5. ETHICS Training The profi les most exposed to the risks of corruption and bribery include employees who interact with customers and suppliers, along with new hires. These employees must follow a 30-minute online session entitled “Fighting corruption and infl uence peddling”. The course covers the regulations that apply to the different legislations in force (Sapin II(1), FCAP(2) and UKBA(3), among others), as well as risk situations, with practical case studies and a fi nal quiz. A certifi cate is awarded on completion of the course, which must be renewed every two years. Anti-corruption control plan GEODIS has designed fi rst- and second-level controls, applicable to all Group entities, allowing it to continuously assess the operational effectiveness of the system, in accordance with the recommendations of the French Anticorruption Agency. This process is subject to an independent assessment by the Internal Audit Department. Results ● In 2024, 69 individuals among “high-risk” third parties completed compliance training, in addition to the 153 people trained in 2023(4). ● The 2024 training program targeted 11,278 employees. A total of 10,616 employees, or 94% of the target population, completed the anti-corruption training. ● Number of convictions and total fi nes for breaches of anticorruption legislation in 2024: 0 ● Number of convictions for violations of anti-corruption laws: 0 ● Total fi nes for violations of anti-corruption laws: 0 5.1.3 Free and fair competition GEODIS is particularly committed to complying with competition law covering anti-competitive agreements and the abuse of dominant market positions. The fair competition policy introduces employees to the fundamental principles of competition law, outlining both the behaviors to adopt and those to avoid. It also explains the procedures for reporting incidents. The document reiterates that professional organizations must not be used as platforms for anti-competitive exchanges or information-sharing between members. In order to mitigate this risk, the Group has set up a formal membership application and renewal control procedure. All employees concerned are required to take an online training course addressing this issue. 5.1.4 Customs and export controls In response to the increase in international trade, GEODIS has implemented measures designed to ensure compliance with the regulations applicable to the provision of customs services, as well as with export control regulations: ● “customs rules” are designed to provide a framework for the customs clearance operations handled by GEODIS, and cover the customs subcontracting procedure, the payment of customs duties, taxes and other charges to the customs authorities, and the customs compliance program. They are based on the principles of the World Customs Organization (WCO), regulations issued by customs authorities and other government bodies, and best professional practices, and are enforced in all Group entities; ● the “export control procedure” is designed to provide a framework for export, import, domestic transport, logistics, customs clearance and transit operations carried out within all GEODIS entities, to ensure that they do not involve anyone designated on sanctions lists or prohibited goods. Any commercial activity involving countries or goods identifi ed in the procedure is subject to prior approval. Online training courses on the principal customs rules and export control regulations are provided to support the employees in question. (1) French law on transparency, the fight against corruption and the modernization of economic life. (2) Foreign Corrupt Practices Act, United States federal anti-corruption law. (3) United Kingdom Bribery Act, British anti-corruption law. (4) Data for 2023 has been adjusted as it represented people registered for training, not those who actually took part. 88 - 2024 ACTIVITY AND SUSTAINABILITY REPORT
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