Orano - Annual Activity Report 2024 240 4 SUSTAINABILITY STATEMENT Governance information The Company’s ethical culture and business conduct procedures are promoted through the mandatory e-learning module for all employees, who also reaffirm their commitment to the Code of Ethics during their annual review. Regular general communications remind employees of the key principles and periodic training sessions supplement these reminders. The rules state that the variable portion of compensation of 3,200 group managers must not be paid if unethical means have been implemented to achieve the objectives. An ethics alert system guarantees the confidentiality and protection of whistleblowers The whistleblowing system within the group is a complementary channel of expression to dialogue with managers and compliance correspondents. A secure portal for whistleblowing (https:// oranoethic.signalement.net) is accessible to all, i.e., to all group employees, employees and contractors of business partners (suppliers, service providers, subcontractors, customers, etc.), or to recruitment candidates, for any whistleblowing not related to the United States. It should be noted that a specific whistleblowing platform has been deployed for entities based in the United States (https://orano.integrityline.com). Through these systems, employees are able to report any breaches of applicable regulations or of the group’s internal rules and procedures, in particular breaches related to the Code of ethics and business conduct. This system is constantly communicated via the intranet and/or by posters at the sites. The categories targeted by whistleblowing are: 01 Human rights, discrimination, moral or sexual harassment, sexist behavior and acts, verbal or physical aggression 02 Breaches of the protection of people and property, theft and misappropriation of assets 03 Breach of safety, security and/or the environment 04 Breach of the rules governing the protection of intellectual property or personal data or confidential information 05 Violation of the export control rules, non-compliance with international sanctions 06 Irregularities/Quality fraud, document falsification and breach of quality rules 07 Financial fraud, misrepresentation, insider trading, abuse of corporate assets 08 Corruption, influence peddling, conflicts of interest, undue advantages, money laundering, financing of terrorism 09 Anti-competitive practices 10 Other breach of the rules of the group’s Code of Ethics Orano pays particular attention to the confidentiality of whistleblowers and the protection of whistleblowers in accordance with legal requirements, and notably the regulatory changes in France in 2022 through the Wassermann law, legislation which transposed the EU directive 2019/1937. Alerts are processed under the group procedure. The Risk, Compliance, Internal Audit Department analyzes the admissibility of alerts filed on the portal. This admissibility is independent of the reality of the alleged facts, which can only be ascertained when dealt with. Where appropriate, investigations are carried out internally or using an external expert, ensuring the impartiality of the investigator. In order to ensure the impartiality and independence of those involved in an investigation, the group has formalized an applicable methodology and supporting tools. Where appropriate, those involved are made aware of the implementation of the methodology. When the alerts issued are proven, appropriate measures are taken.
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