Anti-corruption program GEODIS has introduced a compliance program to combat corruption and influence peddling. This program is driven by a strong commitment from the management team with the support of a network of correspondents in the lines of business and the regions. It comprises a set of measures, adapted to the company and corresponding to the eight pillars stipulated by the Sapin II law: a code of ethics, supplemented by internal policies and procedures distributed to all employees, any breach of which may give rise to disciplinary sanctions; regularly updated risk mapping for corruption and influence peddling, aligned with the most recent recommendations of the supervisory authorities; a system for verifying the integrity of third parties using a riskbased approach; a training program for employees and suppliers/ subcontractors most at risk; an internal alert system; an accounting control plan and a system for monitoring the effectiveness of the program, including first, second and third-level controls. Training program GEODIS uses a specialized e-learning platform that offers interactive and adaptable modules to ensure that the training courses reflect as closely as possible the company’s culture, risks and operational situations that may arise. GEODIS offers modules internally in eight or nine languages, depending on the topic. The tool enables the automatic integration of new employees, the traceability of completed training courses and automatic reminders to employees. Each year, GEODIS is able to train thousands of employees around the world, spread its culture of ethics and compliance, and prevent risks of violation related to these topics. > Code of Ethics module Training on the GEODIS Code of Ethics runs on a continuous basis throughout the organization. It is intended for all employees who have a computer workstation giving them access to the e-learning platform (i.e., approximately 30,000 employees in 2022). They are required to complete the training within one month of their arrival in the Group. The training includes modules dealing with all the subjects covered by the Code of Ethics. If the final test is successfully completed, a certificate is awarded which is valid for two years. When this period elapses, employees are required to follow and validate the training again. 14,034 employees completed the e-learning module on the Code of Ethics in 2022. > Anti-corruption and influence peddling module Training dedicated to fighting corruption and influence peddling is also provided on an ongoing basis throughout the organization. It targets employees belonging to job categories identified as being particularly at risk in terms of corruption risk mapping. Like the training on the Code of Ethics, it is validated by a final test based on operational situations that present a risk for GEODIS and leads to the award of a certificate. A major training campaign was organized in 2021 for employees considered to be at risk of corruption, i.e., more than 13,000 people. Of this population, over 99%(10) passed the final test. In 2022, only those employees who had been unable to complete the training during the 2021 campaign, as well as new employees at risk, were involved in the campaign. (10) This percentage does not take into account employees who were on long-term leave at the time the campaign ended. 70 2022 ACTIVITY AND SUSTAINABILITY REPORT 05 ETHICS
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