Groupe Renault - 2020 Universal Registration Document

230 GROUPE RENAULT I UNIVERSAL REGISTRATION DOCUMENT 2020 Find out more at group.renault.com 02 ETHICS AND GOVERNANCE GROUPE RENAULT: A COMPANY THAT ACTS RESPONSIBLY Highlights of 2020 2.5.1.3 Renault has been audited by the French Anti-Corruption Agency (AFA) under Article 17 of the Sapin II law of December 9, 2016. At the time of writing, Renault had not received the AFA report. The procedure for declaring and dealing with conflicts of interest and the related training have been rolled out. A communication campaign on the declaration of interests of senior executives has been conducted and will be repeated annually. The Group has also set up a procedure for managing gifts and invitations applicable to all of its entities. The Group Ethics and Compliance department is now split into four divisions: ethics, professional alerts, compliance and the deployment division created in 2020. An “Inspiring Ethics” seminar was held in December 2020. It is part of an initiative to raise awareness of ethics and compliance for all employees within Groupe Renault. The Chief Executive Officer was thus able to develop and share his convictions on ethics and compliance. Three external speakers followed one another in order to nurture the thinking of all attendees on subjects as varied as “meaning and leadership”, “normality and singularity at work” and finally “ethical questions concerning neuroscience”. Lastly, the Chairman of the Board of Directors concluded the seminar by stressing the Group’s responsibility and interest in having an "ethical backbone" enabling it to develop sustainably. Five information sessions on the Group’s ethics and compliance policy were given to the business management committees in the plants and at a country headquarters. Reinforcement of the ethics and compliance network The network of ethics and compliance officers is now composed of 86 people. In order to improve the effectiveness and impact of the actions of the Group Ethics and Compliance department, the network of officers has now been extended to new countries and subsidiaries. A total of 37 officers cover all countries where the Group operates. These officers are supported by five regional officers and 14 function officers. They are assisted by 30 implementation leaders. The Group Ethics and Compliance Department leads the network via e-conferences, newsletters and an annual seminar. Despite the context of telework, health crisis and travel restrictions, contact was maintained and reinforced through individualized exchanges with each member of the network. Deployment of the prevention of corruption and influence-peddling plan EFPD16b The law known as "Sapin II" of December 9, 2016 on transparency, the fight against corruption and the modernization of economic life, led Renault to continue to strengthen its overall prevention of corruption and influence-peddling policy, in particular in the following areas: a renewed and increased commitment by governing bodies to the 1. prevention of corruption; with third parties. The various risks mapped are then taken into consideration when adjusting the Group’s ethics and compliance policy; the corruption risk mapping approved by the Executive Committee 2. allows risks to be identified, assessed and prioritized. It includes in particular those risks inherent to its international activities or links the Group’s Guide for preventing corruption and influence- 3. peddling was deployed in all countries via operating committees, meetings with managers and team meetings. The Guide is also available on the Renault website: www.group.renault.com; the Third Party Integrity Management Process has now been 4. rolled out in the Group's main subsidiaries. In 2020, the TIM process was integrated into the Delegation of Authority (DoA) for decisions requiring an opinion on the integrity of the third parties involved. In total, the level of coverage of third parties at risk was above 90% at the end of the year despite an increase in the scope of consolidation; employees and managers have access to online training on the 5. prevention of corruption and influence peddling, as well as the detailed presentation of the Group’s prevention plan. In 2020, more than 3,000 employees attended this training. This represents a cumulative total of 39,600 employees, i.e. , 94% of the population registered according to the position held in the company. An online training module, "Ethics within Groupe Renault", was delivered to 25,800 employees; a communication campaign launched at the end of 2019 reminded 6. everyone of the operation of the worldwide whistle-blowing tool implemented in 2018. Available in 14 languages, the tool is operational in almost all countries and is supported by the local ethics and compliance officers. It replaces the tool implemented in 2012. It allows Group employees as well as external and occasional employees and suppliers to activate alerts directly with the Group Ethics and Compliance function. As a reminder, this tool brings together in a single system the three warning mechanisms provided for by the "Sapin II" law (general system, prevention of corruption and influence peddling) and the 2017 law on the duty of vigilance. It is accessible confidentially at any time, on an external site, from a computer, tablet or smartphone, both professional and personal. During 2020, new initiatives were conducted to raise awareness, in particular using the Group intranet; in 2020, the Group Ethics and Compliance Department carried out 7. a self-assessment on the roll-out of the corruption prevention system in the Group’s entities and subsidiaries. This CCQ (Compliance Control Questionnaire) received input from 33 subsidiaries this year. Compliance tests were conducted on 11 entities to verify the quality of the responses and thus confirm the overall results. Eight audit assignments including a review of local implementation of the corruption prevention policy were carried out in 2020. Compliance with laws, regulations and corporate rules Compliance with laws and regulations is a major objective of the Group. The Group’s Ethics and Compliance Committee (CECG) is responsible for monitoring these systems. The Group Ethics and Compliance department is responsible for overseeing regulatory compliance. It is responsible for ensuring that reliable systems are in place for the departments that prescribe compliance: Technical Regulations department, Legal department, Environment department, etc . It is also responsible for ensuring that the Group’s regulatory authorities have the necessary resources to