APAVE_RA_RSE_EN

is the corporate purpose of Apave and its 12,650 employees.

The French industrial revolutions have gradually changed the face of the economic world and consumption patterns. With 150 years of experience, Apave has always accompanied these changes, guaranteeing the safety of industrial goods, people and the environment.

More than ever, in a world that is transforming and internationalising, innovating and digitalising, Apave is pursuing its mission as a trusted third party for its customers, to enable them to carry out their professions, adapt to them safely and protect what is most precious to them: their teams, their assets and their customers.

This integrated report, combining the CSR (Corporate Social Responsibility) Report and the NFPS (Non-Financial Performance Statement), aims to explain the way in which Apave acts on behalf of its teams, its customers and the Company.

Acting as a trusted partner, to make the world safer, more sustainable and a source of shared progress

Backed by a rich history of more than 150 years, the Apave Group has constantly adapted to its clients new risks and expectations, in order to continue supporting them in their core challenges: the safety of people, goods, the environment, and today’s digital environment. Apave has also had to face these changes. We are committed to taking our share of responsibility, acting with humility and determination to combat climate change and to support the social and societal transitions that lie ahead.

Acting to combat climate change and supporting social and societal transitions

Chairman of the Board of Directors

Rémi SOHIER

Our Group’s purpose is to act as a trusted partner to make the world safer, more sustainable world and a source of shared progress. This sets out the key principles of our actions for our employees and customers in the areas of Health, Safety and the Environment, in order to preserve human life and ecosystems. Our new strategic plan, launched in early 2021, confirms the Apave Group’s determination to be a responsible and socially committed player. We are continuing to implement our roadmap, with an awareness of the need for continuous adaptation given the accelerating changes in the world in which we live and evolve.

We are continuing to implement our roadmap, with an awareness of the need for continuous adaptation

Group

CEO Philippe MAILLARD

Key Figures for the Year 2021

the number of companies that joined the Apave Group in 2021, bringing their cutting-edge expertise in specific fields: digital twins, cyber security, artificial intelligence, apprentice training centre (CFA)...

the subscription rate for the employee shareholding offer launched at the end of 2021

Apave, a Socially Responsible Group

Apave, a Socially Responsible Group

2021, a Pivotal Year in the Group’s History

Founded in 1867, the Apave Group’s model has evolved over time to remain as closely aligned as possible with the realities of the market and its customers. After almost 150 years as an association, Apave has been a private company (SA status) since 2011. It has subsidiaries in France and abroad that enable it to carry out its activities and meet the needs of its customers. Apave and its subsidiaries hold external recognitions (approvals, accreditations, certifications and qualifications) that guarantee their quality system and prove their technical competence and independence.

The Apave Group’s shareholding model evolved in 2021 with two important events: l the opening, in July 2021, of the Group’s capital to a growth partner: PAI Partners, which now owns 36% of the capital alongside the Gapave association (Groupement des Associations Apave), which remains the majority shareholder, l the creation of an employee shareholding scheme, which has enabled 70% of French employees to become Group shareholders.

and performance plan should enable Apave to strengthen its position as a reference in the TIC (Test Inspection Certification) market and become a leader

in four key sectors: energy, industrial goods/manufac turing, transportation, infrastructure & construction. Innovation, team commitment, orienting customers and listening closely to their needs are the keys to the success of this new strategic plan.

The Apave Group

Activities and Business Model

Apave specializes in the management of technical, human, environmental and digital risks, and provides technical and intellectual services to public and private customers of all sizes, through five complementary business lines: l inspection: inspection and monitoring of equipment and facilities, fire safety, technical inspection of buildings and safety on construction sites, l training: professional training courses for employees, l tests and measurements: product and material testing, environmental analysis, l certification and labels, l consulting and technical support.

These services all aim to improve the safety of goods and people and the performance of equipment or organisations. These services are pro vided in a regulatory (mandatory) or voluntary context.

In order to carry out its activities, Apave develops and maintains state-of-the-art expertise in the following technical fields: l Electricity l Mechanics l Pressure l Infrastructure and Construction l Energy and Environment l Quality, Safety and Health l Digital and cyber security

Apave operates in all sectors of activity: infrastructure and construction, nuclear, renewable energies, industrial goods/manufacturing, railways, aeronautics, space, health, local authorities, services, etc. In order to provide its customers with the best possible support, both in France and abroad, Apave is organised by sector, with four cross-functional sector lines: l Energy l Infrastructure and Construction l Industrial Goods and Manufacturing l Transportation

Nearly 60% of Apave’s turnover stems from SMEs and very small businesses (see table opposite).

Locations

The Apave Group is divided into four operating divisions (France, International, Specialised Entities, OSAC) and 10 crossfunctional departments.

A local player

Apave is positioned as a local player, thanks in particular to its network of 130 branches in France and 29 in Spain, enabling it to cover the entire territory. Apave also has 170 training centres around the world, delivering stateof-the-art technical training to 360,000 trainees every year.

An international presence

Apave is present in more than 45 countries, including 10 countries defined as “key” countries (France, Spain, Italy, Morocco, Tunisia, Senegal, Côte d’Ivoire, Cameroon, India, Vietnam). This international presence is organised around major regions: Europe, Africa, the Middle East and Southeast Asia.

The locations are listed and updated on the apave.com website

Apave, a Socially Responsible Group

Strengths Apave’s Positioning, Stakeholders

l Competent teams who take pride in what they do

l High-level technical and regulatory expertise

l A unique model of trainersinspectors

l An important operational network in France and abroad

l A presence across the entire TIC (Test Inspection Certification) value chain, complemented by training, consulting and technical support

l A strong and widely recognised historical brand

Resources

As a service company, Apave carries out its missions through the mobilisation of resources. In 2021, these were distributed as follows:

Human resources: approximately 12,650 employees, mainly engineers and technicians.

Intellectual resources: knowledge and expertise on risk management regulations in particular, backed up by the technical know-how and experience acquired by our employees.

Natural resources and raw materials: fuel for travel, paper for the production of reports and other deliverables, even though the rate of reports and bids distributed electronically is increasing each year.

Financial resources: to ensure the economic health of the company in the short, medium and long term.

Subcontractors and suppliers

Customers Employees

Shareholders

Certification and accreditation authorities and organisations (COFRAC, ASN, ministries, DREAL, ANSM, Global, etc.)

Formerly known as an “inspection agency”, Apave carries out missions as a “trusted third party”. This positioning is demonstrated by the Group and its employees through:

l its brand signature “Our mission, your confidence”

l its Purpose

“Acting as a trusted partner to make the world safer, more sustainable and a source of shared progress”

Apave is a member of several organisations that support the deployment of ecological, environmental and societal transitions. For example:

l Global compact (in progress)

l Enterprise pour l’Environnement (EpE)

Apave is a member of, and actively contributes to, professional federations in its fields of activity and associated commissions: l Filiance, for France

l TIC Council, international federation of TIC players

Our role is to ensure our customers can carry out their activities in complete safety.

Organisation and

A Unique Shareholder Model

The Apave Group has a unique shareholder model: l the Gapave association (Groupement des Associations Apave), the majority shareholder, l PAI Partners, a European investment fund, l Group employees (2.15%).

The alliance of these three shareholders allows Apave to combine general interest and financial resources in the service of businesses that are fundamental to the lives of people and society.

Group Governance

The Apave Group’s governance is structured around a Board of Directors and an Executive Committee.

The Board of Directors defines the Group’s business strategy and oversees its implementation. More than one third of the Board members are women. It is sup ported by four committees:

l Strategic Committee

l Nominations & Compensation Committee

l Audit & Risk Committee

l Ethics Committee

The Executive Committee, headed by the Chief Executive Officer, is the Apave Group’s management body. It implements the business strategy set by the Board of Directors and manages the Group’s operations. It has nine members, 22% of whom are women.

CSR Governance

Corporate Social Responsibility challenges are addressed at several levels, including the Group’s Board of Directors, reflecting the importance attached to the related strategy and its implementation.

Board of Directors’ thematic workshops

Cross-functional CSR Steering Committee

Strategy & Communication Department

Human Resources Department QHSE Department General Secretariat Operations

Group Executive Committee Business Strategy Ethics Committee Board of Directors

Apave, a Socially Responsible Group

Our Purpose, the Cornerstone of our Social and Environmental Policy

At the beginning of 2021, the Apave Group defined its corporate purpose. The result of several months of co-construction with its customers and employees (more than 5,300 contributions collected), the Group’s corporate purpose was endorsed by the Board of Directors on 10 December 2020. It is fully in line with the Group’s history and reflects the active contribution that Apave and its 12,650 employees wish to make to the world of today and tomorrow. It also provides input for the Group’s 2025 strategic plan.

Acting as a trusted partner to make the world safer, more sustainable and a source of shared progress the Apave Group’s purpose.

We are convinced that safety is the cor nerstone of all progress, that it must be sustainable and contribute to preserving the lives of people and ecosystems. Preventing, monitoring and managing risks, whatever they may be, guarantees performance and supports innovation. This is the starting point for our actions, our strategic choices and the develop ment of our activities. And this is why we put our expertise and our solutions at the service of our customers

Our Objective

Enabling our customers to: l comply with regulations, l secure industrial production assets

and above all: l guarantee the safety of their employees, contractors and customers, l protect tomorrow’s resources, whether they are environmental, societal or economic.

Apave has a code of ethics that applies to all Group employees and reflects its commitment to strong values: integrity, independence, competence, respect for laws and people, social and environmental responsibility. Apave is committed to respecting and promoting the principle of non-discrimination in favour of cultural, ethnic and social diversity within its organisation. Apave is committed to

respecting human rights, international labour standards, environmental protec tion and the fight against corruption. Apave is committed to contributing to the implementation of the United Nations’ sustainable development objectives, in order to make the world safer and more sustainable.

Thanks to a concerted and evaluated policy, the Group’s employees are taking action every day and demonstrating their professionalism as responsible citizens, both at our customers’ sites and at our branches and locations.

Our Actions and Progress in 2021

Commitments to Safety

Our commitments

Apave is committed to ensuring that its development combines economic, social and environmental progress. Safety is the cornerstone of all progress. Preventing, monitoring and managing risks guarantees performance and supports innovation. This is the starting point for Apave’s actions, its strategic choices and the development of its activities.

Apave provides its customers with all the expertise they need to manage and monitor the safety of their teams, from day-to-day operations to the implementation of a safety culture for all. Internally, Apave aims for “zero accidents” by strengthening a common HSE culture and

Our conviction: without safety, there can be no sustainable progress

implementing an active risk prevention policy throughout the company: l management and all managers integrate safety as a key performance indicator for their teams, l all Apave employees (managers, supervisors, adminis trative staff, functional staff, sales staff) take a proactive role in ensuring their own safety on a daily basis and apply the eight safety principles on the road, at their customers’ sites and on the company’s premises.

Our achievements in 2021

MONITORING

Apave monitors frequency and severity rates on a monthly basis. These two indicators are constantly decreasing and are also better than the industry average.

Apave, a Socially Responsible Group

Commitments to Safety

ADAPTING

The year 2021 was once again marked by the public health crisis, and Apave therefore constantly adapted its operating conditions while protecting its employees. To this end, several resources were deployed: l regular updating of the COVID-19 prevention plan and the associated FAQ, l regular discussions with the Health, Safety and Working Conditions Commission (CSSCT): 40 meetings in 2021. This continuous process of adaptation involved not only employees, but also trainees at our training centres.

TRAINING

In-house training for Apave teams is a key element in the added value we provide to our customers. In 2021, 187,630 hours of in-house training were provided in areas related to safety and/or the environment.

COMMITMENT AND TAKING ACTION OVER THE LONG TERM

Apave obtained ISO 45001 certification in September 2021. This is a major recognition of the high level of commitment and action of our employees and the company in the field of occupational health and safety. Apave also has 58 sites with MASE certification.

l 2021 Safety Day: organised in April, in the form of a digital event, introduced and moderated by the Group’s CEO, it brought together nearly 800 employees.

l Objective Zero Accident (OZA): launched in 2019, Apave is continuing the OZA initiative for its teams, in particular through the application of the 8 safety principles. In 2021, all teams were reminded of the 8 principles.

Environmental Commitments

Our commitments

Apave is committed to protecting the environment through the actions it takes, either as part of its customer assignments or as part of its activities.

Environmental protection is at the heart of Apave’s business, through the management of environmental risks. On a daily basis, the Group’s experts work on behalf of their customers to protect the environment, reduce the risk of pollution, reduce the carbon footprint of their activities, preserve biodiversity, etc.

Internally, Apave is working to reduce its environmental footprint and its consumption of natural resources. In 2021, Apave carried out a Carbon Footprint Assessment for the entire Group, providing a new baseline.

Our achievements in 2021

REDUCING OUR CARBON FOOTPRINT

Apave entities have been carrying out a carbon assessment of their activities for several years. For comparison purposes, a review based on a common methodology was conducted in 2021.

l Total emissions (scope 1, 2 and 3, including purchased products and services): 49,657 teq CO2. This represents an average of 3.96 teq CO2/employee

l Excluding the “products and services purchased” category, the Group’s carbon footprint is 2.3 teq CO2/ employee

In order to reduce its carbon footprint, Apave has undertaken various initiatives, such as: l the incorporation of clean vehicles into its vehicle fleet (49% A-label vehicles, including 49 hybrids, and 86% of vehicles with A or B labels),

Our conviction: without safety, there can be no green transition.

l taking into account the environmental impact of buildings in its real estate projects, l increasing the frequency of remote meetings.

Apave, a Socially Responsible Group

Environmental Commitment

REDUCING OUR CONSUMPTION

Whether in terms of energy or paper, Apave has been working for several years to better manage its consumption. For example, paper consumption has been reduced by 23% compared to 2019 thanks to proactive awarenessraising among teams to print less and to gradually switch to digitalisation of documents. The decrease in fuel consumption underscores Apave’s policy of reducing its carbon footprint. Although the proportion of electric or hybrid vehicles is still limited, eco-driving training programs are contributing to efforts to reduce greenhouse gas emissions (see table below).

CONSUMING BETTER

Purchasing: better consumption starts, in part, with better purchasing. For several years, Apave has had a Responsible Purchasing Charter, which allows it to take

EVCF

Key figures

Throughout France, more than

Fuel Paper

6.3 million liters 9.7 l/€k TO 162.64 T

2,000

have been trained …by 25 certified Apave trainers.

Mobile teaching platforms for all load levels and multi-brand platforms for tailored practical work, allow Apave to organise training courses wherever its clients are located in France. Apave is now closed to its customers to help reduce the carbon footprint associated with travelling to training sessions!

environmental and broader CSR criteria into account when choosing suppliers and products. For example, Apave uses eco-labelled products to clean its sites.

2021 2020 (non-representative year – COVID-19)

5.4 million liters 9.36 l/€k TO 161.5 T

2019 2021 vs 2019

6.5 million liters 10.3 l/€k TO 214.6 T

-3% -6% -23%

Circular economy: Apave is also involved in initiatives that promote the circular economy. For example: l regarding IT equipment, which is one of the most used office supplies, the computers and monitors purchased are made with 30% recycled materials and are 90% recyclable. Once used, they are either recycled or reconditioned and given a second life by the service provider, l numerous educational platforms designed with materials mainly from the reuse sector come from its customers or suppliers.

PRESERVING NATURAL RESOURCES

Waste sorting and recycling: at most Apave sites and branches, waste is sorted. For example, 1,133 print toners were collected in 2021 and sent to recycling facilities, which represents a saving of 2 metric tons of natural resources and 203 kg of CO2 avoided.

Biodiversity: 100% of the paper used by Apave comes from sustainably managed forests. In addition, some branches or local entities have set up a beehive spon sorship programme or have installed beehives at their entity, for example, at the branches in Annecy, Chambéry, Marseille, Nîmes, Montpellier, Nice, Tassin, Toulon, Tou louse and Valence, and at the Group’s headquarters in Courbevoie (92).

ADAPTING TO THE CONSEQUENCES OF GLOBAL WARMING

Apave has begun a phase-out of its internal data centres in favour of external data centres that are fully backed up and secure against power loss. Apave has continued to adapt its Professional Training catalogue to take into account new expectations related to the energy and ecological transitions: l Apave has signed a partnership with EIT InnoEnergy to support the training of mechanics and electric vehicle

experts. By the end of 2021, Apave was offering and delivering 15 training courses dedicated to the ecosys tem, design and operation of electric batteries, l Apave has greatly accelerated the training of EVCF (Electric Vehicle Charging Facilities) installers and oper ators, who must follow and pass certification training courses, l Apave trains numerous players in the energy transition: LINKY meter installers, air conditioning or heat pump (refrigerant) installers. In total, Apave has nearly 64 training courses contributing to a safe energy transition.

Apave has adapted its Professional Training catalogue to the new expectations related to the energy and ecological transitions.

TRAINING

Supporting the ecological and environmental transition

80.000

trainees trained in 2021

60 training centers equipped for these courses

+ 60 training courses related to the energy and ecological transitions

Apave, a Socially Responsible Group

Social Commitments

Our commitments

Apave contributes to the quality of the professional life of its employees and encourages internal promotion and mobility.

This is reflected in particular through: l training initiatives for employees to maintain a high level of technical expertise and to develop their skills and employability, l encouraging internal mobility, contributing to the devel opment of versatility, l a commitment to manage the career paths of each employee within the company more proactively, l a commitment to taking on interns and work-study students with a view to passing on know-how, l a high level of recruitment, both in terms of numbers and skills, in order to support development ambitions, l increasing attention for listening to employees and involving them more closely in the company’s perfor mance.

Our achievements in 2021

LISTENING

Every two years, an extensive listening mechanism is organised throughout the Group, including internation ally and in specialised entities. The last survey, in June

2020, had a high success rate (83%) and gave everyone the opportunity to express their views on their daily lives within the company and to contribute to the 2025 strategic project. The next survey is scheduled for June 2022.

FORMER

Training accounts for 4.8% of the total payroll.

This ambitious policy of internal training is mainly focused

on technical and safety-related professions and fields. On average, Apave provides 30.88 hours of training per employee.

In 2021, Apave invested heavily in new training courses in line with its strategic plan. For example: l a “Group Culture” module was defined and deployed between February and September 2021 with 96% of the Group’s employees, i.e., 11,878 people,

l a “Being an Apave manager” module was defined and deployed to all Group managers. In 2021, the first part on remote management was rolled out, an important issue given the significant development of remote relations in the professional world.

DIALOGUE

Apave engages in a social dialogue with employee representative bodies organised around: l the CSEC (Central Social and Economic Committee) and its Health, Safety and Working Conditions Commission (CSSCT), l the Social and Economic Committee (CSE) of each of the entities, l in 2021, negotiations to define a new Common Social Base led to the signature of 12 agreements, which were implemented on 1 January 2022, l within the framework of this social dialogue, the aspects relating to remote work and QWL were discussed at meetings.

These interactions with employee representatives totalled 192 meetings in 2021.

Apave organises, via its management team, discussion sessions that allow everyone to express themselves within their entity.

INTERNAL TRAINING

“Our collective culture” training module Training «Being an Apave manager - How to manage remotely”

96%

participation

78% of participants say they are very satisfied

A participative, clear and accessible module for all!

A user-friendly, participatory and innovative module that allows you to take on board and explore a number of concepts. To be repeated with other topics.

A very good, lively and fun presentation.

This module enables us to understand where we are heading as a Group and how we are going to get there, ambitions, means...

85%

participation

Modules available in 6 languages: French, English, Spanish, Italian, Portuguese and Vietnamese, maxi mising team engagement.

Apave, a Socially Responsible Group

Social Commitments

LOYALTY

Apave contributes to sustainable employment, as shown by the high rate of permanent employment contracts: 95.7% The breakdown by seniority is as follows: l less than 6 years: 41% l between 6 and 15 years: 26% l more than 15 years: 33%

In 2021, Apave set up an employee shareholding scheme. The high subscription rate (70% of employees now own 2.15% of the Group) confirms the teams’ support for the Group’s strategic project and their commitment to making it a success.

RECRUITMENT

In 2021, nearly 1,650 new employees joined the Group: 1,400 through recruitment and 250 through acquisitions of external companies. For each of them, an induction, integration and training process was put in place. Apave is continuing to expand and plans to recruit 1,500 new employees in 2022.

ACTING FOR A MORE INCLUSIVE COMPANY

Gender Equality

l 2021 index: 94/100

l Proportion of women in the workforce: 29%

Disability

Apave has a joint national framework agreement on the employment and retention of disabled workers. Apave is committed to increasing the number of people with disabilities in its workforce. At the end of 2021, disabled employees represented 3.4 % of the workforce.

As part of Apave’s QUALIOPI certification process as a professional training organisation, a Disability Training

Advisor has been appointed with a dedicated contact address (info.handicap@apave.com). Through its website apave.com, the accessibility of training centres and courses for people with disabilities is made clear in a completely transparent manner.

In addition, in-house training on welcoming people with disabilities has been provided to the teams managing professional training.

In 2022, the Apave Group plans to recruit 1,500 new employees in France and abroad, including 900 per manent positions. This large-scale recruitment plan concerns all the Group’s businesses and subsidiaries. The profiles sought are young graduates, managers, engineers, technicians, but also work-study students

and interns in the scope of their 2- to 5- year tertiary education diplomas. Thanks to the diversity of its businesses, customers and sectors of activity, Apave offers numerous opportunities for career development and personal fulfillment, in technical, managerial and geographical terms.

Societal and Ethical Commitments

Our commitments

Apave is committed to ensuring that its development brings together economic, social and environmental progress. Apave has adopted a code of ethics that applies to all of the Group’s employees and reflects its commitment to strong values: integrity, independence, competence, respect for laws and people, social and environmental responsibility.

Apave’s independence is guaranteed by its COFRAC (French Accreditation Committee) ISO 17020 accredita tion as a type A (third party) inspection body. As such, its ethics procedure is subject to annual audits by COFRAC.

l Reference documents govern Apave’s actions, services and relations with its customers, suppliers and stake holders

l Apave also has a procedure for managing the collection of reports of facts contrary to the Code of Ethics and the Anti-Corruption Code, as well as the protection of whistleblowers

The Ethics Committee of the Board of Directors is fully involved in the monitoring of reports and facts collected within the Group.

Apave, a Socially Responsible Group

Societal and Ethical Commitments

Our achievements in 20211

A “TRUSTED THIRD PARTY” POSITIONING

As a recognised and accredited third-party organisation (COFRAC in France), Apave is positioned as a trusted player and, thanks to its independence, guarantees impartiality and transparency with regard to economic players (suppliers, manufacturers, etc.). This impartiality encourages its customers engage in certification or labelling (creation or obtention of certification labels) processes.

A REGIONAL PLAYER

As a player in the local economy, Apave is committed to serving all its customers, regardless of their size, sector of activity or geographical location.

Through its inspection activities, such as checks on children’s playgrounds and amusement parks, and its certification and labelling activities, Apave helps to make living spaces safer.

Safe&Clean label: launched in 2020 during the COVID19 crisis, Apave’s Safe&Clean label enables establish ments open to the public to reassure their own customers regarding the public health prevention and protection measures they have implemented. Since

the beginning of the pandemic, more than 58 custom ers have been awarded the label by the Apave teams.

As a player in the local economy, Apave is committed to serving all its customers, regardless of their size, sector of activity or geographical location.

HS2 label: In 2021, Apave continued to develop its HS2 label, which is designed to help frail people stay in their homes. A total of 191 projects have been approved since the label was created. In 2021, 17 new companies were awarded the label and 10 labels were presented at official ceremonies. In a context where the number of seniors is increasing significantly and for whom home care solutions are sought, the HS2 label is a key endorse ment for all the players involved: associations, start-ups, SMEs, local authorities, etc.

HS2 LABEL

A societal approach to home care

For companies, adopting the HS2® approach guarantees seniors and people in vulnerable situations a product or service that allows them to live at home as long as possible and in the best conditions.

In 2021,

17 21 10 191

companies involved in the process since the creation of the label, i.e., 7,726 homes registered in the process

Local initiatives

All Apave branches are encouraged to participate in local initiatives. Examples for the year 2021 include: l participation in solidarity sports events (Nantes, Mar seille, Chambéry, etc.), l mobilisation of all Apave agencies in France during the StreetCo challenge in November 2021, which resulted in the identification of 789 obstacles, l participation in clean-up and waste-collection days.

ACTING IN FAVOUR OF INTEGRATION

In partnership with temporary employment agencies, Apave trained nearly 3,500 people in 2021 in short-staffed professions, almost all of whom found employment after their training.

Apave’s teams work closely with protected or adapted sectors, which are used for certain activities, such as the cleaning of green spaces (Strasbourg branch, Chartres branch, Strasbourg training centre, etc.)

RESPONSIBLE PURCHASING

The Apave Group has a “responsible purchasing” charter, which means that environmental and social criteria are systematically taken into account in Group-wide consul tations.

Apave, a Socially Responsible Group

Societal and Ethical Commitments

The selected suppliers must also contribute to improv ing the safety/protection of people and goods. Since 2019, Apave has been evaluating its Top 100 suppliers via the Ecovadis platform.

CSR RATING/EVALUATIONS

Apave has been evaluated by the independent organi sation Ecovadis. Its score, 66 in the GOLD category, places Apave among the top 4% of companies in its category and top 8% of all companies evaluated by Ecovadis (see details below).

Apave also received the A+ green index, a label issued by the public and private hospital purchasing centre (CAHPP).

COMMUNICATION

As an expert in risk management, Apave publishes yearly compendiums aimed at deciphering regulations related to environmental protection, in order to improve practices and raise team awareness.

In 2021, the publications on “RE 2020 and the construction of the future”, and “Low-carbon strategy and greenhouse gas reduction” were downloaded nearly a thousand times from the Apave website.

Every year, Apave publishes the “Your regulatory obligations“ guide to help customers better understand sometimes complex regulations and implement them in their companies to ensure the safety of their customers, the people who work for them, industrial assets and the environment.

A true Apave bestseller, the guide “Your regulatory obligations” has been distributed to nearly 8,000 people and downloaded nearly 2,000 times from our website.

Sharing our knowledge and expertise with our customers

2021 Non-Financial Performance Statement

This chapter of the report aims to meet the non-financial reporting requirements defined by the decree dated 9 August 2017, which transcribes the European Union Directive 2014/95 into French law. The scope of this reporting corresponds to that of the consolidated financial statements (see chapter on the methodological memo).

The business model is included in the section “Apave, a Socially Committed Group” on page 13.

Business Model and Resources Risks and Performance Indicators

Materiality and Risk Analysis Method

Apave’s main CSR risks and commitments are identified in two ways: l risks to the company, carried out in accordance with the risk analysis procedure described by the Internal Control Department (Group Directive “Internal Control System”), l risks, including Apave’s externalities and its impact on the environment and society. The second approach is based on the “materiality analysis” method, which positions the risks in relation to the challenges.

As part of this NFPS, Apave has conducted a materiality analysis in order to identify CSR issues, while including its stakeholders’ expectations with regard to the Group’s activities that may have an impact on them, the company and the environment. For the first stage, the identification of key stakeholders and the qualitative assessment of each issue were carried out through workshops and discussions with the CSR steering committee. In this context, CSR issues were rated according to their importance: 1 - Low, 2 - Medium, 3 - Important, 4 - Very important.

This evaluation makes it possible to determine the main issues, based on the average expectations of external stakeholders (customers, shareholders, authorities and subcontractors/suppliers) and issues seen from an inter

l climate change: Key Performance Indicator on green house gas emissions; adaptation to climate change: see part II, l circular economy: Key Performance Indicator on paper consumption and data on waste management and the purchase of sustainable supplies (see “Apave, a socially committed Group” page 22), l collective agreements and impacts on economic per formance (see “Apave, a socially committed Group” on page 25),

l fight against food waste: indicator excluded from reporting, given the almost systematic outsourcing of catering services, l diversity and the fight against discrimination: Key Per formance Indicator on gender equality

l disability (see “Apave, a socially committed Group” on page 26),

l food insecurity, animal welfare and responsible eating: this indicator is not included in the reporting, as Apave’s activities are not related to these issues, l promotion of physical activity and sports: this indicator is not included in the reporting; however, initiatives have been taken to improve the ergonomics of work stations (warm-ups, etc.) or to encourage cycling (Apave headquarters).

CSR Risks and Challenges

Identified

As a result of this analysis, the following 6 issues were identified as “material”, i.e., the most important:

l Ethical governance - Fighting corruption

l Diversity, inclusion and equality - Fighting discrimination

l Employee health and safety

l Employee skills

l Fight against climate change and air pollution

l Consumption of natural resources - biodiversity

Finally, the main CSR risks were identified according to these issues:

Environmental Impacts

Greenhouse gas emissions: since Apave’s activities often take place on customer sites, they require frequent travel, often by car, which is a significant source of greenhouse gas emissions. Internationally, this also involves air travel.

Associated risk: Global warming

Paper consumption: Apave’s activity is intellectual. For customers, this translates into a deliverable: a report or a certificate of training. The use of paper resources is another significant environmental aspect.

Associated risk: Depletion of forest resources

Social Impacts

Employee safety: Apave’s activities generate safety risks for employees, whether they arise from our business or from customer environments. This is a major challenge in terms of human resources, but it is also a business risk, because safety is at the heart of the Group’s business and customers have increasingly high expectations.

Associated risk: Safety

Training: employee qualifications are the company’s main asset. Training is therefore a particularly important issue to maintain the qualification levels of personnel.

Associated risk: Company know-how

Societal and Ethical Impacts

Gender equality: changes in regulations and society’s expectations in terms of equal rights make this an impor tant issue for Apave. For Apave, this means increasing the number of women in its teams, particularly in operational and management positions.

Associated risk: Discrimination

Fight against corruption: Apave’s presence in high-risk countries and its independent third-party status make the fight against corruption an important issue.

Associated risk: Ethics

2021

Non-Financial Performance Statement

Key Indicators - Definition

The key indicators of Non-Financial Performance are therefore the following:

CSR issues Risk Indicator and unit Source of information SDG(1)

Fight against climate change and air pollution

Consumption of natural resources - Biodiversity

Health and safety of employees

Greenhouse gas emissions

Skills of our employees

Paper consumption Safety Training

metric tons CO2 equivalent/ employee kg of paper consumed/employee

Procurement, Management teams for international subsidiaries

Procurement, Management teams for international subsidiaries

Frequency and severity of workrelated accidents

Number of training hours per employee

HSE management system and Human Resources Department

Human Resources Department

Diversity, inclusion and equality - Fight against discrimination

Ethical governanceAnti-corruption

Gender equality Ethics and anti-corruption

% of women among technical and managerial staff

Roll out rate (%) of the “ethics and corruption” training course amongst companies and employees

Human Resources Department Compliance Department

(1) The United Nations Sustainable Development Goals are indicated in relation to the main CSR indicators and commitments because they contribute to a safer and more sustainable world.

Policies and Objectives for Risk Management

CSR policies are described in the section “Apave, a socially committed Group” on page 11. In addition, the associated objectives and action plan to manage the risks iden tified are defined below:

Risk/theme

Greenhouse gas emissions

Objective

2022*: 5% reduction in GHG emissions (base year 2021 NFPS)

* transition year

Paper consumption

20 kg/employee of paper consumption on average

Action plans

l Choice of Apave cars with lower GHG emissions

l Training in eco-driving

l Development of remote working, web-conferencing and internal training

l Building renovation or relocation works

l Establishment of mobility plans for the 20 largest sites in France, in progress

l Dematerialisation of reports, especially for international use

l Promotion of double-sided printing

l Reduction of the weight of paper purchased (from 80g to 75g), where possible

l Reduction in the number of printed training catalogues and the number of pages

l Reduction and dematerialisation of trainee documents, in particular for international business

Safety Training

Gender equality

Anti-corruption

Zero accidents

Continuation of the OZA (Objective Zero Accident) approach:

l 8 safety principles known and applied by all

l Management involvement

l MASE or ISO 45001 standard applied by all Apave sites

Maintaining skills

Increasing the number of female employees throughout the group

By the end of 2022, roll out for 50% of companies representing 90% of employees (objective taking into account the expansion of the Group’s scope)

l Skills development plan (internal training)

l Recruitment policy

l Agreements on gender equality

l Generalisation of training on corruption risks to all staff

l Completion of risk mapping for international subsidiaries

l Audits of subsidiaries, integration of new Group subsidiaries

2021 Results

Spotlight on the 2021 GHG emissions assessment

In 2021, Apave conducted its GHG emissions assessment while expanding its scope to include all entities, including international entities, in order to properly measure its carbon footprint. Following the rules of the Greenhouse Gas Protocol (GHG Protocol), one of the international standards for accounting for GHG emissions, its assessment covers part of the value chain according to the emission categories defined (see tables opposite).

*Definitions (see table opposite)

l Scope: emission category, l Scope 1: direct greenhouse gas emissions from stationary combustion sources (natural gas, fuel oil, etc.) and motorised travel with the internal fleet, l Scope 2: indirect emissions from electricity consumption in Apave buildings, l Scope 3: emissions related to the purchase of goods and services, business travel not operated by Apave, and emissions linked to the production and transport of fuels and energy taken into account for the calculation of Scopes 1 and 2 emissions.

DIRECT GHG EMISSIONS - SCOPE 1*

Direct emissions from stationary combustion sources

Direct emissions from mobile combustion sources (business travel)

INDIRECT GHG EMISSIONS - SCOPE 2*

OTHER INDIRECT GHG EMISSIONS - SCOPE 3*

Products and services purchased

Fuel and energy-related emissions (not included in Scope 1* or Scope 2*) Business travel

TOTAL GROUP EMISSIONS

Total emissions from business travel (scopes* 1 and 3)

teq CO2

Apave SAS (France)

International of which Eurocontrol (Spain) Other subsidiaries (including OSAC)

18,705 5,499 2,226 1,309

417 1,134 146 229

25,513 1,818 23,695 1,780 22,364 14,224 6,555 1,586 14,953 5,373 2,041 2,038

49,657 teqCO2 31,039 teqCO2

% TOTAL

51% 7% 93% 4% 45% 64% 29% 7% 34,075 12,006 4,413 3,576

Summary

2019 Reminder 2020 Reminder 2021 Results Risk

Greenhouse gas emissions Paper consumption Safety Training

3.96 metric tons CO2 equivalent/employee (not comparable with 2020 due to improved calculation method and scope: ratio now based on total emissions of scopes 1, 2, and 3 worldwide) 24.1 kg of paper purchased or printed/employee

1.87 metric tons equivalent CO2/ employee (ratio based on total emissions of scopes 1,2 France + scope 3 limited to travel)

17.8 kg of paper purchased or printed per employee

2.01 teq.CO2/employee (ratio based on total emissions of scopes 1,2 France + scope 3 limited to travel)

26.7 kg/employee (indicator limited to France)

Gender equality

Workplace accident frequency rate: 3.66 Workplace accident severity rate: 0.12 20.73 hours of training per employee 14.9% of women among managers, technicians and branch managers

Frequency rate: 4.37 Severity rate: 0.19 20.16 hours of training per employee 16.5%

Frequency rate: 4.74 Severity rate: 0.14 21.25 hours 17.4%

Anti-corruption

“Ethics and Corruption” training rolled out in 64.7% of Group subsidiaries representing 71.9% of Group employees

“Ethics and corruption” training rolled out to 25% of the Group’s subsidiaries, representing 73% of the Group’s employees

(No quantitative indicator)

Analysis of Results

Greenhouse gas emissions

In 2021, the geographical scope of the GHG emissions assessment was expanded to include all French entities as well as those outside France, including Eurocontrol. The scope of calculation of other indirect emissions (Scope 3) was also expanded by taking into account purchases of goods and services and emissions related to fuels and

energy not taken into account in Scopes 1 and 2. As a result, the GHG assessment in 2021 is not compa rable to that of the previous year. However, emissions linked to business travel (all scopes combined) are still Apave’s main GHG emissions, accounting for 62.5% of the overall assessment. Among scopes 1 and 2, emissions related to motorised travel represent 87%.

On an equivalent basis (Scopes 1, 2 and 3 limited to business travel), GHG emissions are comparable to 2020 (1.65 teqCO2/employee)

For the Apave Group, this 2021 assessment is the start ing point for setting new multi-year carbon footprint reduction targets in 2022, the year in which the Group’s CSR strategy will be redefined.

Paper consumption

Paper consumption has increased. Consumption is particularly high in Spain and Cameroon. In France, however, the objective has been achieved in comparison with 2019 (approximately -20%). The changes can there fore be explained to a large extent by the change in scope due to the growth of the Apave Group.

Paper consumption in 2020 was exceptionally low due to the COVID-19 crisis.

Safety

The indicators show an improvement in safety perfor mance in terms of both frequency and severity rates. The OZA approach has therefore proved its worth, even if it remains a long-term project. In addition, various actions were carried out in 2021: l roll out of the Avert Premium application for the direct reporting of dangerous situations, l setting up the “risk portal” to raise awareness of risk prevention methods and develop a safety culture, l ISO 45001 certification in France.

Training

There was a slight increase in internal training figures. Training remains essential to maintain the level of skills required by Apave’s businesses.

Gender equality

There has been a 1.5-point drop in the indicator for the percentage of women in technical and managerial posi

tions. This change can be explained by the reliability of data collection (international), to better take into account the rate of feminisation of management and technical positions and not the overall rate of feminisation. How ever, the calculation of the Gender Equality Index in France, created by the Ministry of Labour, gives a result of 94/100 (identical to 2020).

Fight against corruption

More than half of the subsidiaries have undertaken awareness-raising of the ethics and anti-corruption code. However, the objectives were not achieved in terms of

the number of employees concerned. Translation prob lems explain this development, as do the change in scope and the growth of the Group.

It should also be noted that:

l Ethical risk mapping was carried out

l A “Fraud” risk analysis was set up as part of the inspec tion in France, and awareness-raising was carried out for this topic

Operationally, the Audit and Compliance Committee carried out 14 audits of subsidiaries and 18 investigations, including the handling of six reports.

Methodological Memo and Validation

The base year for this statement is 2021. The scope taken into account is that of the consolidation of the Apave Group accounts.

Data was able to be collected for 91.9% of the entities concerned, representing 99.18% of the workforce. The following subsidiaries were unable to provide the requested information:

l Apave Vertech

l Apave Mali

l Apave Liban (being sold)

l Apave Libya

l Apave Ghana Inspection

l AIO Développement

The methods of calculation and collection of information are specified in the note S.QHSED.36, available on request from the QHSED.

The Departments involved in the NFPS are:

l QHSE Department (Quality, Health, Safety and Environ ment)

l General Management and General Secretariat

l Human Resources Department

l Strategy and Communication Department

The risks were validated by General Management, after consultation with the CSR Steering Committee. The CSR Report was validated by the Chief Executive Officer.

The NFPS was approved by the Board of Directors. It is included in this Group CSR Report, published on the apave.com website.

The European Green Taxonomy

Rapport RSE du Groupe Apave

Reporting Methodology

With the introduction of EU regulation 2020/852 dated 18 June 2020, known as the Green Taxonomy, companies listed in the European Union are now required to publish the share of their turnover, investments and operating expenses resulting from products or services associated with economic activities considered sustainable. Aware of the challenge of encouraging sustainable investments, Apave, although not subject to this requirement, is voluntarily reporting on the European Green Taxonomy for the 2021 fiscal year.

Substantial Contribution to Environmental Objectives

The regulation seeks to ensure that activities that substantially contribute to one of six environmental objectives are declared:

l Climate change mitigation l Climate change adaptation

l Sustainable use and protection of water and marine resources

l Transition to a circular economy l Pollution prevention and reduction l Protection and restoration of biodiversity and ecosystems

In 2022, the first two objectives (climate change mitiga tion and adaptation) are affected by this regulation for the reporting year 2021.

Eligibility of Activities

Third-party Testing Inspection & Certification (TIC) organ isations, of which Apave is a member, offer many services

that contribute substantially to these two objectives. Based on the guide published by the international professional association of these organisations, the TIC Council, the categories of services have been identified according to their level of eligibility for the Taxonomy: l Level L1: TIC services and others listed in the delegated acts of the Taxonomy

l Level L2: TIC services associated with contributory activities through the NACE M71 codes for testing and technical analysis services

l Level L3: TIC services not eligible for the Taxonomy

Eligible Activities

Only the activities mentioned in the delegated acts are taken into account in our report. There are other activities of third party control bodies that contribute substantially to one or more environ mental objectives. As they are not mentioned in the delegated acts of the Taxonomy, they are therefore considered as non-eligible for the time being, pending an evolution of the delegated acts.

Level L1: activities explicitly listed in the delegated acts of the Taxonomy

l Building inspection and verification services and monitoring of electrified rail infrastructure (Annex I6.14)

l Energy audits and performance evaluations of accred ited buildings (Annex I - 9.3)

l Installation, maintenance and repair of charging sta tions for electric vehicles in buildings in parking lots (Annex I - 7.4)

l Installation, maintenance and repair of technologies related to renewable energies (ref annex I - 7.6)

Level L2: the two activities are linked to contributing activities through the M71 codes

l Testing, inspection, certification of energy efficiency equipment (Annex I - 7.3)

l Testing, inspection, certification of instruments and devices for measuring, regulating and controlling the energy performance of buildings (Annex I - 7.5)

Reporting

Turnover

Scope: the four largest countries where Apave oper ates: France (Apave SA and 4 SAS), Spain, Italy and Vietnam, which account for 76% of turnover (see table 1 on page 46).

None

Capex Opex

In accordance with French GAAP regulations, vehicle fleet leasing contracts are Opex. They are considered eligible for the Taxonomy. Due to the difficulty of iden tifying those eligible for the Green Taxonomy, leases for offices and laboratories are excluded from the declaration this year (see table 2 on page 47).

Table 1

The European Green Taxonomy

Economic activity Absolute TO (M€)

2021 Group turnover

Level 1 - Contributing Activities

Railway transportation infrastructure (6.14): - Building inspection and verification services

Specialised services related to the energy performance of buildings (9.3): - Accredited energy audits and building performance evaluations

Installation, maintenance and repair of charging stations for electric vehicles (7.4)

Installation, maintenance and repair of renewable energy technologies (7.6): - Services on photovoltaic installations, performance of renewable energy production systems

Level 2 - Associated Activities

Testing, inspection, certification of energy efficiency equipment (7.3)

Testing, inspection, certification of instruments and devices for measuring, regulating and controlling the energy performance of buildings (7.5)

Activity Eligible for Taxonomy

748.8 1.159 0.916 0.146 0.0005 0.096 3.772 1.573 2.198 4.93

TO share (%)

Substantial contribution criteria

Climate change mitigation (%)

0.15 0.12 0.02 0.00007 0.01 0.50 0.21 0.29 0.66

0.15 0.12 0.02 0.00007 0.01 0.50 0.21 0.29 0.66

Climate change adaptation (%)

0 0 0 0 0 0 0 0 0

Water and marine resources (%)

N/A N/A N/A N/A N/A N/A N/A

N/A N/A N/A N/A N/A N/A N/A

N/A N/A N/A N/A N/A N/A N/A

N/A N/A N/A N/A N/A N/A N/A

Circular economy (%)

Pollution (%) Biodiversity and ecosystems (%)

Vigilance Plan

This chapter of the report aims to meet the requirements of French Law No. 2017-399 of 27 March 2017, on the duty of vigilance of parent companies and ordering companies, with regard to the identification of risks and prevention of serious violations of human rights and fundamental freedoms, the health and safety of individuals, and the environment, resulting from their activities, those of their subsidiaries and those of subcontractors or suppliers with whom they have an established business relationship.

The Group’s Vigilance Committee

A Vigilance Committee was set up for the Group in January 2020. It is composed of the General Secretary, the members of the Group’s Compliance Audit Commit tee and the QHSE Director.

The missions of this committee were defined by the Group’s General Management after consultation with the Board of Directors. Namely: l establishing the Apave Group’s vigilance plan, l disseminating the vigilance plan to the Apave Group’s stakeholders, l monitoring the implementation of risk mitigation and prevention measures, l adapting the vigilance plan to new risks that Group entities may face.

This committee reports to the Group’s Chief Executive Officer. It reports annually on its activities to the Board of Directors

The Group’s Vigilance Plan

The Apave Group’s vigilance plan is based on its commitments related to the protection of people (health and safety) and human rights, and to the preservation of the environment. These commitments have been set for all employees, as well as for third parties who interact with the Group’s entities through:

l this CSR report,

l Health, Safety and Environment policy and the Group HSE manual

l the Code of Ethics, l the anti-corruption code, l the security management manual, l the personal data protection policy, l the whistleblowing procedure, l the sustainable purchasing charter.

The vigilance plan includes the following five measures: l a risk map to identify, analyse and prioritize risks,

l procedures for regular assessment of the situation of subsidiaries, subcontractors or suppliers with whom there is an established business relationship, with regard to risk mapping, l appropriate actions to mitigate risks or prevent serious harm, l a mechanism for alerting and collecting reports on the existence or occurrence of risks, established in consul tation with representative trade unions, l a system for monitoring the measures implemented and evaluating their effectiveness.

Risk Mapping

The mapping of risks covered by the duty of vigilance is based on:

- the mapping of ethical and anti-corruption risks - Apave’s general risk mapping - internal and ethical audits

- whistleblowing - feedback from the roll out of the Group’s various policies, codes and manuals over several years

The risks have been identified through an approach taking into account 3 topics:

l Impacts of Apave’s Activities on the Environment; for the Group, this means: - greenhouse gas emissions, see NFPS, - paper consumption: see NFPS,

- specific pollution: the possession of radioactive sources generates a risk of accidental pollution in the event of loss, misuse or theft; this also concerns the risks related to soil analysis activities.

l Personal Health and Safety: - safety: see NFPS, - health: current events show that the prevention of epidemics has become a major issue for the entire Group and for international travel, - accommodation and working conditions: these are localised risks where Apave employees are tempora rily housed.

l Human Rights: - protection of personal data: information systems are sometimes fragile in some countries; professional training is a business that manages personal data, - security: Apave’s operations are sometimes located in high-risk areas, - discrimination, violation of dignity: in some territories, Apave employees may discriminate on the basis of custom (sexist, homophobic, religious, racist, etc.); this also includes harassment, - freedom of association and expression: some regimes severely restrict the freedom of association or expres sion of employees, - freedom of movement: in some areas, some people are restricted in their movements.

The risks were evaluated according to their frequency and severity, which made it possible to classify them into 4 levels:

- Green: minor

- Yellow: moderately critical - Orange: very critical

- Red: major

The results of this analysis are summarised in the table below on page 48.

Action Plan

Assessment of the Actions of the 2021 Vigilance Plan

l Health

- monthly monitoring of the COVID-19 crisis by the COPEX for Apave international - country-specific monitoring of epidemics, with an external company, for international travel

- for France: implementation of a Coronavirus Preven tion Plan, regularly updated by the QHSED; appoint ment of COVID-19 points of contact by company and correspondents by branch

l Security (Africa and Middle East regions)

- implementation of a Group security management system, including monitoring, tracking, audits and a travel security policy

- local security plans, as required (e.g., Mozambique, Senegal, Oman, etc.)

- monitoring of security by country, with an external company, for international travel

Topic

Risk North Africa SubSaharan Africa

Asia India Middle East Europe (outside France)

France Service providers and subcontractors

Environment

Protection of people

GHG Paper Specific pollution Safety Workplace health

Human Rights

Accommodation and working conditions Data protection Security Discrimination

(sources, soil) (source risks) (sources in Oman) (oil and gas level) (Oman audit follow-up)

Freedom of associa tion and expression

(1) North Africa: Morocco, Algeria, Libya, Tunisia

Sub-Saharan Africa: Cameroon, Gabon, Angola, Côte d’Ivoire, Guinea Conakry, Burkina Faso, Mali, Senegal, Ghana, Equatorial Guinea, Chad, Madagascar, Mauritius

Asia: Vietnam, China, Japan, Malaysia

Middle East: Lebanon, Abu Dhabi, Qatar, Oman

Except CND sources, geothermal energy

(for some nationalities) DP in Spain and Italy

Europe (except France): North Macedonia, Serbia, Croatia, Italy, Belgium, Hungary, Spain

(2) except North Macedonia with medium risk

NB: subsidiaries in Latin America are not evaluated (very few people)

4 risk levels Minor Moderately critical Very critical Major

l Discrimination

- creation of a poster reminding people of the rules of the code of ethics and the possibility of reporting dis crimination through the reporting procedure. Poster published in Vietnamese and Arabic.

l Freedom of Association and Expression

- reminder of the code of ethics (e-learning...) and of the possibility of raising an alert on this subject via the reporting procedure (translated into local language). Poster produced in Vietnamese.

2022 Action Plan for Major Risks

l Security (Sub-Saharan Africa region)

- local audits and security plans: Niger, Ghana, Equa torial Guinea, Madagascar.

l Discrimination (Middle East and Other Regions)

- management reminder, - Group campaign against sexism and discrimination.

l Freedom of Association and Expression (Asia Region)

- reminder of the code of ethics: roll out of an e-learning module in Vietnamese.

Other Risks

- security: sale of the Lebanese operation

- data protection in Spain and Italy: CISO and DPO action plan

- health: raising awareness of vaccination against COVID-19, depending on the context of each country

- specific pollution in India: safety and technical audit on source management

- paper consumption (North Africa, India and Europe): development of information systems

- GHG: action plan to be implemented following the group GHG assessment.

Evaluation of Subsidiaries

In addition to the various external audits required for its certifications and accreditations, the Group’s subsidiar ies are regularly audited by four bodies: l the QHSE Department, which carries out audits that include, among other things, reviews of ethics, relations with subcontractors, environmental protection and the health and safety of employees, l the Audit and Compliance Committee, which oversees the proper implementation of, and compliance with, ethical and anti-corruption codes, l the Security Department, which conducts audits of Group entities to ensure that protection against phys ical and logistical threats is in place, l Internal Control, which audits compliance with all other Group directives and procedures. These bodies conduct audits directly, but also rely on networks of managers and correspondents (HSE, Com pliance, Security and Internal Control) who carry out first-level checks and/or audits within their entities.

Depending on the scope of each of these bodies, the action plan linked to the vigilance plan will be integrated into their audit grids, to the extent possible.

Evaluation of Suppliers and Subcontractors

Given Apave’s activities, the risk related to subcontract ing and suppliers has been considered minor in its mapping, as subcontracting is relatively marginal and purchases are not very significant for Apave’s services. However, specific actions have already been taken that include elements of the vigilance plan.

Actions undertaken and monitored

l Through its “Responsible Purchasing Charter”, Apave defines the social and environmental criteria it takes into account when selecting its suppliers. This system has been strengthened with the introduction of an “Apave Supplier Relationship Charter”, signed between Apave and its main suppliers and subcontractors (sales of more than €100,000), which formalises their mutual commitments, taking into account environmental and social criteria.

l Since 2019, Apave has been working with the inde pendent service provider ECOVADIS to evaluate the top 100 suppliers in terms of sustainable development and social responsibility.

l 95 suppliers have been assessed to date, with 18 in progress. 80% of the suppliers evaluated are at least Silver level and 52% of the suppliers evaluated are Gold and Platinum level.

l Apave has signed a contract with the service provider Provigis to collect a set of “regulatory” documents from its suppliers and to have those considered critical sign an ethics questionnaire in compliance with the Sapin II law.

l

Of the 1,691 suppliers >€5k, 79% are up to date with regulatory documents, 77% have provided a certificate of liability insurance (document added in 2022), 55% of the service providers concerned have completed the Sapin II law ethics questionnaire and 73% of the service providers concerned have signed the Apave Supplier Relationship Charter.

l With regard to safety, Apave ensures that subcontrac tors comply with the health and safety rules defined by the Group, while subcontractors remain responsible for their own safety. The safety instructions and cam paigns that Apave carries out for its employees are communicated to the subcontractors concerned.

Alert and Reporting Mechanism

As part of the Group’s Compliance Program, Apave has set up a system for reporting facts, conduct or situations that are contrary to the Group’s code of ethics and anti-corruption code. This system is operated via a secure platform managed by a trusted third party responsible for collecting reports in order to ensure their independ ent and effective processing. This system has been extended to all subjects covered by the law on the duty of vigilance. It is accessible to all employees, but also to suppliers and subcontractors. The procedure is online on our website: https://www.apave.com/fr-FR/Le-Groupe/Nos-valeurs

Monitoring of the Vigilance Plan

The Vigilance Committee is responsible for monitoring the application of vigilance measures and evaluating their effectiveness.

Once a year, an assessment is carried out by the Vigilance Committee to verify the implementation of the action plan linked to the vigilance plan. The Vigilance Commit

tee is notified of any new acquisition of an entity or of a foreign establishment within the Group, in order to assess the impact and risks.

The vigilance plan is updated at least once a year, when the annual CSR report is published, taking into account new risks, activities or locations.

Annexes

Rapport RSE et DPEF du Groupe Apave 2021 55

2021 Apave Group CSR Report

Tables of CSR Results

This section presents various CSR data for the year 2021. The scope of calculation is indicated next to each data item. The methods for calculating and collecting the figures are specified in memo QHSED.22.005

Indicator

Workforce

Gender breakdown

Age breakdown

Social Data

Data scope: UES Apave (see table opposite)

Breakdown by seniority

2021 data

Women

Men

Under 35 35 - 55 Over 55 Less than 6 years 6 - 15 years More than 15 years

Proportion of permanent contracts Organisation of working time Recruitments Layoffs

Average annual remuneration for all socio-professional categories Internal training

Youth training

Functioning of employee representative institutions

Proportion of part-time employees

Number of training hours

7,263 95.7% 1,220 72 €37,408

Number of hours per beneficiary

Proportion of employees who have received training % of payroll devoted to lifelong learning

Number of work-study students

Number of trainees

Number of meetings

29% 71% 24.3% 58.2% 17.5% 41.4% 25.7% 32.9% 187,790 30.88 79.8% 3.1% 114 103 192

Proportion of employees with individual schedules 6.7% 13.8%

Environment

Data perimeter: APAVE SA + SAS. (see table opposite)

2021 data Indicator

Energy

Electricity consumption

Electricity consumption per €k of turnover

Gas consumption

Gas consumption per €k of sales

Fuel consumption

Fuel consumption per €k of turnover

Paper consumption

Total mass of copy paper purchased

Paper consumption per €k of turnover

Print production Waste Recovery of toners and print cartridges

Number of sheets 3.13 t

Number of toners collected

Mass collected and processed Natural resources saved

Energy consumption saved CO2 emissions avoided

GHG assessment

Total emissions Emissions per practitioner per day of intervention

Main sources (scopes 1 and 2): - vehicle fleet (90%) - fossil fuel heating installations (7%)

Societal and Ethical

Data perimeter: APAVE SA + SAS. (see table opposite)

Gender equality

Number of women on the Apave Board of Directors

Number of female branch managers

Gender equality Index

Disability

Percentage of disabled workers

10.17 GWh 15.6 kWh/€k turnover 7.18 GWH 11 kWh/€k turnover 6.3 million litres 9.7 l/€k turnover 165.78 t 249 g/€k turnover 30 million 1,133 623 kg 2,012 kg 4 MWh 203 kg 34.075 TeqCO2 26.5 kg 5/16 6 94/100 3.4%

Health, Safety and Environment (HSE) Policy

Acting as a trusted partner to make the world safer, more sustainable and a source of shared progress

This is the Purpose of our Group. It is the basis for the actions we take on behalf of our employees and customers in the areas of health, safety and the environment in order to preserve human life and ecosystems.

Safety

We have set ourselves the goal of “Zero Accidents” by strengthening a common HSE culture and implementing an active risk prevention policy at all levels of the company:

l management and all managers make safety a key factor in the performance of their teams, l all Apave employees (managers, supervisors, administrative staff, functional staff, sales staff) take a proactive role in ensuring their own safety on a daily basis and apply our eight safety principles on the road, at our customers’ sites and at our premises.

Health

We are committed to improving quality of life at work for our employees and fighting

against occupational diseases, in particular by limiting and managing exposure to dangerous substances (ionizing radiation, chemical products, etc.).

Environment

We are taking action to: l reduce our waste and greenhouse gas emissions and prevent any risk of pollution, l encourage local initiatives to protect the environment, l develop socially and environmentally responsible solutions for our customers.

Towards Shared Progress

We are committed to: l combating risks at source, analysing, reducing and preventing them in collaboration with our stakeholders (employees, social partners, customers, subcontractors, etc.), l complying with ISO 45001, MASE, CEFRI-E and ISO 14001 standards, l keeping up to date with regulations and other compliance obligations, applying them and verifying their application, l pursuing our continuous improvement approach in terms of HSE by setting annual HSE objectives defined during management reviews.

Each Apave Group employee, through his or her daily actions, professionalism, initi ative and adaptability, is a key player in meeting these commitments, which are at the heart of our Corporate Purpose and our Boost 2025 strategic plan.

Verification by an Independent Third Party

Report of the independent third party on the consolidated statement of non-financial performance included in the management report

Fiscal year ending December 31, 2021

To the Shareholders

In our capacity as an independent third-party auditor, and a statutory auditor of the company APAVE, accredited by COFRAC Inspection under number 3-1321 (scope of accreditation available at www.cofrac.fr), we have performed work designed to provide a reasoned opinion expressing a moderate level of assurance on the historical information (recognised or extrapolated) of the consolidated non-financial performance statement, as well as, at the request of the company and outside the scope of accreditation, a reasonable assurance conclusion on a selection of information, prepared in accordance with the procedures of the entity (hereinafter referred to as the “Reporting Criteria”), for the year ended 31 December 2021 (hereinafter the “Information” and the “Statement” respectively), presented in the Group’s management report pursuant to the provisions of Articles L. 225-102-1, R. 225-105 and R. 225-105-1 of the French Commercial Code.

Conclusion

We have detected anomalies in the indicators relating to accidentology (frequency and severity rates) for Apave Nord-Ouest and Apave Parisienne, which could call into question the fair presentation of these indicators. The reporting system for these indicators needs to be made more reliable.

Based on the procedures we performed, as described in the “Nature and scope of our work” section, and on the information we obtained, with the exception of the items described above, nothing has come to our attention that causes us to believe that the consolidated statement of non-financial performance is not in compliance with the applicable regulatory requirements and that the Information, taken as a whole, is presented fairly in accordance with the Reporting Criteria.

Reasonable Assurance Report on Selected Information

With regard to the information selected by the company1, at the company’s request and on a voluntary basis, we carried out work of the same nature as that described in the paragraph “Nature and scope of the work” below for the key performance indicators and for the other quantitative results that we considered most important, but in greater depth, particularly with regard to the number of tests. The sample selected thus represents 59% of the workforce and between 54% and 63% of the environmental information. We believe that this work allows us to express reasonable assurance on the informa tion selected by the company.

Conclusion

The calculation of the frequency rate and severity rate indicators calls for the same reservation on our part as that expressed in the first part of this report. Based on our work and subject to this reservation, the information selected by the company has been prepared, in all material respects, in accordance with the Report ing Criteria.

Preparation of the Non-Financial Performance Statement

The absence of a generally accepted and commonly used framework or established practices on which to base the assessment and measurement of Information allows

1. Metric tons of CO2 equivalent per employee, kilograms of paper consumed per employee, frequency rate and severity rate of workplace accidents, number of training hours per employee, percentage of women among technical and managerial staff, percentage roll out rate (companies and employees) of “ethics and corruption” training.

for the use of different, but acceptable, measurement techniques that may affect comparability across entities and over time. Therefore, the Information should be read and understood with reference to the Reporting Criteria, the significant elements of which are presented in the Statement or available upon request from the entity’s headquarters.

Limitations Inherent in the Preparation of Information

The information may be subject to uncertainty inherent in the state of scientific or economic knowledge and in the quality of the external data used. Certain information is sensitive to the methodological choices, assumptions and/or estimates made in preparing it and presented in the Statement.

Responsibility of the Company

It is the duty of the Board of Directors: l to select or establish appropriate criteria for the preparation of the Information; l to prepare a Statement in accordance with the legal and regulatory requirements, including a presentation of the business model, a description of the principal non-financial risks, a presentation of the policies applied with regard to these risks and the results of these policies, including key performance indicators; l and to implement the internal control procedures it deems necessary to ensure that the Information is free from material misstatement, whether due to fraud or error.

The Statement has been prepared by applying the Entity’s Reporting Criteria as mentioned above.

Responsibility of the Independent Third Party Organisation

It is our responsibility, based on our work, to provide a reasoned opinion expressing a conclusion of moderate assurance on: l the compliance of the Statement with the provisions of Article R. 225-105 of the French Commercial Code; l the fairness of the historical information (observed or extrapolated) provided pur suant to 3° of I and II of Article R. 225-105 of the French Commercial Code, namely

the results of policies, including key performance indicators, and actions, relating to the main risks.

As it is our responsibility to provide an independent conclusion on the Information as prepared by management, we are not permitted to be involved in the preparation of the Information as this could compromise our independence. It is also our responsibility to express, at the request of the entity and outside the scope of accreditation, a reasonable assurance conclusion on whether the informa tion selected by the entity has been prepared, in all material respects, in accordance with the Reporting Criteria.

Our responsibility does not include expressing an opinion on: l the entity’s compliance with other applicable legal and regulatory requirements (in particular with regard to the fight against corruption and tax evasion); l the compliance of products and services with applicable regulations.

Regulatory Provisions and Applicable Professional Standards

We conducted our work described below in accordance with the provisions of Articles A. 225-1 et seq. of the French Commercial Code, the professional standards of the Compagnie Nationale des Commissaires aux Comptes (French National Institute of Statutory Auditors) relating to this work in lieu of an audit program, and the International Standard on Auditing (ISAE) 3000 (revised).

Independence and Quality Control

Our independence is defined by the provisions of Article L. 822-11 of the French Commercial Code and the Code of Ethics of the Statutory Auditors. In addition, we have implemented a quality control system that includes documented policies and procedures designed to ensure compliance with applicable laws and regulations, ethical rules and professional guidance issued by the Compagnie Nationale des Commissaires aux Comptes relating to this engagement.

Means and Resources

Our work drew on the skills of 5 people and took place between November 2021 and May 2022 over a total of 2 weeks.

We called upon our specialists in sustainable development and social responsibility to assist us in our work. We conducted seven interviews with the persons responsi ble for preparing the Statement, representing in particular the General Management, the Human Resources Department, the Health, Safety and Environment Department and the Training Department.

Nature and Scope of Work

We planned and performed our work taking into account the risk of material mis statement of the Information. In our opinion, the procedures we have performed in the exercise of our professional judgment enable us to provide a moderate level of assurance:

l we reviewed the activities of all the entities included in the scope of consolidation and the description of the main risks;

l we assessed the appropriateness of the Reporting Criteria with regard to its relevance, completeness, reliability, neutrality and comprehensibility, taking into account, where appropriate, best practices in the sector;

l we verified that the Statement covers each category of information provided for in III of Article L. 225 102 1 on social and environmental matters;

l we verified that the Statement presents the information required by II of article R. 225-105 when relevant to the principal risks and includes, where appropriate, an explanation of the reasons for the absence of the information required by the second paragraph of III of article L. 225-102-1;

l we verified that the Statement presents the business model and a description of the principal risks associated with the activity of all the entities included in the scope of consolidation, including, where relevant and proportionate, the risks created by its business relationships, products or services, as well as the policies, actions and results, including key performance indicators relating to the principal risks;

l we consulted documentary sources and conducted interviews to:

- assess the selection and validation process of the main risks and the consistency of the results, including the key performance indicators, with the main risks and policies presented, and - corroborate the qualitative information (actions and results) that we considered

the most important presented in Annex 1. Our work was carried out at the level of the consolidating entity and in a selection of entities;

l we verified that the Statement covers the consolidated perimeter, i.e., all the entities included in the consolidation perimeter in accordance with Article L. 233-16, with the limits specified in the Statement;

l we examined the internal control and risk management procedures implemented by the entity and assessed the collection process aimed at ensuring the complete ness and fairness of the Information;

l for the key performance indicators and other quantitative results that we considered the most important presented in Annex 1, we implemented:

- analytical procedures consisting of verifying the correct consolidation of the data collected and the consistency of their evolution;

- detailed testing on the basis of surveys or other selection methods, consisting of verifying the correct application of definitions and procedures and reconciling the data with supporting documents. This work was carried out for a selection of contributing entities2 and covered between 54% and 82% of the consolidated data selected for these tests;

l we assessed the overall consistency of the Statement with our knowledge of all the entities included in the scope of consolidation.

The procedures performed for a moderate assurance mission are less extensive than those required for a reasonable assurance mission performed in accordance with the professional standards of the Compagnie Nationale des Commissaires aux Comptes; the procedures performed for reasonable assurance required more extensive audit work.

Lyon, May 9, 2022

MAZARS independent third party organisation

Frédéric MAUREL Partner

Paul-Armel JUNNE Technical Partner

2. APAVE Nord-Ouest, APAVE Sud Europe, APAVE Parisienne, APAVE Alsacienne.

62 Rapport RSE et DPEF du Groupe Apave 2021 2021 Apave Group CSR Report