PERSPECTIVA DE GÉNERO EN EL PROyECTO COHOUSING

In order to comply with all applicable laws and regulations, the Group has developed compliance procedures with respect to antitrust and laws and corruption risk.

4.5.3.1 Compliance with Antitrust Laws

The Group’s goal is to preserve dynamic, healthy and honest competition.

To that effect, in 2011 the Group instituted an antitrust law compliance program, piloted by the Group’s Legal Department and outside experts. This program is intended to ensure strict compliance by the Group’s employees with competition laws, regulations and rules.

This program is deployed in a consistent and continuous manner, on a worldwide basis, through distribution of the antitrust policy and through numerous events promoting sensitivity to competition issues. It is applicable in all of the countries where the Group operates and covers all of its activities, including where such activities are carried out through joint ventures.

Local legal departments participate actively in verifying that local competition regulations are followed in each of the geographical regions where the Group operates.

4.5.3.2 Prevention of Corruption and Fraud

The prevention of corruption and fraud is one of the Group’s major priorities as it is for all of its employees. Given the diversity of contexts in the geographic regions in which the Group operates and the significance of investments made, the Group is particularly vigilant against the risks of corruption and fraud. Although the large majority of the Group’s customers in the most sensitive countries operate in the private sector, where corruption is less present than in the public sector, the Group is not immune from a potential instance of corruption.

In 2012, supervised by the Group’s Legal Department and with the cooperation of the local legal departments, the Group launched a specific action plan to fight corruption.

In connection with this action plan, the Group has put in place anti-corruption policies, presented in-person and electronic anti-corruption training and issued guidelines covering the delivery and receipt of gifts and relationships with intermediaries.

The fight against fraud is carried out as part of the Group’s financial and internal control processes, and verifications are carried out by the Audit and Internal Control Department. To that effect, fraud prevention and detection guidelines have been distributed to raise awareness of these issues.

4.6 INSURANCE AND COVERAGE OF RISKS

The Group’s policy with respect to insurance is coordinated by the Legal Department, which is responsible for identifying the main insurable risks and quantifying their potential consequences.

This policy has the following objectives:

• limit certain risks by recommending preventive measures in cooperation with the Group’s other departments; or

• choose to cover risks of an exceptional nature through insurance, including risks with high potential magnitude but low frequency.

In connection with the insurance program, the Group actively mitigates industrial risks, by collaborating with FM Global, its property and casualty insurer, which provides expertise in engineering and fire prevention.

Each of the Group’s subsidiaries is responsible for providing the Group’s Legal Department with the necessary information to identify and quantify insured or insurable risks at the Group level, and for implementing the proper methods to ensure business continuity if an event occurs. On these bases, the Legal Department negotiates with the major insurance and reinsurance providers to put in place optimal insurance coverage for its risk-coverage needs.

The Group’s local subsidiaries also enter into local insurance policies to cover risks suited to local coverage, such as automobile insurance.

The Group purchases insurance based on reasonable estimates of probable liability resulting from tort, property-casualty and other risks. This evaluation takes into account the analyses of insurance companies as the risk subscribers. The Group does not insure against risks for which there is no coverage available on the insurance market, for which the cost of insurance is disproportionately high compared with the potential benefit or for which it believes the risk does not require insurance coverage.

The Group’s insurance programs generally take the form of master policies. These are complemented by local policies in certain countries where having only master policies is not permitted. The master insurance policies apply to the Group’s overall operations, complementing local policies (difference-in-conditions/difference in limits, or “DIC DIL”), if the coverage in question proves insufficient or does not cover the event. The local policies are also entered into to take into account local legislative specificities or constraints in the country or countries in question. The Group also has captive insurance companies, enabling it to reduce the premiums paid to insurers and thus to reduce its insurance costs.

The Group’s insurance policies contain exclusions, caps and deductibles that could expose it to unfavorable consequences in the event of a significant event or legal action against it. Moreover, it may be required to pay indemnification that is not covered by its insurance policies or to incur significant expenses that may not be covered, or may be insufficiently covered, under its insurance policies.

The Group’s primary insurance policies, entered into with insurance companies of international reputation, are the following:

• general liability insurance, which includes operational liability coverage and product liability coverage. The maximum coverage amount is €60 million. Professional liability insurance is also included in this policy, and is subject to a specific limit.

General liability insurance covers all damages caused to third parties, such as bodily, tangible and intangible damages;

• property-casualty and business interruption insurance (maximum combined coverage of €400 million). All of the Group’s facilities are covered by this policy if and to the extent that values of local sites exceed the contract deductibles;

• director and officer liability insurance;

• environmental liability insurance; and

• transport insurance, covering inventory and inventory in transit.

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