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Combatting corruption and influence peddling (Compliance)

Naval Group’s commitment in the area of combatting corruption and influence peddling is embodied through the implementation and deployment of a Compliance program that is in line with the provisions and evolutions of French and international law to which it is subject in this domain.

Applying zero tolerance with regard to any infringements of the applicable law in this domain or the Group’s Compliance program, and with the full backing of the group’s management and governance bodies, this program applies to all employees, regardless of their hierarchical level and whether directly employed by Naval Group SA or one of its controlled companies.

It is deployed around the following pillars:

1. The presence of a group department and a compliance referent, responsible for developing and implementing the Compliance program : the Group Ethics, Compliance and Governance department (DECG). The DECG director (the Compliance referent as defined in the so-called “Sapin II” law) receives his delegation directly from the Chairman and CEO of Naval Group and has the necessary level of independence for performing his mission.

2. The strict compliance with a repository aimed at combatting corruption and influence peddling, whose message is directly backed by the top management and distributed to all employees via internal channels.

This repository includes, in particular, the following:
– The Compliance Code of Conduct, which is annexed to the internal rules of each Group site in France.
Instructions defining the provisions according to which each employee must:

  • Declare gifts, meals and marks of hospitality as a function of the defined thresholds, if they are given/received by persons external to Naval Group.
  • Submit their membership of associations and their patronage and sponsoring activities carried out in the name of Naval Group to the required prior approval.
  • Ensure that their business practices abroad are always in compliance with the applicable local anti-corruption laws and the accounting procedures in force within the group.
  • Ensure that prior and periodic checks (due diligence) with regard to entering into a business relation with third parties (in particular sales advisors, industrial and strategic partners, offset suppliers and representatives of interest groups or lobbyists) have been performed.
  • Ensure that all decisions are exempt from any conflict of interest, in particular for the recruitment of new employees, in the selection of new commercial partners or new suppliers.

3. The development and regular updating of a corruption and influence-peddling risk map intended to identify, analyse and rank the corruption risks to which the group is exposed and including an action plan aimed at reducing the identified risks.

4. The deployment of a training and awareness-raising plan aimed at all Naval Group employees (in France and globally) and in particular the personnel that is the most exposed to the risk of corruption, in accordance with the established risk map, but also our external stakeholders, whenever this is possible.

5. The setting up of a secure Naval Group whistleblowing hotline (ethics@naval-group.com) that is accessible to all and allows in particular the reporting of corruption and influence-peddling risks. When required, Naval Group shall initiate an investigation to process the report, in accordance with the Naval Group defined instruction.

6. The implementation of performance indicators and several areas for verification allowing the evaluation of the maturity of the compliance program and the adherence to this by the employees on the basis of an internal control plan implemented in all group entities. Through a continuous-improvement methodology, these controls are taken into account to adapt or extend the compliance program and, in particular, the risk map.

7. Annual reporting on the progress and results of this Compliance program and any verified incidents reported to the group management and its governance bodies, in particular the Audit, Accounts and Risks Committee of the Board of Directors.

In accordance with the French Law of 9 December 2016 in relation to transparency, the fight against corruption and economic modernisation (the so-called Sapin II law), Naval Group declares its interest representatives in the digital register of interest representatives of the French High Authority for Transparency in Public Life (Haute autorité pour la Transparence de la Vie Publique – HATVP).

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