5. 5.1.4.2 Program for free and fair competition Mapping of competition risks Among the measures in place, an internal digital tool is used to monitor employees’ membership of professional organizations where the risk of exchanging commercially sensitive information is considered high. Internal policies and procedures on free and fair competition As with the anti-corruption program, GEODIS has put in place policies and procedures designed to ensure that all its employees abide by competition rules. A dedicated “free and fair competition” policy was adopted in 2020. It contains a reminder of the fundamental principles of competition law, examples of behaviors to be followed or, on the contrary, proscribed, and a presentation of the mechanisms available for internal noti cation of incidents. This policy is accompanied by an internal procedure for authorizing employees to join professional organizations. This procedure was strengthened in 2023 with the introduction of a questionnaire to fine-tune the risk analysis and thus improve the quality of processing applications. The substantial increase in the number of applications for membership in professional organizations in 2023 (615 applications compared to 196 in 2022) attests to the effectiveness of the awareness campaigns, particularly during the annual Compliance Week. Training program To support senior management’s commitment to ensuring compliance with competition law, the Group has developed a specific e-learning course designed to make employees aware of the risks associated with their participation in professional organizations. The training program is designed to help employees identify risks and take the necessary steps to prevent or manage them. The training program forms part of the internal tool that validates participation in professional organizations. From 2024, it will be automatically assigned to any employee whose request has been authorized in the tool. 5.1.4.3 Customs and export control Against the background of an increase in international trade, GEODIS must ensure that customs clearance operations are carried out and that export control measures are implemented in accordance with applicable regulations. To this end, internal rules and policies have been established and rolled out across all Group entities. Customs compliance program GEODIS has set up a customs compliance program designed to ensure the compliance of its customs services and reduce risks for the Group and customers engaged in import and export operations. This program is supported by a strong commitment from the Group’s senior management and relayed by a network of specialists within the lines of business and the regions. It is made up of several elements: the GEODIS Customs Rules with additional internal policies and procedures, a widely distributed customs regulatory watch, and a customs internal control plan with self-assessment campaigns, reports to management, internal visits and corrective action plans. The GEODIS Customs Rules are based on the principles of the World Customs Organization (WCO), the regulations of customs authorities and other government agencies, and best professional practices in the customs sector. They specifically cover the customs subcontracting procedure, the tariff classification of goods, the payment of customs duties, taxes and other charges to customs authorities, and the customs compliance program. The Group has established 28 rules to address the complexities of supply chain operations and customs activities. Each entity adds customs rules specific to the country in which it is established. An e-learning course on the main Customs Rules is available to support the employees concerned. A certificate is awarded on successful completion of the final test. Export controls Recent changes in legislation concerning export controls and sanctions have led GEODIS to introduce export control measures aimed at controlling the transfer of goods, technologies, software, know-how and financial flows to certain countries or to foreign individuals or legal entities present in France. As a global supply chain operator, GEODIS is obliged to comply with export control regulations, and is specifically required not to transport embargoed goods or deliver goods to an entity on a sanctions list. As a result, GEODIS has implemented an export control procedure, which is regularly updated in line with legislative and regulatory developments. This procedure applies to all export, import, domestic transport, logistics, customs clearance and transit operations carried out by GEODIS entities. Prior approval is required for any commercial activity involving the countries or goods identified in the procedure, to ensure compliance with the applicable regulations. 5.1.4.4 Personal data protection Personal data protection is covered by a specific program, managed by the Governance, Risks and Compliance Department (see section 5.3). 2023 ACTIVITY AND SUSTAINABILITY REPORT - 85 EDITORIAL > 1. PROFILE AND AMBITION > 2. CSR POLICY > 3. ENVIRONMENT > 4. SOCIAL > 5. ETHICS > 6. TABLE OF INDICATORS
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