Business ethics

As a responsible stakeholder, the Fnac Darty Group is committed to acting with integrity. Respect, loyalty and transparency are at the heart of the Group’s daily work, with particular importance attached to embodying its values in its relations with its employees, suppliers, customers, partners and shareholders.

An ethics framework shared across the Group as a whole

Fnac Darty is vigilant and mindful of acting in line with its ethical commitments in all circumstances. The ethics framework formalizes this very commitment everywhere the Group operates:

— The Code of Business Conduct, which states the fundamental principles that should underpin everyone’s professional conduct, both as individuals and as a collective.

— The Gifts and Benefits Charter, which sets out the Group’s internal rules on accepting gifts and invitations. It aims to give employees advice on how to handle receiving a gift or invitation.

— The Conflicts of Interest Prevention Charter, designed to raise awareness on this topic. It aims to help employees avoid conflicts of interest and understand what to do when they arise.

— The Ethical Whistleblowing Line (see here)

In order to achieve the exemplary level set by the Group, Fnac Darty continues its work to continuously improve its ethical framework, reviewed regularly by the Ethics Committee.

This Committee ensures that the company is doing business ethically, particularly pursuant to the French anti-corruption law Sapin II, the French law on the Duty of Vigilance of Parent Companies and Instructing Undertakings, and the General Data Protection Regulation.

Protecting the personal data of our employees and customers

With millions of visitors each month to its shopping sites, and nearly 10 million members, the protection of personal data is at the heart of Fnac Darty’s challenges.

The protection of customer data involves ensuring greater transparency in the use of data collected by the brands as well as legitimate, proportionate and secure use. Customer confidence – which is essential for the Group – necessarily involves enhanced protection of their data, but also that of Fnac Darty employees.

For the latter, the Group has also continued to work actively in all its businesses to improve its processes in order to ensure, in an increasingly transparent way, that its employees have greater control over their data.

Preventing the risk of corruption

Under Sapin II, the Group is deploying a targeted roadmap on risk of corruption.

The prevention plan is continuously being refined and includes a specific mapping of the risk of corruption, a training program (mandatory for the most exposed employees), regular awareness-raising for all employees and controls during internal audits.

Implementing the oversight plan

Fnac Darty relies on strong ethical principles and standards in the conduct of its activities, and refers in particular to the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, and the International Labour Organization’s Fundamental Conventions. The Group also adheres to the United Nations Global Compact, of which it is a signatory and whose principles it promotes.

Since 2018, Fnac Darty has published a summary of the implementation of its Oversight Plan annually. This plan includes a risk mapping covering any serious violations of human rights and fundamental freedoms, or to human health and safety, and the environment, that could be committed by the Group or by the third parties with whom it maintains lasting relationships.

In order to involve employee representatives in this oversight process, a special working group was set up with elected representatives from each country.

Ethical whistleblowing and compliance platform

In 2021, Fnac Darty launched an outsourced ethics whistleblowing and compliance platform to complement the usual communication channels: report.whistleb.com/en/portal/fnacdartygroupe

Managed by a third-party company, this ethics whistleblowing platform lets employees and external stakeholders confidentially and securely file reports about:

— professional misconduct, illegal conduct pertaining to accounting, finance or corruption, and breach of competition law;

— health, hygiene and safety, and discrimination or harassment in the workplace;

— concerns regarding the protection of the environment;

— health, hygiene and safety, and human rights or environmental protection in regard to a partner or supplier.

These reports are sent immediately and exclusively to the authorized people, who decide what measures to take and ensure that each case is followed up in accordance with the applicable legislation and the Group’s ethics rules.

Implementing a policy of responsible indirect purchasing

Aware of the social and environmental impacts of its indirect purchasing, the Group has committed itself to a global and sustainable performance approach for the Company and for the stakeholders within its ecosystem.

To this end, the Indirect Purchasing Department has made commitments specific to its activities:

— to be a responsible purchaser with respect to suppliers and work toward the continuous improvement of purchasing practices by developing sustainable and balanced relationships with suppliers;

— to contribute to the achievement of the objectives set out in the Group CSR roadmap in terms of climate change and the sustainability/recyclability/eco-design of products by integrating social and environmental responsibility within purchasing processes;

— to encourage the Group’s partners to develop a CSR approach by promoting and following the approaches and initiatives of Fnac Darty suppliers

In January 2022, the Médiation des Entreprises (French business ombudsman) awarded Fnac Darty the “Relations Fournisseurs & Achats Responsables” (Responsible Supplier Relations & Purchasing) label for its indirect purchasing for a period of three years, thus welcoming the Group into the community of 65 companies distinguished by public authorities for the sustainable and balanced relations they maintain with their suppliers on a daily basis.