Table of contents
Company Information
3. WIN Programme - A Commitment to Integrity and Ethical Business
At Schréder, integrity is one of our core values, guiding the way we operate and work with our stakeholders. The WIN (Worldwide Integrity) programme embodies this commitment and serves as a comprehensive compliance initiative to ensure that our business practices are transparent, responsible and in line with international ethical standards. More than just a regulatory framework, the WIN programme fosters a culture where ethical behaviour is expected at every level. By integrating clear policies, targeted training and strong monitoring mechanisms, we proactively identify, prevent and address ethical risks, strengthening trust with our employees, customers and partners. Updated in 2024 to increase its impact, the WIN programme follows a risk-based approach to effectively assess and mitigate compliance risks. Focus areas include: Anti-Corruption & Anti-Bribery Competition Law WIN Line & Investigations Corporate Governance Trade Restrictions & Export Controls Today, companies are looking for partners who meet the highest ethical standards. The WIN programme ensures that when customers choose Schréder, they are working with a company that values: Anti-corruption and anti-bribery measures, reducing risks in business relationships; Fair competition, ensuring compliance with international regulations;
Whistleblowing mechanisms, enabling early detection and response to misconduct; Strong corporate governance, guaranteeing stability and long-term reliability; Responsible trade practices, adhering to global trade restrictions and export controls. WIN Steering Committee In the fourth quarter of 2024, Schréder established a Steering Committee (SteerCo) for the WIN Programme to enhance strategic oversight and ensure alignment with Schréder’s compliance objectives. The SteerCo, consisting of the Chief Executive Officer, Chief Legal Officer, Chief People Officer, Chief Financial Officer and Chief Innovation, Technology and Operations Officer, will meet quarterly from early 2025 to provide guidance, oversight and alignment with Schréder’s corporate strategy. The head of the WIN programme will report to the SteerCo, ensuring regular updates on key compliance initiatives, risks and progress. This initiative reinforces Schréder’s commitment to strong corporate governance, ethical business practices and continuous improvement in compliance management. Code of Conduct and Policies To reinforce our commitment to integrity, we implemented a new Code of Conduct in 2022, designed to promote ethical behaviour, transparency, and accountability at all levels of the organisation. This key document sets out clear guidelines for ethical conduct, reflecting Schréder’s core values and how we uphold them in the workplace, business and community. The Code of Conduct is available in 15 languages
and has been formally adopted by our subsidiaries and acknowledged by Schréder employees worldwide. To support this framework, Schréder has also established policies and procedures under the WIN Programme to strengthen internal governance. In addition, the Delegation of Authority and Signatory Sheet define a structured authorisation framework, ensuring that employees act within clear and responsible boundaries on behalf of the Schréder Group. In 2024, the introductory section of the Code of Conduct was updated to reflect the appointment of Philippe Felten as Schréder’s new CEO, succeeding Werner De Wolf, while the core ethical principles remained unchanged. To further reinforce our commitment to integrity, a new acknowledgement process was introduced in the fourth quarter of 2024, requiring all employees and intermediaries acting on behalf of Schréder to formally reaffirm their commitment to the Code every two years, starting in 2025. This initiative ensures continued awareness and strengthens compliance with our ethical standards. By continuously improving our governance and ethics framework, we reaffirm our commitment to integrity, trust and responsible business practices, fostering ethical, transparent and secure partnerships for our customers and stakeholders. Fair Competition At Schréder, fair and open competition is not just a legal obligation - it is a core principle of how we do business responsibly and sustainably. A competitive market fosters innovation, drives continuous improvement and ensures that customers receive the best possible value.
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