Human rights and fundamental freedoms in the context of the corporate duty of care The SNCF Group is subject to the French Corporate Duty of Care law, which requires companies and groups with more than 5,000 employees in France or 10,000 employees in France and internationally for two consecutive years to devise, publish and effectively implement a plan containing appropriate measures to identify risks and prevent serious violations of human rights and fundamental freedoms, or to the health and safety of individuals and the environment that may result from their activities or those of their suppliers or subcontractors with whom they maintain an established business relationship. The 2022 plan is the second to be published by the SNCF Group(11) under the corporate duty of care legislation. It covers the entire SNCF Group, including GEODIS, which contributed to it by reporting consolidated information within its scope. Governance GEODIS has set up a governance system for the duty of care adapted to its businesses in conjunction with the SNCF Group. A steering committee has worked to identify the risks of serious violations of human rights and the environment, as well as the health and safety of individuals, in the context of GEODIS’s activities and those of subcontractors or suppliers with whom GEODIS maintains an established commercial relationship. This work has made it possible to prepare appropriate action plans to supplement existing measures in order to strengthen the prevention of risks and serious breaches. The whistleblowing system in place at GEODIS makes it possible to collect and process reports from all employees and external stakeholders concerning the existence or realization of risks of serious violations with regard to human rights, the health and safety of individuals or the environment. 5.3 Responsible value chains GEODIS occupies a key position in global value chains and makes use of numerous suppliers and subcontractors. The risk of noncompliance by these suppliers and subcontractors on ethical, social or environmental issues could expose the Group to legal action and have an impact on its performance and its ability to satisfy its customers. Anticipating these risks is therefore a matter of responsibility and exemplarity for the Group, which must be vigilant not only in its role as an employer, but also as a customer. Depending on the country and on the services provided, GEODIS teams may assign part of the work to subcontractors, provided that the latter comply with the third-party management program, which includes but is not restricted to ethical and compliance issues. Third-party integrity verification procedure GEODIS has introduced a third-party integrity verification process called “Know Your Business Partner” to supplement the verification procedures prescribed by local legislation. This was launched in 2015 and consists of a policy attached to the Code of Ethics, a supplier code of conduct and two questionnaires. The objective is to ensure that the third party in question respects the same level of commitment as GEODIS in terms of ethics and compliance. The “Know Your Business Partner” process includes a detailed review of the third party under consideration, using a risk-based approach. As a result, third parties deemed to present a high risk according to the Group’s risk mapping are subject to enhanced due diligence (including questions about their compliance program, ownership, ultimate beneficiary) and integrity checks against external databases, which may result in the imposition of remedial measures. (11) https://www.sncf-reseau.com/fr/plan-vigilance-sncf 72 2022 ACTIVITY AND SUSTAINABILITY REPORT 05 ETHICS
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