Orano - Annual Activity Report 2025 243 SUSTAINABILITY STATEMENT 4 Governance information THE PILLARS OF THE ORANO PROGRAM TO PREVENT CORRUPTION AND INFLUENCE-PEDDLING Risk mapping Code of Ethics Third party assessment Training Whistleblowing system Accounting controls Monitoring and evaluation Remediation measures Tone from the top Source: Orano Basis of the system Prevention pillars Detection pillars Remediation pillar A monitoring and evaluation system aimed at preventing and detecting acts of corruption and influence-peddling To ensure the adequacy and effectiveness of measures to prevent and detect acts of corruption or influence-peddling, the group has developed an internal monitoring and evaluation system for the prevention of corruption risks program, at three levels, involving in particular operational staff or the direct reporting line at level 1, the internal control and compliance functions at level 2, and internal audit at level 3. The control system includes: ● a specific section dedicated to accounting controls to ensure that at-risk transactions liable to conceal acts of corruption are identified and verified if necessary; and ● a global component covering the entire anti-corruption program through the internal control system and maturity reviews carried out in the entities in order to monitor the effective implementation of the program. The evaluations enable identification of the improvement actions to be implemented, depending on the entity. Any discrepancies or noncompliance with procedures are subject to appropriate corrective measures (updating of documentation, additional training, etc.), or even disciplinary sanctions. Reports relating to allegations of corruption or influence-peddling are handled via the ethics whistleblowing mechanism described in Section 4.4.1.3, including in terms of the independence and impartiality of the investigators. Within the framework of the Judicial Agreement of Public Interest (JAPI) signed in December 2024 with the French National Financial Prosecutor’s Office for a case that occurred in Mongolia between 2013 and 2015 before the creation of Orano, the group’s compliance program is reviewed by the French Anticorruption Agency for a period not exceeding three years. A risk assessment process for business relationships with third parties Business relationships with third parties (clients, intermediaries, suppliers, service providers, consultants, etc.) may incur risks of corruption and influence-peddling. In order to prevent these risks, and in keeping with changes in the French Sapin II law (anticorruption and prevention of influence-peddling) and the duty of vigilance law, the group carries out appropriate checks on the integrity of third parties with a view to establishing ethical and long-lasting partnerships. Depending on the level of a priori risk assessed according to the criteria resulting from the mapping, additional checks may be carried out, both internally and with the third party concerned, or via external sources. The compliance committee ensures that, for all business relationships with potentially high-risk third parties, the risks of non-compliance with the group’s standards, particularly with the regulations on corruption, money laundering and international rules on sanctions, are identified and managed wherever possible, in order to ensure informed operational decision-making. It issues opinions and recommendations on the planned or current relationship with the partner in question.
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