Report - COP Prototype

2022 Communication on Progress

EGIS

Published date

July 28, 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

In accordance with the French regulation, which transposes the European directive of 22nd October 2014, Egis has published annually a Non-Financial Performance Statement (NFPS) since 2018. The NFPS presents our sustainability development approach and deployment as well as our contribution to sustainable development goals. The NFPS covers the business model of the Group as well as the social, societal and environmental implications of our business activity (impact of our operations on climate change, commitments to sustainable development and the circular economy, collective agreements signed). It also describes the main non-financial risks identified, the policies applied to prevent these risks, and the KPI and results of these policies. Annually, the NFPS is submitted to the board for approval. For more details, please consult our NFPS which are publicly available under our website : https://preview.egis-prod.tangentlabs.co.uk/corporate-social-responsibility/reporting-for-progress

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

& Egis Human ressource code : https://media.umbraco.io/egis/gmdntb2r/code-du-management-des-rh-ukjuin2018.pdf & Egis Ethic code (statement at the beguinning of the document) : https://media.umbraco.io/egis/q1dktd1c/sie_e027-gb_charte-de-d%C3%A9ontologie_2022.pdf & Egis Code of integrity (statement at the beguinning of the document): https://media.umbraco.io/egis/biglr344/sie_e027-gb_code-d-int%C3%A9grit%C3%A9-egis-2022.pdf & Egis Partners Code of Integrity (statement at the beguinning of the document) : https://media.umbraco.io/egis/g1gfb5jm/sie_e027-gb_code-d-int%C3%A9grit%C3%A9-des-partenaires-2022.pdf Environment: - Egis Sustainable Development Charter 2012: https://media.umbraco.io/egis/ws4oqqia/2014_egis_sustainability_charter-en.pdf - Egis has made five major pledges in favor of the environment in 2021: https://preview.egis-prod.tangentlabs.co.uk/all-news/climate-challenge-new-video-on-our-commitments http://www.batibtp.fr/actualites/actualite/fiche/defi-climatique-egis-prend-cinq-engagements-concrets-au-coeur-de-son-activite.html https://www.bsmart.fr/video/9969-smart-impact-partie-10-novembre-2021

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

& Egis Human ressource code : https://media.umbraco.io/egis/gmdntb2r/code-du-management-des-rh-ukjuin2018.pdf & Egis Ethic code : https://media.umbraco.io/egis/q1dktd1c/sie_e027-gb_charte-de-d%C3%A9ontologie_2022.pdf & Egis Partners code of integrity : https://media.umbraco.io/egis/g1gfb5jm/sie_e027-gb_code-d-int%C3%A9grit%C3%A9-des-partenaires-2022.pdf & Egis Code of integrity: https://media.umbraco.io/egis/biglr344/sie_e027-gb_code-d-int%C3%A9grit%C3%A9-egis-2022.pdf & Egis Sustainable Development Charter 2012 https://media.umbraco.io/egis/ws4oqqia/2014_egis_sustainability_charter-en.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

& Human rights and Labour rights : In Egis, we don't have a Human Right responsible but our director in charge of human ressources is in charge of thoses thematics (Human Rights and Labour Rights) & Environment: The department in charge of Coorporate Social Responsability (CSR), known as the “Business Transformation and CSR Department” until end of 2021, reports directly to Senior Management, as its Director is member of the Executive Committee. The Sustainable Development manager, who manages the Environmental Management System (ISO 14 001), is part of the CSR Department. & Anti-Corruption: Under the leadership of Egis CEO and the COMEX, the Ethics and compliance director is responsible for developping and implementing the ethics program. To assist in this mission, he can rely on three instances: the Ethics Committee, which ensures that the ethics program is deployed within all Egis entities and is the highest decision making body; the Ethics Steering Committee, which role is to guide and supervise the operationnal side of the program; the Ethics Correspondents Network which participates to the development of the program and ensures the implementatioon of the ethics approach within their entities.

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

& The Executive Committee is the main management body of the Egis group. It is composed of the group functional directors and the executive directors in charge of the main business units (BU). Cross-functional issues are discussed in this committee, & Human ressources : The department in charge of HR works under the leadership of our Group Chief Human Resources Officer, including four divisions which ensures the compliance with all the requirements, meaning: Social affairs for all labour righst and conditions/hr compliance-related matters, Health/Security and Safety, Compensation & Benefits and HR Operations and integration (eg. talents, culture, diversity & inclusion, performance...), and in charge of animating the HR network through two networks: the HRD network with one HR representative per Business Line/Region ; an HR global network, with all the employees belonging to the HR community. & Environment: The department in charge of CSR, known as “The Business Transformation and CSR Department” until end of 2021, reports directly to Senior Management, as its director is member of the Executive Committee. The CSR Department internally works with: - the SD-CSR network composes with correspondants in each Business Unit (BU) ; - all internal cross-cutting networks (such as human ressources, purschasing, performance, environment, transport economics, water, intelligent transport systems, climate change adaptation, energy efficiency, etc); - the cross-cutting environmental expertise within our BUs (ecology and climate, nuisances mitigation (air pollution, odour, polluted soils and sites, noise, etc.), operational security/industrial risks, geomatics, pollution abatement, etc. ; & Sustainable Developpement Steering Committee: Created in 2010 and chaired by the group’s senior management, this committee brings together in-house representatives and some twenty external figures, recognised in the various fields of sustainable development affected by our activities: transport, town planning, consultation, and the environment. It meets twice a year with a view to preparing and enhancing Egis’s policies for sustainable development and corporate responsibility bringing different viewpoints on the development strategy, on solutions and dilemmas that the group encounters during projects. & Anti-Corruption: Under the leadership of Egis CEO and the COMEX, the Ethics and compliance director is responsible for developping and implementing the ethics program. To assist in this mission, he can rely on three instances: the Ethics Committee, which ensures that the ethics program is deployed within all Egis entities and is the highest decision making body; the Ethics Steering Committee, which role is to guide and supervise the operationnal side of the program; the Ethics Correspondents Network which participates to the development of the program and ensures the implementatioon of the ethics approach within their entities. & Other cross-functional committee: And Egis has set up a Risks and Commitments Committee (RCC) whose role is: - ensure that measures are in place to address risks, - to issue an opinion on the Bid / No Bid for the Group's major projects presenting significant potential risks for the Group. It assists BU and Group management by analyzing, before a decision is made, the scope of commitments that may be made, particularly with regard to the signing of client contracts presenting potential risks.

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

Egis is an international group which, through the nature and geographic location of its activities, is liable to be exposed to numerous risks. The risk management system is integrated into the performance management system. The CEO of the Egis Group is its guarantor. The risk management system is coordinated at Group level by the Risk function of the DECRP (Ethics, Compliance, Risk and Performance Department). It rolls out the methodology and updates the procedures and tools necessary for the process. The Business Unit (BU) risk correspondents, appointed by the BU heads, lead the approach within their BU. They coordinate the process for identifying, assessing and managing risks within their scope of responsibility. They report annually on the major risks identified as well as any significant incidents. At Group level, major risks are identified as part of the processes in the performance management system by the process manager. One of the procedures is dedicated to mapping the risk of corruption. The risks identified by the managers are consolidated in the Group’s map of major risks. The Operational Risk Committee (ORC) is a group-wide body in charge of governing risk management. Twice a year, the DECRP presents at ORC “Risk” meetings the major risks identified alternately by the BUs and the Process Managers at Group level. The ORC is responsible for validating the Group’s major risk mapping as well as reviewing and approving the associated action plans. The Egis group’s risk analysis methodology is in line with the best practices suggested by the recognised international reference frameworks (COSO 2 ERM et ISO 31000-2018). The risk mapping is reviewed each year. The risks are evaluated and prioritised according to an assessment matrix, taking into account their likelihood on the one hand and the severity of the impact on the other. The identification of non-financial risks (environmental, social and societal, human rights, anti-corruption) is part of our risk assessment process.

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

In our risk management system, one of the procedures is dedicated to mapping the risk of corruption. The latest is based on an objective, structured and documented analysis of the scenarios of exposure to the risk of corruption that each Egis Group entity may encounter in the course of its activities. The risk linked to suppliers and business relationship enters in the scope of the corruption risk map.

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

In its Performance Management System, Egis provides due diligence process on sustainability topics for: - Acquisition of companies; - Entering into partnership agreement and contracts; - Contract Acquisition with the Risks and Commitment Committee ; and - Patronage and sponsorship policy.

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

For the major Group projects presenting potentially significant risks, the Risks and Commitments Committee (RCC) shall be consulted to issue Bid/No Bid opinions, with or without reservations. Potential significant risks include the followings: commercial relating to partners, subcontractors or countries, Human Resources, Ethics & Compliance, Sustainable Development, etc. For Environmental risks, while only few suppliers or business relationships are assessed, they represent a higher pourcentage of turnover as it is the major Group projects that go through the Risks and Commitments Committee process. (The mission of the Risk and Commitments Committee is to ensure that measures are in place to address risks within the Group). For the risk of corruption, a risk-based approach is applied and all suppliers/relevant business relationships are reviewed. In its Performance Management System, Egis provides: - an instruction to carry out the KYC process prior to entering into partnership agreement and contracts. The KYC process aims to improve knowledge of the different parties (clients, financers, partners of all sorts) involved in our projects so as to reinforce the security of our activities in terms of prevention of corruption and combating money laundering. - an instruction to provide general rules including ethic due diligence prior to the conclusion of an external commercial assistance contract

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

In its Performance Management System, Egis provides a procedure relating to its Whistleblowing system made available to compagny's workforce as well as external and occasional staff. The internal whistleblowing system has been implemented at Group level in October 2018. The purpose of this system is to be able to report any conduct or situations that are contrary to the established common rules. It aims to make it easier and more secure for people to report a breach, and ensures the confidentiality of information and the protection of personal data. It consists of : - a procedure that defines the scope of the alerts, their reporting and processing methods, and the measures in place for protection; and - an internet platform accessible to all employees from the My Egis portal (intranet home page) or from the internet link specified in the procedure. The platform was modified in october 2021 (new solution) following a tender 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

Language: The procedure relating to our Whistleblowing system is available under our intranet in French, English, Spanish and Portuguese. The whistleblowing system plateform is accesible from our intranet or a dedicated internet page and available in English, French, Spanish, Portuguese, Polish and Hindi. Non-Employee: In its Partner's Code of Integrity, Egis provides the procedure for a partner to raise the alarm if it becomes aware of a supposed or proven violation of the rules by one of its employees, an Egis employee, a client or another partner.

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

In its Partner's Code of Integrity, Egis provides the procedure for a partner to raise the alarm if it becomes aware of a supposed or proven violation of the rules by one of its employees, an Egis employee, a client or another partner. Our Partner's Code of Integrity is publicly available under our website (https://www.egis-group.com/fr). Still via our website, stakeholders can enter into contact with Egis's services to raise concerns (for example: https://www.egis-group.com/corporate-social-responsibility/contact-us)

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

Our continual improvement loop (internal performance audits, record of and monitors major malfunctions, cause analyses/investigation, mitigation and improvement actions plan) is integrally part of our Performance Management System, which takes account globally and consistently of the requirements of the standards selected with regard to: Quality (ISO 9001), Health and Safety (ISO 45001), Environment (ISO 14001) and Anti-corruption (ISO 37001). Egis has set up an AVANTEAM platform to identify incidents or near misses, analyse them and implement preventive actions to avoid repetition. It is by analysing problems that we can avoid their repetition and the occurrence of much more serious incidents. Egis has implemented a procedure that defines the Group's rules for handling undesirable events and specifies the rules associated with the analysis of causes, in order to improve the performance of our activities.

Executive Pay

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

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 (%)	57
Female (%)	43
Non-binary (%)
it is illegal in France (Egis is a French group) to mention minority or vulnerable groups (this is a discriminatory practice and contrary to the General Data Protection Regulation)
Under 30 years old (%)	0
30-50 years old (%)	43
Above 50 years old (%)	57
From minority or vulnerable groups (%)
it is illegal in France (Egis is a French group) to mention minority or vulnerable groups (this is a discriminatory practice and contrary to the General Data Protection Regulation)
Executive (%)	0
Independent (%)	14

Optional comment

For Executive and Independent : our answers are based on the definitions of the French governance codes

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

Our annual Non-Financial Performance Statement (NFPS) is audited by an accredited independent third party. The veracity of the information contained in the NFPS is attached as an appendix to the report. The scope of works done by the accredited independent third party is performed in accordance with national and international (ISAE 3000) standard and allows to provide a “moderate” level of assurance.

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
2020
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

For several years, Egis is commited to comply with privacy and data protection regulations. In that respect, Egis has implemented a policy of compliance with the General Data Protection Regulation (EU) 2016/679 of 27 April 2016, more commonly known as the GDPR. In 2020, the Group extended this programme to take into account various regulations related to the protection of personal data around the world. In 2018, the Group appointed a group Data Protection Officer who oversees and monitors the implementation of the group compliance programme within all of its controlled subsidiaries, including internationally. The group DPO relies on a dedicated group network and on the teams of the relevant subsidiairies. Egis, as data controller or processor, is highly committed to ensure compliance with the principles set out by the regulations in force for all activities and processing involving personal data. Our privacy policy applies to all data subjects in the world, and for ours subsidiaries located in EU/EEA and where Egis is the principal shareholder. & Our Privacy policy is on our website : https://www.egis-group.com/privacy-policy & Our Ethic code (see page 8) : https://media.umbraco.io/egis/q1dktd1c/sie_e027-gb_charte-de-d%C3%A9ontologie_2022.pdf

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 Privacy policy is on our website : https://www.egis-group.com/privacy-policy & Our Ethic code : https://media.umbraco.io/egis/q1dktd1c/sie_e027-gb_charte-de-d%C3%A9ontologie_2022.pdf (for personnal data protection) & Our Sustainability charter: https://media.umbraco.io/egis/ws4oqqia/2014_egis_sustainability_charter-en.pdf. Our Charter is based on a body of internationally recognised texts: The Universal Declaration of Human Rights, the ILO’s Fundamental Conventions, the OECD’s Guiding Principles, the Ten Principles of the UN’s Global Compact and the voluntary commitments signed by SYNTEC Ingénierie (Federation of engineering professionals) with France’s Ministry for Ecology and Sustainable Development. The charter has been adopted by the Egis Executive Committee.

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

Our data privacy policy applies to all Egis subsidiaries based in EU/EEA and where Egis owns a majority shareholding. This compliance framework applies to all data subjects in the world to ensure the protection of their rights and freedom pursuant to the GDPR. Within the framework of the Egis risk policy and the control of the "information disclosure" risk, an action plan has been prepared to be put in place in 2022: 1-Annual awareness-raising plan for employees on information security 2-Deployment of the Cybersecurity and GDPR clauses in contracts 3-Cyberwatch on internet to detect information leaks originating from the Egis Information System or Egis partners 4-Control and audit of our partners (operational or service providers) 5-A three years cybersecuriyty roadmap for data protection and information security is built according to the risk base approach Each contract with our "Data Processor" must comply with our data protection policy and must include the relevant and appropriate contractual provisions.

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

& A data security training was organised entitled Cyberpass. By the end of 2021 5000 French-speaking learners have been trained & A data protection compliance program has been performed from 2019 to 2021 for all EU/EEA for egis group subsidiaries

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

& Data security training was organised entitled Cyberpass. By the end of 2021 5000 French-speaking learners have been trained & For Direct Suppliers of the organization : All french Information and Communication Technologies department suppliers are part of our french awareness

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

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

Optional comment

For 2021, despite the significant rise in cyber-attacks observed both globally and within our own Information System (IS), our mechanisms designed to protect Egis’ data and that of its clients enabled us to achieve our goal. Egis did not record any disclosure of confidential or sensitive information, or a partial or complete shutdown of our IS.

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.

Digital security / privacy: Within the framework of the Egis risk policy and the control of the "information disclosure" risk, an action plan has been prepared to be put in place in 2022: 1-Annual awareness-raising plan for employees on information security 2-Deployment of the Cybersecurity and GDPR clauses in contracts 3-Cyberwatch on internet to detect information leaks originating from the Egis Information System or Egis partners 4-Control and audit of our partners (operational or service providers) 5-A three years cybersecuriyty roadmap for data protection and information security is built according to the risk base approach

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
2019
Forced labour
2019
Child labour
2019
Non-discrimination in respect of employment and occupation
2019
Occupational safety and health
2021
Working conditions (wages, working hours)

Optional comment

& Egis Human ressources code: https://media.umbraco.io/egis/1zldnhe0/2018_hr_management_code.pdf & Egis code of Ethics: https://media.umbraco.io/egis/q1dktd1c/sie_e027-gb_charte-de-d%C3%A9ontologie_2022.pdf & Egis has signed the Modern Slavery Act in 2021 : https://fr.calameo.com/egis/read/004024910945fb38a5e0f & For the Safety and Health, Egis has general rules for the Group and specific policy per country. the Group has a documented management system for occupational safety and health which applies to all employees. The Guidelines are available and accessible to all employees on the corporate intranet Egis is certified ISO 45001 ; In 2021 about 60% of the Group’s business scope is certified.

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

& Egis Human Ressources code: https://media.umbraco.io/egis/1zldnhe0/2018_hr_management_code.pdf & Egis has signed the Modern Slavery Act in 2021: https://fr.calameo.com/egis/read/004024910945fb38a5e0f & In 2021, about 60% of the Egis group’s business scope is certified ISO 45001.

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

In accordance with the French Act of Parliament No. 2017-399 of 27 March 2017, Egis has implemented a vigilance plan that includes reasonable measures to identify risks and prevent serious violations of human rights and fundamental freedoms, health and safety, and the environment standards. This applies to the activities of the company and its subsidiaries, as well as the activities of its subcontractors or suppliers. Egis' vigilance plan is regularly monitored and assessed by the Operational Risk Committee (ORC), a body chaired by the Group's Chief Executive Officer, and which is responsible for approving the Group's risk mapping and the monitoring of associated action plans. The Group's risk mapping is also validated by the Audit Committee, a sub-committee of the Egis Board of Directors.To continue to ensure compliance with the regulatory requirements affecting the Group, an action plan was implemented in 2019 to anticipate any lack of conformity with regard to new regulations.

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

See additional explanation on above question L2 concerning action plan. As part of our Health and Safety management system (ISO 45001), audits are carried out and corrective action plans are implemented and monitored.

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

Those subjects are dealt within the framework of the managers' training courses (they are not specific training courses in labour rights). The network of human resources directors are available to employees for any questions relating to labor rights . Conferences (in webinar format) are also regularly proposed to all employees on the subjects of non-discrimination, health and safety etc.

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

&For non discrimination in respect of employment and occupation : annual targets for Egis French scope only &For occupational safety and health : annual targets for Egis French scope only

Performance

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

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	26.5

Optional comment

Egis employs around 16,000 people worldwide, including more than 11,000 abroad. In France, the group will have 4,939 employees in 2021, including 4,280 in engineering and 659 in operations. 4267 employees in France are under the Syntec agreement as of 31/12/2021.

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 (%)	7

Optional comment

French scope only.

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

	Percent of women (%)	Unknown
Senior leadership level position	22
Non-executive board	43

Optional comment

& For Senior leadership level position, the above percentage of women represents the one for the Executive Committee (4 women over 18 persons) & For Non-executive board, the above percentage of women represents the one for the Board. (6 women over 14 persons)

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 (%)	2.8

Optional comment

For Egis french scope the Pay gap in 2021 (average weighted by category and age bracket) = 2.8% in favour of men (3.5% in 2020)

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
Egis choose to not disclose because the definition of the frequency rate is not reliable with whole number only allowed by the EarlyAdopters CoP plateform

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

	Incident rate	Unknown	Choose to not disclose
Incident rate
Egis choose to not disclose because the definition of the incidence rate is not reliable with whole number only allowed by the EarlyAdopters CoP plateform

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 the course of the reporting period, the Egis group is not necessarily concerned; nevertheless Egis choose to not communicate on this topic
Forced labour
In the course of the reporting period, the Egis group is not necessarily concerned; nevertheless Egis choose to not communicate on this topic
Child labour
In the course of the reporting period, the Egis group is not necessarily concerned; nevertheless Egis choose to not communicate on this topic
Non-discrimination in respect of employment and occupation
In the course of the reporting period, the Egis group is not necessarily concerned; nevertheless Egis choose to not communicate on this topic
Occupational safety and health
In the course of the reporting period, the Egis group is not necessarily concerned; nevertheless Egis choose to not communicate on this topic
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.

In 2022 a Health and Safety Director has been appointed. A pluri-year roadmap is being validated. A network of correspondents is being deployed across the business lines.

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
2021
Forests / Biodiversity / Land Use
2021
Air Pollution
2021
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2021
Energy & Resource Use
2021

Optional comment

Our environmental policy is driven and supported by our environmental management system (ISO14001) since 2015, enabling us to manage and control our impact on the environment, mitigate risks, and also identify all opportunities. In our Performance Management System, our environmental policy is expressed on three levels: - the management of the environmental impact of projects or our clients’ activities (prevent, reduce, offset); - the management of the impact of our own operations; - the development of solutions and offerings meeting the challenges of the energy and environmental transition. In accordance with our 2021 – 2026 Sustainable Development Objectives and with a view to continual improvement, General Management undertakes in respect of the Environment: - To prevent environmental impacts, to offer eco-design solutions and services in line with the challenges of the energy and ecological transition; - To contribute to carbon neutrality by working on our internal footprint; - To ensure the development of employees’ skills in terms of eco-design and decarbonation. Our environmental commitments encompass all facets of environmental impacts and are approached with a Biosphere/ Water / Climate / Biodiversity systemic vision, as all these issues are interconnected. In view of the climate and ecological emergency, our commitments regarding climate and biodiversity have been clarified and strengthened through: - Five major pledges in favour of the environment made by Egis in 2021 (https://preview.egis-prod.tangentlabs.co.uk/all-news/climate-challenge-new-video-on-our-commitments); - Our multi-year environmental programme entitled climat and biodiversity roadmap for 2021-2025. Our flagship actions focus on the systematic deployment of eco-design and eco-operation, which allow reducing environmental impacts or even improving situations. Another action concerns R&D and innovation focused on the environment, which allows to provide new solutions for the climate, biodiversity, soil, water, ocean and waste management. More information on Egis Non-Financial Performance Statement (NFPS) available under our website / Environmental programm on PP. 24-41: https://preview.egis-prod.tangentlabs.co.uk/corporate-social-responsibility/reporting-for-progress

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

Optional comment

Capacity building: In october 2021, Egis has organised it is first worldwide CSR week, with a focus on its actions in the fight against climate change and biodiversity. The agenda was rich with mini-conferences every day on business aspects according to a pathway where the employees could register for several themes: Adaptation, Carbon neutralization and biodiversity, Eco-design, and Corporate Social Responsability /commitments and actions. Audit and corrective actions plans: As part of our environmental management system (ISO 14001), performance audits are conducted and the necessary corrective action plans are implemented. Collective Action for Climate: In 2019, Egis signed the climate charter of the engineering employers' association "Syntec Ingénierie" (France) and committed to be a source of proposals through the missions and projects that the Group conducts and to adopt low-carbon internal practices. Within this scope, Egis contributed in 2021 to address the need to reinforce the consideration of eco-design and climate issue in engineering. Collective Action for Biodiversity: In 2021, the majority shareholder of Egis is the Caisse des Dépôts. Egis has been a member of the B4B+ club of Caisse des Dépôt for several years as part of Nature 2050, and is actively involved in various working groups for the development of a Biodiversity indicator. During the Nature Day organised by the Caisse des Dépôts group in September 2021, several Egis experts shared the innovative solutions implemented within land development projects to preserve biodiversity and fight against climate change. Collaboration with governmental or regulatory bodies for Climate Action: Egis is an active member of AFNOR (French ISO) Environment and Climate Change (E2C) commission, and has been actively involved in the preparation of the future norm for “Carbon Neutrality” (Future ISO 14068 ; French mirror group for ISO/TC 207/SC 7/WG 15)

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

In its environmental management system, Egis has a procedure which defines the methodology for conducting the environmental analysis of the Group. This analysis includes the compilation of an inventory of environmental aspects (EA), and the ranking of these EA to identify significant environmental aspects (SEA). An action plan is then designed to improve the environmental performance of the Group and reduce its SEA. The non-significant environmental aspects do not have annual target set. However, our action plan to systematic deploy eco-design also contributes to reduce environmental impacts on oceans, water, air and waste generation. Concerning Energy and Resource Use, we have set-up some targets in an internal program relating to the management of our main buildings, IT and vehicules fleet in France.

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	On a worldwide scale, Egis pledges to reduce its greenhouse gas emissions, with ambitious targets aligned with a 1.5% pathway and built according to the SBTi (Science Base Target initiative) framework: • by 30% by 2030, • by 60% by 2040, • by 80% by 2050. The baseline year is 2016. By 2025, 100% of Egis’ projects will include climate adaptation By 2030, 100% of Egis’ projects will be eco-designed or eco-operated. Between 2021 and 2025, doubling R&D investment in climate and biodiversity i.e. up to 22 millions of euros invested
Energy & Resource Use
Water
Forests / Biodiversity / Land Use	By 2030, 100% of Egis’ projects will be eco-designed or eco-operated. Between 2021 and 2025, doubling R&D investment in climate and biodiversity i.e. up to 22 millions of euros invested
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

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

No actual negative impacts nor complaints in 2021 about the above 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

In 2021, Egis has extended its carbon footprint calculation scope to new categories and geographies. For the first time, the emissions generated by commuting and information systems were included in the historical perimeter of the carbon footprint calculation covering the group's subsidiaries headquartered in France. In addition, Egis has included Brazil in the scope of its carbon footprint calculation. The 2021 emissions below cover both extensions of the carbon footprint calculation scope: Scope 1 = 2 775 TCO2 Scope 2 = 767 TCO2 Scope 3 = 11 851 TCO2

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)

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

Unknown

Optional comment

The above-mentioned 6% cover only electricity consumption from renewable source over total electricity consumption for Egis’ premises located in France for 2021. Egis has contracted with a supplier to purchase from September 2021, electricity from renewable source for some of its premises located in France; this supply will be deployed on the majority of its premises in France in 2022. It should be noted that in France, electricity is mainly produced from decarbonised energy (nuclear). In Brazil (country included in Egis group carbon accounting in 2021), electricity is mainly produced from hydroelectricity (the related electricity consumption from renewable source for Brazil is not included in the above percentage).

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)

Egis is not yet required by regulation to publish results regarding the objectives of the European taxonomy. We have started to work on this issue by conducting an initial assessment on the scope of our subsidiaries headquartered in France in order to determine which of our economic activities could be qualified as contributing substantially to the climate change mitigation and adaptation objectives of the European taxonomy. Egis will publish its data in 2023 (fiscal year)

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	0
Groundwater:	0
Surface water:	0
Rainwater:	0
Wastewater:	0
Percentage of water withdrawn in regions with high or extremely high water stress (%)	0

Water consumption (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	0.024
Groundwater:
Surface water:
Rainwater:
Wastewater:
Percentage of water consumed in regions with high or extremely high water stress (%)	0

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)

Egis is an intellectual service group (in construction engineering and mobility services sectors). The water intensity of products is not an indicator that it is monitored in engineering services.

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
SOx
Volatile Organic Compounds (VOC)
Hazardous air pollutants (HAP)
Particulate matter (PM10)
Persistent organic pollutants (POP)
Other (please specify in text box)

Optional comment

Egis is an intellectual service group (in construction engineering and mobility services sectors); Egis is not an industry. The Egis’s internal operations for infrastructure consulting, engineering and operating do not directly require to monitor company's emissions of the above pollutants. However, Egis is monitoring its carbon footprint since 2012 ; please see our results for greenhouse gas emissions for the reporting period in the above E-6 question.

Sector-specific: Waste

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

Waste Generated (t)

252

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 (%)

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)

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.

The actions took by the company during the reporting period are described in our 2021 Non-financial Performance Statement (https://www.egis-group.com/corporate-social-responsibility/reporting-for-progress). However, it can be mentioned: - Commitment: Egis made five major pledges in favour of the environment and has issued its Climat and Biodiversity Roadmap for 2021-2025; - Reduce the greenhouse gas emissions caused by internal operations: Egis has extended its carbon footprint calculation scope, adapted its vehicle fleet and increased the proportion of business trip made by train in metropolitan France. - Reduce the emissions of our clients’ projects, and limit their impact on biodiversity: Egis has committed to deploying eco-design on all projects with reference framework “Act4design” by Egis. Regarding the emissions of our client’s projects, our goal is to provide all the Group's activities with GHG emissions measurement tools to consolidate all the emissions caused and avoided by our design choices. - Increase carbon sequestration: Egis has developped the innovative solution "Smart Soil"

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

Our ethic compliance programme is structured in 6 sections, thus constituting a complete and coherent system, and is inspired by international best practices: 1/ Commitment at the highest executive level ; 2/ Risk analysis ; 3/ Policies and procedures; 4/ Due diligence; 5/ Communication and training; 6/ Monitoring and updating. Our ethic compliance programme is revised annually and our procedures on regular basis. In 2021, Egis decided to submit its anti-corruption programme to the audit process for certification according to the international standard ISO 37001. The certification body Eurocompliance found Egis' anti-corruption management system to be robust and fully compliant with the ISO 37001 standard, and decided to award Egis the ISO 37001 anti-corruption certification at the end of 2021.

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

Our Code of Ethics is the concrete expression of our ethical approach. It reflects our values, defines common rules of behaviour for all employees, and assist them in handling day-to-day situations that arise in their professional lives. Our code of Ethic reminds the basic principle that you should never wrestle with your concerns on your own and recommends to seek advice for from your line manager if you have any doubt concerning the interpretation of the principles in the Code or their application to actual situations. Our Code of Integrity aims to clarify the major rules that Egis has laid down for all issues of integrity and business ethics, it is a continuation of the Code of Ethics on this topic. Procedures for each subject then outline rules to be followed and the responsibilities of the various stakeholders. & Code of Ethics: https://media.umbraco.io/egis/q1dktd1c/sie_e027-gb_charte-de-d%C3%A9ontologie_2022.pdf & Code of integrity: https://media.umbraco.io/egis/biglr344/sie_e027-gb_code-d-int%C3%A9grit%C3%A9-egis-2022.pdf

Prevention

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

Optional comment

Our ethics and compliance training programme includes in-person training dedicated to exposed employees and e-learning for all employees. An instruction has been established in 2021 to outline the principles for identifying the target population for training and awareness actions in the area of ethics and compliance, organising and renewing such actions, and monitoring and managing their implementation amongst employees.

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

Refreshment is provided in both cases of our ethics and compliance training programme. In-person training: The Group provides initial in-person training to a target population designated by each entity. Based on the principle of subsidiarity, each entity provides refresher training on specific topics and to target groups designated according to identified needs. The minimum number of awareness sessions organised by each entity is 1 session per year. E-learning : All Egis employees are required to participate in e-learning course on ethics and compliance. Group HRD organises campaigns every year.

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

Optional comment

Ethical audits and controls are regularly carried out in the Group's various subsidiaries to ensure that Egis' ethical principles are correctly applied. This control action is part of a continuous improvement aimed at consolidating the effectiveness of the Ethics approach. In 2021, Egis decided to submit its anti-corruption programme to the audit process for certification according to the international standard ISO 37001. The certification body Eurocompliance found Egis' anti-corruption management system to be robust and fully compliant with the ISO 37001 standard, and decided to award Egis the ISO 37001 anti-corruption certification at the end of 2021. As part of the ISO 37001 certification process, annual monitoring audits are conducted by the certification body.

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
Our company is publicly reporting in its Non-Financial Performance Statement on the total number of alerts received every year in its whistleblowing system. However, we do not publicly report nor disclose externally the number and nature of the incidents.
Confirmed during the current year, and related to this year
Our company is publicly reporting in its Non-Financial Performance Statement on the total number of alerts received every year in its whistleblowing system. However, we do not publicly report nor disclose externally the number and nature of the incidents.

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

According to Egis procedure on whistleblowing system, all alerts declared as valid are registered as incidents in the incident database. They are handled as any valid alert and checks and investigations are conducted by the Processing manager in charge of the treament of alerts for the matter concerned.

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 2021, Egis decided to submit its anti-corruption programme to the audit process for certification according to the international standard ISO 37001. The certification body Eurocompliance found Egis' anti-corruption management system to be robust and fully compliant with the ISO 37001 standard, and decided to award Egis the ISO 37001 anti-corruption certification at the end of 2021.