The Group's compliance culture has been the subject of a specific program since 2009 that reinforces the effective application of the Principles of Conduct and Action and the obligations resulting from them, in all Group Activities and worldwide. Regularly expanded since its launch, the compliance program today focus on the following main themes: responsible development, compliance with rules on competition, corruption prevention, compliance with economic sanctions and embargoes. Responsible development The responsible development department seeks to ensure that the Principles of Conduct and Action are disseminated and properly understood by all Group employees . The Principles of Conduct and Action express the Group's core values, the implementation of which is a requirement for belonging to Saint-Gobain. Every Saint-Gobain officer and employee is personally bound to implement them daily, and to comply with the rules laid down within the Group as well as applicable laws and regulations. Competition compliance plan The “competition compliance plan”, launched in 2007, is aimed at ensuring compliance with the rules of competition law. The competition compliance plan comprises different training actions (online and classroom training), conducting audits, providing handbooks, newsletters but also dedicated teams for any operational questions on the subject. Corruption prevention The corruption prevention program builds on the actions and best practices already implemented in different subsidiaries to avert risks related particularly to international business transactions; it concerns active and passive corruption, relations with public officials and the private sector; it includes training tools (on line and classroom training), in-company policies (gifts, conflicts of interest, agents, etc.) and monitoring by a network of correspondents by Delegation and by Sector that respond to operational questions on this subject. Compliance with economic sanctions and embargoes The purpose of implementing compliance with economic sanctions is to ensure that Group entities comply with all applicable economic sanctions. Screening tools, training and specific policies are also deployed, as well as an active monitoring of developments and privileged ties with specialized external lawyers. Internal audit and business control The business control system seeks to control the main risks to which the entities are exposed. Tis purpose is also to ensure: compliance with applicable laws and regulations, the application of guidelines fixed by General Management, the smooth functioning of processes, the reliability of financial information, preserving tangible and intangible assets, detecting and handling cases of fraud. Whistleblowing system The Group's whistleblowing system is operational in virtually all countries, in compliance with local legal and administrative constraints. It concerns serious, bona fide breaches of applicable legal rules, of Group internal rules and procedures, and of the Principles of Conduct and Action. Compliance network The implementation of the compliance program is detailed in an annual report to the board of directors of Compagnie de Saint-Gobain. It is supported by a compliance network, coordinated by the general secretary, composed of 80 senior functional and operational executives.
