The most exposed departments identified in the URW corruption risk mapping are investment, development, public affairs, and procurement.

To secure the proper application of these rules, in the case of a tender process and over the term of a contract, the supplier can contact the URW CO at any time to raise and submit a complaint, in accordance with the Group’s whistleblowing procedure.

URW strives to reduce payment times for small and medium enterprises in its supply chain, as part of its broader commitment to fostering strong, mutually beneficial relationships with its suppliers.

The sustainability roadmap of the Group encompasses a much wider footprint than the Group itself. Being a substantial buyer, URW is aware of the importance of driving industry standards and works on integrating sustainability further in its supply chain. Given the size of its portfolio, the Group works with a large number of suppliers and contractors, and ensures it is not exposed to the risk of depending on only a few strategic suppliers. The Group has designed a Responsible Procurement Roadmap and performed a mapping of sustainability risks in its supply chain in 2021. URW became a signatory to the UNGC in 2004, thus committing to adopting, upholding and enacting within its sphere of influence the 10 universally recognised principles relating to human rights, labour laws, environmental protection and anti-corruption. In addition to this, URW annually issues a Modern Slavery Statement and has a Responsible Purchasing Charter and a Human Rights Policy covering its interactions with suppliers.

General Purchasing Conditions apply for all the countries in which URW operates, although they vary between Continental Europe, the UK and the US, according to local requirements. A clause is also automatically included in these conditions, requiring suppliers to abide by the Group’s Code of Ethics provisions, including complying with applicable laws and regulation, prevention of all forms of corruption and discrimination, respect for human dignity and for employees’ work, preservation of the environment, and reporting practices that are in breach of these principles using the contact procedure provided by the Group.

The Group has implemented robust internal mechanisms to anticipate, monitor and counter any risks of engaging in practices that could amount to corruption or bribery, such as the ACP, the Anti-Money Laundering Programme, and the Group Code of Ethics. Additionally, all employees are trained to identify and distinguish situations that could be associated with corruption, with a clear communication of the Group’s zero tolerance principle for any violation.

The Group has implemented robust internal mechanisms to anticipate, monitor and counter any risks of engaging in practices that could amount to corruption or bribery, such as the ACP, the Anti-Money Laundering Programme, and the Group Code of Ethics.

To raise awareness and entrench the compliance culture within the Group, employees are required to participate in an annual and mandatory e-training, covering ethics and compliance topics such as the prevention of corruption and influence peddling (the ACP). As of December 31, 2023, 80% of URW staff have completed the online training. In addition to the online training, the most exposed departments identified in the URW corruption risk mapping (investment, development, public affairs, and procurement) are required to attend classroom training. Several training sessions were held throughout the Group, hosted by the Local Compliance Correspondents (LCC) in local languages. Finally, an ACP training session was attended by all Supervisory Board, Management Board and Executive Committee members. The objective was to present actions implemented to comply with the Sapin II Law.

An ACP training session was attended by all Supervisory Board, Management Board and Executive Committee members. The objective was to present actions implemented to comply with the Sapin II Law.

To raise awareness and entrench the compliance culture within the Group, employees are required to participate in an annual and mandatory e-training, covering ethics and compliance topics such as the prevention of corruption and influence peddling (the ACP). As of December 31, 2023, 80% of URW staff have completed the online training. In addition to the online training, the most exposed departments identified in the URW corruption risk mapping (investment, development, public affairs, and procurement) are required to attend classroom training. Several training sessions were held throughout the Group, hosted by the Local Compliance Correspondents (LCC) in local languages. Finally, an ACP training session was attended by all Supervisory Board, Management Board and Executive Committee members. The objective was to present actions implemented to comply with the Sapin II Law.