SCHREDER - Sustainability Report 2024

Table of contents

Company Information

Fraud and Corruption At Schréder, we are committed to upholding the highest standards of ethics, integrity and transparency. Fraud and corruption not only violate our values - they undermine fair competition, damage trust and expose the company to serious legal and reputational risks. We have a zero- tolerance policy towards all forms of fraud and corruption at all levels of the organisation. Our Anti-Bribery and Anti-Corruption Policy, together with our Code of Conduct, provides a clear framework for ethical behaviour and responsible business practices. All employees, intermediaries and business partners are expected to uphold these principles at all times. Key measures include: Mandatory anti-fraud and anti-corruption training; A new process requiring formal acknowledgement of the Code of Conduct by all employees and intermediaries every two years, starting in 2025, to reinforce awareness and accountability; A risk-based due diligence process: • Applied to all intermediaries across the Group since 2020; • Recently extended to include suppliers, in line with our Sustainable Procurement Policy and risk assessment methodology, ensuring a comprehensive and proactive approach to managing third-party risk; • Through our WIN programme, and in collaboration with our Sourcing, Legal and Audit teams, we continue to foster a strong culture of compliance, accountability and integrity in all Schréder operations worldwide.

Data Protection Since the implementation of the GDPR in 2018, Schréder has proactively undertaken numerous initiatives to ensure compliance with the law on Personally Identifiable information (PII). These efforts include the publication of information notices, staff training and the creation of a register of processing activities. In 2022, recognising the dynamic digital landscape of its environment, particularly in the realm of smart cities, Schréder embarked on a new programme called Priva-see. This initiative adopts a more structured approach to PII law compliance. Inspired by the ISO 27701 standard, the Priva- see programme introduced additional measures throughout 2023. These included the appointment of a Data Protection Officer, active involvement and sponsorship from senior management, the development of digital registers of processing activities, the implementation of risk management strategies including DPIAs (Data Protection Impact Assessments) and TIAs (Transfer Impact Assessments), the adaptation of documentation and agreements to Schréder’s supply chain management and the revision of data protection policies and training programmes. These comprehensive measures have significantly enhanced the transparency of personal data flows throughout Schréder’s organisational framework. It complements Schréder’s data protection compliance journey, along with Schréder’s ISMS (Information Security Management System) and ISO 27001 certifications.

Schréder is committed to respecting competition laws and maintaining a level playing field in all our markets, in line with the highest standards of integrity and ethical behaviour. We have established a clear Competition Law Policy that applies to our relationships with suppliers, distributors, customers, competitors and trade organisations. This policy is embedded in our broader governance and compliance framework, which ensures responsible business practices throughout the company. In 2024, Schréder reinforced its commitment to fair competition through a number of targeted initiatives. A new e-learning module on competition law was rolled out across the organisation to increase employees’ understanding of competition principles and legal responsibilities. In addition, the Legal Department conducted face-to-face training sessions at the DACH Sales Convention and in France, ensuring that local teams were equipped with practical knowledge in line with applicable regulations. Competition risks continued to be actively assessed and managed through the WIN programme, which oversees compliance efforts, supported by legal reviews of contracts and business practices and audit controls to monitor compliance. Our Code of Conduct and internal policies provide all employees with accessible, clear guidance - particularly on interactions with competitors and trade associations - helping to embed compliance into everyday decision-making.

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