4.6 Report of the independent third-party entity
Independent third party’s report on the consolidated non-financial statement
To the General Meeting,
In our quality as an independent third party, accredited by the COFRAC under the number no. 3-1681 (scope of accreditation available on the website www.cofrac.fr), and as a member of the network of one of the statutory auditors of your entity (hereafter “entity”), we present our report on the consolidated non-financial statement for the year ended 31 December 2019 (hereafter referred to as the “Statement”), included in the management report pursuant to the requirements of articles L. 225 102-1, R. 225-105 and R. 225-105-1 of the French Commercial Code (Code de commerce).
RESPONSIBILITY OF THE ENTITY
Pursuant to legal and regulatory requirements, the Managing Partners are responsible for preparing the Statement, including a presentation of the business model, a description of the principal non-financial risks, a presentation of the policies implemented considering those risks and the outcomes of said policies, including key performance indicators.
The Statement has been prepared in accordance with the entity’s procedures (hereinafter the “Guidelines”), the main elements of which are presented in the Statement and available on request from the entity’s registered office.
INDEPENDENCE AND QUALITY CONTROL
Our independence is defined by the provisions of article L. 822‑11-3 of the French Commercial Code and the French Code of Ethics (Code de déontologie) of our profession. In addition, we have implemented a quality control system including documented policies and procedures regarding compliance with applicable legal and regulatory requirements, ethical requirements and French professional guidance.
RESPONSIBILITY OF THE INDEPENDENT THIRD PARTY
On the basis of our work, our responsibility is to provide a report expressing a limited assurance conclusion on:
- the compliance of the Statement with the provisions of article R. 225-105 of the French Commercial Code;
- the fairness of the information provided in accordance with article R. 225-105 I, 3° and II of the French Commercial Code, i.e., the outcomes, including key performance indicators, and the measures implemented considering the principal risks (hereinafter the “Information”).
However, it is not our responsibility to comment on the entity’s compliance with other applicable legal and regulatory requirements, in particular the French duty of care law and anti-corruption and tax avoidance legislation, or on the compliance of products and services with the applicable regulations.
NATURE AND SCOPE OF THE WORK
The work described below was performed in accordance with the provisions of articles A.225-1 et seq. of the French Commercial Code, as well as with the professional guidance of the French Institute of Statutory Auditors (“CNCC”) applicable to such engagements and with ISAE 3000(1):
- we obtained an understanding of all the consolidated entities’ activities and the description of the principal associated risks; we assessed the suitability of the Guidelines with respect to their relevance, completeness, reliability, neutrality and understandability with due consideration of industry best practices, where appropriate;
- we verified that the Statement includes each category of social and environmental information set out in article L. 225-102-1 III of the French Commercial Code, as well as information regarding respect for human rights and the fight against corruption and tax evasion;
- we verified that the Statement provides the information required under article R. 225-105 II of the French Commercial Code, where relevant with respect to the principal risks, and includes, where applicable, an explanation for the absence of the information required under article L. 225-102-1 III, paragraph 2 of the French Commercial Code;
- we verified that the Statement presents the business model and the principal risks associated with the activity of all the entities included in the scope of consolidation, including where relevant and proportionate, the risks associated with their business relationships, their products or services, as well as their policies, measures and the outcomes thereof, including key performance indicators associated to the principal risks;
- we referred to documentary sources and conducted interviews to:
- assess the process used to identify and confirm the principal risks as well as the consistency of the outcomes, including the key performance indicators used, with respect to the principal risks and the policies presented, and
- corroborate the qualitative information (measures and outcomes) that we considered to be the most important presented in Appendix 1; concerning certain risks (tax avoidance, data protection, human rights risk management for the Travel Retail division), our work was carried out on the consolidating entity; for the other risks, our work was carried out on the consolidating entity and on a selection of operational perimeters listed hereinafter: Grupo Anaya and Lagardère Travel Retail Czech Republic;
- we verified that the Statement covers the scope of consolidation, i.e., all the consolidated entities in accordance with article L. 233-16 of the French Commercial Code;
- we obtained an understanding of internal control and risk management procedures the entity has put in place and assessed the data collection process to ensure the completeness and fairness of the Information;
- for the key performance indicators and other quantitative outcomes that we considered to be the most important presented in Appendix 1, we implemented:
- analytical procedures to verify the proper consolidation of the data collected and the consistency of any changes in those data;
- tests of details, using sampling techniques, in order to verify the proper application of the definitions and procedures and reconcile the data with the supporting documents. This work was carried out on a selection of contributing operational perimeters (Grupo Anaya, Lagardère Travel Retail Czech Republic, Hachette UK and Duty Free Opérations France), covering between 13% and 24% of the consolidated data relating to the key performance indicators and outcomes selected for these tests (17% of the workforce, 24% of the paper purchased and supplied, 13% of the tertiary energy consumption);
- we assessed the overall consistency of the Statement based on our knowledge of all of the entities included in the scope of consolidation.
We believe that the work carried out, based on our professional judgement, is sufficient to provide a basis for our limited assurance conclusion; a higher level of assurance would have required us to carry more extensive procedures.
MEANS AND RESOURCES
Our verification work mobilised the skills of five people and took place between July 2019 and March 2020 on a total duration of intervention of about seven weeks.
We conducted four interviews with the persons responsible for the preparation of the Statement including, in particular, the Sustainable Development and CSR Department, the Risk and Internal Control Department, the Human Relations Department and the Tax Department.
CONCLUSION
Based on the procedures performed, nothing has come to our attention that causes us to believe that the consolidated non‑financial statement is not presented in accordance with the applicable regulatory requirements and that the Information, taken as a whole, is not presented fairly in accordance with the Guidelines, in all material respects.
COMMENTS
Without modifying our conclusion and in accordance with article A. 225-3 of the French Commercial Code, we have the following comments:
- in the context of the strategic refocusing plan, the organisation of the reporting and consolidation processes for non-financial data is being strengthened to accelerate the deployment of policies and the monitoring of performance, in particular environmental performance.
French language original signed at Paris-La Défense, 19 March 2020.
The independent third party
EY & Associés
Jean-François Bélorgey Partner
Eric Duvaud Partner, Sustainable Development
Items appearing in the Annual Financial Report are cross‑referenced with the following symbol AFR
(1) ISAE 3000 – Assurance engagements other than audits or reviews of historical financial information.
Appendix 1: Information considered the most important
| Social Information | |
|---|---|
| Quantitative Information (including key performance indicators) |
Qualitative Information (measures or outcomes) |
|
|
| Environmental Information | |
| Quantitative Information (including key performance indicators) |
Qualitative Information (measures or outcomes) |
|
|
| Societal Information | |
| Quantitative Information (including key performance indicators) |
Qualitative Information (measures or outcomes) |
|
|