In 2005, Safran introduced Ethical Guidelines setting forth the principles and standards common to the Group as a whole, to be used as a basis for employee conduct under all circumstances. The guidelines, which are summarized below, are not intended to replace or revise the laws and regulations in force, but to provide points of reference and guidance for the conduct of professional activities.
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Safran’s ethical guidelines
Behavior outside the Group
Upholding the laws
In all the countries in which the Group operates, its personnel must uphold the law. Care should be taken, as it may be difficult to understand the law in a legal and cultural environment that is very different than that in which the employee has previously worked. When there is a question or there is any doubt, the employee should immediately consult with a superior or the Legal Department.
Personnel working in a subsidiary jointly owned by a Group company and a foreign company must uphold the law of the country in which the subsidiary is based, and the country or countries in which it operates and where its shareholders are based. Integrity, honesty and transparency should guide each of the Group’s employees in their work. Employees are expected to deal with customers, suppliers and other business partners in the Group’s interest and in compliance with laws and regulations. All personnel must take particular care to uphold laws on competition, export and re-export control, labor and employment, safety, health and environmental protection.
Engaging in proper business practices
Zero tolerance of corruption, Safran, its companies and employees do not tolerate any form of corrupt practices, be they active or passive, direct or indirect, for the benefit of those in the public or private sector. The Group’s companies apply all international conventions on combating corruption and the anti-corruption laws in force in the countries where they do business. The Group, its companies and its employees never use a third party to perform any task that they are ethically or legally forbidden to perform themselves. Engaging a third party for the purpose of bribing a natural person or a legal entity violates anti-corruption laws. Prior to entering any contractual relationship with a business partner, the Group’s companies must follow a methodical and documented procedure.
Complying with export laws
As a global company, Safran purchases goods and services from a diverse group of suppliers. The Group also provides goods and services to customers all over the world. It is therefore critical that the Group strictly complies with all applicable regulations that govern its export activities. Before engaging in any export activity, Group employees must verify the eligibility of both the delivery location and the recipient. They must also obtain, when applicable, all required licenses and permits, including government authorizations and approvals for government-controlled products or technologies. These authorizations can be obtained from the relevant management in cooperation with Safran’s export control organization. Import activities are also subject to various laws and regulations, and it is the responsibility of the Group’s employees to comply with all of the applicable standards. Any breach of these regulations on imports and exports has serious consequences for the Group. It is the Group’s responsibility to know and comply with the laws and regulations that apply to the Group’s activities.
As part of its commitment to fair competition, the Group must strictly comply with applicable competition laws in the countries where it does business. In general, these laws prohibit agreements or practices likely to restrain or alter competition or trade. Examples of prohibited agreements include: price fixing, bid rigging, allocating markets, territories or clients amongst competitors, or boycotting or discriminating among certain customers or suppliers unless legally justified The exchange or disclosure of commercially sensitive information relating to competitors, customers or suppliers may also violate applicable laws.
Gifts and hospitality
Business courtesies, such as gifts and hospitality, given to or received from customers, suppliers and other partners are commonly used to build goodwill and acknowledge appreciation in business relationships. However, these courtesies must not exceed a nominal value and may not influence, or give the appearance of influencing, any business decision. Good judgment, discretion and prudence should always guide the Group in these situations. Business courtesies are prohibited by law under certain circumstances and in certain countries. The Group’s personnel must comply with the policies and laws that apply in each country where Safran does business.
Behavior towards customers
Each employee must uphold the principles of fairness and integrity in his or her dealings with customers. The business of the Group, to a large extent, concerns air transport safety; no compromise can be tolerated for any reason; any situation that may seem questionable to an employee must immediately be referred to a superior or the Quality manager.
Relations with shareholders
The Group ensures that its shareholders receive, on a timely basis, and in an effective manner, complete, relevant, accurate and precise information that is consistent with previous published information. It takes particular care to implement international corporate governance standards and principles.
Relations with suppliers
The Group selects suppliers on the basis of objective criteria and demands high performance from them, in order to ensure that the Group’s expectations and those of its customers are fully met. Under no circumstances will the Group use suppliers that make use of child or forced labor. In 2010, the Group signed a charter governing relations between major contractors and SMEs, drawn up on the initiative of the French Ministry of Economic Affairs, Industry and Employment.
Under no circumstances may employees damage the reputation of the Group or compromise the integrity of its assets or its information systems. Paid work of any kind that employees may perform outside the scope of their employment with the Group must not cause conflicts of interest with their duties within the Group. Similarly, considerable caution is required when purchasing shares, directly or via an intermediary, in companies doing business with the Group. Such restrictions do not apply to listed companies, unless confidential information is used which may be construed as insider trading.
Today more than ever, protecting the environment is a critical concern for all Group employees, starting with product design and running through to the industrial process as a whole.
Political and religious activities
The Group does not finance any political parties and any political activities must be carried out exclusively outside the work-place and working hours. Any religious practices in which employees may be involved must be practiced exclusively outside the work-place and working hours, except in the case of a legal obligation.
Behavior inside the Group
Employees must ensure the protection of information acquired in the course of or in connection with the performance of his or her duties. Employees are to pay particular attention to respect the internal rules of protection and applicable requirements during both written and oral communication.
Protecting the confidential nature of certain information
In the course of their duties, all employees have access to confidential information, which represents a key asset of the Group. Confidential or classified information is sensitive information which must not be disclosed or communicated outside of the Group. Similarly, Group employees may have information concerning the national security of the country in which the Group company is located. Care must therefore be taken to ensure that such information is protected from third parties. Any information that could influence the value of the Group’s stock price must remain confidential, until it has been communicated by the Group to the public. Any personal use of such information would constitute insider trading and could expose the employee to both civil and criminal liability.
Respect for other people
The safety and health of individuals are prime objectives for the Group. The Group is an equal opportunity employer. Recruitment and promotion are based exclusively on professional qualities and performance. The Group respects the dignity and private life of each of its employees. Furthermore, one of the Group’s key values is to create the necessary conditions for all employees to achieve fulfillment in their chosen profession. All Group companies comply with the rules of protection of personal data known as the “Binding Corporate Rules” (BCR), applicable to the treatment and transfer of data outside of the European Union.
Compliance with the Ethical Guidelines
Each employee is required to review, understand and comply with these Ethical Guidelines.
In the event of a question or any doubt regarding appropriate conduct, it is the responsibility of the employee to immediately contact a superior or the Group’s Legal Department. Each employee has an affirmative obligation to comply with these Ethical Guidelines.
Safran is the first company in the French stock market index CAC 40 to receive this certification from ADIT.
Following an audit carried out from September 1 to December 15, 2012, on December 23, 2012, Safran received the anti-corruption certification awarded by ADIT (“Agence pour la Diffusion de l’Information Technologique”). This certification was conducted on the basis of a reference table validated by the Central Service of Prevention of the Corruption (SCPC), a body with interministerial composition placed with the Minister of Justice. The certification is valid until December 2015, and recognizes the effectiveness of the procedures deployed by Safran.
The certification audit, in compliance with current international standards (ISAE 3000, International Standards on Assurance Engagements), involved an evaluation of Safran’s corporate culture and management’s commitment to implementing the anti-corruption program (based on a clear policy and broadly circulated ethics standards, the existence of Compliance Officers, deployment of effective procedures, etc.). The audit also entailed checking that any risks in this area are well understood and that controls have been implemented, and that measures are taken to apply the program and ensure that the information is widely circulated both within the company and externally.
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