5. Ethics Mapping risks of corruption and influence peddling GEODIS carries out a risk mapping exercise for corruption and influence peddling, consisting of a map for each region and line of business and a consolidated map at Group level, updated annually. The key stages in risk mapping are identifying risk scenarios and the processes impacted, assessing gross and net risks, identifying and monitoring action plans, and ensuring continuous risk monitoring. Consolidated risk mapping is an essential tool that enables the Group’s senior management to monitor and manage risks relating to corruption and influence peddling. Internal policies and procedures on corruption and influence peddling GEODIS has adopted a global policy against corruption and influence peddling, which incorporates more specific policies (gifts and invitations, preventing and managing conflicts of interest, knowing your business partner) and has been rolled out across all Group entities. The “Know Your Business Partner” policy is an integral part of the program. It sets out all the checks to be carried out on all the Group’s business partners to ensure that they adhere to the same level of commitment to ethics and compliance as GEODIS. Additional elements include a questionnaire to be completed by the partner, and a Code of Conduct to be signed by the partner. This policy is based on an approach that is aligned with the risks identified in the Group’s corruption risk map. Business partners considered to be most at risk are subject to : ● an in-depth analysis (including questions on their compliance program, their shareholding and their ultimate beneficial owner); ● integrity checks using external databases; ● specific training delivered by the Group Compliance Department. GEODIS has set up a disciplinary system applicable to any violation of the rules relating to corruption and influence peddling set out in the anti-corruption policy. This disciplinary procedure has been rolled out in all Group entities and is regularly monitored through a consolidated register. Training program A dedicated training course on the fight against corruption and influence peddling targets employees in job categories identified as being particularly at risk on the basis of the corruption risk map. Like the training on the Code of Ethics, this training must be given to new employees within a month of their arrival. It is validated by a final test based on operational situations presenting a risk for GEODIS and is rewarded with a certificate. As of December 31, 2023, 14,814 employees considered to be at risk (89.17%(1) of the target population) had completed the anticorruption training program. Evaluation and internal control GEODIS has designed first- and second-level controls, applicable to all Group entities, allowing it to continuously assess the operational effectiveness of the system and to improve the anti-corruption control plan in accordance with the recommendations of the French Anticorruption Agency. The process is subject to independent assessment by the Group Internal Audit Department. . (1) Figure obtained by counting: (i) for the target population, all employees considered to be at risk of corruption, and still active on December 31, 2023, and (ii) for employees who have completed the training, all employees in the target population who have obtained the certificate for all campaigns since the launch of the training, and counting a maximum of one certificate per employee. 84 - 2023 ACTIVITY AND SUSTAINABILITY REPORT
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