Report - COP Prototype

2022 Communication on Progress

Schneider Electric SE

Published date

June 27, 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

At Schneider Electric, sustainability is integrated in the processes and bodies that design and execute the Group’s strategy at Board, executive, and operational levels. In 2013, the Board of Directors decided to extend the powers of the Governance & Remunerations Committee to corporate social responsibility (CSR) issues. Since 2014, there has been a specific committee for CSR, the Human Resources & CSR Committee. The Committee meets at the initiative of its Chairperson or at the request of the Chairman & CEO. The agenda is drawn up by the Chairperson. The Committee shall meet at least three times a year (five meetings in 2021). The Committee may seek advice from any person it feels will help it with its work. Main responsibilities: • Employee shareholding schemes and share allocation plans; • Compensation of Group managers; • Succession plan for key Group Executives; • Human resources; • CSR policy and results. In 2021, the Human Resources & CSR Committee reviewed the Sustainability strategy.

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

Schneider Electric has taken a strong commitment for sustainability in its ecosystem, notably formalized in its Trust Charter and Supplier Code of Conduct. Progress towards these commitments is measured in the Schneider Sustainability Impact and Essentials Programs.

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

In 2021, Schneider Electric evolved its Principles of Responsibility to the Trust Charter, acting as the Group’s Code of Conduct and demonstrating its commitment to ethics, safety, sustainability, quality, and cybersecurity. Schneider Electric believes that trust is a foundational value. It is earned. It serves as a compass, showing the true north in an ever more complex world and Schneider Electric considers it to be core to its environment, sustainability, and governance commitments. Trust powers all Schneider Electric’s interactions with stakeholders and all relationships with customers, shareholders, employees, and the communities they serve, in a meaningful, inclusive and positive way.

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

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

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

As part of its Extra-Financial Performance Declaration, the Group presents the main risks and opportunities identified with respect to major societal challenges. In order to compile the list of main extra-financial risks for the Group, a panel of both internal and external tools is used to address the expectations of its stakeholders as best as possible. The Group Sustainability team leads the evaluation, working in close collaboration with the Group Risk Management function and with the Duty of Vigilance Committee. In 2021, seven main risk categories were identified: • Business conduct • Corporate governance • Cybersecurity and data privacy • Environment • Product, projects, system quality and offer reliability • Human rights • Responsible workplace • Talent development and competencies

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

Schneider Electric seeks to be a role model in its interactions with customers, partners, suppliers, and communities when it comes to ethics and the respect and promotion of human rights. The Group strives to have a positive impact on the planet and the environment by contributing to finding solutions to limit climate change. The Group’s vigilance plan reflects this ambition. It also complies with the provisions of 2017 French law on Corporate duty of vigilance. The plan includes: • A risk analysis specific to vigilance: risks that Schneider Electric poses on the ecosystem and environment; • A review of the key actions implemented to remediate or mitigate these risks; • An alert system; • Governance specific to vigilance.

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

Each topic is monitored by the relevant departments and their management teams, or “Risk Overseers”, who are in charge of proper risk assessments and the implementation of mitigation and prevention actions. The main identified risks are quantified on probability of occurrence and magnitude of impact by these departments to determine gross risks, and an assessment of current mitigation measures informs on potential net impacts.

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

Schneider Electric developed a specific risk matrix for the implementation of its vigilance plan which is reviewed annually. The methodology is consistent with other risk evaluations maintained at Group level but focuses specifically on the risks posed by Schneider on its environment and ecosystem. In 2021, Schneider went further to deepen its analysis on local communities specifically. The Group has studied four areas where risks may occur: • Schneider Electric sites: they have been segmented based on categories that present a specific level of risk. Employees with frequent travels (sales, field services, travelers, audit, top management) have been assessed separately; • Suppliers: the level of risk differs based on the type of process and technologies used, and the Group has therefore segmented the analysis by component category of purchase. The risk level is an average assessment. The geographical location is factored in when selecting suppliers for the audit plan; • Contractors: when implementing a customer project, like building a large electrical system at a customer’s site, Schneider Electric is working with contractors, leveraging their expertise (civil work, electrical contracting, etc.). This “off-site” project work generates a specific level of risk for contractors. A separate “off-site and projects execution” category for contractors has therefore been defined for the assessment. • Local Communities: Schneider Electric has identified two distinct segments: communities located around Schneider Electric sites and communities located around customer projects sites. Communities have been assessed against three risk categories; human rights, environment, and business ethics.

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

Optional comment

Employees and external stakeholders (suppliers, subcontractors, customers, business agents, etc.) can directly access the whistleblowing system through the Trust Line portal, which provides support to people if they are a victim/witness to a potential violation of the Trust Charter. The Trust Line is available online globally, at all times, and protects the anonymity of the whistleblower (unless there is legislation to the contrary). The Trust Line is available here: https://www.se.com/ww/en/about-us/sustainability/responsibility-ethics/trustline/

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

In compliance with local legislation, the whistleblowing system is provided by an external, impartial third-party company and proposes alert categories, a questionnaire, and an information exchange protocol between the person issuing the alert and the person responsible for the internal investigation.

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

https://www.se.com/ww/en/about-us/sustainability/responsibility-ethics/ https://www.se.com/ww/en/about-us/suppliers/

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

Executive Pay

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

Optional comment

Annual short-term incentives for the Group’s executives and about 64,000 eligible employees are linked to the Schneider Sustainability Impact (SSI) performance since 2011. From 2019, the weight of the SSI criteria has increased from 6% to 20% in the collective part of the annual incentive, highlighting further the importance of ESG on Schneider Electric’s business agenda. Schneider Electric’s long-term incentive plan offers share ownership opportunities to the Group’s key talents and critical roles to align their rewards with the interests and experience of Schneider Electric shareholders. Similar to the short-term incentive, a portion of the award under the long-term incentive plan is subject to the achievement of sustainability objectives. From 2020, the long-term sustainability performance is measured through the Schneider Sustainability External & Relative Index (SSERI), which accounts for 25%, a combination of external indices which cover a range of environmental, social, and governance indicators wider than and different from the SSI criteria included in the annual incentive plan.

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 (#)	15
Male (%)	58
Female (%)	42
Non-binary (%)
Currently not reported
Under 30 years old (%)	0
30-50 years old (%)	27
Above 50 years old (%)	73
From minority or vulnerable groups (%)
Currently not reported
Executive (%)	25
Independent (%)	75

Optional comment

As of March 29, 2022, the Board of Directors consisted of 15 Directors and 1 Observer before the Annual General Assembly.

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)

Limited assurance for majority of metrics

In keeping with its commitment to continuous improvement, Schneider Electric asked Ernst & Young to conduct a review in order to obtain a “limited” level of assurance for certain Human Resources, safety and environmental data indicators, and all of the key performance indicators from the Schneider Sustainability Impact (SSI) and Schneider Sustainability Essentials (SSE) (see Independent verifier’s report attached). The audit work builds on that conducted since 2006.

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

Other (Please provide additional information)

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
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

Schneider Electric lives up to the highest standards of corporate governance, through initiatives that monitor and educate teams on ethics, cybersecurity, safety, and quality. The 2021 Trust Charter sets out the expectations of how we work at Schneider and equips teams to confront any unethical behavior they might encounter: https://www.se.com/ww/en/download/document/SchneiderElectric_TrustCharter/ Schneider Electric is committed to privacy and adheres to the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA) and the Personal Information Protection Law (PIPL). Our privacy compliance is overseen by our Data Privacy Officer who works with our global network of Country Data Privacy Correspondents to maintain compliance across the many geographies we operate in. Our Privacy Policy can be found at https://www.se.com/us/en/about-us/legal/data-privacy.jsp.

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

At Schneider Electric, Data Protection and Privacy compliance is overseen by a Group Data Protection Officer, working with a global network of Country Data Protection Correspondents in Europe and privacy contacts outside Europe. Our data privacy and protection compliance program is built upon a scalable framework that leverages training, awareness, policies, processes, templates, a maturity matrix, and related tools. The implementation of the data protection and privacy framework is a collaborative approach between central teams led by Chief Data Officer and local teams led by country leadership.

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

For cybersecurity, Schneider Electric engages cyber discussions with its customers, suppliers, and partners to improve the resilience across the value chain. The Group proposes cybersecurity by design with: - Schneider Electric’s Security policy framework is structured around major and recognized cybersecurity standards (ISO 27001; NIST; IAS/IEC 62443; GDPR) and comply with their requirements. - Schneider Electric IoT-enabled EcoStruxure™ platform providing customers with end-to-end cybersecurity solutions and services to protect a vast digital ecosystem. For data privacy, Schneider Electric has put in place a governance ecosystem including a Group Data Protection Officer, a DPO network, an implementation team, Data Privacy & Protection Champions and Steercos.

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

Schneider Electric deploys several actions to reinforce its cyber posture and that of its ecosystem of partners and customers: • Holding a cyber-related business risk register to articulate potential vulnerabilities/attacks and define remediation activities • Performing security and privacy reviews. • Identifying and prioritizing high-value digital assets to the Company’s operation. • Implementing cyber capabilities and digital locks around people, processes, and technologies. • Deploying general and dedicated awareness and training programs on cybersecurity and data protection, with a strong focus on high-risk population (customer-facing people, HR). • Monitoring, detecting, responding, and learning from cyber events. Performing reality checks via metrics, internal and external reviews, cyber crisis drills, and vulnerability assessments to our extended enterprise (including our acquired companies). • Engaging cyber discussions with our customers, suppliers, and partners to improve the resilience across the value chain. • Concluding with suppliers data processing agreements to ensure the protection of personal data. • Partnering with leading companies, experts, and authorities in the field of cybersecurity and data protection. The Group's actions are further detailed in its: - Third-Party Security Principles: https://download.schneider-electric.com/files?p_Doc_Ref=3rd_party_cyber_09112020AR0&_ga=2.28181948.1448289183.1656239304-1843282557.1654090559 - Cybersecurity Position paper: https://download.schneider-electric.com/files?p_enDocType=Brochure&p_File_Name=998-21913650_schneider-electric-cybersecurity-posture-paper.pdf&p_Doc_Ref=SECyberSecurity&_ga=2.22031803.1448289183.1656239304-1843282557.1654090559 - Cybersecurity and Data Protection Posture : https://www-prd.corp.staging.sdl.se.com/ww/en/about-us/cybersecurity-data-protection/index.jsp???%C3%A8

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

Online training on cybersecurity is mandatory for all employees. This training helps employees to understand what cyber threats they may face and how they should behave to be protected from the risks. At the end of 2021, 99% of Schneider Electric employees have completed this training. Specific employee categories received mandatory training for risks linked to their activity. Schneider Electric implemented the General Data Protection Regulation (GDPR) requirements and specific training was launched to present the major challenges of this regulation. This training is mandatory for Schneider Electric employees in Europe and key functions.

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

As part of the Trust pillar of its 2021-2025 sustainability strategy, Schneider Electric commits: - to be in the top 25% in external ratings for Cybersecurity performance - train 100% of its employees on Cybersecurity and Ethics every year - assess its suppliers under its ‘Vigilance Program’ For all these commitments, Schneider Electric publishes results externally and obtains a “limited” level of assurance on methodology and progress from an independent third party verifier.

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.

To implement the human rights principles, Schneider Electric implement actions towards all its stakeholders: - internal actions: the Internal Audit team works on an annual self-assessment of human rights to benchmark its entities and prioritize mitigation plans where necessary. The Group is also implementing training programs (some are mandatory) to raise the level of awareness of employees and give them advice on how to react or behave on a wide variety of topics from anti-harassment to well-being, or how to overcome bias and develop an inclusive culture. Specifically, for health and safety, the Group maintains a follow up of safety metrics. Incidents are reviewed with management, corrective actions are implemented when necessary. - actions towards suppliers: Human rights are included in the integration of the sustainable purchases approach in the selection of new suppliers. Schneider Electric uses a qualification process called Schneider Supplier Quality Management (SSQM) to select new suppliers. It is based on an evaluation questionnaire combined with on-site audits, which include human rights and health and safety assessments. Schneider Electric’s Supplier Code of Conduct states the framework in which the Group wishes to operate with vendors. Schneider Electric expects suppliers to respect the fundamental principles on health, safety, people’s protection, and development as defined in this document. Strategic suppliers are also assessed through Ecovadis 3rd party, leveraging ISO26000 norm, where Labor and Human rights is one of the four pillars of the methodology. - actions towards contractors: The Group is working on the evolution of the project decision-making process to incorporate a risk assessment covering ESG topics including human rights. The aim is to better calibrate the mitigation measures and anticipate their implementation earlier in the project process. Schneider Electric is also conducting specific on-site audits for contractors included into the Vigilance Supplier Audit program. At the end of 2021, 13 subcontractors have been audited. - actions towards local communities: Local communities are integrated in the vigilance risk matrix on two types of locations: Schneider sites (factory or an office building) and customer project sites (where the Group is operating as a contractor or subcontractor for a customer). - partnership and working groups: The Group has joined Entreprises pour les droits de l’Homme (EDH – Businesses for Human Rights), a leading French association of businesses providing its members with tools and advice on implementing the United Nations Guiding Principles on Business and Human Rights. In 2018, Schneider Electric also joined the Responsible Business Alliance (RBA), a non-profit coalition of more than 120 companies from the electronic, retail, automobile, and leisure industries, for compliance with human rights and sharing the best practices with regards to on-site auditing and monitoring of suppliers’ activity, including forced-labor issues. The Group also joined the Global Compact LEAD working group “Decent Work in Global Supply Chain”. Schneider Electric co-leads the G7 Business for Inclusive Growth (B4IG) coalition’s “Advancing human rights in direct operations and supply chains” and “Building inclusive workplaces” working groups. As a result of the working group on advancing human rights, in 2020, B4IG members adopted a collective statement supporting a European framework on mandatory human rights due diligence and providing suggestions to be considered in legislation. In 2021, the working group has implemented a toolbox gathering best practices from companies’ members and put specific attention on migrant workers and fair recruitment.

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
2017
Forced labour
2017
Child labour
2017
Non-discrimination in respect of employment and occupation
2017
Occupational safety and health
2022
Working conditions (wages, working hours)
2017

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)

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)

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)

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)

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)

Performance

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

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	72

Optional comment

Schneider Electric considers freedom of association and collective bargaining as fundamental rights that must be respected everywhere and therefore in its Trust Charter commits to complying with local laws in every country where it operates. In its Human Rights Policy, Schneider confirms that it considers freedom of association as the basis of a regular dialog between a company and its employees. To that purpose, Schneider respects the individual right of its employees to freely join, participate in, or quit labor organizations to assert and defend their interests. Subsequently, Schneider guarantees that any employee wishing to do so shall be protected against any internal measure limiting his or her freedom of association such as discrimination of any kind, pay loss, or dismissal. Schneider also recognizes the importance of dialog with freely appointed employee representatives, employee representative bodies (such as Works Councils or employee forums), or organizations (like trade unions) and supports collective bargaining. In addition, Schneider joined the Global Deal initiative in 2017. The Group is promoting social dialog as a means to foster decent work, quality jobs, increased productivity and, by extension, greater equality and inclusive growth.

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 (%)

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

	Percent of women (%)	Unknown
Senior leadership level position	26
Non-executive board	42

Optional comment

Schneider Electric is strongly committed to building a diverse organization at every level. In that context, the Group has identified increasing the share of women in its workforce and leadership as an absolute priority. Significant progress has been made in the representation of women, especially on the Board and Executive Committee level (respectively, 42% and 44% female as of end of 2021). In 2019, the Company revitalized its commitment to gender equity in leadership roles and partnered with INSEAD to launch the Schneider Women Leaders’ Program (SWLP) – a global program with a common cause, enabling more women at their mid-career point to build the skills and confidence to step up their leadership capability and impact. The SWLP program is a seven-month coaching and virtual workshop experience, culminating in a three day virtual global summit, bringing the graduating women together with senior Schneider leaders and world-class business school faculty. Since its inception in 2019, more than 230 women have benefited from this targeted leadership development program. In addition to SWLP, a new program called “How Women Rise” was launched for Schneider employees in several countries. Over the last couple of years, this leadership program has benefitted more than 1000 women.

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 (%)
The average ratio of remuneration of women to men is calculated based on Schneider Electric's own pay equity methodology. As part of its Schneider Sustainability Impact commitments over the last five years, Schneider Electric has proactively worked to identify and address female pay gaps with appropriate corrective actions through a country driven approach. The global pay equity framework was implemented in all countries by the end of 2020, covering 99.6% of Schneider Electric’s total workforce. Given the progress made on Pay Equity and to support its inclusion philosophy, starting in 2021, Schneider Electric has engaged in best practices to maintain a pay gap below 1% by 2025 for both females and males. Measurement of the individual pay gap is achieved by comparing each employee to a universal median total target salary “TTC” (base salary + target short term incentive) for all genders. In other words, an individual’s TTC is assessed against the median TTC of their comparator group (individual TTC/median of comparator group TTC – 1). The comparator group is defined by the drivers of job level (grade) and salary structure within a country. As of the end of 2021, the pay gap was -1.61% for females and 1.11% for males, on track with target. Note that this measurement will differ from Country figures that may be required to be reported due to statutory requirements.

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	6.5e-7

Optional comment

At Schneider Electric our mission is to protect Occupational Health and Safety of employees, customers, contractors, and visitors to our locations. As such, we aim to reduce the Medical Incident Rate (MIR) to 0.38 by 2025. The MIR is the number of work incidents requiring medical treatment per million hours worked (i.e. average hours of 500 employees working for one calendar year). Over the past 10 years, the Group has reduced the frequency of incidents (MIR) by 81%. In 2021, the MIR is at 0.65 (per million hours worked), translating into 0.00000065 per hour worked.

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

	Incident rate	Unknown	Choose to not disclose
Incident rate	3.3e-7

Optional comment

Schneider Electric measures the severity of incidents with the Lost Time Incident Rate (LTIR). It captures the Captures the number of work-related incidents requiring time off work (>24hrs). In 2021, the LTIR is at 0.33 (per million hours worked), translating to 0.00000033 per hour worked.

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
In 2021, we were not aware of any significant freedom of association issues
Forced labour
In 2021, we were not aware of any forced labor issues
Child labour
In 2021, we were not aware of any child labor issues
Non-discrimination in respect of employment and occupation
Occupational safety and health
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.

To implement the labour right principles, Schneider Electric uses different levers, including: - The Groups upholds labour rights principles in its Human Rights Policy: https://www.se.com/ww/en/download/document/Human_Rights_Policy/ - As part of its 2021-2025 Schneider Sustainability Impact and Essentials programs, Schneider Electric is working towards several labour rights commitments for its own employees and suppliers. For instance, the Groups commits that 100% of its employees are paid at least a living wage and that 100% of its strategic suppliers provide decent work to their employees. - Through its Vigilance plan, Schneider Electric seeks to be a role model in its interactions with customers, partners, suppliers, and communities when it comes to ethics and the respect and promotion of human rights. The plan includes a risk analysis, review of actions implemented, an alert system and dedicated governance.

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
2021
Water
2021
Oceans
Schneider Electric has limited direct impact on the oceans. Yet, the Group is committed to be more efficient with resources, notably by eliminating single use plastic from packaging by 2025.
Forests / Biodiversity / Land Use
2021
Air Pollution
2021
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2021
Energy & Resource Use
2021

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

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

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

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

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	The Group aims to be a role model in the fight against climate change, by sharply decarbonizing its own operations, is supply chain and by delivering services and solutions for its customers to deliver a climate positive impact. Schneider Electric is a signatory of the Business Ambition for 1.5°C initiative aimed at setting Greenhouse Gas (GHG) emissions reduction targets in line with the global effort to limit warming to 1.5°C. Climate ambitions are defined for 2025, 2030 and 2050: • Before 2025, demonstrate that Schneider Electric is carbon positive together with its customers and partners, thanks to CO2 savings delivered by EcoStruxure™; • On the Group’s operations (scope 1 and 2): be carbon neutral by 2025 (allowing CO2 offsets) and net-zero CO2 emissions by 2030 (with no CO2 offsets); • On indirect emissions (scope 3) in its supply chain and with customers: reduce emissions by -35% by 2030 (versus 2017) as part of the Group’s validated 1.5 °C SBT targets, by actively engaging suppliers to accelerate their climate strategy and sourcing greener materials, as well as reducing offers’ emissions on customers’ ends; • Become carbon neutral on the Group’s full end-to-end footprint by 2040 (scope 1, 2, and 3), 10 years ahead of 1.5 °C trajectory. This means that all Schneider Electric’s products will be carbon neutral in 2040; • Engage with suppliers to move towards a net-zero CO2 supply chain by 2050 (with no CO2 offsets). The Group’s 2030 targets (net-zero CO2 emissions on scope 1 and 2, and -35% on scope 3) are a validated 1.5°C Science-Based Target. Schneider Electric climate goals are published externally and verified by an independent third party every year.
Energy & Resource Use	To deliver its Scope 1 and 2 targets, the Group has launched several transformations under the Climate and Resources pillars of its Schneider Sustainability Essentials (SSE) programs: • Reach 150 Zero-CO2 sites by 2025 (SSE #1), • Propose SF6-free alternatives for all medium voltage technologies by 2025 (SSE #2), • Source 90% of electricity from renewables by 2025 (SSE #3), and 100% by 2030, • Increase energy efficiency in our sites by 15% by 2025 (SSE #5) and double energy productivity by 2030 (vs 2005), • Shift one third of corporate vehicle fleet to electric vehicles by 2025 (SSE #7), and 100% by 2030.
Water	Due to the nature of most of its industrial processes (manual and automatic assembly), water consumption is not generally a critical resource for Schneider Electric. However, Schneider fully realizes the importance of water in local communities, especially those that are located in water-stressed areas. Having approximately 90 ISO 14001 sites in areas classified as ‘high’ or ‘extremely high’ baseline water stress, as defined by World Resources Institute’s (WRI) Aqueduct Water Risk Atlas, the Group has set the ambition that 100% of its sites in water-stressed areas have a water conservation strategy and related action plan by 2025 (Schneider Sustainability Essentials #11). In 2021, the Group achieved 9% of its 2025 target. In addition, Schneider’s aims to reduce water intensity (in m3 of water consumption per euro of turnover) by 35% in 2025 versus 2017, with a focus on sites with high water consumption and within severely water-stressed areas. In 2021, water consumption intensity was 72 m3 per million euro of revenue, an evolution of -34% against the 2017 baseline.
Forests / Biodiversity / Land Use	In the framework of act4nature international, Schneider Electric's biodiversity pledge outlines the Group's plan to protect and preserve nature and biodiversity in line with our commitment to being Resource efficient. Five main levers of actions have been identified and will be addressed through specific actions: 1. Quantify and regularly publish the assessment of impacts on biodiversity (MSA.km²) 2. Commit to reduce our impacts and align biodiversity objectives with science 3. Develop solutions and technologies that contribute to the preservation of biodiversity 4. Engage and transform the value chain 5. Act locally, engaging employees and partners By 2025, Schneider Electric commits that 100% of sites have local biodiversity conservation and restoration programs (Schneider Sustainability Essentials #8).
Air Pollution	Because Schneider Electric is mainly an assembler, its discharge into the air is very limited. Schneider manufacturing sites are carefully monitored, as part of ISO 14001 certification. Discharges are locally tracked as required by current legislation.
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)	Schneider Electric has set new waste recovery ambitions with the goal to have 200 'Waste-to-Resource' sites by 2025 (Schneider Sustainability Essentials #9). A site achieves ‘Waste-to-Resource’ status if it recovers more than 99% (by weight) of its non-hazardous waste while leveraging waste-to-energy solutions for less than 10% of its non-hazardous waste. Additionally, if a site generates hazardous waste, it must ensure 100% proper handling and treatment of that waste.
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

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
No significant spills or discharges were reported in 2021 with known harmful impacts in terms of water pollution.
Oceans
No significant spills or discharges were reported in 2021 with known harmful impacts in terms of ocean pollution.
Forests / Biodiversity / Land Use
Air Pollution
No significant spills or discharges were reported in 2021 with known harmful impacts in terms of air pollution.
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
No significant spills or discharges were reported in 2021 with known harmful impacts in terms of soil or water pollution.
Energy & Resource Use

Climate Action

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

Scope 1 Emissions

Full

None

Emissions (tCO2e)

140936

Scope 2 Emissions

Full

None

Emissions (tCO2e)

153115

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

68901866

Optional comment

Schneider Electric updates its end-to-end carbon footprint (Scope 1, 2 and 3) annually and obtains a “limited assurance” from an independent third party verifier on all figures. Scope 3 emissions represent more than 99% of the Group’s carbon footprint, of which 90% are due to the use phase and the products’ end of life, and around 10% result from the purchase of raw materials, equipment, and services.

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

In addition, to further contribute to a new electric and digital world, 100% of Schneider Electric’s innovation projects are aligned with its purpose, more than 90% qualifying as impact innovation under Schneider’s definition, or neutral. This concerns every innovation contributing to a decarbonized world, for instance energy and process efficiency, resource optimization, SF6-free projects, or Green Premium™ offers. The methodology to calculate this figure is similar to the Schneider Impact Revenue methodology and should not be confused with OpEx and CapEx eligible under the EU Taxonomy.

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

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

50.6

Unknown

Technology

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

Percent of total revenue (%)

This year, Green Premium products and services accounted for 78% of Schneider Electric's product revenue. Launched in 2008, Schneider Electric’s Green Premium™ program was created to provide its customers with more sustainable products and to be transparent with environmental information. Since then, Green Premium™ has been the absolute warranty for the Group to deliver products that comply with RoHS and REACH regulations as well as being perfectly transparent by delivering environmental disclosures and end-of-life instructions.

Unknown

Not applicable (Please provide additional information)

Sector-specific: Water

12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

Water withdrawal (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	2072
Groundwater:	514
Surface water:	19
Rainwater:
Wastewater:
Percentage of water withdrawn in regions with high or extremely high water stress (%)	45

Water consumption (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total
Groundwater:
Surface water:
Rainwater:
Wastewater:
Percentage of water consumed in regions with high or extremely high water stress (%)

Optional comment

Due to the nature of most of its industrial processes (manual and automatic assembly), water consumption is not generally a critical resource for Schneider Electric, and the Group has a minimal impact on water quality. The topic was considered not very material by both internal and external stakeholders during the sustainability materiality analysis. In 2021, water management and performance information was disclosed in the CDP Water program, and Schneider was awarded a B rating. However, Schneider fully realizes the importance of water in local communities, especially those that are located in water-stressed areas. The Group has set the ambition that 100% of its sites in water-stressed areas have a water conservation strategy and related action plan by 2025 (SSE#11).

13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

Water intensity of products (cubic meter/$):

Unknown

Not applicable (Please provide additional information)

In 2021, water consumption intensity was 72 m3 per million euro of revenue. Conversion rate used: https://www.federalreserve.gov/releases/G5A/current/

Optional comment

In 2021, water consumption intensity was 72 m3 per million euro of revenue. Conversion rate used: https://www.federalreserve.gov/releases/G5A/current/

Sector-specific: Air pollution

17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.

	Emissions (tCO2e)	Unknown	Not applicable (Please provide additional information)
NOx
Not material
SOx
Not material
Volatile Organic Compounds (VOC)
501,455 kg
Hazardous air pollutants (HAP)
Particulate matter (PM10)
Persistent organic pollutants (POP)
Other (please specify in text box)

Sector-specific: Waste

18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.

Waste Generated (t)

136816

Unknown

Not applicable (Please provide additional information)

19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.

Hazardous Waste Ratio (%)

6.2

Unknown

Not applicable (Please provide additional information)

20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.

Single-use plastics (tonnes)

Unknown

Not applicable (Please provide additional information)

Optional comment

By 2025, Schneider has committed to make sure that 100% of our primary and secondary packaging is free of single-use plastic.

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.

Schneider Electric’s long-term commitment is to be efficient with resources, by protecting and restoring biodiversity and innovating towards circular business models. On biodiversity, Schneider Electric is committed to fast-track the adoption of ambitious biodiversity strategies, leveraging best practices from climate Science-Based Targets: measuring impacts and aligning targets with science. With Schneider Sustainability Impact and its concrete programs, the Group innovates towards a more circular economy, in industrial processes, product design, and business model innovation. More details in the 2021 Resources Report: https://www.se.com/ww/en/assets/564/document/322984/resources-report-2021.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

Schneider Electric has a zero tolerance policy with regard to corruption. This commitment is materialized through a strong and continuously developing Anti-Corruption Compliance program, which is part of the Ethics & Compliance program. As stated in our Trust Charter and Anti-Corruption Policy, Schneider Electric is committed to comply with all applicable laws and regulations, such as the OECD’s Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, the US Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and the French Sapin II law.

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

In order to meet the requirements of the French Sapin II law, the Group released an Anti-Corruption Policy. The Policy was reviewed in November 2019 to take into account results of the corruption risk mapping and to provide employees with examples illustrating situations they may face. The Anti-Corruption Policy shall serve as a handbook that anyone may consult when having doubts about appropriate business practices. It is not intended to address every issue one may encounter, but it provides appropriate examples of corruption risks and offers guidance to resolve many ethical dilemmas. The Gifts & Hospitality Policy provides guidance to employees on the ethical handling of gifts and hospitality received and given by Schneider Electric employees. A new version of the Business Agent Policy was released in August 2019 to meet legal requirements and public authorities’ guidance, especially regarding risk-based approach of the due diligence, as well as internal recommendations following several audits performed on applicability of the policy in 2018. The risks associated with onboarding new acquisition targets are numerous and consequently, Merger and Acquisition (M&A) guidelines have been published to identify, manage, and mitigate those risks at the earliest stage possible. These guidelines aim to cover the very first steps of identifying potential targets (M&A strategy), what to look out for in data-rooms, and finally how we plan to integrate the acquired entity into our compliance organization. These same rules also apply when Schneider Electric decides to make a divestiture with a step-by-step approach to managing the transition. In 2021, a Conflict of Interest Policy was published, in particular creating a procedure to disclose and manage any identified conflict of interest. A Donations Policy has also been published and implemented, which aims, among other things, to manage risks of unlawful use of money and then corruption.

Prevention

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

Optional comment

In 2020 and 2021, a set of anti-corruption e-learnings was built, providing guidance on real life risk scenarios; it was designed taking into account the trainees’ needs and expectations, and is mandatory for targeted employees exposed to corruption risks through their job codes, i.e. those identified as such by the corruption risk mapping. This led to a curriculum of modules of e-learnings, deployed in 2020: a general module on the “zero tolerance” message against corruption and an explanation of the legal framework and risks, and two specific modules about third parties and gifts and invitations. In 2021, four additional modules were created about facilitation payments, conflict of interest, conditions that make people commit the wrongdoing, and how to raise concerns in Schneider Electric. The modules were supported by top leaders’ videos demonstrating the “tone at the top” on this crucial matter and are available in 14 languages. In 2021, the set of anti-corruption e-learnings has been assigned to more than 40,000 employees and 97% completed it.

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

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 Ethics & Compliance program is an integral part of the Group’s Key Internal Controls. In 2021, this Key Internal Control framework has been significantly reshaped and enhanced, which will allow for improved monitoring of key pillars of the Ethics & Compliance program. Whenever an evaluation indicates points of weakness, action plans must be set up and monitored by internal auditors. Also, Schneider Electric is working on additional second-level controls to monitor and assess the effectiveness of some of the recent evolutions of the Ethics & Compliance program. Furthermore, the Group’s Internal Audit program includes specific tasks related to the Ethics & Compliance program, and to activities or subsidiaries for which an evaluation of the maturity and effectiveness of the program will be reviewed. Several internal audits were conducted in 2021 resulting in recommendations related to the improvement of the Ethics & Compliance program. In 2021, to measure the effectiveness of the Trust Line, Schneider Electric has added to its annual employee engagement survey, OneVoice, a new question: “I can report an instance of unethical conduct without fear”. 81% of employees surveyed answered “yes”, and the Group will work to increase this measurement by 10 points by 2025 as part of Schneider Sustainability Impact.

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	12
Bribery & Corruption
Confirmed during the current year, and related to this year	32
Bribery & Corruption

Optional comment

Some cases are still under investigation.

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

Optional comment

Each concern reported on the whistleblowing system is analyzed by the Group Operational Compliance Committee (GOCC) and relevant Regional Compliance Officer, and where considered necessary, investigated. Each year, a detailed report on the effectiveness of the system is presented to the Audit & Risks Committee, which reviews effectiveness of the alert system. In the event of non-compliance with the Ethics & Compliance program by an employee (especially based on the findings of an investigation), disciplinary measures may apply depending on local disciplinary policies and law. The relevant managers, or the Group Disciplinary Committee for the most sensitive alerts, take the appropriate measures in order to sanction the party or parties involved and to remediate consequences of the misconduct (such as launch a specific audit, review a process, perform training, etc.).

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)

Schneider Electric participates in the initiatives of many nongovernmental organizations (NGOs) and professional associations, such as Transparency International France, a leading NGO that aims to stop corruption and promote transparency, responsibility, and integrity across all sectors. Schneider is also member of Le Cercle d’Éthique des Affaires (The Ethical Business Circle), a professional association that facilitates co-operation between business leaders across France to share best practices. To maintain innovation in its approach to ethics and compliance, Schneider became the eighth sponsor of the Master of Law and Business Ethics at CY Cergy Paris University in 2020 and benefits from the work of the Master’s Chair, led by experts in France and in the United States, as well as from listening to the students and reviewing their work.

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 2021, Schneider Electric has implemented several practical actions to support the anti-corruption principle: - a Conflict of Interest Policy was published, in particular creating a procedure to disclose and manage any identified conflict of interest. - a Donations Policy has also been published and implemented, which aims, among other things, to manage risks of unlawful use of money and then corruption. - a set of anti-corruption e-learnings was built, providing guidance on real life risk scenarios with four additional modules four additional modules were created about facilitation payments, conflict of interest, conditions that make people commit the wrongdoing, and how to raise concerns in Schneider Electric. The modules were supported by top leaders’ videos demonstrating the “tone at the top” on this crucial matter and are available in 14 languages. - In 2021, the set of anti-corruption e-learnings has been assigned to more than 40,000 employees and 97% completed it. - the evolution of our Principles of Responsibility to the Trust Charter, acting as the Group’s Code of Conduct and demonstrating its commitment to ethics, safety, sustainability, quality, and cybersecurity. Schneider Electric believes that trust is a foundational value. It is earned. It serves as a compass, showing the true north in an ever more complex world and Schneider Electric considers it to be core to its environment, sustainability, and governance commitments. - In 2021, this risk assessment was updated as part of the new Ethics & Compliance risk mapping, which focuses in particular on Corruption and Conflicts of Interest.