Ethics and Compliance Charter
Preamble
The company conducts its business in compliance with the law and in accordance with the principles of integrity, fairness, transparency, and accountability. The purpose of this charter is to prevent the risks of corruption, fraud, conflicts of interest, violations of fair competition, breach of contract, and breaches of confidentiality. It applies to all employees, executives, temporary staff, service providers, and, more broadly, to any person acting on behalf of or for the company.
Article 1 — Principles of Conduct
Every employee must act with honesty, loyalty, impartiality, and professionalism. All decisions must be made in the best interests of the company, without seeking personal gain or undue favors. Unethical conduct may result in disciplinary, civil, or criminal liability for those responsible.
Article 2 — Compliance with the Law
The company and its employees comply with all applicable laws and regulations, including those relating to anti-corruption, trade, sanctions, competition, data protection, and labor law.
Article 3 — Trade Relations
Relationships with customers, suppliers, carriers, intermediaries, and partners must be based on objective criteria. Business commitments must be realistic, verified, and documented. Any information provided to a third party must be accurate, complete, and not misleading.
Article 4 — Combating Corruption
It is strictly prohibited to propose, promise, offer, solicit, or accept an improper benefit in order to obtain or retain a contract, expedite a decision, or influence a third party. Facilitation payments, even in small amounts, are prohibited. Intermediaries, agents, and business introducers may only be used if they have undergone due diligence and are bound by a formal contract.
Article 5 — Gifts, Invitations, and Benefits
Gifts, invitations, meals, travel, or other benefits must never influence—or appear to influence—a business decision. Cash benefits are prohibited. Gifts of minor value may be accepted only occasionally, provided they are in keeping with professional courtesy, transparent, and unrelated to any pending decision. Any benefit exceeding the threshold set by the company must be declined or reported in accordance with internal procedures (Gifts and Invitations Policy).
Article 6 — Fair Competition
The company prohibits all anti-competitive practices, including price-fixing, market-sharing, the exchange of sensitive information with competitors, and predatory conduct. Employees must exercise caution at trade shows, professional associations, industry negotiations, and informal discussions.
Article 7 — Customs Compliance
Every import or export transaction must be properly documented, with accurate information regarding the nature of the goods, their origin, their value, and their classification. The company ensures the accuracy of customs declarations and the retention of the supporting documents required for customs clearance.
Article 8 — Conflicts of Interest
Every employee must immediately report any actual, apparent, or potential conflict of interest. In the event of a conflict of interest, the person involved must recuse themselves from participating in the decision, negotiation, or approval of the matter.
Examples of conflicts of interest:
- Friendly or personal connection: An employee gives preferential treatment to a friend when awarding a contract, providing a service, or granting a promotion.
- Gifts, invitations, or perks: An employee gives preferential treatment to a business partner who offers him or her gifts, trips, meals, or services.
- Dual employment: An employee engages in an outside activity—such as consulting or serving on a board—that competes with the company.
- Use of Inside Information: An employee uses confidential information for personal gain or for the benefit of a third party.
Article 9 — Social and Environmental Responsibility
The company is committed to promoting respect for human rights, core labor standards, and environmental protection throughout its supply chain. It avoids working with partners whose practices are clearly contrary to these principles.
Article 10 — Confidentiality
Commercial, financial, legal, technical, and personal information is strictly confidential. It may be disclosed only to authorized individuals and solely for the purposes of the assignment. This obligation remains in effect after the termination of the employment contract or the assignment.
Article 11 — Reporting Violations
Every employee must report, in good faith, any suspicious behavior or conduct that violates this charter. The company provides an accessible, confidential internal reporting system that ensures reports are addressed within a reasonable timeframe. Whistleblowers are entitled to the protections provided by French law when they act in good faith and without direct financial compensation.
Article 12 — Implementation
Management ensures that the charter is distributed, that teams receive training, and that the rules are effectively enforced. Each employee acknowledges that they have read the charter and agrees to comply with it. Management may conduct random checks.
Article 13 — Penalties
Any violation of this code may result in corrective, disciplinary, contractual, or legal action, depending on the severity of the violation and applicable law. No violation will be tolerated if it exposes the company, its employees, or its partners to legal or reputational risk.