even if you are uncertain;
- Don’t be satisfied when no reply is provided to a question.
Updated 09/23/2014
IV. Reporting to the Chief Ethics and Compliance Officers
In case of doubt on how to proceed or how to respond to a given situation or to

obtain details on the implementing of codes of conduct or ethics charters, the
employee may contact either his immediate supervisor or – if that is difficult to
do or if reporting to an immediate supervisory does not appear to have been
followed by an appropriate response – the Divisional Chief Ethics and
Compliance Officer, or, where there is one, a dedicated structure that the
Divisional Chief Ethics and Compliance Officer has set up to relay the
information.
Similarly, if an employee is informed of, or believes in good faith that there
exists, a breach as defined in Section I, he may freely inform his immediate
supervisor or – if that is difficult to do or if reporting to an immediate supervisory
does not appear to have been followed by an appropriate response – the
Divisional Chief Ethics and Compliance Officer directly, while stating his identity
and describing the facts.
Employees wanting to find out about the procedure for transmitting alert information
may phone (+33 1 46 96 42 13) or email, the Chief Ethics and Compliance Officer
appointed within the Division or, if none has been appointed, the Group’s Chief Ethics
and Compliance Officer.
The whistle-blower shall report the breaches or irregularities that he has observed at
the following address:
The whistle-blower as well as potential witnesses and persons against whom

the allegations have been made have a right of access to, and rectification of,
their personal data if such data are inaccurate, incomplete or equivocal,
outdated, or obsolete, in accordance with Articles 39 and 40 of the French Loi
Informatique et Libertés” (IT Security and Freedoms Act). Requests must be
emailed to the following address:
The entire whistle-blowing mechanism is under the responsibility of SA, the

parent company of the group of the same name.
V. Good faith
The whistle-blower must act in good faith, equitably, honestly and in respect of
others.
group companies pledge to protect whistle-blowing employees from any
reprisals.
Any abuse of the whistle-blowing procedure is subject to prosecution. However,
no penalties will be imposed on employees who opt not to use the whistle-
blowing procedure.
VI. Whistle-blowers
Updated 09/23/2014
The identity of the employee whistle-blower shall not be made public and the
case shall be dealt with internally and on a fully confidential basis. The Chief
Ethics and Compliance Officer shall make the necessary arrangements to
ensure this confidentiality, and, more generally, to safeguard alert information.
He is the guarantor of the whistle-blower’s protection.
The whistle-blower shall be informed of the reception of his alert within a
reasonable amount of time.
VII. Persons targeted by the alert
If an alert mentions one or more persons by name and the decision is made to
continue the investigation, this or these persons shall be so informed, to allow
them to contest or modified the information submitted. However, the targeted
person(s) shall not be informed of the alert before measures have been taken,
when necessary, in particular to preserve evidence.
The targeted person(s) may under no circumstances have access to

information on the whistle-blower’s identity, even as part of the targeted
person’s(‘) exercising of his (their) rights of access to, rectification of, opposition
to, or deletion of information of a personal nature.
VIII. Alert information
Information must be expressed objectively, be directly related to the scope of

the procedure, and be strictly necessary for verifying the alleged facts.
The nature of the reported facts must be described in a manner that shows that
they are presumptions.
IX. How long alert information must be kept on file
Any alert information collected that is not within the scope of the
aforementioned mechanism must be destroyed immediately.
Information this is subjected to verification must be destroyed within two months
of the end of the verification when the alert is not followed by a disciplinary or
legal procedure.
When a procedure is undertaken, information pertaining to the alert is kept on
file until the end of the procedure.
X. Investigations
If the Chief Ethics and Compliance Officer is made aware of a breach in the
code of conduct or ethics charter, he must arrange for an investigation of the
infraction without delay.
Updated 09/23/2014
If the Chief Ethics and Compliance Officer decides to pursue the investigation
and, if he deems it necessary at this point, he may consult the Group’s Chief
Ethics and Compliance Officer in order to decide what course of action to take
and may seek the backing of the legal, internal audit and human resources
departments, among others.
If the investigation shows that the facts are inaccurate or that the breaches are
immaterial, the alert investigation shall be closed and the related documents,
destroyed.
If an infraction has indeed occurred, the Chief Ethics and Compliance Officer
shall forward the investigation’s findings and his own observations to the head
of the company concerned (or to the person appointed by him), as well as to the
Group’s Chief Ethics and Compliance Officer, for information, in order to take
suitable rectification measures.
In the event of contradiction between the French version of this document and the version in a foreign language, the
French version shall take precedence.
Updated 09/23/2014

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Ethical whistleblowing procedure

Whistleblowing is an optional procedure to allow employees who have observed

I. What types of breaches are covered by the whistleblowing procedure?

- financial, accounting, and corruption issues;

II. Who may use the ethical whistleblowing procedure?

Any employee who may have knowledge of the facts in question.

Act on the basis of the identified facts and, in any case:

In case of doubt on how to proceed or how to respond to a given situation or to

The whistle-blower as well as potential witnesses and persons against whom

The entire whistle-blowing mechanism is under the responsibility of SA, the

VII. Persons targeted by the alert

The targeted person(s) may under no circumstances have access to

VIII. Alert information

Information must be expressed objectively, be directly related to the scope of

IX. How long alert information must be kept on file

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