Orano - Annual Activity Report 2024 244 4 SUSTAINABILITY STATEMENT Governance information THE PILLARS OF THE ORANO ANTI-CORRUPTION AND PREVENTION OF INFLUENCE-PEDDLING PROGRAM Risk mapping Code of Ethics Third party assessment Training Whistleblowing system Accounting controls Monitoring and evaluation Disciplinary sanctions 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. 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. ● the whistleblowing system, which makes it possible to report suspected acts of corruption or influence peddling; ● the disciplinary regime, with a principle of zero tolerance in the event of proven acts of corruption by the group’s employees; and ● the evaluation and control plan for the entire program, aimed at identifying discrepancies and carrying out corrective actions. This program is part of a continuous improvement approach with regard to the assessment of identified risks, changes in indicators and the results of controls. It relies in particular on a network of around 30 compliance correspondents and compliance liaisons covering all the group’s activities, and on regular communication with operational staff.
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