Orano - Annual Activity Report 2024 239 SUSTAINABILITY STATEMENT 4 Governance information In addition, in order to strengthen the ethics culture within the group, each employee is asked during the annual review to reaffirm their commitment to respect and ensure respect for the principles and commitments of the group’s Code of Ethics. It is supplemented by the operational guide “Ethics and Compliance; how to act?”, illustrating, using concrete examples, the behaviors to be adopted by the group’s employees in their activities. Regular communication with governance bodies The compliance system is based on the governance, processes and internal control environment set up in the organization in each area. The Board of Directors, through its Audit and Ethics Committee, and the Executive Committee are given presentations twice a year to monitor the deployment of the anti-corruption compliance program, and once a year on the ethics report. The ethics report is a summary of the incidents and points of vigilance identified during the year; in particular, it sets out the changes in volume in the various topics of the Code of Ethics, as well as the actions implemented or to be implemented. Risk mapping updated each year A risk assessment campaign is launched annually to take into account the impact of potential events on the achievement of the group’s strategic and operational objectives (more details in Chapter 3). Its main objectives are: ● the formal identification of every type of risk; ● the characterization of these risks in order to prioritize them; and ● the definition and implementation of action plans to control them. Risks are mapped specifically as part of the group’s risk analysis process according to three criteria: severity, occurrence and level of control. The purpose of this map is to identify and prioritize risks according to the activity, geographical region, and processes concerned. It allows the compliance program to be adapted to the risks to which the group is exposed. The action plans and their prioritization are defined on the basis of this mapping. The update is managed by the Risk, Compliance, Internal Audit Department. The results are presented to the Executive Committee and to the Audit and Ethics Committee. In 2024, the mapping was updated. This exercise is based on a methodology developed by the group (Business Risk Model; see Section 3.2). For each business unit, corporate department and the entities concerned, it consisted in identifying the risk scenarios according to 12 defined sub-families of generic risks and based on the previous mapping, processes, and history of the group. On the basis of these maps, which are reviewed by the Compliance Committee, a summary highlighting the exposure areas and action plans is presented to the Executive Committee and the Board of Directors’ Audit and Ethics Committee for validation. An annual ethics report presented to Executive Management and the Board of Directors Each year, Executive Management asks the managers of units or subsidiaries in France and abroad to prepare an ethics report listing, a posteriori and in a summary and anonymized manner, the ethics incidents of which they have become aware, and the points of vigilance. Ethics incidents include events contrary to the Code of Ethics that have occurred during the past year, including any events giving rise to whistleblowing, while the points of vigilance include situations or risks that could give rise to an ethics incident. The trend in recent years shows that the topic with the most incidents is “discrimination and harassment.” An annual summary of alerts and incidents is presented to the Executive Committee and the Audit and Ethics Committee. In 2024, the whistleblowing process made it possible to report 153 incidents and 42 points of vigilance. Information on cases of serious human rights violations and cases of discrimination is presented in Section 4.3.1.6. Reference documentation available to employees The group endeavors to provide accurate and relevant information enabling objective assessment of its performance in terms of environmental, economic, social, and societal responsibility. Its compliance program is aimed at developing this culture of business ethics based on: ● the Code of ethics and business conduct (also called the “Code of Ethics”), which includes anti-corruption and prevention of influence peddling, and forms the basis of the group’s compliance policy. Updated in 2021 and published at the beginning of 2022, it is available on the group’s intranet and website, and is given to all new hires; the group’s employees are reminded of it during the individual interview, and it is communicated to third parties at the time contracts are signed. In particular, it includes Executive Management’s commitment to conducting a process to prevent and detect corruption and influence peddling and the group’s “zero tolerance” policy on corruption. It defines the behaviors to be prohibited and liable to characterize acts of corruption and influence peddling, based on the risks identified by the risk mapping, and sets out the consequences and disciplinary measures of non-compliance with these rules. In addition, a guide entitled “Ethics and Compliance: How to act?” has been published. It illustrates, through concrete examples, the rules of the Code of ethics and business conduct and identifies the reflexes that should be adopted in the various situations with which employees may be confronted, particularly in terms of prevention of corruption; and ● a set of internal policies and procedures dedicated to anticorruption and the prevention of influence peddling on subjects identified as being at risk (i.e., gifts and invitations, evaluation of third parties, conflicts of interest, facilitation payments, etc.), is communicated and regularly updated for all employees via the documentation system.
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