ANTI-CORRUPTION AND INFLUENCE PEDDLING COMMITMENT

UPERGY, which attaches the utmost importance to acting in an irreproachable manner with its stakeholders, has adopted a code of conduct in accordance with the Sapin II law.

It is intended for all employees, members of executive and management committees, corporate officers of UPERGY and its subsidiaries worldwide. It formalises the principles that the Group’s employees respect in the context of their professional activities. It completes the rules, procedures and standards defined in each country to which employees must continue to refer. All persons acting on behalf of UPERGY are required to comply with this Code of Conduct, regardless of the location or nature of their work. UPERGY ensures that its partners share the same values. This detailed code describes the fundamental rules concerning the following subjects:

• Gifts, sign of courtesy and hospitality, entertainment
• Specific rules for public officials
• Donations to charitable or political organisations
• Patronage, sponsoring
• Facilitation payments
• Commitment to monitoring third parties.

However, this document may not answer all the questions that may arise and does not dispense with exercising one’s own judgement and using common sense. In the event of any doubt about what to do, the Group has set up assistance and advice tools. In addition to the code of conduct, UPERGY has a purchasing policy and a gift policy to comply with the principles of the Sapin II law.

ETHICS COMMITTEE

If you witness or are the victim of a violation of the Code of Ethics or the Code of Conduct, please complete the form available at the following link, so that we can investigate your complaint. You can also contact the Anticorruption Committee using the contact details below:

• lanceurdalerte@upergy.com
• anticorruption@upergy.com
• 04 26 10 21 09

Since 2012, UPERGY has complied with the Global Compact principles on human rights, labour standards and environment, supported by a universal consensus and inspired by the following texts: The Global Compact invites companies to adopt, support and apply within their sphere of influence a set of fundamental values in the areas of human rights, labour standards, the environment and the fight against corruption.

Ethifinance was at the origin of the Gaïa Index, established to measure the ESG (Environment / Social / Governance) performance of companies. UPERGY has taken this voluntary step since 2012, and joined the Gaïa Index in 2018, which includes the 70 companies with the best ESG performance. UPERGY’s ranking evolution below: