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Whistleblower Procedure

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 This Whistleblower Procedure (“WP”) is an integral part of the Sonepar Code of Conduct (“SCC”) and is applicable to all Sonepar associates, worldwide, and aims at facilitating the cooperation of all in the fight against corruption at Sonepar. Also, this procedure constitutes a part of the rules and regulations of the Sonepar entity by which any associate is employed. This procedure is also open to third parties.

 Reporting procedure

 The formal reporting of an alert must be directed through the “Whistle B” alert system, on the following web site: Any reporting should include actual facts and circumstances, and documents if available.

 Acting in good faith

Any associate filing a complaint about a violation of the SCC must act entirely in good faith, in a selfless spirit and have reasonable grounds and evidence to believe that a violation of the SCC has occurred or may occur. Any filing of a complaint that, following investigation by Sonepar’s compliance resources, prove not to be substantiated and made in bad faith or maliciously, or knowingly to be false, is a serious violation of the rules and regulations of the Sonepar entity by which the aforementioned associate is employed, and could entail disciplinary measures, leading up to and including termination of employment.

 Disclosure of identity

The associate filing a complaint under the WP must disclose his identity, job title and the Sonepar entity for which he is working. The anonymity of the associate is preserved and secured. Sonepar shall take all reasonable steps to protect the associate from any harm against him resulting from such disclosure. An anonymous complaint may be examined by Sonepar according to the allegations and documents produced.

Any associate of any Sonepar entity agrees that his/her personal information and data may, in the territory of  the People’s Republic of China or any other countries or districts in the world, be collected, stored, used, treated, transferred internally or to any affiliate or designated third party of the Sonepar entity by which he/she is employed necessary for the purpose of management, performance of his or her employment contract, service agreement, any rules and regulations of such entity (including this WP) and other aspects relating to the employment relationship with such entity.


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