CHAPTER 3 We advance in sustainable performance

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CULTURE OF ETHICS

Awareness-building is essential when integrating ethical principles into our daily lives and we undertake various initiatives to raise awareness of ethical issues, such as:

VI Ethics Day We celebrate the VI Ethics Day by exploring the ethical challenges posed by the de- velopment and use of new technologies such as artificial intelligence, the conclusion being that ethics must be present from the very design of technologies. We have also recognised our professionals special commitment to ethics by means of the Com- pliance Believers 2021 award ceremony, which was closed by the independent direc- tor and Audit, Compliance, Ethics and Risk Committee chair.

Ethics opinion survey We launched a survey of all our employees to receive feedback on our ethics model and whistleblower channel. Through initiatives of this kind, the company seeks to fos- ter employee engagement with our commitment to ethical behaviour. Where room for improvement was identified, action plans have been put in place.

World Whistleblower Day On World Whistleblower Day, the work of those who step forward to report wrongdoing and help improve company integrity was recognised. The importance of reporting any irregular conduct was recalled, stressing that there is a safe, confidential and retaliation-free channel for bona fide whistleblowers.

Taking stock of the Ethics and Compliance Channel Initiative organised to communicate the results of the Ethics and Compliance Channel's activity in 2020.

Communication of the updated 'Code of Ethics and Conduct and compliance policies Following the review of the 'Code of Ethics and Conduct' and compliance policies, carried out in 2021, the entire organisation received news of the Board of Directors approval on 3 November.

Ongoing ethics and compliance training for employees and suppliers To ensure knowledge of and compliance with our ethical principles, we launched training and awareness-raising initiatives, both online and face-to-face, which were attended by 488 employees and 344 suppliers in 2021.

APPENDIX 4.12. Ethical

management

We have a compliance management system including the prevention and management mechanisms needed to address risks of non-compliance or inappropriate behaviour.

3.8.2 A robust compliance management system