Group Whistleblowing
PolicyFirst publication: February 2016

Current publication: January 2023

Version:5

Document type

: Policy

Scope: GlobalInternal

Policy name: Group Whistleblowing Policy
Purpose:- Explain how employees, interns and contractors, and external stakeholders of Schneider Electric can report concerns
about suspected misconduct in confidence and without fear of retaliation;- Describe what employees, interns and contractors, and external stakeholders of Schneider Electric can expect if theyreport such a concern.
Legal framework: As Schneider Electric is a French group, this policy complies with the principles of the European
Directive on Whistleblower's protection1 and requirements set out by French law2. All entities and subsidiaries controlled
by Schneider Electric must comply with this policy regardless of where they are established or operate from, except toensure compliance with local law and regulations. In such circumstances, adaptations of the policy will be made by therelevant Regional Compliance Officer with legal support; in cases when local adaptations are necessary, the final local
policies will be validated by the Chief Compliance Officer.
Related documents:-

Trust Charter;
Case Management & Investigation Policy;
Internal Investigation Guide;
Data Privacy notice available on our Trust Line page.

Audience: All employees, interns and contractors, and external stakeholders of Schneider Electric and its subsidiaries
Content:
1.
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3.
4.
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6.
7.
8.

Definitions
What is Whistleblowing?
Who can report a Concern?
What Concerns can be reported?
How and when to report?
What happens after a report?
Rights and responsibilities of people involved
In case of doubt

Confidentiality Status: Public
Local adaptation authorization: Possible to ensure compliance with local law and regulations. Local adaptations, whenneeded, listed by country in Appendix 4.
Document Owner: Audrey Morin, Group Compliance Director
Document Reviewers:
Pascale Gelly, Group Data Protection Officer
Sandrine Reinneis, Group HR Compliance Officer
Pierre Lormeau, Fraud Examination Director
Peter Wexler, SVP Group Chief Legal Officer
Pierre Levêque, SVP Group Internal Audit & Control
Nicolas Vlieghe, SVP Group Chief Compliance Officer
Karine Armand-Fedida, SVP Total Rewards & Performance
Document Approver: Hervé Coureil, EVP Chief Governance Officer and General Secretary

1 Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 20192 Law No. 2016-1691 of 9 December 2016, modified by Law No. 2022-401 of 22 March 2022, and Law no. 2017-399 of 27 March 2017

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1. Definitions
Concern – Allegation made by a Reporter about a conduct.
Alert – Concern assessed as a potential Misconduct resulting from the activities of Schneider Electric andits subsidiaries, as well as the activities of subcontractors and third parties with whom Schneider Electric
maintains a business relationship.
Non-Alert – Concern not assessed as a potential Misconduct resulting from the activities of Schneider
Electric and its subsidiaries, as well as the activities of subcontractors and third parties with whom
Schneider Electric maintains a business relationship.
Misconduct – Violation of laws and regulations, and/or our Trust Charter and group policies.
Reporter (or “Whistleblower”) – Anyone who wishes to report a Concern in good faith about a potential
Misconduct.
Reported Person – Person identified by a Reporter as having committed a potential Misconduct.

2. What is Whistleblowing?
Whistleblowing corresponds to all methods of reporting available to employees, interns or contractors,
and external stakeholders to report on a voluntary basis a potential Misconduct.
As a worldwide company, Schneider Electric (the Company) is committed to conduct business with integrity,
by upholding strong ethical values. That is why this Policy aims to encourage employees and others
stakeholders who have ethical concerns to come forward and voice those concerns. Indeed, employees,
interns or contractors, and external stakeholders are often the first to realize when there might be something
seriously wrong. Whistleblowing is viewed by Schneider Electric as a positive act that can make a valuable
contribution to the Company’s efficiency and long-term success.

3. Who can report a Concern?
The Reporter may be any individual who wishes to report a Concern in good faith. He/she can thus be:ooInternal: employees, interns and contractors working for the Company or one of its subsidiaries;
External: anyone in relations with the Company such as third parties (e.g. supplier, customer,
client/distributor representative, consultant, former or prospective employees, shareholders) or who
are impacted by the Company’s activities such as representatives of local communities and nongovernmental organizations.

Good faith - Malicious allegations
It is expected good faith from Reporter's end when reporting Concerns, i.e. he/she must have thereasonable belief that the facts are true to the best of his/her knowledge at the time he/she reports
them.

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3InternalAny Concern will be handled with particular care to identify or avoid any malicious or bad faithreporting. Appropriate disciplinary action could be taken in accordance with the local disciplinary
procedure against any person who is found to have raised a Concern in bad faith or by intentionallyproviding false information.
No sanction will be taken against any person who has reported a Concern in good faith, regardlessthe investigation outcome, and to the best of their knowledge at the time of reporting.

4. What Concerns can be reported?
The Reporter can report a Concern about potential Misconduct, i.e. a suspected violation of:ooLaws and regulations; or
Our Trust Charter and group policies.

Such suspected violation may result from the activities of the Company and its subsidiaries, as well as theactivities of subcontractors and third parties with whom the Company maintains a business relationship. A
Concern assessed as a suspected Misconduct will be qualified as an Alert.
An Alert is categorized as follows:oooFraud & Business Misconduct: Antitrust and non-competitive behavior, Asset misappropriation,
Bribery & Corruption, Conflicts of Interests, Fraudulent statement, Insider trading and violationof securities law, Money laundering, Sanctions & Export Controls;
HR & Workplace Violation: Discrimination, Disrespectful behavior, Harassment, Health & Safety,
Sexual harassment, Unfair treatment, Violation of human rights, Violation of labor laws, Violent
behavior;
Other Misconduct: Grey Market, Environmental issues, Quality issue, Other.

The definition of each type of issue can be found in Appendix 3.
IMPORTANT: The Reporter cannot mention information in his/her report covered by (i) national defense
secrecy, (ii) medical confidentiality, (iii) legal privilege (iv) confidentiality linked to prosecutions, (v) secrecyof legal proceedings and (vi) judicial deliberations secrecy.

5. How and when to report?
5.1. What are the reporting channels?
Reporters may report Concerns about potential Misconduct through a variety of channels, either bycontacting an appropriate person in the Company and/or using the Trust Line, Schneider Electric’s
whistleblowing system:oAppropriate persons:
The Reporter may contact in writing or orally:

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A HR Business Partner;
A Legal Counsel;
A Regional Compliance Officer.

If the recipient of the Concern assesses it as an Alert as defined in section 4, he/she must ensure
the case is reported in the Trust Line, either by advising the Reporter to report directly or by doing
it him/herself or by escalating to the Regional Compliance Officer. In case the recipient intentionally
does not report the Concern, this may be considered a severe omission and/or, potentially, as aform of retaliation, which may lead to disciplinary action against the recipient. For more information,refer to the Case Management & Investigation Policy.
IMPORTANT: The Reporter has a choice to request a meeting with an appropriate person to reportorally through face-to-face meeting, telephone or any other voicemail system (e.g. Teams). The
appropriate person will have to meet the reporter within 20 working days after receipt of the request.
WARNING! When there is an emergency (such as an immediate threat to life or property), theReporter should directly contact the relevant Regional Security Officer, Compliance Officer, Safety
Officer, or local authorities.
oTrust Line:The Reporter may use Trust Line, Schneider Electric’s whistleblowing system, which is available:- online: https://www.se.com/ww/en/about-us/sustainability/responsibility-ethics/trustline/- or by phone: phone numbers available on https://www.se.com/ww/en/aboutus/sustainability/responsibility-ethics/trustline/ and on posters displayed on the Company’ssites.
It is a digital platform, available 24 hour a day, 7 days a week, managed by an independent thirdparty company. Reports can be done in the local and/or official language where Schneider Electrichas business. This is a confidential and encrypted reporting channel. When accepted by local
legislation, the Reporter can choose to report in a totally anonymous manner. Anonymity is fully
respected by the set-up of Trust Line, which prevents knowing the identity of the Reporter.

Reports received outside of Trust Line and appropriate persons
No other internal reporting channel exists in Schneider Electric, except the ones recognized in local
laws (e.g. employees’ representatives). All Concerns about potential Misconduct received by any
employee outside of the Trust Line and appropriate persons must be immediately forwarded to the
Regional Compliance Officer for assessment and potential investigation.

Ethics Delegates
The Company has appointed Ethics Delegates as a further point of contact for employees, interns
and contractors to help them with any questions about Trust Charter, Compliance Policies and about
on how to report a Concern, including how to use of the Trust Line.
Please click here for the contact details of Ethics Delegates.

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5.2. What kind of information needs to be provided?
When a Reporter reports a Concern about a potential Misconduct, he/she should provide at least a
description of the situation at stake (date, time, location, general nature of the Concern, names of
person(s) involved, etc.) and, if possible, any additional relevant information (names of possible
witnesses, documents, etc.) to facilitate the assessment of his/her Concern. A reported Concern can be
managed more efficiently if it contains sufficient factual information and clear access to further data forassessment and/or investigation purpose.

Is it possible to report a Concern when all the facts are not known?
If someone is aware of a potential Misconduct and acts in good faith (see section 3), he/she shouldreport it with the facts that he/she is aware of. It is not expected from the Reporter to know all theinformation at stake, and he/she does not have to prove that the Concern is a founded Alert, as it is
up to the Company to do so.
People should not investigate the matter themselves and seek evidence. The Company guarantees
that no disciplinary measures or other steps will be taken against a Reporter if his/her reporting
Concern later turns out to be mistaken or misguided.

6. What happens after a Concern is reported?
Any reported Concern will be managed according to the Case Management & Investigation Policy. The
Case Manager and investigator(s) are bound by the following principles from assessment of the case toclosing of it: neutrality, impartiality, independency.

6.1. Step 1: Reception
All reported Concerns are logged into the Trust Line, our whistleblowing system. Access to the cases
reported into the Trust Line is restricted to a limited Compliance audience: the relevant Regional
Compliance Officer, the members of the Group Operational Compliance Committee and the Complianceadministrators of the Trust Line tool.

Group Operational Compliance Committee
The Group Operational Compliance Committee is Schneider Electric’s internal authority in chargeof detecting and supervising cases of non-compliance with the Ethics & Compliance program, andof reviewing monthly the effectiveness of the whistleblowing system.
It is composed of the following members: Chief Compliance Officer (Committee Secretary), Chief
Legal Officer, Group Internal Audit & Control Officer, Group Compliance Director, Group HR
Compliance Officer, and Head of Fraud Examination Team.

The Company takes every reported Concern of potential Misconduct seriously. Whether the Concern isreported orally or in writing, the Reporter will receive a written acknowledgement of receipt within 24 hours.

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When the Reporter chooses to report a Concern anonymously, he/she will be given access to an
anonymous messaging platform through the Trust Line tool. All interactions and information sharing willtake place on this platform; without the Reporter's credentials ever being asked or disclosed.

6.2. Step 2: Initial Assessment
The Concern will be assessed by the relevant Regional Compliance Officer, who will confirm thequalification of the Concern as an Alert or not and notify the Reporter accordingly with justifications. If theConcern is qualified as a valid Alert, it will be appropriately investigated. If the Concern is not qualified as avalid Alert, the Concern will be closed, the Reporter will be informed in writing and, if necessary, referredto the relevant organization likely to help him/her.

6.3. Step 3: Investigation of a valid Alert
The Alert is managed by a Case Manager who can be, depending on the nature, urgency and potential
impact of the Concern: the relevant Regional Compliance Officer who works under the supervision of theGroup Operational Compliance Committee, or directly by the Group Operational Compliance Committee incase of high severity (severity criteria defined by the Case Management & Investigation policy).

The Case Manager can lead the investigation or assign an investigation team, at discretion and after criticalevaluation, composed of people trained in conducting internal investigations. If needed, any external orinternal experts (e.g. lawyers or accountants) can be mandated to support the investigation. All investigatorsand supports work under strict confidentiality. To secure safe, respectful and inclusive collaboration, theCase Manager may also propose intervention of an internal or external mediator to help rebuild respectful
collaboration.

WARNING! No one beside the nominated investigation team is entitled to conduct investigation, interferewith an investigation, nor to gather any evidence or supporting documents related to the Concern if notentitled to do so.

6.4. Step 4: Post-Investigation
Once its investigation is complete, the investigation team will submit an investigation report, possibly
including recommendations, to the Case Manager. If an Alert is founded (i.e. Misconduct is confirmed), theCase Manager may take steps to ensure that appropriate measures may apply depending on local
disciplinary policies and law. They can take the form of:oodisciplinary measures decided by the relevant managers together with Human Resources, or by
the Group Disciplinary Committee for the most sensitive alerts;
remediation measures (such as launch a specific audit, review a process, perform training, etc.).

In addition, external actions can be taken, such as entering civil litigation or similar legal proceedings.

At discretion and after critical evaluation, the Case Manager can appoint people for next steps following theclosing of the case, such as the monitoring of the proper execution of the measures decided.

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Group Disciplinary Committee
The Group Disciplinary Committee is in charge of levying sanctions and remediation actions onserious non-compliance cases confirmed by the Group Operational Compliance Committee.
It is composed of the following members: Chief Governance Officer & Secretary General, Chief
Human Resources Officer, Chief Compliance Officer (Committee Secretary), Chief Legal Officer,
and one rotating member.

7. Rights and responsibilities of people involved
7.1. Rights & Responsibilities of the Reporter
Anonymity
When reporting a Concern into the Trust Line, the Reporter may choose to do so anonymously, except incountries where it is not possible because of local regulations. The Reporter will then be able tocommunicate with the Case Manager and/or appointed investigator(s) through an anonymous messaging
platform available in the Trust Line tool. It is a secure channel protecting anonymity when parties exchange
on a Concern.

Confidentiality
The identity of the Reporter is kept confidential and may only be accessible to the restricted list of persons
involved in the case management (subject to obligations arising from the law or the applicable legal
proceedings): the relevant Regional Compliance Officer, the members of the Group Operational
Compliance Committee, the Compliance administrators of the Trust Line tool, the appointed investigator(s),and any external or internal person mandated to support the investigation or next steps following the closingof the case. No one else must be informed.
The identity of the Reporter must be kept confidential at any circumstances (regardless of the job positionor seniority in the Company) and, if necessary for the investigation to inform another person, the CaseManager should be consulted and approve. An unauthorized disclosure may lead to disciplinary actions.
In all cases, the identity of the Reporter will not be provided to the Reported Person, unless expressly
agreed by the Reporter or required by law or in the framework of legal proceedings.

Good faith
It is expected good faith from Reporter's end when reporting Concerns, i.e. he/she must have thereasonable belief that the facts are true to the best of his/her knowledge at the time he/she reports them.
For more information, refer to section 3.

Non-retaliation
Schneider Electric has a zero-tolerance policy against retaliation, therefore prohibits retaliation or otherdiscrimination against anyone who reports in good faith. Protection applies even if the alleged violation is
unfounded after investigation is closed.
The Non-Retaliation Procedure is detailed in Appendix 2.

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Right to information
The Reporter will be regularly informed – no later than 3 months after the acknowledgment of receipt of theConcern – about the outcome of the assessment and, if any, the progress of the Alert management. The
Reporter is informed in writing when the Alert is closed. However, for reasons of confidentiality, privacy andthe legal rights of persons involved, full details of the investigation and outcome may not be shared with theReporter.

Protection & CareIn the course of the investigation, specific measures can be offered to the Reporter, in case he/she needs
and as per local legislation, such as:
•
•
•
•
•
•

Security measures (distancing)Accommodations
Flexible Time management
Change of function/service
Mediation
Psychological support

Privacy
The Company is committed to protecting the privacy of the Reporter. It implements organizational andtechnical measures in order to protect personal information from unauthorized access and processing. Any
personal information obtained in the framework of this Whistleblowing Policy will only be used for the
purposes explained in this Policy or to comply with the law. Please find more details on the protection of
personal information in Annex 1.

7.2. Rights & Responsibilities of the Reported Person, witnesses
and all third parties mentioned in the report
Confidentiality
All persons involved are entitled to confidentiality in order to avoid unnecessary damage to their reputation.
Therefore, the identity of the Reported Person, the facts reported, and the subsequent investigation andfindings are kept confidential and limited to the strict necessity of the management of the Concern (subject
to obligations arising from the law or the applicable legal proceedings).
Information shared must be kept confidential at any circumstances (regardless of the job position orseniority in the Company) and, if necessary for the investigation to inform another person, the CaseManager should be consulted and approve. An unauthorized disclosure may lead to disciplinary actions.

Cooperation
If a Schneider Electric employee becomes involved in an investigation, he/she must cooperate in good faithand answer all questions completely and honestly. Lying to the people performing the investigation as well
as delaying, interfering with or refusing to cooperate with an investigation may lead to disciplinary measures.
In addition, it is strictly forbidden to willfully destroy documents, tamper with information, interfere with or
threaten witnesses, intentionally mislead investigators, or block an investigation in any way.
WARNING! People external to Schneider Electric involved in the investigation (including, but not limited toformer Schneider employees) are not obliged to cooperate with an internal investigation. It is voluntary andentirely at their discretion.

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Non-retaliation
The non-retaliation protection mentioned in section 7.1. about the rights of the Reporter is also extended to
the following persons:••••"Facilitators", i.e. anyone who helped the Reporter in the reporting process (e.g. obtaining theinformation, evidence, etc.);
Investigation cooperators (e.g. witnesses);
People connected with the Reporter and who could suffer retaliation in a work-related context (inparticular co-workers);
Legal entities that the Reporter owns, works for or is otherwise connected in a work-related context.

Protection applies even if the alleged violation is unfounded after investigation is closed.

Right to information
All persons involved in an investigation have the right to know the reasons for their involvement in theinvestigation and the investigation process. Depending on the needs of the investigation, they are kept
regularly informed of its progress.

Presumption of Innocence
The presumption of innocence is guaranteed. Any individual involved and/or suspected of a potential
Misconduct cannot be considered to have committed such a Misconduct until it has been establishedotherwise by investigation. Nevertheless, in case of founded Misconduct with regards to Trust Charter andgroup policies, an employee can be subject to disciplinary measures (up to termination) as per his/her
employment contract and related duties, in respect with local labor laws and regulations.

Protection & CareIn the course of the investigation, specific measures can be offered to the Reported Person and witnesses,
in case they need and as per local legislation, such as:
•
•
•
•
•
•

Security measures (distancing)Accommodations
Flexible Time management
Change of function/service
Mediation
Psychological support

Privacy
The Company is committed to protecting the privacy of everyone involved. It implements organizational andtechnical measures in order to protect personal information from unauthorized access and processing. Any
personal information obtained in the framework of this Whistleblowing Policy will only be used for the
purposes explained in this Policy or to comply with the law. Please find more details on the protection of
personal information in Annex 1.

8. In case of doubt
If in doubt about any aspect of this Policy, employees should seek advice from their line manager, HR
Business Partner or Ethics Delegate or contact their Regional Compliance Officer. Their contact
information is available on Schneider’s Ethics & Compliance intranet page.
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Annex 1: Protection of Personal Information
The handling of Concerns and Alerts involves the processing of personal information as described in this Group Whistleblowing Policy.
To enable the raising of Concerns in confidence, an online platform is provided by a third party on behalf of Schneider Elect ric, using
such degree of care as is appropriate to prevent risks of unauthorized access, use or disclosure. It is implemented by Schneider ElectricIndustries SAS and its affiliates to comply with a legal obligation and to pursue the legitimate interest of the group in order to ensure atrust environment within the group, maintain the reputation of the group and ensure a consistent approach in dealing with reports acrossthe group. Information may also be processed for statistical purposes in order to further improve the platform and the manage ment ofconcerns reported, in the legitimate interest group.

Categories of processed personal information
The following data are collected to manage and investigate Alerts:- Identity, job position and contact details of the person issuing a Concern;- Identity, job position and contact details of the person(s) against whom the Concern is issued;- Identity, job position and contact details of the persons involved in collecting or processing the Concern;- Reported facts;- Information collected as a result of investigation;- Investigation reports;- Action(s) taken in response to the Alert.
Sharing of personal information
Concerns and Alerts are managed as described in this Policy. Schneider Electric being a global company, teams involved in the processing
may have global or multi-country roles. These teams and our suppliers can be located anywhere where Schneider Electric operates. In suchcases, we take measures to ensure that your personal information receives an adequate level of protection, which include Standard
Contractual Clauses and our Binding Corporate Rules.
Personal information may be disclosed to the police and/or other enforcement or regulatory authorities. For example, if the alleged facts are
related to a criminal prosecution, or in the context of a control carried out by public authorities.
Privacy Rights
The Reporter, the Reported Person and any person involved in the Alert have a right of access to their personal information and rightsof rectification,
deletion, restriction to the processing of personal information which can be exercised by contacting
group.compliance.team@schneider-electric.com.
Questions or comments about Schneider Electric data processing activities under the Group Whistleblowing Policy can be addressed
to our Group Data Protection Officer (Group DPO) at DPO@schneider-electric.com. A person believing that personal information has
been processed in violation of applicable law may file a complaint with the Group DPO or with a supervisory authority.
Data retention
In case of Concerns not validated as Alerts, the Group Operational Compliance Committee or Regio nal Compliance Officers mustwithout undue delay delete them or anonymize them by deleting any personal information if they need to keep Concerns for statistic purpose.
If after investigation, alleged Misconduct is unfounded, the Alert must be anonymized within two months following the closure of theinvestigation.
If after investigation, alleged Misconduct is founded but there is no disciplinary action neither legal proceeding initiated, the Alert must
be anonymized within two months after the closing of any remediation actions decided.
If after investigation, alleged Misconduct is founded and there is disciplinary action and/or legal proceeding initiated, the Alert must be
anonymized after all rights of appeal have been exhausted or following the final court decision.
The Group Operational Compliance Committee and Regional Compliance Officers are responsible to ensure compliance with the rul es
above. They may decide to archive an alert instead of anonymize it for the following reasons: (i) to comply with applicable l egal
requirements, (ii) to protect the Reporter from retaliation until the risk is properly handled, or (iii) to ensure that findings of theinvestigation are available for request by public authorities. Access to the archived Alert will be subject to prior v alidation by the GroupOperational Compliance Committee. It will have to be justified by (i) one of the grounds for archiving the personal informati on, (ii) a
request by an individual on the basis of personal data protection rights, or (iii) an existing or potential legal action initiated by or against
Schneider Electric.

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Annex 2: Non-Retaliation Procedure
1. Risk identification
When receiving a Concern, the relevant Regional Compliance Officer shall analyze if there is any retaliation
risk. If this is the case, he/she may decide specific risk management and/or care measures.
During the investigation and after the case is closed, a Reporter, a victim or any other person protectedagainst retaliation (as explained in section 7.2) who feels or is afraid to be retaliated against can report thesituation through the Trust Line or directly by informing the Regional Compliance Officer.
2. Risk management
When the retaliation risk is confirmed, specific protection measures may be proposed by the Regional
Compliance Officer with the relevant management and Human Resources, subject to the person’s consent,such as:otemporary or permanent reassignment (e.g. work from home);ochange in reporting line;oplacement on special leave with full pay;oengagement with the manager or Human Resources Business Partner to ensure monitoring of theworkplace situation;orescission of the retaliatory decision, including reinstatement;otransfer of the person who allegedly is engaged in retaliation (subject to local regulations and internal
rules).

In addition, a follow-up by the Regional Compliance Officer or the Group Operational Compliance Committee
will be performed after 6 months of the closing of the investigation in order to make sure that recommended
actions have been applied and there has been no retaliation (see Case Management & Investigation Policy).
Employees who carried out retaliation may be subject to disciplinary actions, including employment
termination.

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Annex 3: Definitions of Alert Types
FRAUD & BUSINESS MISCONDUCTAntitrust and noncompetitive behavior

Practice that prevents or reduces competition in a market.
Asset misappropriation schemes include both the theft of company assets, such as cash orinventory, and the misuse of company assets, as follows:- Theft of assets: it is any stealing or misuse of Schneider Electric’s tangible or intangible(proprietary data, patents, etc.) assets without permission.

Assetmisappropriation- Fraudulent disbursements: When an employee uses his position of employment to cause apayment for some inappropriate purpose. The perpetrator has taken money from his employer
in such a way that it appears to be a normal disbursement of cash, as follows, but not limitedto:• Billing schemes: For example, when an employee divert cash through overbilling thecompany in collusion with a vendor or through payment of products or services not delivered or
not rendered by the vendor,• Payroll schemes: For example, when disbursements are made as payments of wages toghost employees, or through falsified working hours or timecards for workers,• Expense reimbursement schemes: An employee submits falsified expense claims as togenerate fraudulent disbursements.
- Embezzlement is the fraudulent misappropriation of goods of another by a person to whom it
has been lawfully entrusted or to whom lawful possession was given. If a plant manager
diverts cash through a billing scheme it will be considered as an embezzlement. If a worke rsteals product from the stock it will be considered as a theft.

Bribery & Corruption

Abuse of entrusted power for private gain and it can take many forms, including bribery.
Bribery can be defined as the offering, promising, giving, accepting or soliciting of anadvantage as an inducement for an action which is illegal, unethical or a breach of trust.
Inducements can take the form of gifts, loans, fees, rewards or other advantages (taxes,
services, donations, favors, etc.).

Conflicts of Interests

It is when an employee's personal interests’ conflict with those of Schneider Electric. In otherwords, it is the situation in which the personal interests of an employee are likely to affect his
decision in the performance of his professional duties.
It includes favoritism, which is a practice of giving unfair preferential treatment to one person
or group at the expense of another.
Fraudulent statement schemes are intentional false statement or misrepresentation of the facts
made with the intent to deceive another party, as follows:

Fraudulent statement- Financial statement fraud: It is the deliberate misrepresentation of financial conditions andoperating results of an enterprise or entity including concealment of liabilities and omission of
disclosures. It can be a way to deceive financial statement users, particularly investors andcreditors as to increase stock value or obtain, for example, more favorable financing
conditions. The outcome of financial processes are the financial statements which i nclude thebalance sheet, the statement of income (P&L statement), statement of cash flow, etc. plus theaccompanying explanation notes and disclosures.
In addition, it may be deliberate misstatement or omission of amounts or disclosure of financial
statements to deceive financial statement users, particularly investors and creditors.
- Accounting fraud/manipulation: Intentional misrepresentation or alteration of journal entries
and accounting records regarding sales, revenues, expenses, assets or liabilities for example.
When the amounts manipulated are small there may be no impact on the financial statements.
• It may be a way for local management to reach the objectives and get better incentives,• It is also a way to conceal a fraud scheme such as a fraudulent disbursement or a theft of
products from the inventory.
- Falsification of document: Act of intentionally changing or modifying information on a
document with the intention of misleading company's stakeholders, authorities or regulato ry
bodies.

Insider trading
and violationof securities law

Practice in which securities or trading laws have been violated, including insider trading.
Insider trading can be defined as practice of purchasing or selling a publicly traded company’s
securities while in possession of material information that is not yet public information. Material
information refers to any and all information that may result in a substantial impact on thedecision of an investor regarding whether to buy or sell the security.

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Process by which criminal proceeds are "cleaned" so that their illegal origins are hidden. It is
usually associated with the types of organized crime that generate huge profits in cash, suchas fraud.

Sanctions& Export Controls

Laws and regulations published by various regimes that are intended to protect and enforce
national security, foreign policy and local country economic interests. Behaviors, transactions,and business dealings are subject to Sanctions and Export Control Regulations. Failure toabide by local country regulations may result in restriction or suspension of economic orcommercial relations (or other areas) with a particular country or groups of individuals andentities imposed by law, or regulations relating to the shipment or transfer, by whatevermeans, of items, software, technology, or services out of a territory.

HR & WORKPLACE VIOLATION

Discrimination

Any behavior or decision that involves treating someone unfavorably because of a personal
characteristic which can include (but not limited to):• a disability or temporary disability• a disease or injury• parental status• skin color, descent, national origin, or ethnic background• generation• sex, including pregnancy, childbirth, or related medical conditions• gender or gender identity• membership to an industrial organization, like a trade union• religion• nationality, immigration status, citizenship, or ancestry• sexual orientation• marital status• political opinion• socio-economic background• medical record

Harassment

Any offensive, inappropriate, unwelcomed, or even inadvertent behaviors at the workplace,that has the effect of violating a person’s dignity or creating a degrading, humiliating or
offensive/hostile work environment.

Health & Safety

Any practice that does not ensure that a safe and free environment at work is maintained at all
times. It relates to both your physical health and your mental health.

Sexual harassment

Any unwelcomed sexual conduct (physical, visual, verbal or written) which affects an
individual’s dignity and creates an intimidating, hostile or uncomfortable working environment.

Violationof human rights

Behavior that endangers the basic rights and freedoms that belong to every person in theworld, from birth until death. The Universal Declaration of Human Rights, adopted by theUnited Nations on 10 December 1948, sets out the basic rights and freedoms that apply to all
people. For discrimination or any type of harassment, use specific issue.

Violation of labor laws

Actions by employers that violate labor laws.

OTHER MISCONDUCTGrey Market

Genuine, branded products sold through unauthorized distribution channels or imported intoanother country for sale without the consent and knowledge of the brand owner.

Environmental issues

Issue or behavior that can generate possible harmful effects to natural systems (on small orlarge geographical areas), including water bodies, soils, air quality, biodiversity, climate, or
generate an increased risk of natural disaster (flood, land slide, etc.). Environmental issues
can lead to human health risks, reputational risks, fraud risks, financial loss and/or litigation. In
addition to occasional events, environment issues should be reported if there is possibility ofwidespread occurrence across many Schneider Electric locations.

Quality issue

Intentional breach of quality policies, directives and procedures in order to obtain a personal
gain or a benefit for the Company, at the expense of lower product quality, additional risks ofmalfunction and customer impact

Other

Any other misconduct not listed and defined above.

Annex 4: Local Adaptations
https://schneiderelectric.sharepoint.com/:w:/s/responsibilityethicsdynamicsprogramme/EeETzyy_MKxAuq
YW36TkoB0ByB11L7H-sRZY189xypcuMA?e=H2VOOn
Group Whistleblowing Policy

14Internal