SASB Report 2020

Anti-corruption There were no cases of corruption within the Prysmian Group during the two-year period 2019-2020. With regard to and in accordance with the three-year non-prosecution agreement (“NPA”) signed by General Cable with the U.S. Department of Justice (“DOJ”) in December 2016 and the related disclosure made to the U.S. Securities and Exchange Commission (“SEC”) regarding violations of the U.S. Foreign Corrupt Practices Act (“FCPA”), Prysmian submitted the final report to the above Authorities at the end of 2019 without receiving any requests for clarification. Furthermore, the DOJ and the SEC did not raise additional matters with regard to the above during 2020. Anti-trust On 15 April 2020, the Prysmian Group disclosed that, in the context of proceedings commenced in 2011, the Court of the Brazilian Competition Authority (CADE) had issued a ruling on the alleged anticompetitive practices of the Prysmian Group in the Brazilian market for high voltage terrestrial and submarine cables. The Court held the Prysmian Group responsible for such practices between February 2001 and March 2004 and sentenced it to pay a fine of BRL 10.2 million (about Euro 1.8 million), which is in line with the provisions recorded by the Group for this specific matter. The Prysmian Group has appealed against this ruling made by CADE. On 24 September 2020, the Group disclosed that the European Court of Justice had ruled on the appeal filed by Prysmian S.p.A. and Prysmian Cavi e Sistemi S.r.l. against the ruling of the European Court dated 12 July 2018 which, as notified to the market on that day, had upheld the decision made of European Commission dated 2 April 2014 following an anti-trust investigation into the markets for high voltage terrestrial electricity cables and for submarine electricity cables. In this ruling the Court rejected the appeal filed by the Group companies, thus confirming the responsibilities and fine specified in the original decision. In addition, during 2020, the Group made additional payments following the settlement of certain disputes promoted by third parties seeking the reimbursement of alleged losses incurred as a consequence of Prysmian’s participation in the anti-competitive conduct penalised by the European Commission (follow-on cases), as well as for legal expenses. The total cash outflow in relation to the above matters, including therefore payment of half the fine imposed by the European Commission, was about Euro 112 million. With regard to the antitrust investigations still underway, details on which are provided in section “Provisions for risks and charges” of the Explanatory Notes to the Consolidated Financial Statements 2020, it should be noted that the Group’s provisions for risks and charges amounted to approximately €120 million at 31 December 2020. Despite the uncertainty of the outcome of the investigations and legal action in progress, the amount of this provision is considered to represent the best estimate of the liability based on the information now available. SASB Report 2020