65SUEZ

Supervised by the Board's Ethics and Sustainable Development Committee, the SUEZ ethical approach is based on adherence to the Group s ethical values in all the Group s activities, both in internal relationships within the Company, and in its relationships with clients, suppliers and all external stakeholders.

A STRONGER FRAMEWORK IN LINE WITH THE IMPLEMENTATION OF THE VIGILANCE PLAN SUEZ has made ethics an essential aspect of its plan to improve its global performance, based on the fundamental principles of compliance with laws and regulations, integrity, loyalty, honesty and respect for others. Respect for these principles is essential in all the Group's activities, including both internal relations between employees and external relations with customers, suppliers and all outside stakeholders. To ensure this compliance, the Group has introduced an ethical framework based on three pillars: An Ethics Charter supplemented by an Ethics in Practice

Guide and a Guide to Ethics in Commercial Relations. These documents are available in eight languages and supplemented by a set of internal procedures; Specific governance including the Ethics and Sustainable

Development Committee, the Board of Directors, the Ethics and Compliance Committee and the network of ethics officers; Ethical reporting instruments.

The Group established an Ethics and Compliance Division in 2017, following the recommendations published by the French anti-corruption agency. The Ethics and Compliance Director, reporting to the Group Ethics Officer and General Secretary, coordinates a network of 19 ethics officers, whose scope has been widened to ensure it corresponds to the Group's operational organisation.

Specific training, supplemented in 2017, by case studies in e- learning format aim to increase corruption risk prevention while taking into account the specific circumstances of each location. Training adapted to employees who are most

exposed will continue in 2018, based on a corruption risk mapping conducted at the Group and Business Unit level after the Sapin 2 Law took effect.

The Group s audit plan, which provides for systematic reviews of its entities at regular intervals, includes ethics as a compulsory theme in various reviews, such as training activities, the operation of alerts and, more generally, the application of corporate social responsibility regulations.

ANTICIPATING EXPECTATIONS OF TRANSPARENCY IN LOBBYING ACTIVITIES The Group is listed on the European Union Transparency Register. In particular, it publishes information annually on the European Commission website. This includes the Group's fields of interest, membership of associations linked to the European Union, the amounts and sources of funding received from European Union institutions and the costs of advocacy at the European institutions (staff and travel costs, contributions to professional associations, external service providers). In 2017, these costs were between 800,000 and 899,000 euros.

In France, the Group is registered with the Higher Authority for Transparency in Public Life (HATVP) in accordance with the Sapin 2 act. Since April 2018, this registration has included annual reporting on all its lobbying activities to public institutions and the associated costs.

Much of the spending on these activities comes from SUEZ's membership of national and international associations this represented 300,000 euros in 2017 in France, for example.

GOVERNANCE

AN ETHICAL FRAMEWORK TO MATCH THE GROUP'S NEW ORGANISATION