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ETHICS THE FIGHT AGAINST CORRUPTION GOVERNANCE

ETHICS

ETHICS CORRESPONDENTS WITHIN THE GROUP

40Rexel s approach to ethics is a continuous improvement process and is based on prin- ciples shared by the Group s 30,000 employees. It helps safeguard the Group s repu- tation and strengthen its part- ners trust, thus contributing to its sustainable growth. The implementation of this

policy is supported by the Ethics Guide, which is dis- tributed to all employees and specifies: the principles and practic-

es of professional ethics at Rexel;

the proper conduct to adopt in various professional situ- ations, including purchasing, client relations, gifts, conflicts of interest, confidentiality, diversity, freedom of expres- sion, harassment, etc.

The guide was updated in 2013 to include compliance with the principles of the Global Compact, the rules regarding fair competition, corporate values and the use of social media. A network of 40 ethics corre- spondents promotes and im- plements the Group s ethics

policy. A submission proce- dure allows everyone, inside or outside the Group, to ask a question or report a problem anonymously by filling out an online contact form. Ethics is the focus of regu- lar information campaigns targeting all employees. At its 2014 plenary meeting, the European Works Council made proposals on the best ways to raise employee awareness regarding the pri- ority issues to be addressed and the form that an ethics- related event should take.

FOREIGN LANGUAGE TRANSLATIONS

OF THE ETHICS GUIDE

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Internal ethics audit In 2014, an in-depth appraisal of the ethics program was carried out by Rexel s Internal Audit Department. Its goal was to evaluate the level of compliance with internal control procedures by the Group and its

subsidiaries, and to assess the current ethics mechanisms. The investigation

consisted of interviews with ethics correspondents in ten countries

and with reference persons at the head office, an analysis of the regulatory

information published since 2008 and a study of current market practices.