Carrefour SA

Lobbying Governance

AI Extracted Evidence Snippet Source

**Responsible lobbying**

**Carrefour 2023**

The commitment of the Carrefour Group and its management bodies to
responsible lobbying is based on four pillars: integrity and transparency, ethical
principles, total political neutrality and ongoing dialogue with stakeholders.

Within the Carrefour Group, lobbying activities are the responsibility of the
Group's General Secretary (COMEX member). This document applies to all
employees of the Carrefour Group and more particularly to those who are
required to act as interest representatives to public authorities. They formally
undertake to carry out their activities with probity and integrity and to respect
the following principles of transparency and ethics.

**1. Compliance with legal obligations**

The Carrefour Group complies with the legal obligations applicable to interest
representatives in liaison with the French High Authority for the Transparency of
Public Life (HATVP). In addition, under the impetus of its Executive Committee,
the Carrefour Group supports the promotion of transparency and integrity issues
around responsible lobbying in the context of its activity. The Haute Autorité
pour la Transparence de la Vie Publique (HATVP) defines interest representation
or lobbying as the act of coming into contact with those responsible for drafting
and voting on laws and leading the State's action (in ministries, in Parliament,
but also in local administrations) in order to influence their decisions.

- The Carrefour Group complies with the legal obligations relating to
the representation of interests, in particular those laid down by :

- French Law 2016-1691 of 9 December 2016 on transparency,
the fight against corruption and the modernisation of
economic life, in particular Article 25 on the declaration of
interest representation actions with French public officials on
the digital directory of the Haute Autorité pour la
Transparence de la Vie Publique (HATVP);

- French law 2013-907 of 11 October 2013 on the
transparency of public life;

- the Decree of 9 May 2017 on the digital directory of interest
representatives amending Article 18 of Law 2013-907 of 11
October 2013 on transparency in public life.

- Carrefour Group employees acting as interest representatives to public
authorities are identified in a dedicated internal register that is regularly
updated and expressly state that they speak on behalf of the company
during their institutional contacts.

- The Carrefour Group's interest representatives declare their influential
communication actions with regard to public officials at national level to
the Haute Autorité pour la Transparence de la Vie Publique (HATVP) on an
annual basis.

- The Carrefour Group keeps a register of meetings between interest
representatives and public officials.

- Employees who represent interests at national level must inform their
superiors in the event of any actual or potential conflict of interest that
could affect the relationship between the Carrefour Group and public
decision-makers involved in public policy decision-making.

- The Carrefour Group complies with the obligations arising from the codes
of conduct of the professional and trade organisations of which it is a
member.

- The Carrefour Group promotes the adoption of best practice in lobbying
within the professional associations in which it participates.

- The Carrefour Group is listed in the transparency register of the European
institutions.

- Any person who is aware of situations or behaviour that contravene the
Carrefour Group's ethical principles can report them in complete
confidentiality 24 hours a day, 7 days a week via the alert channel
http://ethique.carrefour.com. The Carrefour Group undertakes to handle
all the reports it receives in accordance with the law.

**2. Ethical principles and the fight against corruption**

- In its Ethical Principles, the Carrefour Group has defined a framework
within which Group employees must carry out their professional activities
on a daily basis. The fight against conflicts of interest, corruption and
influence peddling are pillars of this ethical approach.

- The rules applicable to "Gifts and Invitations" adopted by the Carrefour
Group are based on exemplarity, transparency and balance in the
relationship with third parties.

- Any attempt to obtain information or decisions by using inappropriate
pressure is prohibited.

**3. Relations with public authorities**

The Carrefour Group interacts with the public authorities in the countries where
it is present in compliance with local legislation. The Carrefour Group does not
make any contributions to political parties, politicians and related institutions or
organisations raising political funds.

**4. Dialogue**

The Carrefour Group encourages dialogue with national and local public
authorities, as well as with civil society stakeholders (trade unions, NGOs,
citizens' associations, etc.). This dialogue is open and there are no strings
attached to any action that may be taken.

The dialogue and lobbying activities carried out by the Group are described in
the appendix to this document.

**APPENDIX: Table of the Carrefour Group's lobbying activities**

Carrefour openly declares its commercial interests and the amount of
contributions paid by the Group.

--NEW-PAGE--

|Col1|Consistency with the Paris Agreements|Governance function|Financing via a membershi p fee|Financing other than through contributi ons|Amount of funding|
|---|---|---|---|---|---|
|European and worldwide recognition||||||
|Global Compact|🗹||🗹||30 k€|
|Eurocommerce|🗹||🗹||63 k€|
|CGF|🗹|🗹|🗹||155 k€|
|Ellen Mac Arthur Foundation|🗹||🗹||40 k€|
|WWF|🗹|||🗹|100 k€|
|FIDH|||||30 k€|
|National recognition||||||
|Open Agrifood|🗹|🗹|🗹||40 k€|
|Perifem|🗹|🗹|🗹||34 k€|
|FCD||🗹|🗹||2 000 k€|
|AFEP|🗹||🗹||77 k€|
|France Logistique|||🗹||10 k€|
|FEVAD|🗹||🗹||26 k€|
|ARPP|||🗹||17 k€|
|UDM|🗹||🗹||57 k€ excl.|
|FACT (formerly CNCC)|🗹||🗹||1 k€|

https://www.carrefour.com/sites/default/files/2024-07/Responsible%20lobby.pdf

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]The Group Sustainability Development Director is in charge of the relations with stakeholders and of lobbying actions. He is working along with business department managers (merchandise assets and not for sale assets, public affairs) and is relying on the Deputy CEO and General Secretary to ensure that the Group's strategy is deployed throughout the Group and through external engagements. He defines and coordinates the implementation of the Group CSR strategy and internal/external engagements, including the involvement on Climate Change. Each business departments appoints a committee responsible for the projects monitoring and reporting. An annual report per country/Business Unit is deployed in order to check the projects' progress and the alignment with the Group's overall climate strategic goals change strategy. This process also allows the prevention of potential conflict in the future.

CDP Questionnaire Response 2022

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes

CDP Questionnaire Response 2023

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]The Sustainability Director is in charge of the relations with stakeholders and of lobbying actions. He is working along with business department managers (merchandise assets and not for sale assets, public affairs) and is relying on the CEO to ensure that the company strategy is deployed throughout the business and through external engagements. She defines and coordinates the implementation of the Group CSR strategy and internal/external engagements, including the involvement on Climate Change. An annual report is deployed in order to check the projects' progress and the alignment with the Group's overall climate strategic goals change strategy. This process also allows the prevention of potential conflict in the future.

CDP Questionnaire Response 2023

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes

CDP Questionnaire Response 2023