Danone // 2020 Universal Registration Document

5 Social, Societal and Environmental Responsibility 5.1 An integrated approach of sustainable business model 149 DANONE UNIVERSAL REGISTRATION DOCUMENT 2020 RESPONSIBLE PRACTICES: ETHICS AND INTEGRITY Definition Danone works actively against corruption, bribery, payments in kind, conflicts of interest, theft, embezzlement, inappropriate use of company resources and money laundering. Policies Danone has established policies and procedures for responsible practices that apply to all its employees, its subsidiaries, the companies controlled by the Company and, in some cases, its business partners. In 2020, Danone updated its compliance framework which sets out the most important principles with regard to standards, responsibilities, organization and processes for its policies and programs. Code of Business Conduct • Based on principles derived from: • the Universal Declaration of Human Rights; • the Fundamental Conventions of the International Labour Organization; • the Organization for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises; • the UN Global Compact on human r ights, labor standards, env ironmental protection and anti-corruption. • Translated into 34 languages; • Covers a number of responsible practices-related topics, including anti-corruption, conflicts of interest, confidentiality, fraud and money laundering. Disciplinary Code for Business Conduct Breach • Applies to all employees to ensure that the Company appropriately and fairly sanctions any unethical behavior in general, and/or any breach of its Code of Business Conduct in particular. Integrity Policy • Defines the rules and responsibilities governing the conduct of every Danone employee with respect to corruption, including gifts and hospitality, sponsorships and donations, fraud, money laundering, conflicts of interest, third-party review and concerns; • Describes the expectations that must be met by specific functions, such as Executive Committee members, general managers, and directors of human resources, public affairs, medical and healthcare. Compliance Policy for Third Party Vetting • Refers to the due diligence that Danone performs on business partners, in order to evaluate and, if neces- sary, address the potential risk they may pose to the Company in relation to anti-corruption, anti-bribery and/or international trade sanction laws and regulations as well as any other criminal or unethical activity; • Applies to all third parties; • Defines the rules, responsibilities and guidance that require and enable Danone employees to follow a robust decision-making process for selecting, contracting with and monitoring third parties. Code of Conduct for Business Partners • Ensures that Danone’s business partners comply with applicable laws on bribery and corruption, money laundering, unfair competition and international trade sanctions. Competition Policy • Defines Danone’s commitment to engaging in fair competition on the merits in all its business activities in compliance with all applicable competition laws. International Trade Sanctions Policy • Defines Danone’s commitment to complying with trade, financial and other restrictions imposed by national governments and international bodies on certain sanctioned countries, entities and/or individuals. Personal Data Privacy Policy • Recognizes individuals’ fundamental right to privacy and protection of personal data; • Defines Danone’s commitment to processing personal data in a fair, lawful and transparent manner. It applies to all Danone entities worldwide, including all the subsidiaries and affiliates that are majority owned or effectively controlled by the Company, and all their employees; • Establishes the rules and responsibilities that employees and any third parties that process personal data on Danone’s behalf must abide by when managing personal data. HCS (Health Care Systems) Compliance Policy • Ensures that all interactions with health care professionals are conducted in an ethical, open, transparent and responsible manner and are in compliance with applicable laws and regulations; • Applies to all Danone employees worldwide, as well as third-party contractors who interact with the health care system. Policy on advocacy activities (updated in 2020 and available on the website) • Describes the Company’s vision of advocacy and the way it engages with external stakeholders, including the behaviors expected of its employees. In particular: • Danone interacts with governmental and non-governmental players as part of its dialogue with stakehol- ders and in the regular course of business. For example, it is listed in the registers of interest repre- sentatives of the European Union and of the French High Authority for Transparency in Public Life ( Haute Autorité Française pour la Transparence de la Vie Publique , or HATVP); • Danone does not pay any sums of money to individuals or organizations involved in politics to support their activities. As a result, no candidates or political parties receive funds or assets from the Company. • Sets out the expectation that all advocacy efforts must comply with the principles of business conduct and the integrity policy described above and also describes how Danone’s advocacy activities are monitored.