Report - COP Prototype

2022 Communication on Progress

Power Corporation of Canada

Published date

June 6, 2022

No. of questions

Supplemental files

CEO Statement

Signed

Governance

Policies and Responsibilities

1. Does the Board / highest governance body or most senior executive of the company:

Issue an annual statement about the relevance of sustainable development to the company

Issue an annual statement that addresses impacts on both people and the environment

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

Optional comment

Annual statement: Annually, as we update the content of the Corporation’s sustainability microsite, the Corporation’s Chief Executive Officer (CEO) issues a message on the Corporation’s commitment to responsible management, which can be found here: https://www.powercorporationcsr.com/en/responsible-management/message-our-ceo/. Sustainability targets and ESG reporting: At the executive level, while the CEO plays an active role in reviewing and approving the CSR strategy, performance and reporting, and the executives of the Corporation are responsible for setting the tone for company culture, including espousing the Corporation’s ethics, overall values and approach to environmental, social and governance (ESG) factors, formal responsibility for Corporate Social Responsibility (CSR) has been delegated to the Vice-President and General Counsel, who is our CSR Lead. (Sources: https://www.powercorporationcsr.com/en/responsible-management/governance/; https://www.powercorporation.com/media/uploads/reports/proxy/pcc-notice-proxy-circular-2022-en.pdf, pages 40 and 71) Regular risk review: The Board of Directors provides oversight and carries out its risk management mandate and addresses operational risks primarily through the following committees: the Audit Committee, which addresses risks related to financial reporting and cybersecurity; the Human Resources Committee, which considers risks associated with the Corporation’s compensation policies and practices; the Governance and Nominating Committee, which oversees the Corporation’s approach to appropriately address potential risks related to governance matters; and the Related Party and Conduct Review Committee, which reviews and considers for approval transactions with related parties of the Corporation. In addition, Power Corporation actively monitors emerging risks through: (i) review and analysis at the boards and committees of its operating companies, where local executives describe the emerging risks in their respective environments; and (ii) the Corporation’s executive officers acting as the de facto risk management committee, meeting regularly to identify, analyze, and review the Corporation’s risks and to implement strategies to mitigate those risks. (Source: https://www.powercorporation.com/media/uploads/reports/annual/power_corporation_-_2021_annual_report-final.pdf, pp. 53–57)

2. Does the company have a publicly stated commitment regarding the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a commitment within 2 years	Yes, and the commitment is focused on our own operations	Yes, and the commitment includes our own operations and the value chain	Yes, and the commitment includes our own operations and the value chain along with communities and society
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Additional explanation: The Corporation’s commitments regarding the above-mentioned sustainability topics are formalized in our Code of Business Conduct and Ethics, CSR Statement, Respectful Workplace Policy, Environmental Policy, Responsible Procurement Policy Statement, Anti-Bribery Policy Statement and corresponding Global Anti-Bribery Policy. We also extend these commitments to third parties that work for/on our behalf through our Third Party Code of Conduct. Our major publicly traded operating companies have similar commitments in place. https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-code-of-business-conduct-and-ethics-2020-03-18-eng.pdf https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc_third_party_code_of_conduct_eng_final.pdf https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc_csr_statement_final_2020-03-18.pdf https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-environmental-policy-final-web-2020-03-18.pdf https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-responsible-procurement-policy-statement-2016-en.pdf https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-respectful-workplace-policy-eng-web.pdf https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-anti-bribery-policy-statement-en.pdf https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-global-anti-bribery-policy-2020-en.pdf

3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a code of conduct within two years	Yes, focused on employee conduct	Yes, focused on employees and suppliers	Yes, focused on employees, suppliers, and other business relationships
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

The Corporation’s Code of Business Conduct and Ethics covers a broad range of topics, including compliance, responsible management, conflicts of interest, anti-corruption and anti-bribery, data privacy, respect at work, human rights, and the environment. Third parties who work for/on behalf of the Corporation are required to attest to their compliance with our business standards via our Third Party Code of Conduct. For more information, please refer to: https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-code-of-business-conduct-and-ethics-2020-03-18-eng.pdf https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc_third_party_code_of_conduct_eng_final.pdf

4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

	No one is specifically responsible for this topic	Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)	Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)	Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights	Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

While upholding our human rights commitments is the responsibility of our entire Corporation, the Vice-President and General Counsel, our CSR Lead, is responsible for providing oversight on our human rights commitments. Our labour commitments are overseen by the Vice-President, Human Resources and Administration. Formal responsibility for overseeing the implementation of our Environmental Policy is assigned to the Vice- President and General Counsel and to the Vice-President, Human Resources and Administration. Formal responsibility for overseeing the implementation of our Code of Business Conduct and Ethics and Global Anti-Bribery Policy is assigned to the Vice-President and General Counsel, who provides an annual report to the Audit Committee of the Board. For more information, please refer to: https://www.powercorporationcsr.com/en/responsible-management/our-commitments/code-business-conduct-and-ethics/ https://www.powercorporationcsr.com/en/responsible-management/governance/anti-corruption/ https://www.powercorporationcsr.com/en/responsible-management/governance/human-rights/ https://www.powercorporationcsr.com/en/empowering-people/respectful-inclusive-workplace/ https://www.powercorporationcsr.com/en/environment/environmental-policy/

5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

	No formal structure	Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)	Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)	Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)	Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Please refer to the additional explanation provided for question G4.

Prevention

6. Does the company have a process or processes to assess risk?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

The Corporation has processes in place to assess human rights, labour rights, environmental and corruption risks. The Board of Directors and executive officers of the Corporation have overall oversight and responsibility for risk management associated with the investment activities and operations of the holding company and maintain a comprehensive and appropriate set of policies and controls. The Board’s risk management oversight includes ensuring that material environmental, social and governance risks are appropriately identified, managed and monitored. Environmental risks relate to the adverse impacts that could result from global warming and climate change, waste, and resource consumption. Social risks relate to the adverse impacts on people that could result from improper practices related to human rights, labour conditions, health and safety, harassment, diversity, wages and benefits, and supplier management. Governance risks relate to adverse impacts from unethical practices, including corruption and bribery, conflicts of interest, and data privacy. The Corporation takes a balanced approach to conducting business, providing training and capacity building for its employees to ensure sustainability risks are identified and mitigated consistent with its policies and procedures. Anchored by a strong responsible management culture, the Corporation adheres to the clear guidelines set out in its Code of Conduct, which applies to the Corporation’s Directors, officers and employees, as well as in its Third Party Code of Conduct, which applies to advisors, consultants and suppliers. The Corporation also maintains other supporting policies, procedures and controls, including a Corporate Social Responsibility Statement, an Environmental Policy, a Global Anti-Bribery Policy, a Global Sanctions Policy, a Privacy Policy, and a Respectful Workplace Policy. In addition, we conduct risk assessments of our business to identify potential high-risk exposures to corruption. We have implemented an anti-corruption compliance program that includes training, due diligence of third parties and mandatory reporting, and ensure that all our personnel undergo the annual training program on our Code of Conduct and key corporate policies. We apply equally high ethical standards to third parties dealing with us by conducting risk-based due diligence on consultants or potential acquisitions. For more information, please refer to: 2021 Annual Report, pp. 53 and 57 - https://www.powercorporation.com/media/uploads/reports/annual/power_corporation_-_2021_annual_report-final.pdf https://www.powercorporationcsr.com/en/responsible-management/governance/anti-corruption/

6.1. During the assessment of risk, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

As part of our responsible procurement approach, and in accordance with our CSR commitments, we strive to: (i) ensure that the minimum business standards in our Third Party Code of Conduct are communicated to our third parties and that they attest to their compliance; while this is a continuous process, to date, the vast majority of them have attested to their compliance with the requirements of our Code; (ii) ensure third-party risks are identified and mitigation measures established during the selection process, taking into consideration reputational, financial, governance, economic, social, and environmental risks; and (iii) monitor performance of higher-risk third parties, where relevant. For more information, please refer to: https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-responsible-procurement-policy-statement-2016-en.pdf https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-global-anti-bribery-policy-2020-en.pdf https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc_third_party_code_of_conduct_eng_final.pdf

7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

The Corporation’s Vice-President and General Counsel, our CSR Lead, provides oversight on the implementation of our commitments, including human rights, labour, anti-corruption and the environment. With the support of our Corporate Communications and Sustainability team, we continuously review our performance so that impacts are adequately managed and addressed. Through our active ownership approach, we assess our exposure to potential human rights risks, as well as the policies and programs in place at our publicly traded operating companies and investments to avoid adverse human rights impacts, and the processes to enable remediation measures. We also engage with the senior management of our group companies, both formally and informally, and as needed, to ensure a proper understanding of how their management teams are addressing human rights when questions or issues arise. Among others, we have reviewed the human rights initiatives at our main publicly traded operating companies and investments, consistent with the United Nations Framework and Guiding Principles on Business and Human Rights (the Ruggie Framework). Together with our major publicly traded operating companies, on an annual basis, we also calculate our environmental impacts as they relate to energy, GHG emissions, renewable energy and waste. Through this process, we monitor our performance against set targets, and continue to disclose our energy and GHG governance, strategy, risks, opportunities, and management programs through the CDP. In 2020 and 2021, Power Corporation was one of the only three Canadian companies to receive the top score of A (Leadership) from the CDP. We continued to maintain our anti-corruption compliance program, which includes due diligence of third parties and mandatory reporting. As part of the due diligence process, we continued to apply high ethical standards to third parties dealing with us by conducting risk-based due diligence on consultants or potential acquisitions. Third parties who work for/on our behalf are required to attest to their compliance with our business standards, including with respect to anti-bribery, via our Third Party Code. Finally, to further prevent potential negative impacts on sustainability topics, the Corporation diligently builds awareness though its mandatory training program which Directors, officers and employees of the Corporation are required to complete annually. As the Corporation’s Code of Business Conduct and Ethics covers a broad range of topics, including compliance, responsible management, conflicts of interest, anti-corruption and anti-bribery, data privacy, respect at work, human rights, and the environment, Power uses the mandatory annual training session on its Code of Conduct to raise awareness and educate its people on key ESG themes, with the training session also covering the application of the Corporation’s Respectful Workplace Policy, Global Anti-Bribery Policy, Cybersecurity Policy, Lobbying Policy, CSR Statement, Environmental Policy, Responsible Procurement Policy Statement and Third Party Code of Conduct, among others. The online training course contains testing to demonstrate that employees understand the Code of Conduct and the other policies of the Corporation. At the end of the training, employees are required to certify their compliance with the Code of Conduct and key corporate policies. For more information, please refer to: https://www.powercorporationcsr.com/en/responsible-management/governance/human-rights/ https://www.powercorporationcsr.com/media/uploads/reports/power_corporation_-_2020_esg_data_supplement_-_final.pdf https://www.powercorporationcsr.com/en/environment/climate-adaptation/ https://www.powercorporation.com/media/uploads/reports/proxy/pcc-notice-proxy-circular-2022-en.pdf

7.1. During the due diligence process, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

Please refer to the additional explanations provided for previous questions.

Concerns and grievance mechanisms

8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

No, this is not a current priority

No, but we plan to within two years

Yes, we have an informal process (e.g., through supervisors, others)

Yes, we have a formal process

8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

	No	Yes
Is the process communicated to all employees/workers in local languages?
Is the process available to non-employees (e.g., contractors, vendors, suppliers)?
Is the process confidential (e.g., whistleblowing process)?
Are there processes in place to avoid retaliation?
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other (Please provide additional information)

Optional comment

The Corporation’s Code of Business Conduct and Ethics (the Code), which is approved by the Chief Executive Officer and the Board of Directors, is made available to all the Corporation’s Directors, officers and employees in both English and French (Canada’s two official languages) and covers a broad range of topics, including compliance, responsible management, conflicts of interest, anti-corruption and anti-bribery, data privacy, respect at work, human rights, and the environment. Section 14 of the Code specifically provides for a reporting mechanism by any Director, officer or employee who believes that a violation of the Code or any law, rule or regulation has been or is likely to be committed. Confidentiality of reports made in good faith regarding alleged violations will be maintained to the fullest extent possible, consistent with the need to conduct an adequate review and subject to applicable law. In addition, the Corporation will not discharge, demote or suspend an employee or officer who, in good faith, brings forward reasonable concerns about actual or potential violations of laws, rules or regulations, or the Code. The Corporation has also established the Accounting Complaints Handling Procedures, to allow employees to report complaints or concerns about the Corporation (including any of its wholly owned subsidiaries) regarding matters such as accounting, internal accounting controls or auditing, and to ensure that such reports are investigated promptly and thoroughly. Again, employees may report any complaint or concern anonymously. In addition, pursuant to section 7.2 of the Corporation’s Third Party Code of Conduct, third parties are expected to provide their employees with mechanisms to report violations or potential violations of the Third Party Code or any law, rule or regulation, without fear of reprisal. Any violation or potential violation relating to work performed for, or on behalf of, the Corporation must be reported to the Corporation’s General Counsel. Finally, the Corporation’s Respectful Workplace Policy and Procedures, also available in Canada’s two official languages, describes behaviours that are prohibited, as well as the roles and responsibilities of everyone in maintaining a respectful workplace, free of discrimination, harassment and violence. The Policy outlines the procedures and mechanisms that are available for anyone believing they have been subject to or have witnessed any behaviour which is contrary to the Policy, including a reporting hotline and web portal operated by a third-party provider that is available 24 hours a day, 365 days a year. The Corporation is committed to handling all complaints swiftly and confidentially, to the extent possible in light of the need to take appropriate corrective measures. The Corporation will not take any reprisal or retaliation measures, including any adverse employment measures, against any Director, officer, employee and/or third party who in good faith brings forward actual or potential violations or other concerns. For more information, please refer to: https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-code-of-business-conduct-and-ethics-2020-03-18-eng.pdf https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc_third_party_code_of_conduct_eng_final.pdf https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-respectful-workplace-policy-eng-web_4ZfAes1.pdf

9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

	No process to enable remedy to stakeholders	Remedy available to some stakeholders (i.e., some geographies, employees only)	Remedy is available to all affected stakeholders	Remedy is available to all stakeholders, and suppliers are expected to have similar policies
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

The Corporation’s Respectful Workplace Policy and Procedures, in its Appendix C, provides for measures that may be taken in the event of a well-founded complaint, both as regards the offender and the victim. For more information, please refer to: https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-respectful-workplace-policy-eng-web_4ZfAes1.pdf

Lessons

10. How does the company capture lessons regarding each of the following sustainability topics?

	No lessons are regularly captured	Conducts root cause analyses/investigation of major incidents	Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly	Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Pursuant to the Corporation’s Code of Business Conduct and Ethics, reports regarding alleged violations of laws, rules or regulations, or the Code (which covers human rights, labour rights, environment, and anti-corruption topics), will trigger the conduct of a review or investigation. In addition, the Corporation’s Respectful Workplace Policy and Procedures specifically provides for the conduct of an investigation when the Policy appears to have been breached. Similarly, the Corporation’s Accounting Complaints and Handling Procedures provides for the conduct of a prompt and thorough investigation of reports of complaints or concerns about the Corporation (including any of its wholly owned subsidiaries) regarding, for instance, accounting, internal accounting controls or auditing matters. Should the conclusion of the review or investigation justify it, the Corporation would modify its organization policies, processes or practices so as to prevent any reoccurrence. For more information, please refer to: https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-respectful-workplace-policy-eng-web_4ZfAes1.pdf https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-code-of-business-conduct-and-ethics-2020-03-18-eng.pdf

Executive Pay

11. Is executive pay linked to performance on one or more of the following sustainability topics?

Optional comment

The Corporation’s executive compensation policy specifically includes ESG considerations in decision making, and a portion of the Named Executive Officers’ (NEOs) performance incentives are tied to the Corporation’s progress in integrating ESG into all facets of its business, including ESG factors. The Human Resources Committee of the Board (the Committee) recognizes that ESG considerations and the appropriate tone-from-the-top are an integral part of the CEO’s and other NEOs’ roles. In 2022, the Committee will formalize specific ESG objectives for NEOs on the basis of the Corporation’s renewed ESG strategy and will continue to review opportunities to further reflect the importance of ESG objectives in its approach to compensation decision making and in evaluating the performance of individuals within the senior management group. For more information, please refer to: 2022 Management Proxy Circular, pp. 40 and 71: https://www.powercorporation.com/media/uploads/reports/proxy/pcc-notice-proxy-circular-2022-en.pdf

Board Composition

12. Percentage of individuals within the company’s Board / highest governance body by:

	Number/Percentage	Not applicable (Please provide additional information)
Total number of board members (#)	14
Male (%)	71.43
Female (%)	28.57
Non-binary (%)
Under 30 years old (%)	0
30-50 years old (%)	0
Above 50 years old (%)	100
From minority or vulnerable groups (%)
Executive (%)	7.14
Independent (%)	78.57

Optional comment

The information provided above is the most recent information following the election of the 14 nominees for election to the Corporation’s Board of Directors at the 2022 Annual Meeting of Shareholders held on May 12, 2022. For more information, please refer to: 2022 Management Proxy Circular, pp. 16–30: https://www.powercorporation.com/media/uploads/reports/proxy/pcc-notice-proxy-circular-2022-en.pdf https://www.powercorporation.com/en/governance/board-directors/

Data Assurance

14. Is the information disclosed in this questionnaire assured by a third-party?

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

We are committed to ensuring the quality and integrity of the data we report. To date, our environmental data related to greenhouse gas (GHG) emissions have been verified by PricewaterhouseCoopers (PwC) to a limited level of assurance in accordance with the International Standard on Assurance Engagements 3410, Assurance Engagements on Greenhouse Gas Statements (ISAE 3410).

Limited assurance for majority of metrics

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Optional comment

The limited-level assurance statement from PwC pertaining to the Corporation’s GHG emissions is attached to the Corporation’s annual response to the CDP Climate Change Questionnaire. The Corporation’s most recent response can be consulted here: https://www.powercorporation.com/media/uploads/esg_hub/pcc-2021-cdp-response-final-web.pdf

Human Rights

Commitment

2. Does the company have a policy commitment in relation to the following human rights issues?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
2018 and 2020
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

We are committed to maintaining the confidentiality and security of all personal information we may collect, use and disclose in compliance with applicable laws and regulations. Data privacy and security are of utmost importance to the Corporation, and we have strict policies in place to ensure the personal information entrusted to us is protected. We have formalized our commitment to protecting the information we collect and generate in the policies that govern the way in which we conduct our business. In these policies, we have established specific guidelines relating to the collection, use and disclosure of personal information. We also have policies and procedures relating to the protection of confidential information from theft, loss, unauthorized disclosure, access or destruction, or other misuse. Our Code of Business Conduct and Ethics (last reviewed in March 2020), and our Third Party Code of Conduct (last reviewed in 2020, with no changes) outline our broad expectations regarding the treatment of personal information for both our personnel and the third parties we work with. These expectations are further detailed in our formal policies that cover personal information collected from the public, employee personal information, cybersecurity and record retention: ‒ Our Privacy Policy (last reviewed in 2018) establishes guidelines for the collection, use and disclosure of personal information from the public, including from those using our websites and third-party social media sites, or subscribing to our e-mail notification service. ‒ Our Employee Privacy Policy (last reviewed in March 2020) establishes the guidelines for the collection, use and disclosure by the Corporation of personal information regarding our employees for the purposes of establishing, maintaining and concluding the employment relationship. ‒ Our Security of Technology and Intellectual Property Policy (the “Cybersecurity Policy” – last reviewed in March 2020) sets forth the Corporation’s expectations for all employees, consultants, and contractors with respect to the proper use of the Corporation’s technology and intellectual property, as well as the protection of cybersecurity. ‒ Furthermore, our Record Retention Policy (last reviewed in March 2020) ensures that our records, including personal information, are retained, processed, and destroyed appropriately and in accordance with applicable laws. It should be noted that, as a holding company, the Corporation has no clients of its own. Our group companies are responsible for implementing their own policies and procedures to protect the privacy of their clients’ information. Our major subsidiaries, Great-West Lifeco and IGM Financial, and their operating companies, have established privacy policies which detail their requirements regarding the collection, use and disclosure of personal information, including: ‒ Clearly identifying the purpose of the information they collect; ‒ Providing a means for individuals to opt in or out of the collection of data; ‒ Providing a means for individuals to verify, correct and delete their data, where relevant; and, ‒ Communicating whether third parties have access to the information, the purpose of their use, and the controls in place to ensure the protection of information. As part of our active ownership approach, we are committed to fostering our subsidiaries’ compliance with data privacy and security legislation. More information about Great-West Lifeco’s and IGM Financial’s privacy and cybersecurity policies and programs can be found in their respective public disclosures, including their most recent annual and sustainability reports. For more information, please refer to: https://www.powercorporationcsr.com/en/responsible-management/governance/data-privacy-and-security/ https://www.greatwestlifeco.com/content/dam/gwlco/documents/reports/2022/lifeco-2021-annual-report-en.pdf https://www.greatwestlifeco.com/content/dam/gwlco/documents/code-of-conduct/lifeco-code-of-conduct-2021-en.pdf https://www.igmfinancial.com/content/dam/igm/en/investrelations/finreporting/files/2022/igm-2021-ar-en-digital.pdf https://www.igmfinancial.com/content/dam/igm/en/corpresp/assets/docs/igm-financial-2021-sustainability-report.pdf#page=1

2.1. For each human rights policy, is it:

	Aligned with international human rights standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

Optional comment

Our Code of Business Conduct and Ethics was adopted by the Corporation’s Board of Directors and is publicly available at https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-code-of-business-conduct-and-ethics-2020-03-18-eng.pdf. It applies to Directors, officers and employees of Power Corporation of Canada and its wholly owned subsidiaries, unless a comparable Code applies in respect of the subsidiary. Our Third Party Code of Conduct was approved by the Corporation’s former Co-CEOs and is publicly available at https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc_third_party_code_of_conduct_eng_final.pdf. It applies to all third parties who work on the Corporation’s behalf, including service suppliers, consultants, and advisors, as well as their employees and sub‐contractors. Our Privacy Policy was approved by the Vice-President and General Counsel of the Corporation and is publicly available at https://www.powercorporation.com/en/other/legal/#privacy-policy. It applies to the Corporation’s own operations as it establishes guidelines for the collection, use and disclosure of personal information from the public, including from those using our websites and third-party social media sites, or subscribing to our e-mail notification service. External legal counsel specializing in privacy matters was retained at the time of the development of the policy and when it was last reviewed in 2018. Our Employee Privacy Policy was approved by the Vice-President and General Counsel of the Corporation and is not publicly available. It applies to the Corporation’s own operations, as it establishes the guidelines for the collection, use and disclosure by Power Corporation of personal information regarding our employees for the purposes of establishing, maintaining and concluding the employment relationship. External legal counsel specialized in privacy matters was retained at the time of the development of the policy and when it was last reviewed in 2018. Our Security of Technology and Intellectual Property Policy (the “Cybersecurity Policy”) was approved by the Corporation’s former Co-CEOs and is not publicly available. It applies to the Corporation’s own operations and those of its supply chains and other business relationships as it sets out the Corporation’s expectations for all employees, consultants and contractors with respect to the proper use of the Corporation’s technology and intellectual property, as well as the protection of cybersecurity. Finally, our Record Retention Policy was approved by the Corporation’s former Co-CEOs and is not publicly available. It applies to the Corporation’s own operations. As mentioned in response to question HR2, our group companies are responsible for implementing their own policies and procedures to protect the privacy of their clients’ information. Our major subsidiaries, Great-West Lifeco and IGM Financial, and their operating companies, have established privacy policies which detail their requirements regarding the collection, use and disclosure of personal information. More information about their respective privacy and cybersecurity policies and programs can be found in their respective public disclosures.

Prevention

3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing /mitigating the risks/impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

In the course of the reporting period, the Corporation engaged with a range of stakeholders in relation to digital security and privacy. Internally, the Corporation engaged with its employees and built data security and privacy awareness through continuous employee training and ensuring that all employees are aware and comply with the Corporation’s policies and procedures related to cybersecurity. As noted earlier, as a holding company, the Corporation has no clients of its own. Our group companies are responsible for implementing their own policies and procedures to protect the privacy of their clients’ information. As part of our active ownership approach, we are committed to fostering our subsidiaries’ compliance with data privacy and security legislation and engage with them in that regard. Externally, as part of the deployment of our Third Party Code of Conduct, we engaged with our new and existing key suppliers and business partners on the importance of ESG factors, including privacy and information security (expressly covered at section 4.1 of our Third Party Code), communicating our expectation that they conduct their activities in accordance with the highest legal, ethical, and professional standards, and requiring them to confirm compliance with the Code. While this is a continuous process, to date, the vast majority of them have confirmed their compliance with the requirements of our Code. The Corporation also engaged with investors as well as ESG rating organizations, including MSCI, Refinitiv, and Vigeo Eiris, regarding data security and privacy in 2021. Through these activities, third parties aimed to understand the Corporation’s approach to data security and privacy and the risks it represents for the Corporation, and to assess the Corporation’s performance on this topic. More broadly, we participate in industry-established forums and engage and collaborate with peers on threat intelligence and critical security threats facing the global financial services sector. For more information, please refer to: https://www.powercorporation.com/media/uploads/reports/proxy/pcc-notice-proxy-circular-2022-en.pdf https://www.powercorporation.com/media/uploads/esg_hub/pcc-third-party-code-of-conduct-2020-en_c24z0si.pdf https://www.powercorporationcsr.com/en/responsible-management/governance/data-privacy-and-security/

4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

During the reporting period, the Corporation undertook a series of actions with the aim of preventing the risks associated with digital security and privacy. These were part of measures that are ongoing at the Corporation: ‒ The Corporation has established a comprehensive information and cybersecurity program, benchmarked its capabilities to sound industry practices and has implemented threat and vulnerability assessments and response capabilities, including an IT Security Incident Response Protocol. ‒ Through an external specialist firm, the Corporation periodically conducts an assessment of the maturity of its cybersecurity. The Corporation’s information technology defences are continuously monitored and adapted to both prevent and detect cyberattacks, and then recover and remediate. ‒ Through our annual corporate policies training program, the Corporation also provides cybersecurity awareness training and ensures that all employees are aware of and comply with its policies and procedures related to cybersecurity. In 2020 and 2021, all the Corporation’s Directors, officers and employees certified their compliance. In addition, from time to time, our personnel receive training on more specific cybersecurity-related issues as new risks are identified, or new systems are implemented. In 2021, training specifically focusing on data privacy and security was rolled out, and was completed by 97% of the Corporation’s officers and employees. ‒ We participate in industry-established forums such as the Canadian Cyber Threat Exchange and collaborate with peers on threat intelligence and critical security threats facing the global financial services sector. For more information, please refer to: https://www.powercorporation.com/media/uploads/reports/proxy/pcc-notice-proxy-circular-2022-en.pdf https://www.powercorporationcsr.com/en/responsible-management/governance/data-privacy-and-security/

5. Who receives training for the following human rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

Please refer to the additional explanations provided in previous questions.

6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

To assess progress in preventing the risks and impacts associated with digital security and privacy, the Corporation: ‒ has established a comprehensive information and cybersecurity program, benchmarked its capabilities to sound industry practices, and implemented threat and vulnerability assessments and response capabilities, including an Information Technology Security Incident Response Protocol. ‒ periodically conducts an assessment of the maturity of its cybersecurity through an external specialist firm. The Corporation’s information technology defences are continuously monitored and adapted to both prevent and detect cyberattacks, and then recover and remediate. ‒ provides cybersecurity awareness training through its annual corporate policies training, and ensures that all employees are aware of and comply with its policies and procedures related to cybersecurity. In 2020 and 2021, 100% of our Directors, officers and employees acknowledged compliance with our key corporate policies. In addition, in 2021, 97% of our employees completed training focused exclusively on data privacy and cybersecurity. For more information, please refer to: https://www.powercorporation.com/media/uploads/reports/proxy/pcc-notice-proxy-circular-2022-en.pdf https://www.powercorporationcsr.com/en/responsible-management/governance/data-privacy-and-security/

Response

7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

Supporting and respecting human rights is an intrinsic part of our responsible management approach. Over the past years, the Corporation and its group companies have continued to strengthen the integration of human rights within our business decisions and in the communities in which we operate. Practical actions taken by the Corporation and its group companies in 2020 and 2021 to implement human rights principles regarding non-discrimination in respect to employment and occupation, and occupational safety and health are presented in the response provided to question L13. In addition: ‒ In 2020 and in early 2021, the employees of Power Corporation, Great-West Lifeco and IGM Financial acknowledged their commitment to the companies’ respective codes of business conduct and ethics, which include human rights-related aspects. ‒ IGM Financial added 11 questions related to suppliers’ sustainability practices to its standard request for proposal template in 2021. The questions cover topics such as a company’s policies and disclosures, targets and initiatives to reduce its carbon footprint, fair labour practices, whether it is certified as a diverse supplier, and whether it has been subject to any human rights or sexual harassment allegations or rulings against it. ‒ Groupe Bruxelles Lambert (GBL), one of the Corporation’s publicly traded operating companies, reinforced its commitment to incorporating ESG considerations, including human rights, into its investment analysis process and active ownership approach. A signatory to the UNGC since 2018, GBL formally outlined its support and respect for internationally proclaimed human rights in its ESG policy, which it made public in March 2021. This policy specifically provides that, as a signatory of the UNGC, and recognizing the provisions included in the United Nations Guiding Principles for Business and Human Rights and the OECD Guidelines for Multinational Enterprises, GBL will assess the behaviour of organizations in accordance with those frameworks and excludes investments in organizations involved in severe breaches of their principles. GBL also excludes direct investments in organizations involved in the pornography, prostitution and sex industries. At the group level, implementation efforts include raising the awareness of all employees in regard to corporate values and related human rights aspects, including freedom of speech and opinion, paying fair compensation and absence of discrimination. ‒ Power Corporation’s investment platforms, Sagard and Power Sustainable, have also formalized their commitments to take ESG factors, including human rights, into consideration in their investment analysis processes, through a CSR statement and/or a responsible investment policy. Power Sustainable and Sagard became signatories of the UN Principles for Responsible Investment in December 2020 and April 2021, respectively. In this reporting cycle, the Corporation and its group companies also continued to engage with community organizations regarding opportunities to support community-based needs and initiatives that promote human rights in our own communities and abroad. Examples include: ‒ The Corporation contributes to Lawyers Without Borders Canada, a non-governmental international co-operation organization whose mission is to support the defence of the human rights of people in situations of vulnerability by strengthening access to justice and legal representation, as well as to Equitas, Canada’s most recognized and active human rights education organization, and its series of EquiTalks conferences, which focus on addressing inequities and discrimination and work to build safer and more inclusive communities throughout the world; ‒ In support of the rights of Indigenous people: o The Corporation supports the development of the Institute of Indigenous Self-Determination (IISD) at Yukon University, whose mission, in a partnership between the university and Yukon First Nations, is to improve education outcomes for First Nations students. o The Corporation and IGM Financial’s subsidiary IG Wealth Management formed a partnership with the National Centre for Truth and Reconciliation (NCTR) in support of Imagine a Canada, a national art and leadership program for youth across the country to envision and aspire for reconciliation. o Among other programs, Great-West Lifeco’s Canada Life supported the NCTR’s Na-mi-quai-ni-mak (I Remember Them) Community Support Fund, to assist communities in acknowledging the children who never made it back home from Canadian residential schools; Saskatchewan Polytechnic’s Learner Pathways for Indigenous Empowerment, to help close the gap in high school completion rates between Indigenous and non-Indigenous students; and Ká Ní Káníchihk, a trusted heart of Winnipeg’s Indigenous community that delivers effective, Indigenous-designed and -led programs helping individuals and families heal, learn, and succeed. o 2021 was the first official year of the IG Empower Your Tomorrow Indigenous Commitment, which will dedicate $5 million over five years to support programs and initiatives to further the financial confidence of Indigenous communities in Canada. As part of this commitment, IG Wealth Management, an IGM Financial operating company, is partnering with Prosper Canada to deliver customized financial literacy and education training to Indigenous Peoples in isolated, rural communities. o Mackenzie Investments signed the Canadian Investor Statement on Climate Change, which supports a distinctly Canadian transition to net zero that leaves no worker or community behind, is informed by Indigenous perspective, and supports Indigenous economic opportunities. ‒ In support of the rights of women and children: o The Corporation has been a long-time supporter of the Dallaire Institute, which works to prevent the recruitment and use of children as soldiers; o Great-West Lifeco, through Canada Life, contributed to several organizations supporting women and children who have experienced violence, abuse and poverty, including the Calgary Women’s Emergency Shelter, SOFIA House, ChezRachel, Food4Kids Ontario, SOS Violence Conjugale, Adsum for Women and Children, and Toba Centre for Children and Youth, the only child advocacy centre in the province of Manitoba, which focuses on the needs of children and youth who have experienced abuse or witnessed violence. For more information, please refer to: https://www.powercorporationcsr.com/en/responsible-management/governance/human-rights/ https://www.greatwestlifeco.com/content/dam/gwlco/documents/misc/public-accountability-statement-2021.pdf https://www.igmfinancial.com/content/dam/igm/en/corpresp/assets/docs/igm-financial-2021-sustainability-report.pdf#page=1 https://www.gbl.be/system/files/public-files/GBL%20ESG%20Policy.pdf https://www.gbl.be/en/media/3749/en-GBL-RA2021_0.pdf#page=123 https://www.unpri.org/signatories/signatory-resources/signatory-directory https://www.sagard.com/responsibility/

Labour

Commitment

1. Does the company have a policy commitment in relation to the following labour rights principles?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
March 2020, February 2016
Forced labour
March 2020, February 2016
Child labour
March 2020, February 2016
Non-discrimination in respect of employment and occupation
March 2020, February 2016, March 2021
Occupational safety and health
March 2020, February 2016
Working conditions (wages, working hours)

Optional comment

At Power Corporation, we strive to create an environment where people feel connected and supported, and where they can thrive both professionally and personally. In addition to complying with relevant labour laws, we are committed to the following labour principles, as outlined in our Code of Business Conduct and Ethics and our Respectful Workplace Policy and Procedures: ‒ Providing a workplace in which all people are treated fairly, with dignity, mutual respect and professionalism. ‒ Providing equal employment, appointment and advancement opportunities based on appropriate qualifications, requirements and performance. ‒ Providing a workplace free from all forms of discrimination. We will not tolerate unlawful discrimination on the basis of, among other things, age, sex, sexual orientation, race, national origin, religion or disability. ‒ We do not tolerate forced or compulsory labour, child labour, harassment, including sexual or psychological harassment, threats, violence, or other disrespectful or inappropriate behaviour in the workplace. ‒ We recognize the right to fair employment and working conditions, as required by law. The Corporation’s Corporate Social Responsibility Statement also provides for the Corporation to support and respect the protection of internationally proclaimed human rights, including when investments are made. We also extend our labour commitments to third parties that work for/on our behalf, through our Third Party Code of Conduct. Our major operating subsidiaries have in place similar labour principles as defined in their respective codes of conduct. • Regarding freedom of association and the right to collective bargaining: Section 5 of the Corporation's Code of Business Conduct and Ethics, which was last reviewed in March 2020, provides that the Corporation is committed to employment practices that comply with applicable employment laws and regulations. For context, freedom of association is a fundamental freedom under the Canadian Charter of Rights and Freedoms. Section 5 also provides that the Corporation endeavours to support and respect internationally proclaimed human rights under the Universal Declaration of Human Rights and International Labour Organization (ILO) conventions. In addition, section 5.1 of the Corporation's Third Party Code of Conduct, which was last reviewed in February 2016, provides that all third parties who work on the Corporation’s behalf, including service suppliers, consultants, and advisors, as well as their employees and sub‐contractors, shall adopt employment practices that comply with applicable employment and labour laws and regulations as well as with internationally proclaimed human rights, which include the Universal Declaration of Human Rights and ILO conventions. This includes but is not limited to requirements regarding minimum wage, working hours, overtime, days of rest, compensation, and freedom of association. For more information, please refer to: https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-code-of-business-conduct-and-ethics-2020-03-18-eng.pdf https://laws-lois.justice.gc.ca/eng/const/FullText.html https://www.powercorporation.com/media/uploads/esg_hub/pcc-csr-statement-en_gcl8hw5.pdf https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc_third_party_code_of_conduct_eng_final.pdf • Regarding forced labour: Section 5 of the Corporation's Code of Business Conduct and Ethics, which was last reviewed in March 2020, provides that the Corporation is committed to employment practices that comply with applicable employment laws and regulations. Section 5 also provides that the Corporation endeavours to support and respect internationally proclaimed human rights under the Universal Declaration of Human Rights and International Labour Organization (ILO) conventions. In addition, section 5.1 of the Corporation's Third Party Code of Conduct, which was last reviewed in February 2016, provides that all third parties who work on the Corporation’s behalf, including service suppliers, consultants, and advisors, as well as their employees and sub‐contractors, shall adopt employment practices that comply with applicable employment and labour laws and regulations as well as with internationally proclaimed human rights, which include the Universal Declaration of Human Rights and ILO conventions. Section 5.1 also provides for third parties to adopt employment practices that prohibit the use of forced labour, which includes work or service exacted under the threat of penalty (including imprisonment), or for which the person performing the work or service has not offered himself or herself voluntarily. For more information, please refer to: https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-code-of-business-conduct-and-ethics-2020-03-18-eng.pdf https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc_third_party_code_of_conduct_eng_final.pdf https://www.powercorporation.com/media/uploads/esg_hub/pcc-csr-statement-en_gcl8hw5.pdf • Regarding child labour: Section 5 of the Corporation's Code of Business Conduct and Ethics, which was last reviewed in March 2020, provides that the Corporation is committed to employment practices that comply with applicable employment laws and regulations and that it endeavours to support and respect internationally proclaimed human rights under the Universal Declaration of Human Rights and International Labour Organization (ILO) conventions. In addition, section 5.1 of the Corporation's Third Party Code of Conduct, which was last reviewed in February 2016, provides that all third parties who work on the Corporation’s behalf, including service suppliers, consultants, and advisors, as well as their employees and sub‐contractors, shall adopt employment practices that comply with applicable employment and labour laws and regulations as well as with internationally proclaimed human rights, which include the Universal Declaration of Human Rights and ILO conventions. Convention No. 138 on Minimum Age and Convention No. 182 on the Worst Forms of Child Labour are two ILO fundamental conventions. For more information, please refer to: https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-code-of-business-conduct-and-ethics-2020-03-18-eng.pdf https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc_third_party_code_of_conduct_eng_final.pdf https://www.ilo.org/ipec/facts/ILOconventionsonchildlabour/lang--en/index.htm https://www.powercorporation.com/media/uploads/esg_hub/pcc-csr-statement-en_gcl8hw5.pdf • Regarding non-discrimination in respect to employment and occupation: The Corporation’s Code of Business Conduct and Ethics, which was last reviewed in March 2020, as well as our Respectful Workplace Policy and Procedures, which were last reviewed in March 2020, reinforce our commitment to provide a work environment of equal opportunities in employment, appointment and advancement, based on appropriate qualifications, requirements and performance, and our commitment to support an inclusive and diverse workforce in which unlawful discrimination will not be tolerated. Section 4 of the Code of Conduct prohibits unlawful discrimination on the basis of, among other things, age, sex, sexual orientation, race, national origin, religion or disability. Section 3.1 of our Respectful Workplace Policy and Procedures goes into greater detail and specifically prohibits unlawful workplace discrimination on the basis of any of the following grounds: ‒ Race, colour, ancestry, Indigenous origin, ethnic background or origin, civil status, nationality, or citizenship; ‒ Age (except as provided by law), sex, gender identity or expression, or sexual orientation; ‒ Religion or religious activity, association, belief(s) or creed; ‒ Physical or mental disability or handicap; ‒ Political belief, opinion, activity or affiliation; ‒ Language or linguistic background; ‒ Marital status, family status or affiliation, pregnancy, or adoption; ‒ Lawful source of income or receipt of public assistance; ‒ Social condition or origin; ‒ Criminal conviction for an offence which is not connected with the employment or for which a pardon has been granted; or ‒ Actual or presumed association with other individuals or groups whose identity or membership is determined by any of the above grounds. Section 5.2 of our Third Party Code of Conduct, which was last reviewed in February 2016, also states that third parties are expected to treat all their employees fairly, ethically, respectfully and with dignity, including respect for differences such as gender, race, colour, age, disability, sexual orientation, ethnic origin and religion. In addition, we are committed to promoting diversity on the Board and within senior management, as provided in our Board and Senior Management Diversity Policy, which was last reviewed in March 2021. For the purposes of our Board and Senior Management Diversity Policy, diversity includes, but is not limited to, age, experience, education, geography, gender, sexual orientation, disability, race, nationality, culture, language and other ethnic distinctions, including Indigenous people. For more information, please refer to: https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-code-of-business-conduct-and-ethics-2020-03-18-eng.pdf https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-respectful-workplace-policy-eng-web.pdf https://www.powercorporationcsr.com/en/responsible-management/governance/board-and-senior-management-diversity/ https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc_third_party_code_of_conduct_eng_final.pdf https://www.powercorporation.com/media/uploads/esg_hub/pcc-csr-statement-en_gcl8hw5.pdf • Regarding occupational safety and health: Section 6 of the Corporation's Code of Business Conduct and Ethics, which was last reviewed in March 2020, reiterates the Corporation’s long-standing commitment to providing employees with a safe workplace in compliance with applicable regulations. Section 1 of the Corporation’s Respectful Workplace Policy and Procedures, which were last reviewed in March 2020, also states the Corporation’s commitment to fostering a discrimination-, harassment- and violence-free workplace where all people are treated with respect and dignity, in a healthy, safe and productive work environment. Through its Third Party Code of Conduct, which was last reviewed in February 2016, the Corporation extends this commitment to all third parties who work on the Corporation’s behalf, including service suppliers, consultants, and advisors, as well as their employees and sub‐contractors. Section 5.3 of the Third Party Code provides that third parties are expected to provide a safe and healthy working environment, in accordance with all applicable laws and regulations, and must take appropriate action to prevent occupational illnesses and work‐related accidents. For more information, please refer to: https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-code-of-business-conduct-and-ethics-2020-03-18-eng.pdf https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-respectful-workplace-policy-eng-web.pdf https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc_third_party_code_of_conduct_eng_final.pdf https://www.powercorporation.com/media/uploads/esg_hub/pcc-csr-statement-en_gcl8hw5.pdf

1.1. For each labour rights policy, is it:

	Aligned with international labour standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

• Regarding freedom of association and the right to collective bargaining: Our Code of Business Conduct and Ethics was adopted by the Corporation’s Board of Directors and is publicly available at https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-code-of-business-conduct-and-ethics-2020-03-18-eng.pdf. It applies to Directors, officers and employees of Power Corporation of Canada and its wholly owned subsidiaries, unless a comparable Code applies in respect to the subsidiary. Section 5 of the Code aligns with international labour standards as it refers to the International Labour Organization (ILO) conventions. It also provides for compliance with applicable employment laws and regulations, which include, in Canada, the Canadian Charter of Rights and Freedoms (which covers freedom of association). In addition, the Corporation’s Corporate Responsibility Statement (CSR Statement), which was adopted by the Corporation’s Board of Directors and is publicly available at https://www.powercorporation.com/media/uploads/esg_hub/pcc-csr-statement-en_gcl8hw5.pdf, provides guidance to our investment professionals at the holding company level; it provides for the support and respect of internationally proclaimed human rights, including when investments are made. Our Third Party Code of Conduct was adopted by the Corporation’s former Co-CEOs and is publicly available at https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc_third_party_code_of_conduct_eng_final.pdf. It applies to all third parties who work on the Corporation’s behalf, including service suppliers, consultants, and advisors, as well as their employees and sub‐contractors. Section 5.1 is aligned with international labour standards as it refers to the ILO conventions. • Regarding forced labour: For information about the alignment with international labour standards, public availability, formal approval and internal/external application of our Code of Business Conduct and Ethics, CSR Statement and Third Party Code of Conduct, please refer to the additional explanations provided under the freedom of association section. • Regarding child labour: For information about the alignment with international labour standards, public availability, formal approval and internal/external application of our Code of Business Conduct and Ethics, CSR Statement and Third Party Code of Conduct, please refer to the additional explanations provided under the freedom of association section. • Regarding non-discrimination in respect of employment and occupation: For information about the alignment with international labour standards, public availability, formal approval and internal/external application of our Code of Business Conduct and Ethics, CSR Statement and Third Party Code of Conduct, please refer to the additional explanations provided under the freedom of association section. Our Respectful Workplace Policy and Procedures were adopted by the Human Resources Committee (previously the Compensation Committee) of the Board of Directors and are publicly available at https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-respectful-workplace-policy-eng-web.pdf. The Respectful Workplace Policy applies to all current employees of the Corporation and its wholly owned subsidiaries (unless such subsidiary has a similar policy in place), including senior managerial personnel and full-time, part-time, contract, student, trainee, permanent and temporary employees (collectively, the “Corporation Personnel”). This Policy also applies to situations in which Corporation Personnel experience discrimination in the workplace by individuals who are not Corporation Personnel, such as contractors, consultants, clients, job applicants, suppliers or visitors. Section 3.1 of our Respectful Workplace Policy and Procedures specifically prohibits unlawful workplace discrimination on the basis of numerous grounds, including race, colour, sex, religion, political opinion, and origin and, as such, is aligned with the International Labour Organization’s Discrimination (Employment and Occupation) Convention, No. 111. Our Board and Senior Management Diversity Policy was adopted by the Board of Directors. Although the policy is not publicly available, details about the policy are provided at pages 67 and 69 of the Corporation’s publicly available Management Proxy Circular available at https://www.powercorporation.com/media/uploads/reports/proxy/pcc-notice-proxy-circular-2022-en.pdf. The Policy applies to the Corporation’s Board and Senior Management and therefore to the Corporation’s own operations. • Regarding occupational safety and health: For information about the alignment with international labour standards, public availability, formal approval and internal/external application of our Code of Business Conduct and Ethics, CSR Statement and Third Party Code of Conduct, please refer to the additional explanations provided under the freedom of association section. For information about the alignment with international labour standards, public availability, formal approval and internal/external application of our Respectful Workplace Policy and Procedures, please refer to the additional explanations provided under the non-discrimination in respect of employment and occupation section.

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks /impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

During the reporting period, the Corporation engaged with a range of stakeholders in relation to the above-listed labour rights issues. Internally, the Corporation engaged with its employees through its performance and career management program, which provides a forum that encourages ongoing conversations between the Corporation’s employees and their supervisors on a host of topics, including labour rights. The Corporation also engaged with employees through periodic webcasts throughout the year that include Q&A sessions with executives for employees to ask questions. Externally, as part of the deployment of our Third Party Code of Conduct in 2020 and 2021, we engaged with our existing and new key suppliers and business partners on the importance of ESG factors, including all of the labour rights issues listed above, expressing our expectations that they conduct their activities in accordance with the highest legal, ethical, and professional standards, and requiring them to attest to compliance with the Code. While this is a continuous process, to date, the vast majority of them have attested to their compliance with the requirements of our Code. The Corporation also engaged with investors, responsible investment and ESG rating organizations such as MSCI, Sustainalytics, Refinitiv, FTSE4Good and Vigeo Eiris regarding labour rights in 2021. All the labour rights issues listed above were covered by one or more of the Corporation’s engagement activities with the aforementioned stakeholders. Through these activities, third parties aimed to understand the Corporation’s approach to these topics and the level of risk they represent for the Corporation, and to assess the Corporation’s performance considering the metrics they are each monitoring on those topics. We are also proud of the actions of our group companies in 2020 and 2021, which have also been engaging with affected stakeholders in relation to the above-listed labour rights: ‒ IGM Financial engaged with its employees in various ways, including through engagement and pulse surveys, employee forums and intranet, performance and development discussions, team meetings and town halls with local leaders, and Q&A webcasts with executives. Key engagement topics in 2021 included health and wellness, diversity, equity and inclusion, and Indigenous reconciliation. ‒ In 2020, Great-West Lifeco’s subsidiary Canada Life continued to engage with its leadership through education and resources that address unconscious biases in its decision-making and management practices. It also continued to offer its Inclusion for All training to all employees in 2021 to help them better identify and understand their own unconscious biases and the unintended impacts they may have. Similarly, IGM Financial engaged with employees and advisors by offering unconscious bias training to all leaders and employees, and added an unconscious bias training program for IG advisors. As at the end of 2021, 70% of IGM Financial’s employees had completed inclusive behaviour training. ‒ All three of IGM Financial’s operating companies are signatories to the United Nations’ Women’s Empowerment Principles, and engage with organizations such as GATE, Catalyst and Women in Capital Markets for guidance in implementing targeted strategies and initiatives aimed at preventing risks and enabling the upward mobility of existing talent and increasing sourcing opportunities for external talent. IGM Financial also engages as a partner with organizations such as Pride at Work Canada and the Canadian Centre for Diversity and Inclusion, whose mission is to help those they work with to be inclusive, free of prejudice and discrimination, and generate awareness, dialogue and action for people to recognize diversity as an asset and not an obstacle. ‒ In 2020, several of the Power group companies, including Mackenzie Investments, IG Wealth Management, Investment Planning Counsel, Canada Life and Wealthsimple, engaged with the non-profit organization BlackNorth Initiative and signed the BlackNorth Initiative’s pledge, which has as its objective to combat anti-Black systemic racism in corporate Canada. Canada Life formed a new Black and People of Colour employee resource group (ERG), alongside its Women in Leadership, Pride@Canada Life, Indigenous Peoples, Ability First, and Young Professionals ERGs. For its part, IGM Financial formed a Black Advisory Council, which includes 54 members from across its operating companies and regions, to share their perspectives and experiences and provide input on initiatives for attracting, retaining and advancing Black colleagues. In 2021, it also engaged with the Onyx Initiative as a new partner to help close the systemic gap in the hiring, retention and promotion of Black college and university students. ‒ IG Wealth Management and Canada Life are signatories of Winnipeg’s Indigenous Accord, committing to acting on one goal each year for three years to help advance a specific Call to Action of Canada’s Truth and Reconciliation Commission. With the support of their Indigenous Partners in Action team, IGM Financial and its operating companies, including IG Wealth Management, offer employee training on the history of Indigenous relations and the need for reconciliation. In addition, in 2021, both IGM Financial and Canada Life continued to engage with employees by offering KAIROS Blanket Exercises, which are sessions developed by KAIROS in collaboration with Indigenous elders, knowledge keepers and educators to foster truth, respect, reconciliation and understanding of our shared history among Indigenous and non-Indigenous peoples. ‒ Regarding occupational safety and health, Great-West Lifeco, through its operating company Canada Life and Workplace Strategies for Mental Health, compliments of Canada Life (Workplace Strategies), engaged with Canadian employees and employers throughout 2021 regarding the protection of psychological health and safety at work. Workplace Strategies teamed up with Mental Health Research Canada to conduct research on several important topics in the mental health landscape. The first survey, completed in fall 2021, engaged with more than 1,200 Canadian managers on how they felt they were protecting their employees’ psychological health and safety. The second survey, completed in December 2021, engaged with more than 5,000 Canadian employers and employees, including a strong representation of marginalized populations, such as people in the BIPOC and 2SLGBTQ+ communities. In addition, in September 2021, Canada Life launched the updated Psychologically Safe Leader Assessment (PSLA) web tool, accessible to all Canadians, aimed at creating a psychologically safe workplace and understanding any gaps there may be between leader and employee perceptions. Canada Life also engaged directly with its own leaders and employees regarding wellness at work. Launched in 2020, its Table Talk sessions continued strong in 2021. Featuring industry experts and Canada Life leaders, some sessions were focused on supporting leaders while others were for all employees. For more information, please refer to: https://www.powercorporationcsr.com/en/responsible-management/governance/human-rights/ https://www.powercorporationcsr.com/en/empowering-people/respectful-inclusive-workplace/ https://www.igmfinancial.com/content/dam/igm/en/investrelations/finreporting/files/2022/igm-2021-ar-en-digital.pdf https://www.igmfinancial.com/content/dam/igm/en/corpresp/assets/docs/igm-financial-2021-sustainability-report.pdf#page=1 https://www.greatwestlifeco.com/content/dam/gwlco/documents/misc/public-accountability-statement-2021.pdf

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

In 2020 and 2021, the Corporation provided all its officers and employees with its annual mandatory training on its Code of Business Conduct and Ethics and its Third Party Code of Conduct, both of which cover the labour rights issues listed above. The mandatory annual training also discusses the Corporation’s Respectful Workplace Policy and Procedures, which emphasize the Corporation’s commitment to provide a respectful and equitable workplace, free of discrimination, harassment and violence. As regards non-discrimination more specifically, as per the procedures and mechanisms available for anyone believing they have been subject to or have witnessed any behaviour which is contrary to the Respectful Workplace Policy and Procedures, the Corporation remained committed to handling and investigating all complaints swiftly and confidentially, to the extent possible in light of the need to take appropriate corrective measures. Outside the organization, the Corporation pursued the deployment of its Third Party Code of Conduct with its existing and new key suppliers and business partners. While this is a continuous process, to date, the vast majority of them have attested to their compliance with the requirements of our Code, which covers all of the labour rights issues listed above. The Corporation also supported initiatives that promote labour rights in our community. For example, Power Corporation supports Lawyers Without Borders as well as Equitas, Canada’s most recognized and active human rights education organization, including its series of EquiTalks conferences that focus on addressing inequities and discrimination and work to build safer and more inclusive communities. The Corporation’s main publicly traded operating companies, Great-West Lifeco and IGM Financial, also took concrete actions in 2021 to prevent risks or impacts associated with discrimination in respect to employment and occupation. Please refer to the additional explanation provided in response to question L2 for an overview of various training programs offered to their respective leadership, employees and advisors, as well as of the engagement initiatives aimed at building awareness they put forward during the year. In addition to these, in 2021, IGM Financial hired its first Vice-President, Diversity, Equity and Inclusion (DE&I) to refresh, expand and implement its strategy across the entire company, and required that all IGM people leaders have a DE&I objective as part of their annual short-term incentive objectives. It also broadened its recruiting strategy to source, attract and hire a more diverse workforce, and addressed unconscious bias in the recruitment process. In addition, it created a new role of Senior Talent Advisor, Indigenous Relations, to help build a pipeline of strong Indigenous talent across IGM, and increased its connections with community groups, including partnerships with the Onyx Initiative and Accelerate Her FutureTM. Finally, IGM Financial updated its DE&I targets in 2021 to 35% female representation in roles of vice-president and up by 2025, 3.5% Black executive representation by 2025, and 3% Indigenous workforce by 2025. At Great-West Lifeco, Canada Life and GWL Realty Advisors participated in the Rick Hansen Foundation’s Buildings Without Barriers Challenge to create accessible spaces for all through inclusive design, and the London, Toronto, and Winnipeg head offices all attained Rick Hansen Foundation Accessibility Certification. The Corporation’s main publicly traded operating companies also took concrete actions in 2021 to prevent risks or impacts associated with occupational safety and health. As part of its approach to health and wellness, in 2021 IGM Financial relaunched its Wellness Watch program, which focuses on where employees are within a spectrum of wellness. In 2020 and 2021, the emphasis was on stress and resilience support, sleep, work-life balance, and financial resources and planning – areas that were identified in IGM Financial’s wellness surveys as being most important to its employees. New programs and events in 2021 included, among others, a mental health virtual wellness fair, bimonthly Wellness 101 education sessions, mental health training for people leaders and mental health awareness training for employees. As for Great-West Lifeco, to help support its employees and their well-being during the COVID-19 pandemic, it updated its Lifestyles benefits program to provide more mental health coverage and enhanced their wellness accounts. It also took concrete action to help prevent risks or impacts associated with occupational safety and health outside its own organizational boundaries through Workplace Strategies for Mental Health, compliments of Canada Life, and the launch of the updated Psychologically Safe Leaders Assessment tool, both discussed in greater detail in the additional explanation provided in response to question L2. For more information, please refer to: https://www.powercorporationcsr.com/en/responsible-management/governance/human-rights/ https://www.powercorporationcsr.com/en/empowering-people/respectful-inclusive-workplace/ https://www.igmfinancial.com/content/dam/igm/en/corpresp/assets/docs/igm-financial-2021-sustainability-report.pdf#page=1 https://www.igmfinancial.com/content/dam/igm/en/investrelations/finreporting/files/2022/igm-2021-ar-en-digital.pdf https://www.greatwestlifeco.com/content/dam/gwlco/documents/reports/2022/lifeco-2021-annual-report-en.pdf https://www.greatwestlifeco.com/content/dam/gwlco/documents/misc/public-accountability-statement-2021.pdf

4. Who receives training for the following labour rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

Please refer to the additional explanation provided for L2 and L3 regarding training by the Corporation and its group companies.

5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

The Corporation assesses progress in preventing and mitigating the risks and impacts associated with the above-listed labour rights issues through monitoring and tracking, reviewing issues on an ad hoc basis when relevant, and as regards non-discrimination and diversity, by setting objectives and tracking progress over time. The various labour rights issues listed in the above table are covered by the Corporation’s Code of Business Conduct and Ethics and Third Party Code of Conduct which, together, govern the conduct of the Corporation’s Directors, officers, employees, advisors, consultants and suppliers. The Board of Directors of the Corporation oversees compliance with the Code of Conduct through the Corporation’s General Counsel and Secretary, who monitors compliance and provides an annual report to the Audit Committee of the Board. Directors and employees of the Corporation are required to confirm annually, and officers of the Corporation are required to confirm quarterly, their understanding of, and agreement to comply with, the Code of Conduct. Participation in the mandatory annual training on the Corporation’s Code of Business Conduct and Ethics and other key corporate policies, including the Respectful Workplace Policy, is also monitored and tracked on an annual basis. The third-party-operated hotline put in place by the Corporation to allow employees to report an incident in breach of the Corporation’s Respectful Workplace Policy is an additional means for the Corporation to assess non-discrimination prevention. Regarding non-discrimination in employment and diversity, the Corporation’s Diversity Policy establishes an objective of having not less than 30% of the seats on the Corporation’s Board held by women by the completion of the Corporation’s Annual Meeting of Shareholders to be held in 2025. Following the 2022 Annual Meeting of Shareholders on May 12, 2022, female representation on the Corporation’s Board of Directors was 28.57%. The Corporation also tracks female representation in management roles at the holding level (which was 43% as at December 31, 2021), as well as throughout the Power group of companies workforce, on an annual basis. In addition, as a Quebec-based company that employs 10 employees or more, the Corporation is subject to the Quebec Pay Equity Act, which provides for the creation of a pay equity plan applicable throughout the enterprise and the conducting of a pay equity audit every 5 years. Every such audit covers the 5 preceding years and Power Corporation has been complying with the Act requirements since 2001. For more information, please refer to the following Quebec government website: http://legisquebec.gouv.qc.ca/en/showdoc/cs/E-12.001. Externally, the Corporation monitors the continued deployment of its Third Party Code of Conduct with its existing and new key suppliers and business partners, and tracks which of them have attested to their compliance with the requirements of the Third Party Code, which covers the labour rights issues listed above. As discussed in the additional explanation provided in response to question L2, several of the Power group companies also assess progress in preventing and mitigating labour rights risks and impacts by tracking participation rates in various training programs. In addition, IGM Financial launched the Count me in! voluntary self-identification initiative in late 2020 to understand the demographic makeup of its workforce, set representation targets and track its progress. It also now requires new hires to self-identify as part of their onboarding process. In 2021, it required that all IGM people leaders have a DE&I objective as part of their annual short-term incentive objectives, which will be tracked. The company also updated its DE&I targets in 2021 and will be tracking progress in them. Those targets are: (i) 35% women representation in vice-president positions and up by 2025 (40% for assistant vice-president positions), (ii) 3.5% Black executive representation by 2025, and (iii) 3% Indigenous workforce by 2025. Finally, IGM Financial retained a third-party firm in 2021 to conduct a gender pay audit among its senior managers and above to identify any pay disparities that may exist between men and women engaged in work of similar value. The results showed that IGM did not have a statistically significant gender pay gap. In the few cases where differences existed, IGM took action to close the gap. As for Great-West Lifeco, it adopted the objective to have at least 30% female representation on its board of directors and senior management team. Great-West Lifeco’s operating company Canada Life is also monitoring and tracking female representation among its management and workforce annually. In 2021, 46% of its management and 68% of its workforce were female. For more information, please refer to: https://www.powercorporation.com/media/uploads/reports/quarter/pcc-q4-2021-eng-web_Z59BM3k.pdf https://www.powercorporation.com/media/uploads/reports/proxy/pcc-notice-proxy-circular-2022-en.pdf https://www.powercorporation.com/en/governance/board-directors/ https://www.igmfinancial.com/content/dam/igm/en/corpresp/assets/docs/igm-financial-2021-sustainability-report.pdf#page=1 https://www.greatwestlifeco.com/content/dam/gwlco/documents/reports/2022/lifeco-2021-annual-report-en.pdf https://www.greatwestlifeco.com/content/dam/gwlco/documents/misc/public-accountability-statement-2021.pdf

Performance

6. What is the percentage of employees covered under collective bargaining agreements?

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	0

Optional comment

There is no collective bargaining agreement in place at the Power Corporation (holding company) level.

7. What is the percentage of employees in a trade union or other workers' organization?

	Percent of employees (%)	Unknown	Not applicable (Please provide additional information)
Employees in a trade union or on a worker committee (%)
There is no employee in a trade union at the Power Corporation (holding company) level.

8. In the course of the reporting period, what was the percentage of women in:

	Percent of women (%)	Unknown
Senior leadership level position	31
Non-executive board	28.57

Optional comment

Senior leadership level positions: 2022 Management Proxy Circular, p. 69: https://www.powercorporation.com/media/uploads/reports/proxy/pcc-notice-proxy-circular-2022-en.pdf Non-executive board: 2022 Management Proxy Circular, p. 67: https://www.powercorporation.com/media/uploads/reports/proxy/pcc-notice-proxy-circular-2022-en.pdf https://www.powercorporation.com/en/governance/board-directors/

9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

	Salary ratio (%)	Unknown	Choose to not disclose
Women / Men (%)
For our operations at the holding level, as a Quebec-based company that employs 10 employees or more, Power Corporation is subject to the Quebec Pay Equity Act, which provides for the creation of a pay equity plan applicable throughout the enterprise and the conducting of a pay equity audit every 5 years. Every such audit covers the 5 preceding years and Power Corporation has been complying with the Act requirements since 2001. Power Corporation also provides complementary enhancement of governmental maternity, paternity and parental leave programs for the duration of the leave. For more information about the Quebec Pay Equity Act, please refer to the following Quebec government website: http://legisquebec.gouv.qc.ca/en/showdoc/cs/E-12.001

10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury

Optional comment

Power Corporation’s employee data is consolidated based on the definition of financial control and therefore includes our publicly traded operating companies Great-West Lifeco and IGM Financial, as well as the Corporation’s wholly owned or controlled subsidiaries. As not all operating companies and/or wholly owned or controlled subsidiaries publicly disclose this information, the Corporation is not in a position to publicly disclose consolidated data. At the holding level, there were no work-related injuries in 2020.

11. In the course of the reporting period, what was the company’s incident rate?

	Incident rate	Unknown	Choose to not disclose
Incident rate

Optional comment

Response and Reporting

12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Power Corporation’s employee data is consolidated based on the definition of financial control and therefore includes our publicly traded operating companies Great-West Lifeco and IGM Financial, as well as the Corporation’s wholly owned or controlled subsidiaries. As not all operating companies and/or wholly owned or controlled subsidiaries publicly disclose this information, the Corporation is not in a position to publicly disclose consolidated data.
Forced labour
Power Corporation’s employee data is consolidated based on the definition of financial control and therefore includes our publicly traded operating companies Great-West Lifeco and IGM Financial, as well as the Corporation’s wholly owned or controlled subsidiaries. As not all operating companies and/or wholly owned or controlled subsidiaries publicly disclose this information, the Corporation is not in a position to publicly disclose consolidated data.
Child labour
Power Corporation’s employee data is consolidated based on the definition of financial control and therefore includes our publicly traded operating companies Great-West Lifeco and IGM Financial, as well as the Corporation’s wholly owned or controlled subsidiaries. As not all operating companies and/or wholly owned or controlled subsidiaries publicly disclose this information, the Corporation is not in a position to publicly disclose consolidated data.
Non-discrimination in respect of employment and occupation
Power Corporation’s employee data is consolidated based on the definition of financial control and therefore includes our publicly traded operating companies Great-West Lifeco and IGM Financial, as well as the Corporation’s wholly owned or controlled subsidiaries. As not all operating companies and/or wholly owned or controlled subsidiaries publicly disclose this information, the Corporation is not in a position to publicly disclose consolidated data.
Occupational safety and health
Power Corporation’s employee data is consolidated based on the definition of financial control and therefore includes our publicly traded operating companies Great-West Lifeco and IGM Financial, as well as the Corporation’s wholly owned or controlled subsidiaries. As not all operating companies and/or wholly owned or controlled subsidiaries publicly disclose this information, the Corporation is not in a position to publicly disclose consolidated data.
Working conditions (wages, working hours)

13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

Over 2020 and 2021, the Corporation and its group companies remained committed to creating an inclusive, respectful, and accessible workplace, which we continued to reinforce through training, communication, engagement and third-party procurement programs. In 2021, the Corporation adopted an objective of having at least 30% female representation on its Board of Directors, and after the 2022 Annual General Meeting of Shareholders, female representation on the Board was 28.57%. The Corporation also continued the deployment of its Third Party Code of Conduct, which covers the labour rights issues listed above, with its existing and new key suppliers and business partners. It also supported initiatives that promote labour rights in our community, such as Lawyers Without Borders and Equitas’s series of EquiTalks conferences, which focus on addressing inequities and discrimination and work to build safer and more inclusive communities. Of note, our publicly traded operating companies Great-West Lifeco and IGM Financial and their own operating companies took the following concrete actions in 2020 and 2021 regarding non-discrimination in respect to employment: • In late 2020, IGM Financial launched the Count me in! voluntary self-identification initiative to understand the demographic makeup of its workforce, set representation targets and track its progress. It also now requires new hires to self-identify as part of their onboarding process. • In 2021, IGM Financial: ‒ Hired its first Vice-President, Diversity, Equity and Inclusion (DE&I) to refresh, expand and implement its strategy across the entire company; ‒ Required that all IGM people leaders have a DE&I objective as part of their annual short-term incentive objectives; ‒ Broadened its recruiting strategy to source, attract and hire a more diverse workforce, addressed unconscious bias in the recruitment process and created a new role of Senior Talent Advisor, Indigenous Relations to help build a pipeline of strong Indigenous talent across IGM; ‒ Updated its DE&I targets to 35% female representation in roles of vice-president and up by 2025, 3.5% Black executive representation by 2025, and 3% Indigenous workforce by 2025; ‒ Retained a third-party firm to conduct a gender pay audit among its senior managers and above to identify any pay disparities that may exist between men and women engaged in work of similar value and, in the few cases where differences existed, IGM took action to close the gap. • Great-West Lifeco’s Canadian companies continued to track female representation within their workforce composition. In 2021, 68% of the Canadian workforce and 46% of its management-level employees in the country were women. Great-West Lifeco’s Canada Life also helped advance women and diversity in leadership in 2021 through its contribution to the LEAD WITH US campaign, which supports the development of diversity in leadership programs at Brescia University College (Brescia) at Western University in London, Ontario. These programs are a foundational element in the newly established Centre for Women and Leadership at Brescia, designed to be a nationally recognized hub for the scholarship and advancement of women’s leadership. Expected to launch in September 2022, the programs will aim to advance women in leadership and systems change, with a particular focus on attracting a diverse student population through outreach and financial support. • IGM Financial and its operating companies, which are signatories to the United Nations’ Women’s Empowerment Principles, continued to engage with organizations such as GATE, Catalyst and Women in Capital Markets to implement targeted strategies and initiatives aimed at enabling the upward mobility of existing talent and increasing sourcing opportunities for external talent. • Both Great-West Lifeco and IGM Financial continued to offer unconscious bias training at various levels of their organization, as well as for external advisors, in addition to awareness-building initiatives. They also offered KAIROS Blanket Exercises in 2021, in line with their commitment to Winnipeg’s Indigenous Accord, and they continued to engage with their respective employees’ resource groups, including as part of their BlackNorth Initiative pledge. • In September 2020, Sagard Holdings launched the Black Wealth Club, an initiative established to help the Black community in Canada build wealth and reinvest it in their community by bringing together emerging Black leaders with inspiring speakers and industry professionals to enhance their leadership skills, network, and business acumen through a series of workshops and networking opportunities. • Two Great-West Lifeco subsidiaries, Canada Life and GWL Realty Advisors, participated in the Rick Hansen Foundation’s Buildings Without Barriers Challenge to create accessible spaces for all through inclusive design, and the London, Toronto, and Winnipeg head offices all attained Rick Hansen Foundation Accessibility Certification. • Power Corporation and IG Wealth Management formed a partnership with the National Centre for Truth and Reconciliation (NCTR) in 2021 in support of Imagine a Canada, a national art and leadership program for youth across the country to envision and aspire for reconciliation. The Corporation also supports the development of the Institute of Indigenous Self-Determination (IISD) at Yukon University, a partnership between the university and Yukon First Nations whose mission is to improve education outcomes for First Nations students, and recognized Canada’s National Day for Truth and Reconciliation by building employee awareness around Indigenous issues. As for concrete actions by our operating companies Great-West Lifeco and IGM Financial in 2021 regarding occupational safety and health, they include: ‒ To help support its employees and their well-being during the COVID-19 pandemic, Great-West Lifeco updated its Lifestyles benefits program to provide more mental health coverage and enhanced their wellness accounts. It also engaged directly with its own leaders and employees regarding wellness at work. Its 2021 Table Talk sessions supporting leaders and employees featured industry experts and Canada Life leaders. In addition, through its operating company Canada Life and Workplace Strategies for Mental Health, compliments of Canada Life (Workplace Strategies), it engaged with Canadian employees and employers throughout 2021 regarding the protection of psychological health and safety at work. Canada Life also launched the updated Psychologically Safe Leader Assessment (PSLA) web tool, accessible to all Canadians. ‒ As part of its approach to health and wellness, in 2021 IGM Financial relaunched its Wellness Watch program, focusing on stress and resilience support, sleep, work-life balance, and financial resources and planning. New programs and events in 2021 included, among others, a mental health virtual wellness fair, bimonthly Wellness 101 education sessions, mental health training for people leaders and mental health awareness training for employees.

Environment

Commitment

1. Does the company have a formal policy on the following environmental topics?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
March 2020
Water
March 2020
Oceans
March 2020
Forests / Biodiversity / Land Use
March 2020
Air Pollution
March 2020
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
March 2020
Energy & Resource Use
March 2020

Optional comment

Power Corporation has a long-standing commitment to conducting its activities in an environmentally responsible manner. It currently has in place an Environmental Policy, which covers all environmental topics as relevant to the Corporation’s activities, investment process and procurement practices. Our environmental commitments are reinforced by our Code of Business Conduct and Ethics and Corporate Social Responsibility Statement. We also extend our environmental commitments to third parties that work for/on our behalf through our Third Party Code of Conduct. Our major publicly traded operating companies have similar environmental commitments in place. For more information, please refer to: https://www.powercorporation.com/media/uploads/esg_hub/pcc-environmental-policy-final-web-2020-03-18.pdf https://www.powercorporationcsr.com/en/environment/overview/ https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-code-of-business-conduct-and-ethics-2020-03-18-eng.pdf https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc_csr_statement_final_2020-03-18.pdf https://www.powercorporationcsr.com/en/environment/environmental-policy/ https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc_third_party_code_of_conduct_eng_final.pdf

1.1. For each environmental policy, is it:

	Aligned with international environmental standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving environmental expertise from inside and outside the company?	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

The Corporation’s Environmental Policy is available on our corporate and sustainability websites. It has been adopted by the former Co-Chief Executive Officers of the Corporation, and applies to the Corporation’s operations, as well as to those of its wholly owned subsidiaries, unless a comparable policy or commitment has been adopted by such subsidiary. It also covers the Corporation’s third-party providers. As for the Corporation’s Third Party Code of Conduct, it applies to all third parties working for or on the Corporation’s behalf, including service suppliers, consultants, and advisors, as well as their employees and sub‐contractors.

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks/ impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

During the reporting period, the Corporation engaged with a range of stakeholders on environmental topics, which have typically included climate action, water, forest/biodiversity/land use, waste, energy and resource use, as follows: • Regarding climate action: At the Power Corporation level, our engagement on climate action has been mainly with employees, suppliers, investors and shareholders, responsible investment and ESG rating organizations, NGOs, our publicly traded operating companies and wholly owned subsidiaries, as well as with trade associations and non-profit organizations. Internally, employee engagement regarding climate action has been focused on our building awareness and educating our employees on our Environmental Policy and Responsible Procurement Policy, and encouraging them to reduce their work-related environmental footprint, including by using public transit to commute to the office. Externally, as part of our Responsible Procurement Policy and Third Party Code of Conduct, we engage with our suppliers and contractors to influence the provision of environmentally friendly products and services for our business. By engaging with suppliers and contractors, we have been able to source more environmentally friendly products, including LED lighting and energy-efficient building equipment, among others, to reduce our energy consumption and related GHG emissions. Our measure of success is the collaboration and innovation we influence in our supply chain and the number of more environmentally friendly products and services we procure. With investors, shareholders, responsible investment organizations and ESG rating organizations such as MSCI, Sustainalytics, FTSE4Good, Vigeo Eiris and the CDP, engagement is aimed mainly at providing information and enhancing understanding of the risks (all of which are non-material) and opportunities that climate change represents for the Corporation, the strategy, policies, framework, targets and metrics that the Corporation has in place in regard to climate (e.g., Scope 1, 2 and 3 emissions), and the Corporation’s overall performance in this area considering the indicators followed by these third parties. The vast majority of the information shared is covered in our response to the 2021 CDP Climate Change questionnaire, for which we received the score of A. We engaged with two NGOs regarding the Corporation’s policy on oil & gas / fossil fuel investments. We confirmed that we were not involved in any type of direct investment in oil and gas projects or infrastructures. We also engage with those of our subsidiaries in which we have financial control and significant influence, specifically our major publicly traded subsidiaries, Great-West Lifeco and IGM Financial, as well as with our wholly owned subsidiaries, regarding climate and the energy and carbon management strategies they establish and implement. This engagement is twofold: first, as part of our annual data collection process for the purposes of our environmental public disclosure, and second, as part of our active ownership approach, recognizing that climate change could potentially impact the companies in which we have investments. The Corporation engages the senior management of its major operating and portfolio companies to further strengthen its ESG integration analysis of company-specific climate change risks and opportunities, where relevant, such as: climate-related regulations; government incentives that support renewable energy markets; exposure to weather events that could impact our investments, corporate properties, and information technology systems; and business continuity plans at office locations. In 2020 and 2021, the Corporation also had ongoing discussions with its major subsidiaries to understand their carbon and energy management strategies, including an awareness session held with third-party experts in the matter. Considerable efforts and progress were made by our major subsidiaries in the past year to strengthen their commitments on reducing GHG emissions and disclosing their climate change strategies. Finally, we engage with trade associations on climate action as well as with non-profit groups that support various climate-related issues. Trade associations with which we engage, either through our Chairman of the Board or our President and CEO, include the International Economic Forum of the Americas (to support efforts to increase awareness and collaboration between international governments on a wide range of issues, including climate change), the Brookings International Advisory Council (to support efforts to develop effective, pragmatic policies for addressing national and global issues, including energy and environmental issues), the C.D. Howe Institute (to collaborate with a distinguished group of Canadian business leaders, academics, former public officials and other experts to support the development of strategic perspectives about emerging policy challenges, including climate change and the environment), and the Business Council of Canada (to share our expertise and support the development of unique insights, in-depth analysis and data-based policy recommendations across a broad range of economic, social and environmental issues, including climate change). In line with our strategy to contribute to community projects and initiatives that increase awareness of and knowledge on climate change, we also engage with, and provide financial support to, initiatives that help address climate change and environmental instability, including Nature Conservancy of Canada and Earth Rangers. Our group companies have also actively engaged with a vast range of stakeholders in the reporting period regarding climate action. While full details of their engagement activities can be found in their respective public disclosure documents, these included: o Engaging employees: Great-West Lifeco, IGM Financial and Groupe Bruxelles Lambert (GBL) engage employees on climate action. Among other initiatives, Great-West Lifeco engages employees through its Global Real Estate Sustainability Council and Corporate Properties Sustainability Working Group, which consists of experienced property management and building operations employees, to direct sustainability initiatives with a particular focus on reducing greenhouse gas (GHG) emissions at its corporate properties. Similarly, IGM Financial engages employees through employee green committees and through its IGM Green Council, which is responsible for creating a consistent culture of environmental awareness and practices across IGM operating companies and consists of leaders from Facility Management, Human Resources, Corporate Sustainability, Information Services and Community Investments, as well as the chairs of the employee green committees. In addition, IGM’s subsidiary Mackenzie Investments provided foundational climate training across its investment teams in 2021. Finally, GBL engages with head office employees and raises their awareness regarding climate action by promoting energy efficiency, clean mobility, and resources conservation. o Engaging advisors and subadvisors: IGM Financial is prioritizing engagement and education with advisors on climate change, climate-related products and ESG integration to increase their understanding of how their company is enabling clients to participate in the low-carbon energy transition, mitigate climate risks in investment portfolios, and accelerate the role of financial advisors as change agents for climate action. In early 2022, IG Wealth Management also engaged with subadvisors through a formal letter encouraging them to support the Glasgow Financial Alliance for Net Zero by joining the Net Zero Asset Managers Initiative, and to become signatories to both the Task Force on Climate-Related Financial Disclosures (TCFD) and Climate Action 100+. The letter is expected to be followed by meetings with the subadvisors to talk about their climate action commitments and strategies. o Engaging clients and customers: IGM Financial’s operating companies are engaging with clients on climate action through sustainable investing education and events, including climate-focused events. Great-West Lifeco, through its subsidiary GWL Realty Advisors’ commercial and multi-residential property managers, engages with the tenants, residents, and occupants of its downstream real estate assets under management to share climate change-related information, such as GHG emissions performance and programs in place to improve GHG emissions at the property level. o Engaging suppliers: Great-West Lifeco specifically engages its critical suppliers to understand the products and services that could reduce the environmental footprint of its buildings, operations, and processes. Working collaboratively with these suppliers enables Great-West Lifeco to meet its green building certification targets and its GHG Scope 1 and 2 reduction target for Canadian properties. o Engaging investee companies: Great-West Lifeco’s subsidiary Irish Life Investment Managers (ILIM) engages with investee companies on specific climate-related topics, including as part of the annual CDP Non-Disclosure Campaign, which offers investors the opportunity to actively engage companies that have received the CDP disclosure request on behalf of investors but have not provided a response. ILIM also conducts collaborative engagement through the Climate Action 100+ group focusing on major industrial GHG emitters to ensure their transition plans align with the Paris Agreement, and specific proxy voting on shareholder proposals regarding climate-related issues through its third-party provider, ISS. IGM Financial engages with its investee companies to collect climate change and carbon information at least annually from long-term investees. In addition, its operating companies also engage with investees regarding climate action. Engagement at Mackenzie is undertaken both internally and by a third-party engagement specialist where climate change is a priority engagement topic. At Investment Planning Counsel, a pooled engagement service provider is used to work with companies to enhance corporate behaviour and strategy related to topics including climate change. At IG Wealth Management, investment management subadvisors, including Mackenzie, are responsible for engagement activities, and IG Wealth Management monitors their practices as part of regular due diligence and oversight. Mackenzie Investments, an IGM Financial subsidiary, favours engagement over exclusion and engages with companies facing transition risk to enable them to de-risk and better manage the risk going forward. In 2021, it identified 100 companies in its retail equity portfolios that account for 70% of its retail equity carbon intensity, and developed a strategy to engage with these companies to drive meaningful progress. Finally, an active and engaged owner, GBL conducts ongoing ESG engagement with its portfolio companies through its Head of ESG and Investments Department. Considering the challenges and threats of climate change, GBL publicly endorses the Paris Agreement and supports the adoption of the TCFD recommendations and the development of long-term adaptation and mitigation climate strategies for itself and its portfolio of participations in order to progressively align financial markets with climate goals. o Engaging industry in sustainable finance: Great-West Lifeco is an active participant in the UN-sponsored “Capital as a Force for Good” initiative which engages key stakeholders, conducts research, publishes thought leadership and has a program of active outreach to major global financial institutions as well as development banks, NGOs and other stakeholders with the potential to act as a force for good in the world, including by tackling climate change. Great-West Lifeco is also a member of Canada’s Sustainable Finance Action Council (SFAC), and participated in its plenary meetings and select subgroups in 2021. The SFAC helps lead the Canadian financial sector toward integrating sustainable finance into standard industry practice and has prioritized climate-related financial disclosure. Through Canada Life, Great-West Lifeco also engages with the International Institute for Sustainable Development (IISD), which has a focus on driving action on climate adaptation in Canada, and financially supports the climate priority of its CREATE (climate, resources, economies, act together and engage) strategic framework. For its part, IGM is a member of the Conference Board of Canada’s Business Council for Sustainability, a network of senior business leaders responsible for environmental management and sustainability who convene to learn and share best practices across a wide range of organizations. Many of the expert speakers at events focus on climate-related topics. IGM Financial also joined the Partnership for Carbon Accounting Financials (PCAF) in November 2021, working with its peers to bring industry-wide consistency to the measurement and reporting of GHG emissions associated with loans and investments. IGM Financial’s operating companies are active participants in collaborative industry groups that support IGM’s climate commitments by engaging companies on improving climate change governance, reducing emissions and strengthening climate-related financial disclosures. In 2021, Mackenzie Investments became a founding participant in Climate Engagement Canada, a Canadian-focused initiative driving dialogue with industry to promote a just transition to a net-zero economy, and became a signatory to the Net Zero Asset Managers Initiative, joining global asset managers committed to supporting the goal of net-zero financed emissions. It also participates in the Ceres Investor Network on Climate Risk and Sustainability. Finally, both Mackenzie Investments and IG Wealth Management support Climate Action 100+ and became founding signatories to the Canadian Investor Statement on Climate Change in October 2021. o Engaging non-profit organizations: Great-West Lifeco and IGM Financial engage with non-profit groups that support various climate-related issues. Among others, Great-West Lifeco supports Nature Conservancy of Canada and Earth Rangers, while IGM supports Manitoba Race to Reduce and FortWhyte Alive. • Regarding water: Given the nature of our activities as an international management and holding company that focuses on financial services, our engagement on water at the Power Corporation level has been limited, and took place mainly with suppliers, investors, responsible investment and ESG rating organizations, as well as with our publicly traded operating companies and wholly owned subsidiaries. As part of our Responsible Procurement Policy and Third Party Code of Conduct, we engage with our suppliers and contractors to influence the provision of environmentally friendly products and services for our business. Our measure of success is the collaboration and innovation we influence in our supply chain and the number of more environmentally friendly products and services we procure. With investors, responsible investment organizations and ESG rating organizations, including MSCI, FTSE4Good and the CDP, engagement is aimed mainly at providing information on the policies, targets and metrics that the Corporation has in place in regard to water, enhancing understanding of the water-related risks (all of which are immaterial) and opportunities for the Corporation, and the Corporation’s overall performance in this area considering the indicators followed by these third parties. We also engaged with those of our subsidiaries in which we have financial control and significant influence, specifically our major publicly traded subsidiaries, Great-West Lifeco and IGM Financial, as well as with our wholly owned subsidiaries, regarding water. This engagement took place mainly as part of our annual data collection process for the purposes of our environmental public disclosure. Our group companies, and in particular Great-West Lifeco’s subsidiary GWL Realty Advisors, which manages all its corporate campuses and over 300 additional Canadian properties, have also actively engaged with a range of stakeholders in the reporting period regarding water. While full details of their engagement activities can be found in their respective public disclosure documents, these included: o Engaging employees: Great-West Lifeco engages employees through its Global Real Estate Sustainability Council and Corporate Properties Sustainability Working Group, which consists of experienced property management and building operations employees, to direct sustainability initiatives at its corporate properties. So far, they have concentrated on retrofits focusing, among others, on energy, water and waste reduction, and on the sharing of best practices and strategies among their facilities. o Engaging customers: Through GWL Realty Advisors’ commercial and multi-residential property managers, Great-West Lifeco engages with the tenants, residents, and occupants of its downstream real estate assets under management to better understand their changing needs and share information on sustainability-related metrics such as green building certification status and water use efficiency, as well as on the Sustainability Benchmarking and Conservation Program for GWL Realty Advisors’ managed office assets (establishing energy, water, waste, and GHG targets). o Engaging suppliers: Great-West Lifeco specifically engages its critical suppliers to understand the products and services that could reduce the environmental footprint of its buildings, operations, and processes. This includes suppliers that support them in improving the sustainability of their real estate assets, as well as other products and services that enable them to reduce energy, water, and material consumption. Working collaboratively with these suppliers enables Great-West Lifeco to meet its green building certification targets. o Engaging investee companies: Great-West Lifeco engages investee companies on water through its asset management operating companies Putnam Investments, GWL Realty Advisors, and Irish Life Investment Managers (ILIM). Putnam Investments engages with investee companies on water on a company- and sector-specific basis based on water risk sector analysis it conducts. GWL Realty Advisors monitors and measures water consumption data from the real estate investment portfolio under management to inform resource efficiency strategies. Finally, as part of the CDP Non-Disclosure campaign, ILIM participated in engaging companies to respond to the CDP’s Water Security Disclosure Request. • Regarding forests/biodiversity/land use: Given the nature of our activities as an international management and holding company that focuses on financial services, our engagement on forest/biodiversity/land use at the Power Corporation level has been limited, and took place mainly with employees, investors and ESG rating organizations, our publicly traded operating companies and wholly owned subsidiaries, and community-based organizations. Internally, employee engagement has been focused on our building awareness and educating our employees on our Environmental Policy and Responsible Procurement Policy, and encouraging them to reduce their work-related environmental footprint, including by working paperless to the extent possible. With investors and ESG rating organizations, engagement aimed mainly at providing information regarding the Corporation’s biodiversity initiatives and portfolio exposure to forest-related risks and opportunities (all of which are non-material). We also engaged with those of our subsidiaries in which we have financial control and significant influence, specifically our major publicly traded subsidiaries, Great-West Lifeco and IGM Financial, regarding forests/biodiversity. This engagement took place mainly as part of our annual data collection process for the purposes of our environmental public disclosure. Finally, we continued to engage with community organizations regarding opportunities to support community-based needs and initiatives that promote and protect biodiversity and land conservation in our communities. Examples include: o Earth Rangers, Canada’s largest children-focused conservation organization specifically committed to educating young people and their families about biodiversity, inspiring them to adopt sustainable behaviours, and empowering them to become directly involved in protecting animals and their habitats. o Nature Conservancy of Canada, which seeks solutions to the twin crises of rapid biodiversity loss and climate change through large-scale, permanent land conservation, working with people, communities, businesses and government. o Appalachian Corridor, a conservation organization that works with local communities to maintain and restore a way of life that respects the ecology of the Appalachians of southern Québec from a perspective of sustainable development. Our group companies also engaged with some stakeholders in the reporting period regarding forests/biodiversity/land use. While full details of their engagement activities can be found in their respective public disclosure documents, these included: o Engaging non-profit organizations: As a member of the Forest Stewardship Council (FSC), Canada Life is committed to using responsibly sourced paper and other forest products meeting FSC’s strict environmental and social standards. FSC brings together private enterprises, NGOs, international organizations, Indigenous groups, and educational institutions to develop its standards regarding responsible forestry. o Engaging investee companies: Sustainable land use and biodiversity are areas of increasing focus for IGM Financial’s subsidiary Mackenzie Investments’ engagement service provider. In addition to their current focus on creating more sustainable food supply chains, they are looking into ways to directly affect land-use change through sustainable management and production of palm oil. Four percent of their environmental engagements for Mackenzie in 2020 were directly focused on forestry and land use. • Regarding waste: Given the nature of our activities as an international management and holding company that focuses on financial services, our engagement on waste at the Power Corporation level has been limited, and took place mainly with suppliers, investors, responsible investment and ESG rating organizations, as well as with our publicly traded operating companies and wholly owned subsidiaries. As part of our Responsible Procurement Policy and Third Party Code of Conduct, we engage with our suppliers and contractors to influence the provision of environmentally friendly products and services for our business. Our measure of success is the collaboration and innovation we influence in our supply chain and the number of more environmentally friendly products and services we procure. With investors, responsible investment organizations and ESG rating organizations, including Sustainalytics, FTSE4Good and Vigeo Eiris, engagement is aimed mainly at providing information about waste reduction commitments, initiatives and metrics, and enhancing understanding of the Corporation’s overall performance in this area considering the indicators followed by these third parties. We also engaged with those of our subsidiaries in which we have financial control and significant influence, specifically our major publicly traded subsidiaries, Great-West Lifeco and IGM Financial, as well as with our wholly owned subsidiaries, regarding waste. This engagement took place mainly as part of our annual data collection process for the purposes of our environmental public disclosure. Our group companies have also engaged with a number of stakeholders in the reporting period regarding waste. While full details of their engagement activities can be found in their respective public disclosure documents, these included: o Engaging employees: Great-West Lifeco, IGM Financial and Groupe Bruxelles Lambert (GBL) engage employees on waste. Great-West Lifeco engages employees through its Global Real Estate Sustainability Council and Corporate Properties Sustainability Working Group, which consists of experienced property management and building operations employees, to direct sustainability initiatives at its corporate properties. So far, they have concentrated on retrofits focusing, among others, on energy, water and waste reduction and the sharing of best practices and strategies among their facilities. Similarly, IGM Financial engages employees through employee green committees, which are the drivers of many of its initiatives to reduce paper, waste and energy consumption, and through its IGM Green Council, which is responsible for creating a consistent culture of environmental awareness and practices across IGM operating companies and consists of leaders from Facility Management, Human Resources, Corporate Sustainability, Information Services and Community Investments, as well as the chairs of the employee green committees. IGM Financial conducts annual waste audits in its corporate offices to highlight improvement opportunities and increase engagement with employees. Finally, GBL engages employees through the promotion of leading waste management practices at its head office. o Engaging customers: Through GWL Realty Advisors’ commercial and multi-residential property managers, Great-West Lifeco engages with the tenants, residents, and occupants of its downstream real estate assets under management to better understand their changing needs and share information on sustainability-related metrics such as green building certification status and waste production, as well as on the Sustainability Benchmarking and Conservation Program (establishing energy, water, waste, and GHG targets) for GWL Realty Advisors’ managed office assets. o Engaging suppliers: Great-West Lifeco specifically engages its critical suppliers to understand the products and services that could reduce the environmental footprint of its buildings, operations, and processes. This includes suppliers that support them in improving the sustainability of their real estate assets, as well as other products and services that enable them to reduce energy, water, and material consumption. Working collaboratively with these suppliers enables Great-West Lifeco to meet its green building certification targets. Similarly, IGM Financial’s operating company IG Wealth Management engages landlords of their leased offices across Canada to increase waste diversion services. • Regarding energy & resource use: At the Power Corporation level, our engagement on energy use has been mainly with employees, suppliers, investors and shareholders, responsible investment and ESG rating organizations, and our publicly traded operating companies and wholly owned subsidiaries. Internally, employee engagement regarding climate action has been focused on our building awareness and educating our employees on our Environmental Policy and Responsible Procurement Policy, and encouraging them to reduce their work-related environmental footprint. Externally, as part of our Responsible Procurement Policy and Third Party Code of Conduct, we engage with our suppliers and contractors to influence the provision of environmentally friendly products and services for our business. By engaging with suppliers and contractors, we have been able to source more environmentally friendly products, including LED lighting and energy-efficient building equipment, among others, to reduce our energy consumption and related GHG emissions. Our measure of success is the collaboration and innovation we influence in our supply chain and the number of more environmentally friendly products and services we procure. With investors, shareholders, responsible investment organizations and ESG rating organizations such as MSCI, Sustainalytics, FTSE4Good, Vigeo Eiris and the CDP, engagement is aimed mainly at providing information and enhancing understanding of the risks (all of which are non-material) and opportunities that climate change represents for the Corporation, the strategy, policies, framework, targets and metrics that the Corporation has in place in regard to energy (including renewable energy) use and reduction, and the Corporation’s overall performance in this area considering the indicators followed by these third parties. The vast majority of the information shared is covered in our response to the 2021 CDP Climate Change questionnaire, for which we received the score of A. We also engage with those of our subsidiaries in which we have financial control and significant influence, specifically our major publicly traded subsidiaries, Great-West Lifeco and IGM Financial, as well as with our wholly owned subsidiaries, regarding climate and the energy and carbon management strategies they establish and implement. This engagement is threefold. First, we engage them as part of our annual data collection process for the purposes of our environmental public disclosure. Second, we engage our subsidiary Square Victoria Real Estate, which manages our owned properties, regarding energy use reduction opportunities. Third, we engage our major publicly traded subsidiaries and wholly owned subsidiaries as part of our active ownership approach. In 2020 and 2021, the Corporation had ongoing discussions with its major subsidiaries to understand their carbon and energy management strategies. Our group companies have also engaged with a number of stakeholders in the reporting period regarding energy and resource use. While full details of their engagement activities can be found in their respective public disclosure documents, these included: o Engaging employees: Great-West Lifeco, IGM Financial and Groupe Bruxelles Lambert (GBL) engage employees on waste. Great-West Lifeco engages employees through its Global Real Estate Sustainability Council and Corporate Properties Sustainability Working Group, which consists of experienced property management and building operations employees, to direct sustainability initiatives at its corporate properties. So far, they have concentrated on retrofits focusing, among others, on energy, water and waste reduction and on the sharing of best practices and strategies among their facilities. Similarly, IGM Financial engages employees through employee green committees, which are the drivers of many of its initiatives to reduce paper, waste and energy consumption, and through its IGM Green Council, which is responsible for creating a consistent culture of environmental awareness and practices across IGM operating companies and consists of leaders from Facility Management, Human Resources, Corporate Sustainability, Information Services and Community Investments, as well as the chairs of the employee green committees. o Engaging customers: Through GWL Realty Advisors’ (GWLRA) commercial and multi-residential property managers, Great-West Lifeco engages with the tenants, residents, and occupants of its downstream real estate assets under management to better understand their changing needs, to enhance their services, and to endeavour to exceed their expectations, including with respect to energy management. GWLRA engages to share information on sustainability-related metrics such as green building certification status and energy performance (e.g., energy reductions), as well as on the Sustainability Benchmarking and Conservation Program (establishing energy, water, waste, and GHG targets) for GWLRA’s managed office assets. o Engaging suppliers: Great-West Lifeco specifically engages its critical suppliers to understand the products and services that could reduce the environmental footprint of its buildings, operations, and processes. This includes suppliers that support them in improving the sustainability of their real estate assets, as well as other products and services that enable them to reduce energy, water, and material consumption. Working collaboratively with these suppliers enables Great-West Lifeco to meet its green building certification targets. Similarly, IGM Financial’s operating company IG Wealth Management engages landlords of their leased offices across Canada to increase waste diversion services. For more information, please refer to: https://www.powercorporationcsr.com/en/environment/overview https://www.powercorporation.com/media/uploads/reports/proxy/pcc-notice-proxy-circular-2022-en.pdf https://www.powercorporation.com/media/uploads/esg_hub/pcc-2021-cdp-response-final-web.pdf https://www.greatwestlifeco.com/content/dam/gwlco/documents/reports/2021/great-west-lifeco-cdp-climate-change-questionnaire-2021.pdf https://www.greatwestlifeco.com/content/dam/gwlco/documents/reports/2022/lifeco-2021-annual-report-en.pdf https://www.canadalife.com/content/dam/canadalife/documents/corporate/pas/canada-life-public-accountability-statement-2021.pdf https://www.igmfinancial.com/content/dam/igm/en/corpresp/assets/docs/igm_2020_sustainability_report_final_en.pdf https://www.igmfinancial.com/content/dam/igm/en/corpresp/assets/docs/igm-financial-2021-sustainability-report.pdf https://www.igmfinancial.com/content/dam/igm/en/corpresp/assets/docs/carbon-disclosure-2021-e.pdf https://www.igmfinancial.com/content/dam/igm/en/investrelations/finreporting/files/2022/igm-2021-ar-en-digital.pdf https://www.gbl.be/en/media/3749/en-GBL-RA2021_0.pdf

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

The Corporation and its group companies have taken a number of actions in the course of the reporting period to prevent and mitigate the risks and impacts associated with the environmental topics of climate, water, biodiversity, waste, and energy and resource use. At the holding company level, we worked diligently to reduce our environmental footprint and limit the impacts associated with the topics mentioned above by focusing our environmental priorities on: (i) reducing our energy and carbon footprint, (ii) increasing the use of renewable resources, (iii) preventing, reducing and diverting waste from landfills, and (iv) procuring products and services responsibly. To that end, we provided training to our employees on our Environmental Policy and Responsible Procurement Policy; we engaged with our suppliers and contractors to influence the provision of environmentally friendly products and services for our business; we engaged with our subsidiary Square Victoria Real Estate regarding opportunities to further reduce our energy consumption and GHG emissions; we monitored and tracked our performance against our energy and GHG emissions reduction targets and key performance indicators regarding waste, water and energy; and we engaged with our major publicly traded operating companies Great-West Lifeco, IGM Financial and Groupe Bruxelles Lambert on sharing best practices and understanding their exposure to environmental risks. Our group companies have also taken actions to prevent and mitigate the impacts associated with the environmental topics mentioned above. Through the work of employee green committees, sustainability/green councils, working groups and internal promotion, Great-West Lifeco, IGM Financial and Groupe Bruxelles Lambert continued to educate their workforce on these topics, building capacity and creating a consistent culture of environmental awareness. IGM Financial also educated financial advisors on climate change and ESG integration to accelerate their role as change agents for climate action, and its subsidiary Mackenzie Investments provided foundational climate training across its investment teams in 2021. IGM Financial continued the work of its cross-functional, enterprise-wide TCFD Working Group of senior leaders focused on: enhancing the company’s knowledge and tools to quantify climate risks in tandem with its industry; further integrating climate into its business strategy, operations and product offerings; evolving its engagement approach with investee companies; and addressing increased disclosure expectations. As for Great-West Lifeco (including its operating company GWL Realty Advisors), actions taken to limit the impacts of the above-mentioned environmental topics have also involved business relationships such as critical suppliers regarding products and services that could reduce the environmental footprint of its buildings, operations, and processes, as well as information sharing with, and awareness building of, tenants, residents, and occupants of its downstream real estate assets under management. In addition to the above, Great-West Lifeco and IGM Financial continued to monitor and track their performance in furtherance of energy use, water use, waste, and GHG emissions reduction targets. IGM Financial also conducted annual waste audits in its corporate offices to highlight improvement opportunities and increase engagement with employees. For its part, Groupe Bruxelles Lambert conducted its annual in-depth risk assessment of its portfolio companies, covering topics that included efficiency in the use of resources, pollution prevention and management, climate change, environmental supplier and procurement standards, and environmental product responsibility. In 2021, Groupe Bruxelles Lambert’s risk assessment included an in-depth analysis of the biodiversity risk exposure and potential biodiversity impact of each portfolio participation. Some of our group companies also took part in collective actions with peers or other stakeholders during the reporting period to address climate issues. In 2021, IGM Financial’s subsidiary Mackenzie Investments became a founding participant in Climate Engagement Canada, a Canadian-focused initiative driving dialogue with industry to promote a just transition to a net-zero economy, and became a signatory to the Net Zero Asset Managers Initiative, joining global asset managers committed to supporting the goal of net-zero financed emissions. Mackenzie Investments and IG Wealth Management also support Climate Action 100+ and became founding signatories to the Canadian Investor Statement on Climate Change in October 2021. Great-West Lifeco’s Irish Life Investment Management also participated in Climate Action 100+. Finally, Groupe Bruxelles Lambert became a supporter of the TCFD in 2021, joining Great-West Lifeco and IGM Financial, which have been supporters since 2020 and 2019, respectively. For more information, please refer to: https://www.powercorporationcsr.com/en/environment/overview https://www.powercorporationcsr.com/en/environment/climate-adaptation/ https://www.powercorporation.com/media/uploads/reports/proxy/pcc-notice-proxy-circular-2022-en.pdf https://www.powercorporation.com/media/uploads/esg_hub/pcc-2021-cdp-response-final-web.pdf https://www.greatwestlifeco.com/content/dam/gwlco/documents/reports/2021/great-west-lifeco-cdp-climate-change-questionnaire-2021.pdf https://www.greatwestlifeco.com/content/dam/gwlco/documents/reports/2022/lifeco-2021-annual-report-en.pdf https://www.canadalife.com/content/dam/canadalife/documents/corporate/pas/canada-life-public-accountability-statement-2021.pdf https://www.igmfinancial.com/content/dam/igm/en/corpresp/assets/docs/igm_2020_sustainability_report_final_en.pdf https://www.igmfinancial.com/content/dam/igm/en/corpresp/assets/docs/igm-financial-2021-sustainability-report.pdf https://www.igmfinancial.com/content/dam/igm/en/corpresp/assets/docs/carbon-disclosure-2021-e.pdf https://www.igmfinancial.com/content/dam/igm/en/investrelations/finreporting/files/2022/igm-2021-ar-en-digital.pdf https://www.gbl.be/en/media/3749/en-GBL-RA2021_0.pdf

4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

• Regarding climate action: Please see our response to question E4.1 for more information concerning Power Corporation’s and its group companies’ climate targets and internal and external progress tracking. • Regarding water and waste: Power Corporation has a long-standing commitment to conducting its activities in an environmentally responsible manner. While we have not set formal annual reduction targets regarding water and waste, we do have key performance indicators in place at the holding level and track our performance on an annual basis. We also engage with our major publicly traded operating companies Great-West Lifeco and IGM Financial and our wholly owned subsidiaries regarding their performance and progress on these topics through our active ownership approach as well as in the context of our annual environmental reporting process. We publicly disclose our consolidated performance regarding water and waste in our annual ESG Data Supplement. Great-West Lifeco and IGM Financial also track and publicly report on their respective annual water consumption and waste generation. • Regarding biodiversity: On an annual basis, our group company Groupe Bruxelles Lambert conducts an in-depth risk assessment of its portfolio companies. In 2021, Groupe Bruxelles Lambert’s risk assessment included an in-depth analysis of the biodiversity risk exposure and potential biodiversity impact of each portfolio participation. • Regarding energy & resource use: Power Corporation set an objective in 2012 of 8% reduction in consumption of electricity and natural gas at our head office properties by 2020, using 2011 as a baseline. We tracked our energy consumption and reported on our progress on an annual basis. We achieved a 32% reduction in energy consumption (electricity and natural gas) in 2020. Great-West Lifeco and IGM Financial also track and publicly report on their respective annual energy use. For more information, please refer to: https://www.powercorporationcsr.com/en/environment/overview/ https://www.powercorporationcsr.com/en/environment/energy-and-carbon-efficiency/ https://www.powercorporationcsr.com/media/uploads/reports/power_corporation_-_2020_esg_data_supplement_-_final.pdf https://www.igmfinancial.com/content/dam/igm/en/corpresp/assets/docs/igm-financial-2021-sustainability-report.pdf https://www.greatwestlifeco.com/content/dam/gwlco/documents/misc/lifeco-esg-key-performance-indicators-en.pdf https://www.gbl.be/en/media/3749/en-GBL-RA2021_0.pdf

4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

	Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)
Climate Action	Power Corporation and its group of companies are all working toward advancing and improving our climate performance. At the holding level, the Corporation set an absolute target in 2012 to reduce its greenhouse gas (GHG) emissions by 8% by 2020 using 2011 as the baseline year. The target relates to Scope 1 and 2 emissions of the Corporation, covering our GHG emissions from electricity and natural gas at our head office properties. This target was surpassed: the 60% reduction achieved as of December 31, 2020 (which divided by our reduction target of 8% yields a 750% achieved reduction), was mainly driven by emission reduction activities related to LED lighting and building equipment upgrades. To date, our environmental data related to GHG emissions have been verified by PricewaterhouseCoopers (PwC) to a limited level of assurance in accordance with the International Standard on Assurance Engagements 3410, Assurance Engagements on Greenhouse Gas Statements (ISAE 3410). For more information on the Corporation’s climate target at the holding level, please refer to our response to the 2021 CDP Climate Change questionnaire. Acknowledging that climate change is one of the greatest and most pressing issues of our times, an internal process has been initiated to determine the Corporation’s next emission reduction target. While this exercise is being conducted, we continue to work diligently with our building managers on enhancing energy consumption and related GHG-emission reduction initiatives. In addition, our major publicly traded operating companies Great-West Lifeco and IGM Financial set their own climate targets several years ago and report annually on their progress through their respective responses to the CDP Climate Change questionnaire: • In 2014, Great-West Lifeco set a 27.3% absolute target reduction of Scope 1 and 2 emissions for Great-West Lifeco’s owner-occupied and investment properties in Canada by 2025, using 2013 as the baseline year. As of December 31, 2020, 43.7% of the target had been achieved. In 2014, Great-West Lifeco also set a 50.4% absolute target reduction of Scope 1 and 2 emissions for Great-West Lifeco’s owner-occupied and investment properties in Canada by 2036, using 2013 as the baseline year. As of December 31, 2020, 43.7% of the target had been achieved. Great-West Lifeco’s environmental data related to GHG emissions have been verified by PwC to a limited level of assurance in accordance with ISAE 3410. • In 2015, IGM Financial set a 40% absolute target reduction of Scope 1 and 2 emissions in Canada, which includes property-level electricity, natural gas, jet fuel, backup diesel, and refrigerant consumption at its corporate head office, by 2020, using 2013 as the baseline year. As of December 31, 2020, 223.7% of the target had been achieved. In 2015, IGM Financial also set a 50% absolute target reduction of Scope 1 and 2 emissions in Canada, which includes property-level electricity, natural gas, jet fuel, backup diesel, and refrigerant consumption at its corporate head office, by 2036, using 2013 as the baseline year. As of December 31, 2020, 179% of the target had been achieved. IGM Financial’s environmental data related to GHG emissions have been verified by PwC to a limited level of assurance in accordance with ISAE 3410. In 2021, both Great-West Lifeco and IGM Financial released new climate commitments: • Great-West Lifeco announced a commitment to achieve net-zero GHG emissions by 2050 for both operations and investments, with interim science-based targets to be announced in 2022. • The IGM group of companies released its climate commitment to become carbon neutral and support the transition to net zero, including setting interim targets for investment portfolios as a first step, consistent with the global ambition to achieve net-zero emissions by 2050. In addition, Groupe Bruxelles Lambert (GBL) committed to the Science Based Targets initiative (SBTi) in May 2021 and submitted its targets to SBTi. In January 2022, GBL became the first investment holding company to have climate targets aligned with a 1.5°C pathway approved by SBTi for both its own operations and its eligible portfolio of participations. Target 1 consists of a 50% reduction of GBL’s Scope 1 (direct emissions) and Scope 2 (electricity-related emissions) greenhouse gas emissions by 2030 from a 2019 baseline. Target 2 consists of 100% of eligible portfolio positions aligned with SBTi climate strategy and targets aligned with a 1.5°C pathway approved by SBTi by 2030 from a 2020 baseline. For this target, an intermediary target of 50% coverage by 2025 has been retained. In 2021, GBL achieved a climate-neutral company status by offsetting its carbon footprint (direct and indirect emissions excluding portfolio emissions). For more information, please refer to: https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-2021-cdp-response-final-web_J4EQ9CX.pdf https://www.greatwestlifeco.com/content/dam/gwlco/documents/reports/2021/great-west-lifeco-cdp-climate-change-questionnaire-2021.pdf https://www.greatwestlifeco.com/news-events/news/lifeco-news-release-nov-10-2021.html https://www.igmfinancial.com/content/dam/igm/en/corpresp/assets/docs/carbon-disclosure-2021-e.pdf https://www.igmfinancial.com/en/corporate-sustainability/climate-statement https://www.gbl.be/en/media/3749/en-GBL-RA2021_0.pdf
Energy & Resource Use
Water
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Oceans

4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

	Progress is reviewed against goals annually or more frequently	Progress is reported internally to the most senior level	Progress is reported externally	Other (Please provide additional information)
Climate Action
Energy & Resource Use
Water
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Oceans

Optional comment

Power Corporation reports annually on climate action progress through its response to the CDP Climate Change questionnaire as well as in its annual ESG Data Supplement. The Corporation’s response to the CDP Climate Change questionnaire also covers progress towards the achievement of Great-West Lifeco’s and IGM Financial’s timebound targets.

5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

At the holding level, during the reporting period, Power Corporation has not been involved in providing or enabling remedy for any actual impacts associated with the above-mentioned environmental issues.

Climate Action

6. What were the company’s gross global greenhouse gas emissions for the reporting period?

Scope 1 Emissions

Full

None

Emissions (tCO2e)

Scope 2 Emissions

Full

None

Emissions (tCO2e)

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

Optional comment

Scope 1 emissions: 18,482 tCO2e Scope 2 emissions: 27,371 tCO2e Scope 3 emissions: 163,756 tCO2e The Corporation’s GHG emissions are consolidated and reported based on the reporting boundary of financial control. Our consolidated GHG emissions therefore include our publicly traded operating companies Great-West Lifeco and IGM Financial, as well as the Corporation’s wholly owned or controlled subsidiaries. Together, we estimate that these subsidiaries represent approximately 98% of our assets. Our GHG emissions were calculated using the GHG Protocol Corporate Accounting and Reporting Standard, which includes the following greenhouse gases: carbon dioxide, methane, and nitrous oxide. We used emissions factors from the National Inventory Report 1990–2019: Greenhouse Gas Sources and Sinks in Canada (Ottawa: Environment and Climate Change Canada, 2021). We applied Global Warming Potentials from the IPCC Fourth Assessment Report. To date, our environmental data related to GHG emissions have been verified by PricewaterhouseCoopers to a limited level of assurance, in accordance with the International Standard on Assurance Engagements 3410, Assurance Engagements on Greenhouse Gas Statements (ISAE 3410). For more information, please refer to: https://www.powercorporation.com/media/uploads/esg_hub/pcc-2021-cdp-response-final-web.pdf https://www.powercorporation.com/media/uploads/esg_hub/power_corporation_-_2020_esg_data_supplement_-_final.pdf

7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

Percent of revenue (%)

Unknown

Not applicable (Please provide additional information)

Optional comment

Given the nature of our business as a financial services and insurance company, we do not typically invest in research and development. While our subsidiary Great-West Lifeco does conduct research into various emerging trends and their impacts on health and life insurance, including climate change, changing demographics and market conditions, they do not, however, target any strategic investments in research and development broadly related to their products and services. Our subsidiary IGM Financial’s business strategy includes financial support and engagement with industry organizations such as the Responsible Investment Association (RIA), Ceres Investor Network on Climate Risk and Sustainability, and Climate Action 100+, which undertake climate-related R&D work on behalf of its companies and the investment industry. An example of a strategic decision for R&D influenced by climate-related risks and opportunities is IGM’s recent integration and customization of S&P’s Trucost into their investment systems, processes and reports. In 2020–21, they developed customized portfolio-level carbon performance reporting and continued to advance its implementation into systems, investment analysis and decision making. Another example of leading research practices is from the Mackenzie Fixed Income team, which has developed a sophisticated proprietary country risk model that integrates climate-related factors alongside various other ESG indicators. For more information, please refer to: https://www.powercorporationcsr.com/media/uploads/reports/pcc-2021-cdp-response-final-web.pdf https://www.igmfinancial.com/content/dam/igm/en/corpresp/assets/docs/carbon-disclosure-2021-e.pdf https://www.greatwestlifeco.com/content/dam/gwlco/documents/reports/2021/great-west-lifeco-cdp-climate-change-questionnaire-2021.pdf

8. Has the organization acted to support climate change adaptation and resilience?

We have taken action to increase organization-wide resilience to climate change

We have taken action to increase resilience in our supply chains

We have taken action to increase resilience in the communities in which we operate

We have provided funding for climate change adaptation and resilience initiatives and projects

We have not taken actions to build climate change resilience in the reporting period

Other (Please provide additional information)

Unknown

Optional comment

In 2020 and 2021, the Corporation and its group companies acted to support climate change adaptation and resilience. • Actions taken to increase organization-wide resilience to climate change: The Corporation and its group companies continued to engage and educate employees, advisors and subadvisors to create a culture of environmental awareness and enhance knowledge and capacities, including as regards climate change, and to engage suppliers and contractors to enhance the provision of products and services to improve the environmental footprint of their operations. The Corporation engaged the senior management of its major operating and portfolio companies to further strengthen its ESG integration analysis of company-specific climate change risks and opportunities, where relevant, such as: climate-related regulations; government incentives that support renewable energy markets; exposure to weather events that could impact investments, corporate properties, and information technology systems; and business continuity plans at office locations. The Corporation continued to grow its alternative asset investment platform Power Sustainable, a global multi-platform alternative asset manager with a long-term investment approach which invests in companies and projects that contribute to decarbonization, social progress and quality growth. Among others, Power Sustainable operates the Power Sustainable Energy Infrastructure Partnership, a leading North American-focused renewable energy platform with 1GW of utility-scale and distributed capacity in operation through its two operating platforms—Nautilus Solar and Potentia Renewables. Power Sustainable also has direct investments in The Lion Electric Company, a leader in the electrification of transportation in North America which manufactures zero-emission vehicles, including all-electric school buses, midi/minibuses for special needs or urban transit and commercial urban trucks, as well as in LMPG, an innovator in the design, development, manufacturing and distribution of sustainable interior and exterior lighting. Power group companies are also adapting to the impacts of climate change on their businesses through products, services, markets and operations. Some examples include: o To continue to strengthen its understanding of physical climate-related risks, Great-West Lifeco’s subsidiary GWL Realty Advisors (GWLRA) completed detailed risk exposure assessments, with the support of a third-party risk analytics provider, across its portfolio, including Canada Life’s head office and investment properties. The assessments covered 20 natural and climate-related physical hazards and climate change projections for the years 2045 and 2070, under three warming scenarios, to better understand how the risk of climate-related hazards may evolve over time. o Great-West Lifeco and IGM Financial are enhancing their sustainable investment offerings. In 2021, Great-West Lifeco’s operating company Putnam Investments launched its first actively managed ESG exchange-traded funds (ETFs) in the U.S., PanAgora launched a Defensive Global Equity ESG Aware Fund and, in the Canadian market, Canada Life Investment Management launched the new Canada Life Sustainable Portfolios, which invest in companies that demonstrate strong environmental, social and governance practices. As for IGM Financial, its operating company Mackenzie Investments acquired Greenchip Financial, which specializes in environmental thematic investing, in late 2020, and added the Mackenzie Betterworld sustainability-focused boutique as well as launched its two inaugural funds in 2021. In addition, IG Wealth Management launched IG’s Climate Action Portfolio in October 2021, a suite of four diversified managed solutions providing clients with a new way to support the world’s transition to net-zero carbon emissions and take advantage of the growth opportunities therein. o Great-West Lifeco, IGM Financial and Groupe Bruxelles Lambert (GBL) all joined the global climate transition movement in 2021. Great-West Lifeco is committed to achieving net-zero greenhouse gas emissions by 2050 for both operations and investments, with interim targets to reduce its emissions in line with climate science to be announced in 2022. IGM Financial committed to investing in a greener, climate-resilient economy, to collaborate and engage to help shape the global transition, and to demonstrate alignment through corporate actions such as achieving carbon neutrality in its own operations by 2022. As for GBL, it committed to the Science Based Targets initiative (SBTi) in May 2021 and submitted its targets to SBTi. In January 2022, GBL became the first investment holding company to have climate targets aligned with a 1.5°C pathway approved by SBTi for both its own operations and its eligible portfolio of participations. o Great-West Lifeco’s subsidiary Irish Life Investment Managers, as well as IGM Financial’s subsidiaries Mackenzie Investments, Investment Planning Counsel and IG Wealth Management, has engaged with investee companies regarding climate action, including climate transition risks and opportunities. Similarly, GBL engages with portfolio companies to support the development of long-term adaptation and mitigation climate strategies. • Actions taken to increase resilience in the communities in which we operate: Several companies within the Power group have been engaging in initiatives to increase the climate-related resilience of the business and financial communities in which they are active participants. Great-West Lifeco is an active participant in the UN-sponsored “Capital as a Force for Good” initiative which engages key stakeholders, conducts research, publishes thought leadership and has an active outreach program to major global financial institutions as well as development banks, NGOs and other stakeholders with the potential to act as a force for good in the world, including by tackling climate change. Great-West Lifeco is also a member of Canada’s Sustainable Finance Action Council (SFAC), which helps lead the Canadian financial sector toward integrating sustainable finance into standard industry practice and prioritizing climate-related financial disclosure. Through Canada Life, Great-West Lifeco also engages with the International Institute for Sustainable Development, which focuses on driving action on climate adaptation in Canada, and financially supports the climate priority of its CREATE (climate, resources, economies, act together and engage) strategic framework. For its part, IGM is a member of the Conference Board of Canada’s Business Council for Sustainability, a network of senior business leaders responsible for environmental management and sustainability who convene to learn and share best practices across a wide range of organizations, including in regard to climate topics. IGM Financial also joined the Partnership for Carbon Accounting Financials (PCAF) in November 2021, working with its peers to bring industry-wide consistency to the measurement and reporting of GHG emissions associated with loans and investments. IGM Financial’s operating companies are active participants in climate-related collaborative industry groups. In 2021, Mackenzie Investments became a founding participant in Climate Engagement Canada, a Canadian-focused initiative driving dialogue with industry to promote a just transition to a net-zero economy, and became a signatory to the Net Zero Asset Managers Initiative, joining global asset managers committed to supporting the goal of net-zero financed emissions. It also participates in the Ceres Investor Network on Climate Risk and Sustainability. Finally, both Mackenzie Investments and IG Wealth Management support Climate Action 100+ and became founding signatories to the Canadian Investor Statement on Climate Change in October 2021. • Funding provided for climate change adaptation and resilience initiatives and projects: In line with our contributions to community projects and initiatives that increase awareness of and knowledge on climate change impacts and management, Power Corporation engaged with, and provided financial support to, various organizations that are focused on issues related to climate change, including: o Nature Conservancy of Canada – Power Corporation has been supporting Nature Conservancy of Canada since 2005. Nature Conservancy of Canada seeks solutions to the twin crises of rapid biodiversity loss and climate change through large-scale, permanent land conservation, working with people, communities, businesses and government. o Earth Rangers – Power Corporation provides funding for Earth Rangers, a kids’ conservation organization whose free programs aim to instill environmental knowledge, positivity and the confidence to take action, and which works with a variety of national, regional and local conservation organizations to develop projects to protect endangered animals, ranging from conservation research to land acquisition and habitat stewardship. For more information, please refer to: https://www.powercorporationcsr.com/media/uploads/reports/pcc-2021-cdp-response-final-web.pdf https://www.powercorporationcsr.com/en/environment/climate-adaptation/ https://www.greatwestlifeco.com/content/dam/gwlco/documents/reports/2021/great-west-lifeco-cdp-climate-change-questionnaire-2021.pdf https://www.greatwestlifeco.com/content/dam/gwlco/documents/reports/2022/lifeco-2021-annual-report-en.pdf https://www.canadalife.com/content/dam/canadalife/documents/corporate/pas/canada-life-public-accountability-statement-2021.pdf https://www.igmfinancial.com/content/dam/igm/en/corpresp/assets/docs/carbon-disclosure-2021-e.pdf https://www.igmfinancial.com/content/dam/igm/en/investrelations/finreporting/files/2022/igm-2021-ar-en-digital.pdf https://www.gbl.be/en/media/3749/en-GBL-RA2021_0.pdf https://www.powersustainable.com/platforms/

Energy / Resource Use

9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

% of total energy consumption

Unknown

Optional comment

https://www.powercorporationcsr.com/media/uploads/reports/power_corporation_-_2020_esg_data_supplement_-_final.pdf

Technology

10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

Percent of total revenue (%)

Unknown

Not applicable (Please provide additional information)

Optional comment

With select assets under management that have been certified as green buildings under LEED® and/or BOMA BEST® certifications, Great-West Lifeco’s subsidiary GWL Realty Advisors offers low-carbon property management services. It is also working with building owners and tenants in its office and multi-residential portfolio to minimize the carbon footprint of those assets by prudently managing their overall environmental impact. The percentage of Great-West Lifeco’s revenue from these low-carbon property management services was approximately 1% in the 2020 reporting year. In addition, Great-West Lifeco affiliates had CA$121 billion in ESG-related investment mandates as at year-end 2020, of which climate change is a component. This group of products includes low-carbon finance and sustainable fund options, as well as integration into mainstream investment decisions by applying an ESG lens. The percentage of Great-West Lifeco’s revenue from these products was approximately 1% in the 2020 reporting year. Sustainable product offerings expanded in 2021 with the launch of Putnam Investments’ ESG ETFs, PanAgora’s Defensive Global Equity ESG Aware Fund, and Canada Life Investment Management’s Canada Life Sustainable Portfolios. Great-West Lifeco affiliates had CA$189 billion in ESG-related investment mandates as at year-end 2021. For its part, IGM Financial had approximately 0.81% of revenue from low-carbon products and avoided emissions as at the end of 2020, related to its Mackenzie Global Environment Equity Fund, Maximum Diversification Funds and ETFs. The percentage of total portfolio value is calculated as the assets under management (AUM) value of the low-carbon product as a percentage of IGM’s total AUM, as at December 31, 2020. Revenue is assumed to be the same proportion, namely 0.81%. The IGM group of companies also launched new environmentally focused products in 2021, including the IG Climate Action Portfolios, the Mackenzie Global Green Bond Fund and the Mackenzie Global Sustainable Bond Fund and ETF. In addition, approximately 0.26% of IGM Financial’s revenues came from corporate and government green bonds as at the end of 2020. The percentage of total portfolio value is calculated as the AUM value of the low-carbon product as a percentage of IGM’s total AUM, as at December 31, 2020. Revenue is assumed to be the same proportion. Finally, the Corporation’s alternative asset investment platform Power Sustainable operates the Power Sustainable Energy Infrastructure Partnership, a leading North American-focused renewable energy platform with 1GW of utility-scale and distributed capacity in operation through its two operating platforms, Nautilus Solar and Potentia Renewables, which also generate revenues. In addition, Power Sustainable has direct investments in The Lion Electric Company, a leader in the electrification of transportation in North America which manufactures zero-emission vehicles, including all-electric school buses, midi/minibuses for special needs or urban transit and commercial urban trucks, as well as in LMPG, an innovator in the design, development, manufacturing and distribution of sustainable interior and exterior lighting. For more information, please refer to: https://www.powercorporationcsr.com/media/uploads/reports/pcc-2021-cdp-response-final-web.pdf https://www.greatwestlifeco.com/content/dam/gwlco/documents/reports/2022/lifeco-2021-annual-report-en.pdf https://www.powersustainable.com/platforms/

Overall Environment

21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

Several practical actions were taken by the Corporation and its group companies during the reporting period to implement the environment principles. At the holding level, as part of our active ownership approach, we continued to regularly engage with our group companies regarding the ESG strategies they adopt and execute. We also continued to publicly report on our environmental performance, including through our response to the 2021 CDP Climate Change questionnaire and, for the second consecutive year, we were proud to be one of only three companies in Canada named on CDP’s Climate “A List.” Examples at our group companies include: • Great-West Lifeco and its operating companies: o Great-West Lifeco’s subsidiary GWL Realty Advisors (GWLRA) continued its efforts to reduce the environmental footprint of its office and residential portfolio. From 2013 to 2020, it reduced GHG emission intensity by 32%, energy intensity by 19%, water intensity by 26% and waste to landfill by 18%. At the end of 2021, 86% of GWLRA’s eligible portfolio by floor area attained green building certifications such as BOMA BEST or LEED. o In 2021, Canada Life’s corporate offices recycled 44 tonnes of cardboard, 17 tonnes of organics (compost), 625 tonnes of paper and 31 tonnes of other recyclables. o Great-West Lifeco continued to publicly report on its environmental performance, including through its response to the 2021 CDP Climate Change questionnaire. o In May 2020, Great-West Lifeco became a supporter of the Task Force on Climate-Related Financial Disclosures (TCFD) and in November 2021, it announced its commitment to achieve net-zero greenhouse gas emissions well before 2050 for their operations and by 2050 for financed emissions, with interim science-based targets to be announced in 2022. o Great-West Lifeco also continuously increased the proportion of its general account investments for which it calculates financed emissions, while its asset management affiliates manage assets of over $189 billion in ESG-related strategies as at year-end 2021. o Great-West Lifeco participated in Canada’s Sustainable Finance Action Council (SFAC) plenary meetings and select subgroups in 2021. The SFAC helps lead the Canadian financial sector toward integrating sustainable finance into standard industry practice and prioritizing climate-related financial disclosure. Great-West Lifeco is also an active participant in the UN-sponsored “Capital as a Force for Good” project, and a member of the Canada Sustainable Finance Action Council. • IGM Financial and its operating companies: o IGM Financial continued to work with its landlords and property managers to expand the availability of electric charging stations for clients at IG Wealth Management region offices and IG Wealth Management and IPC head offices. Employees are also encouraged to consider their business travel requirements carefully and, to the extent possible, they have transitioned to videoconferencing and online training to reduce travel needs and costs in a post-pandemic environment. o IGM Financial continued to publicly report on its environmental performance, including through its response to the 2021 CDP Climate Change questionnaire. o Ahead of the United Nations COP26, IGM Financials’ subsidiaries IG Wealth Management and Mackenzie Investments joined Canadian institutional investors managing $5.5 trillion in signing the Canadian Investor Statement on Climate Change. Both also joined Climate Action 100+, an investor-led initiative to ensure the world’s largest corporate emitters take action on climate change. Mackenzie was also a founding participant in Climate Engagement Canada, a Canadian-focused initiative driving dialogue with industry to promote a just transition to a net-zero economy. o Through its Climate Position Statement launched in November 2021, IGM Financial set a target to be climate neutral in its corporate offices and travel by the end of 2022. It also committed to setting interim targets for investment portfolios as a first step, consistent with the overall ambition to achieve net-zero emissions by 2050. As such, Mackenzie Investments joined the Net Zero Asset Managers Initiative and will set an interim investment target in line with the attainment of net-zero emissions by 2050 or sooner by the end of 2022. IGM Financial also joined the Partnership for Carbon Accounting Financials (PCAF) in November 2021 to support its journey to measure and disclose the greenhouse gas emissions associated with its mortgage loans and investments. o In early 2022, IG Wealth Management sent a formal letter to its subadvisors encouraging them to support the Glasgow Financial Alliance for Net Zero (GFANZ) by joining the Net Zero Asset Managers Initiative, and to become signatories to both the TCFD and Climate Action 100+. The letter will be followed by meetings with the subadvisors to talk about their climate action commitments and strategies. o In 2021, Mackenzie Investments identified the 100 companies in its retail equity portfolios that account for 70% of its retail equity carbon intensity and developed a strategy to engage with these companies to drive meaningful progress. • Groupe Bruxelles Lambert (GBL) o From 2021, GBL ruled out acquiring new internal combustion engine vehicles for its employee fleet in favour of hybrid or electric vehicles. o GBL’s Marnix head office building is currently being renovated with the aim of achieving HQE (“Haute Qualité Environnementale”) and BREEAM Outstanding and CO2 Neutral certifications. The renovation is expected to be completed by 2023 and, combined with the switch to 100% renewable energy sourcing, these initiatives will greatly contribute to reducing GBL’s energy consumption and its direct and indirect greenhouse gas emissions. o In 2021, as part of its ESG Policy, GBL adopted an exclusion policy to support the identification of climate-resilient investment opportunities, which typically excludes direct investments in the coal and non-conventional oil industries or in organizations active in the conventional oil industry and not benefiting from a clearly defined climate strategy aligned with the UNFCCC Paris Agreement and with Scope 1, Scope 2 and Scope 3 targets in place. o In June 2021, GBL became a TCFD supporter. o GBL committed to the Science Based Targets initiative (SBTi) in May 2021 and submitted its targets to SBTi. In January 2022, GBL became the first investment holding company to have climate targets aligned with a 1.5°C pathway approved by SBTi for both its own operations and its eligible portfolio of participations. o Some portfolio rotation decisions in 2021 illustrate the integration of climate risks and opportunities in the portfolio rotation process and the evolution of GBL’s model. GBL reduced its stake in Holcim from 7.57% at the end of 2020 to 2.14% at the end of 2021, which led to a 61% decline in GBL’s Scope 3 “emissions from investments” from 10.4 Mt CO2e (2020) to 4.1 Mt CO2e (2021). In March 2021, GBL acquired a majority stake in Canyon, a leading and fast-growing German manufacturer of premium bicycles, in line with its strategy of investing in companies that deliver growth while contributing to clean mobility as well as health and well-being solutions. o In 2021, GBL’s annual ESG risk review included an in-depth analysis of the biodiversity risk exposure and potential biodiversity impact of each portfolio participation. The conclusions of the biodiversity risk exposure and potential impact review will inform discussions, when relevant, in the different governance bodies of the investee companies. For more information, please refer to: https://www.powercorporationcsr.com/media/uploads/reports/pcc-2021-cdp-response-final-web.pdf https://www.greatwestlifeco.com/content/dam/gwlco/documents/reports/2022/lifeco-2021-annual-report-en.pdf https://www.canadalife.com/content/dam/canadalife/documents/corporate/pas/canada-life-public-accountability-statement-2021.pdf https://www.igmfinancial.com/content/dam/igm/en/corpresp/assets/docs/igm-financial-2021-sustainability-report.pdf https://www.igmfinancial.com/content/dam/igm/en/investrelations/finreporting/files/2022/igm-2021-ar-en-digital.pdf https://www.igmfinancial.com/content/dam/igm/en/corpresp/assets/docs/carbon-disclosure-2021-e.pdf https://www.gbl.be/en/media/3749/en-GBL-RA2021_0.pdf

Anti-corruption

Commitment

1. Does the company have an anti-corruption compliance programme?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

2021

Optional comment

As an international management and holding company, Power Corporation is committed to carrying out our business worldwide ethically and in accordance with all applicable laws, and without the use of bribery. We have formalized our commitment to anti-corruption compliance by establishing an Anti-Bribery Policy Statement and corresponding Global Anti-Bribery Policy, which were approved by the Board of Directors. These documents articulate our zero-tolerance approach to corruption and set out our expectations with respect to anti-bribery, prohibiting our people from receiving, promising, giving, providing, or authorizing the provision of anything of value to obtain or retain business, an advantage, or favoured treatment from anyone. The term “anything of value” is broadly defined in this context and includes not only obvious bribes and kickbacks, but also indirect benefits and any financial or other advantage. These prohibitions apply to dealings with individuals and corporate entities, including public officials, candidates for public office, employees of state-owned enterprises, and any other person with whom we anticipate doing business. Furthermore, we have set up specific rules with respect to giving and receiving gifts and hospitality. We are also committed to fostering our wholly owned subsidiaries’ compliance with anti-bribery laws. Our anti-corruption compliance program includes training, due diligence of third parties and mandatory reporting, and ensures that all our personnel undergo the training program. We maintain books and records that accurately reflect our transactions, the use of our assets, and other similar information, as well as a reasonable system of internal controls, and have implemented a pre-approval mechanism for gifts and hospitality in order to ensure compliance with the policy. To maintain awareness, we send our personnel periodic reminders of their duties and responsibilities under the policy. We also require all our Directors, officers and employees to certify their compliance with the policy at least annually by attesting to their compliance with our Code of Business Conduct and Ethics. We apply equally high ethical standards to our third parties by conducting risk-based due diligence on consultants or potential acquisitions. Third parties who work for/on our behalf are required to attest to their compliance with our business standards, including in respect to our Anti-Bribery Policy, via our Third Party Code of Conduct. For more information, please refer to: https://www.powercorporationcsr.com/en/responsible-management/governance/anti-corruption/

2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

No, and we have no plans to develop a policy

No, but we plan to in the next two years

Yes, included within a broader policy

Yes, articulated as a stand-alone policy

Optional comment

The Corporation formalized its commitment to anti-corruption compliance by establishing an Anti-Bribery Policy Statement and corresponding Global Anti-Bribery Policy, which are both available to employees and publicly at: https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-anti-bribery-policy-statement-en.pdf https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-global-anti-bribery-policy-2020-en.pdf These documents articulate our zero-tolerance approach to corruption and set out our expectations with respect to anti-bribery, prohibiting our people from receiving, promising, giving, providing, or authorizing the provision of anything of value to obtain or retain business, an advantage, or favoured treatment from anyone. These prohibitions apply to dealings with individuals and corporate entities, including public officials, candidates for public office, employees of state-owned enterprises, and any other person with whom we anticipate doing business. Furthermore, we have set up specific rules with respect to giving and receiving gifts and hospitality. Specifically, hospitality and gifts are not only required to be legal, but also consistent with the recipient’s policies and procedures and with the social and business customs in the recipient’s country. They must neither influence an upcoming decision on, or approval or award of, a contract, nor create a sense of obligation on the part of the recipient. Finally, gifts and hospitality provided or received are required to be objectively reasonable and must not be provided so frequently that, when aggregated, they become lavish or unreasonable. The Policy also covers political and charitable contributions. In case of doubt, section 13 of the Global Anti-Bribery Policy specifically states that anyone who has any questions regarding (a) the Policy, (b) the scope and reach of the anti-bribery and anti-corruption laws, (c) whether a particular payment or gift would run afoul of the Policy, or (d) anything else, is to contact the Corporation’s General Counsel. In addition to the Anti-Bribery Policy Statement and corresponding Global Anti-Bribery Policy, the Corporation’s Code of Business Conduct and Ethics, available at https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-code-of-business-conduct-and-ethics-2020-03-18-eng.pdf, provides guidance in conducting our business activities in accordance with the highest legal, ethical, and professional standards. It is made available to all our employees in both English and French, Canada’s official languages, and covers a broad range of topics, including compliance, responsible management, conflicts of interest, anti-corruption and anti-bribery. Section 15 of the Code specifically provides for any questions regarding the Code and its application or interpretation to be directed to a supervisor or the Corporation’s General Counsel, as appropriate. Finally, as regards interactions with public officials, the Corporation has adopted a Lobbying Policy in order to ensure compliance with Canadian federal and provincial legislation regarding communicating with and lobbying of government officials. The policy establishes a framework for compliance with lobbying legal requirements relating to federal and provincial governments and outlines appropriate employee activity and approval processes. If they are in doubt about whether an exemption applies, section 7 of the Lobbying Policy provides that directors, officers and employees seek confirmation from the General Counsel. The Corporation’s Lobbying Policy is available at https://www.powercorporationcsr.com/media/uploads/pdf/sidebar/pcc-lobbying-policy-final-web-2020-08-07.pdf.

Prevention

3. Who receives training on anti-corruption and integrity?

Optional comment

The Corporation’s anti-corruption compliance program includes formalized training on business ethics risks and prevention (including on the topics of corruption and fraud) as part of the mandatory annual training session on its Code of Conduct, other key corporate policies, due diligence of third parties and mandatory reporting. The Corporation ensures that all its personnel undergo this training program. For more information, please refer to: https://www.powercorporationcsr.com/en/responsible-management/our-commitments/code-business-conduct-and-ethics/ https://www.powercorporation.com/media/uploads/reports/proxy/pcc-notice-proxy-circular-2022-en.pdf

3.1. How often is such training provided?

	One time only	Every year	Every two or more years	We do not collect this data
All employees
Select employees
Contractors
Direct suppliers of the organization
Other – such as partners, clients, etc.
Indirect suppliers of the organization

Optional comment

As part of our mandatory annual Code of Business Conduct and Ethics training sessions, we educate our employees on the application of our policies and procedures. The training process is facilitated by a web-based platform, through which the mandatory training module covering Power’s Code of Business Conduct and Ethics and key corporate policies, including our Global Anti-Bribery Policy and our Third Party Code of Conduct, is conducted. At the end of the module, all Directors, officers and employees are required to certify their compliance with our Code of Conduct and key corporate policies as part of our annual certification requirement. In 2020 and 2021, all our people acknowledged compliance with the Code. For more information, please refer to: https://www.powercorporationcsr.com/en/responsible-management/our-commitments/code-business-conduct-and-ethics/

4. Does the company monitor its anti-corruption compliance programme?

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

The risks of internal and external fraud are included in Operational risk, as defined in the Corporation's Annual Management’s Discussion and Analysis. The Corporation manages operational risk by adopting and applying a series of corporate governance policies, procedures and practices, and has established a series of controls for financial reporting and disclosure purposes, and such controls, which are tested on a regular basis, can contribute to identifying and mitigating operational risks. In 2020, 100% of the Corporation’s operations were assessed for risks related to corruption. More specifically, the Corporation’s anti-corruption compliance program includes training, due diligence of third parties and mandatory reporting, and it ensures that all our personnel undergo the training program. In fact, as part of our mandatory annual Code of Business Conduct and Ethics training sessions, all Directors, officers and employees of the Corporation are required to certify their compliance with our Code of Conduct and key corporate policies, including the Global Anti-Bribery Policy, as part of our annual certification requirement. In 2020 and 2021, all our people acknowledged compliance. We also maintain books and records that accurately reflect our transactions, the use of our assets, and other similar information, and a reasonable system of internal controls, and have implemented a pre-approval mechanism for gifts and hospitality in order to ensure compliance with our Global Anti-Bribery Policy. We apply equally high ethical standards to our third parties by conducting risk-based due diligence on consultants or potential acquisitions. Third parties who work for/on our behalf are required to attest to their compliance with our business standards, including with respect to anti-bribery, via our Third Party Code of Conduct. For more information, please refer to: https://www.powercorporation.com/media/uploads/reports/quarter/pcc-q4-2021-eng-web_Z59BM3k.pdf https://www.powercorporationcsr.com/en/responsible-management/governance/anti-corruption/ https://www.powercorporationcsr.com/media/uploads/reports/power_corporation_-_2020_esg_data_supplement_-_final.pdf https://www.powercorporationcsr.com/en/responsible-management/our-commitments/responsible-procurement/

Optional comment

Response and Reporting

5. Please report the company's total number and nature of incidents of corruption during the reporting year.

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years	0
NA
Confirmed during the current year, and related to this year	0
NA

Optional comment

Source: 2020 ESG Data Supplement, p. 3 - https://www.powercorporationcsr.com/media/uploads/reports/power_corporation_-_2020_esg_data_supplement_-_final.pdf

6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

7. Does your company engage in Collective Action against corruption?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

In support of our zero-tolerance approach to corruption, we continued during the reporting period to strengthen our approach to ensuring compliance with our policy regarding anti-bribery with both our employees and third parties. • Third Party Due Diligence: We continued to maintain our anti-corruption compliance program, which includes due diligence of third parties and mandatory reporting. As part of the due diligence process, we continued to apply high ethical standards to third parties dealing with us by conducting risk-based due diligence on consultants or potential acquisitions. Third parties who work for/on our behalf are required to attest to their compliance with our business standards, including with respect to anti-bribery, via our Third Party Code. • Training and Awareness: We reinforced our values with employees through our annual training and Code attestation program, which includes our anti-corruption policy. We also continued to maintain awareness by sending personnel periodic reminders of their duties and responsibilities under our Global Anti-Bribery Policy. • Compliance: In 2020 and 2021, all our Directors, officers and employees acknowledged compliance with our Code, including our Global Anti-Bribery Policy. Furthermore, no violations related to corruption and bribery were identified. In addition, all Great-West Lifeco employees acknowledged their commitment to the company’s code of conduct, which includes anti-corruption expectations. IGM Financial similarly trains all new employees on their code of conduct and reinforces the code through 100 per cent staff acknowledgement annually.