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For major international projects, a specific validation procedure frames the Group s commitment. Distributed to the employees concerned, it requires a risk analysis for each project, including the countries involved as well as the contracting parties. Following

the analysis, if the risk level so requires, the teams involved in the project must have completed the training module and must alert the Chief Compliance Officer, who will make

recommendations and form an arbitration committee to decide whether the project should be continued.

The fight against corruption is a key pillar of Rexel s eth- ics policy. The Group is com- mitted to rejecting corruption in all its forms and refuses to resort to any illicit procedures or actions for the purpose of obtaining advantages or

exemptions outside the scope of local or international law. Consequently, Rexel has de- veloped a body of rules and tools designed to control corruption-related risks for all of its activities under the direct responsibility of the

Chief Compliance Officer. In 2014, Rexel reaffirmed its commitment by publishing a set of guiding principles and best practices in anti- corruption, regulating trade relations and fighting against money laundering. Intended for all employees, it specifies the Group s requirements and recommendations in relation to its subsidiaries. Rexel s employees also have access, via a dedicated sec- tion of the Group s Intranet, to the necessary tools for gain- ing a thorough understand- ing of these principles (review of regulations and principles put forth by the OECD and the Global Compact), which can help guide them in deal- ing with sensitive situations. In addition, since July 2014, Rexel has been developing an e-learning module on cor- ruption prevention, available in nine languages. Its imple- mentation in 22 countries is planned for 2015.

Data protection awareness campaign

As a continuation of its ethics policy, in 2014 Rexel launched an awareness raising initiative on personal data protection. Aimed at all Group employees, this campaign draws attention to the risks related to confidentiality and the use of social media.