Compliance
program
Responsible and committed
French anticorruption agency (AFA) guidelines
French Law Sapin 2 (dated December 9, 2016) requires companies to implement the following program:
Top management commitment
Code of Conduct
Whistleblowing system
Risk mapping
Third party due diligence
Anticorruption accounting control
Awareness and training
Internal monitoring and system evaluation
Responsible and committed
We are all holding in trust for the commitment of men and women who century over century forged the ethics and values of the Bolloré Group.
The Group prohibits all forms of corruption and influence peddling, ensures compliance with competition
laws and international sanctions programs, prevents environmental damages, health and safety risks, violations of human rights and forbids discrimination and harassment.
This Code of Conduct applies to all acting on behalf of Bolloré and I invite you to report any behavior that would be contrary to this Code to your line manager or use the dedicated whistleblowing process.
The Group ensures a confidential processing of personal data and the protection of the informer acting in good faith against any form of retaliation.
We must be exemplary and act in all circumstances with integrity to protect the reputation of our Group and ensure a sustainable success.
Cyrille Bolloré
Chairman and Chief Executive Officer
Bolloré Compliance program - 1
Our compliance program
2 - Bolloré Compliance program
Bolloré Group intends to comply with all applicable laws regarding fight against corruption, international sanction, anticompetitive practices and the expectations of its stakeholders. The Group is monitoring compliance with this commitment and created a Program inspired by international standards such as AFA, US FCPA and OFAC standards.
This document specifies how this program is implemented.
Bolloré Compliance program - 3
Top management commitment
Bolloré Top management is committed
to comply with laws and regulations governing the fight against corruption and strictly prohibits bribery or any other improper payments in business dealings.
On the right, Philippe Labonne and Thierry Ehrenbogen for the International Anticorruption Day in 2018.
Code of Conduct
The Group is signatory of the United Nations Global Compact since 2003, a voluntary initiative supporting companies to align their strategies and operations with ten principles on human rights, labour, environment and anti-corruption; These principles are specified in our Code
of Ethics and our Code of Conduct outlines the behaviors that must be followed to comply with them. Integrity in the conduct of our business is a key element of our Code of Conduct, which all subsidiaries, directors, employees and business partners acting on behalf of the Group must comply with.
This code promotes the fight against corruption in all its forms and against influence peddling, but also fair competition, compliance
with economic sanctions, diversity and environmental protection.
4 - Bolloré Compliance program
Whistleblowing system
The Group whistleblowing procedure may be used by any employees of the Bolloré Group or its business partners, and any individual whose interests may be affected by the Group's activities.
Notably, Employees having knowledge
of misconducts that may constitute violation of the Group's Code of Conduct can report to their line Management or alternatively use the dedicated process.
Risk mapping
Corruption risk mapping were achieved in order to implement action plan
to mitigate risk identified.
Bolloré Compliance program - 5
Third party due diligence
As part of our vetting process we check that our suppliers, subcontractors and other business partners comply with our Code of Conduct and we evaluate them through a risk-based approach.
Anticorruption accounting control
These controls were identified during the risk mapping process. These specific controls are exercised through different level of the organization.
6 - Bolloré Compliance program
Awareness and training
We ensure that our employees have a sound understanding of the Code of Conduct
and we specifically train employees identified as exposed. Sessions are organised
in classrooms and via e-learning online platform, to promote the Code of Conduct and the whistleblowing system.
Internal monitoring and system evaluation
A compliance dedicated reporting collecting information on our subsidiaries, their business, shareholders, directors, employees and business partners.
Bolloré Compliance program - 7
Our anticorruption
system in 2020
In compliance with Sapin 2 Law,
we intent to achieve the adaptation of our anticorruption system by 2020.
February | June |
2018 | 2018 |
Phase 1 | Phase 2 | |||
Analysis of the | Implementation | |||
situation regarding | of transitional | |||
the AFA guidelines | measures and | |||
mid-term actions | ||||
From project…
8 - Bolloré Compliance program
Four key topics of the project
Risk
mapping
Blue Solutions plan
Specific action deploymentCompliance reporting
November | January |
2019 | 2020 |
Action
plan
Phase 3
Mid-term action's deployment
Compliance network and training
… to operations | Key project owners |
CEOs/BU Project
coordinators,
support functions,
external experts
Bolloré Compliance program - 9
Key figures
on compliance
Whistleblowing system
France e-mailing campaign:
Campaign starting date on
Sept. 30, 2019
+200branches
+7,500employees
Code of Conduct
Collective | ||
bargaining | ||
Completion | Number | |
per company | ||
Africa | 100 | |
Americas | 3 | |
Asia-Pacific | 3 | |
Europe | 39 | |
Middle East, | 5 | |
South Africa | ||
Total | 150 | |
Risk mapping
BTL/Bretagne divisions/System and Telecoms
Interaction with | |
public agent | |
Gifts | Obtention |
entertainments | of license |
Applicants | Intermediaries |
evaluation | |
Cash | Call for |
payments | public tenders |
10 - Bolloré Compliance program
Awareness
14,834
attendees
Compliance reporting
313
companies
800+
contributors
Training
23,454
completion
Third party due diligence
Data collection on
5,500+
third parties
Bolloré Compliance program - 11
For more information:
compliance@bollore.com
Design and printing:
Photos: cover/Getty Images, inside pages all right reserved Bolloré and TRACE International.
Bolloré Programme de conformité - 13
Tour Bolloré
31-32, quai de Dion-Bouton
92811 Puteaux Cedex - France Tel.: +33 (0) 1 46 96 44 33 Fax: +33 (0) 1 46 96 44 22 www.bollore.com
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Bolloré SA published this content on 10 December 2019 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 10 December 2019 22:30:04 UTC