SASB Report 2020

rules and procedures adopted from time to time by the Group. In order to ensure the widest possible distribution of its contents, the Code of Ethics is available in 26 languages and is also published on the Company’s website, www.prysmiangroup.com . The Code of Ethics is supported by other Group Compliance Policies, included: y ANTI-CORRUPTION POLICY: prohibits the corruption of both public officials and private individuals for any reason to influencing a business decision to obtain or retain an improper business advantage (including but not limited to winning a bid submission or contract, obtaining a sale, procuring licenses). Furthermore, the Policy requires Prysmian’s employees to abide by it and to observe and comply with all anti-corruption legislation in force in the countries in where they are employed or active, if these are more restrictive. y ANTI-TRUST REGULATIONS: the Board of Directors has adopted an Anti-trust Code of Conduct that all directors, executives and employees of the Group are expected to know and comply with in the performance of their duties and in relations with third parties. As with the other policies, the Antitrust Code of Conduct was also updated following the acquisition of General Cable, in order to have a document, valid for the entire Prysmian Group, that provides an overview of the problems associated with applying the antitrust regulations and the consequent principles of conduct to be followed. Inaddition,moredetaileddocumentswere alsoadopted covering the antitrust regulations in force within the European Union, North America, China and Australia. Furthermore, concerning the participation in bidding process is specified the prohibition of coordination between competing companies. More specifically, any exchange of information concerning bidding terms, as well as the decision of whether to participate in the tender, is prohibited. y HELPLINE POLICY: The new policy reiterates the importance of communications within the Group, guaranteed by the anonymity available to the reporter, as well as the ban on reprisals against those who report violations. With the formalization of the Helpline Policy — previously known as Whistleblowing Policy - has been established dedicated and secure channels (including telephone lines and a web portal) for individuals who wish to report professional misconduct. These channels are managed by an external independent company, NAVEX Global, which has a binding mandate to protect the identity of all who use the Helpline. They also act as an intermediary to relay any required follow-up information, related questions and answers, as well as information about the resolution of the case. Alongside these channels, has been formed a Helpline Committee. This operates to accurately evaluate any reports, perform specific investigations into cases where required, and adopt coherent and appropriate measures. The compliance policies (Code of Ethics, Global Compliance, Helpline, Anti-Corruption, Gifts & Entertainment, Third-Party Program, Antitrust, Antitrust EU, Conflicts of Interest, Export Control) have beenpublishedon thecorporate intranet andareavailable in theofficial languagesof thePrysmianGroup. Topic SASB Code Accounting metric 2020 2019 Business Ethics RT-EE-510a.2. Total amount of monetary losses as a result of legal proceedings associated with bribery or corruption - - RT-EE-510a.3. Total amount of monetary losses as a result of legal proceedings associated with anti-competitive behavior regulations € 112 million (*) IF-EN-510a.2. Total amount of monetary losses as a result of legal proceedings associated with charges of bribery or corruption - - Total amount of monetary losses as a result of legal proceedings associated with charges of anti-competitive practices € 112 million (*) (*) For more details with respect to the amount of monetary losses as a result of legal proceedings associated with charges of anti-competitive practices, please refer to the details below in the section “Anti-trust”. 18 _ 19 Prysmian Group

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