Monitoring the Vigilance Plan

Vigilance Plan

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 subcontractors comply with the health and safety rules defined by the Group, while subcontractors remain responsible for their own safety. The safety instructions and campaigns 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 independent 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 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-

Monitoring of the

Vigilance Plan

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.