Compliance -

• The Dealing Code : this regulation aims to prevent insider trading and market manipulation. It contains precise terms which must be complied with by Belgacom Group directors and employees who wish to carry out stock exchange transactions involving Belgacom shares or shares of other telecommunication companies.
• The "Chinese wall" regulation and competition law: this regulation aims to ensure compliance with the rules that seek to maintain healthy competition between the telecom operators. Firstly, it hermetically separates wholesale activities from retail activities. As the incumbent operator on the Belgian telecommunications market, Belgacom is required to provide access to its network to other operators wanting to offer telecommunication products and services in Belgium. We have therefore concluded interconnection agreements with other operators and offer wholesale products and services.  This inevitably gives us access to information on the traffic routed via our network and on the products and services offered by the other operators.  This information, obtained in the framework of our wholesale activity, can of course not be used in any way to boost our retail activities. That is why a ”Chinese Wall” exists in Belgacom which seals off wholesale information from Belgacom’s retail units. The regulation describes how this Chinese Wall is organized. Secondly, the regulation aims to ensure compliance with the general rules of competition law, both at a Belgian level and at a European level. This part of the regulation concerns all employees with decision-making powers who maintain relationships with the competition, customers or suppliers or who come into contact with them.
• The regulation on Belgacom's regulatory framework: as an autonomous public-sector company in the telecommunications sector, we are subject to many laws, notably the law of 30 June 2005 transposing the European framework relating to electronic communication. The regulation dedicated to this regulatory framework sets out the rights and obligations of the Belgacom Group in that field. It is of crucial importance that these rules be complied with by all Belgacom Group employees.
• The regulation on conflicts of interest: in the exercise of their jobs or in their private life, Belgacom Group employees may face situations in which their personal interests are in conflict with those of the Belgacom Group. The regulation on conflicts of interest gives an overview of such situations, provides guidelines on how to recognize and avoid them and defines the rules which must be adhered to in case such a conflict arises.   The basic principle is that employees must always act in the interests of the Belgacom Group. It is especially important that this principle be observed in the relationships with our suppliers. It is essential that suppliers, who compete with each other to enter into a commercial relationship with the Belgacom Group, can rely on the integrity of the selection process.
• The regulation on the protection of privacy: the respect of the secrecy of telecommunications and the privacy of our customers is not just a legal obligation, it is also the determining factor for gaining and keeping their trust. The regulation on the protection of privacy contains instructions intended to protect the secrecy of telecommunications and to ensure that personal data included in databases are processed in accordance with the legal requirements.
• The regulation on the environment: Belgacom has opted to act as a corporate citizen and to adopt a responsible attitude in relation to environmental issues. We have defined an environmental policy and translated it into a regulation.
• Human rights: our Code of Conduct, values and behavior are in fact inspired by fundamental principles such as those of the Universal Declaration of Human Rights adopted by the United Nations, the European Convention on Human Rights and the United Nations Convention on the Rights of the Child.

• Clarity, accessibility and coherence of the rules: the Compliance Office aims to continuously improve the wording of the rules that apply within the Belgacom Group in order to make them clearer, simpler and more understandable.  It endeavors to make it easier to access the various regulations and to ensure that the different internal regulations form a coherent whole.
• Knowledge of the rules: the Compliance Office organizes communication and training initiatives to ensure that the players in the field know the internal and external rules that apply to their activity and to help them translate these rules into appropriate procedures and behaviors.
• Management of the risk of non-compliance: on the basis of a periodical, systematic assessment of the risks of non-compliance in the whole Belgacom Group, the Compliance Office works out prevention strategies in collaboration with the entities concerned.
• Intervention in case of non-compliance: finally, the Compliance Office intervenes if a situation of non-compliance arises.

The Compliance Office is headed by the Vice President Group Legal, who reports directly to the CEO and is directly accountable to the Chairman of the Audit and Compliance Committee. This committee assists and advises the Board of Directors within the framework of monitoring the company’s compliance with the legal and regulatory requirements and the Code of Conduct.