WHY GROUPE ADP
NEEDS AN ETHICS &
COMPLIANCE PROGRAMME

ETHICS & COMPLIANCE:
OUR DEFINITION

For Groupe ADP, ethics and compliance involve both compliance with laws and regulations and compliance with values.

ETHICS & COMPLIANCE: THE STAKES

Ethics and compliance have become auniversal requirement in business dealings.

Our stakeholders pay very close attention to our behaviour in these two key areas. In turn, our behaviour proves to them that our Group is worthy of their trust.

Similarly, ethics and compliance violations can lead to being excluded from certain markets (the World Bank, etc.) or to prohibitions against borrowing from certain banks in order to fuel our growth.

Therefore, ethics and compliance have a direct impact on the trust our stakeholders have in us, and on our performance.

Some ethics violations can even lead to heavy fines and penalties for the company and its employees.

The aim of our ethics and compliance mechanism is to protect not only the company, but also all of Groupe ADP's employees.

  • Petróleo Brasileiro S.A. – Petrobras (Brasil): 1,78 billion $ (2018).

  • Siemens (Germany): 800 million $ (2008)

  • Alstom (France): 772 million $ (2014).

  • Société Générale S.A. (France): 585 million $ (2018).

  • KBR / Halliburton (USA): 579 million $ (2009)

US AUTHORITHIES APPLIED STRONG SANCTIONS FOR CORRUPTION, FOR EXAMPLE:

CODE OF CONDUCT: REASONING AND APPLICATION

Groupe ADP operates in a highly demanding world in which apparently minor misbehaviours could have extremely costly consequences (examples include fines, prison sentences, business sanctions, damage to our reputation, etc.). Groupe ADP has therefore decided to clearly set out its rules of conduct which, while they cannot cover every eventuality, nonetheless serve to protect both the company and its employees.

This code of conduct applies to all Groupe ADP employees.

The purpose of the code is to spotlight the major Ethics issues providing concrete examples to help our employees take ownership of the principles and apply them in all aspects of their work life.

ETHICS & COMPLIANCE PROGRAMME: DEVELOPMENT AND STEERING

The Ethics Division and the Legal Affairs & Insurance Division are working together at the Group level to develop the programme. They will also work together to implement the programme, with support from the Ethics & Compliance officer persons within our subsidiaries and in collaboration with relay-persons in our cross-cutting divisions.

REACHING OUT WITH QUESTIONS OR IN SENSITIVE SITUATIONS

It is vital that you share your concerns if you have questions or encounter a sensitive situation! Reaching out and discussing these issues sheds light on them, allows us to detect any risks and helps us to find appropriate solutions with your manager.

We have also set up a whistleblowing system*. You can find the whistleblowing charter on the whistleblowing platform.

THE 10 PRINCIPLES
OF THE GLOBAL COMPACT

Human Rights

  • 1/

    Support and respect the protection of internationally proclaimed human rights.

  • 2/

    Make sure that there is no complicity in human rights abuses.

Labour

  • 3/

    Uphold the freedom of association and the effective recognition of the right to collective bargaining.

  • 4/

    The elimination of discrimination in respect of employment and occupation.

  • 5/

    Ensure the effective abolition of child labour.

  • 6/

    The elimination of all forms of forced and compulsory labour.

Environment

  • 7/

    Support a precautionary approach to environmental challenges.

  • 8/

    Undertake initiatives to promote greater environmental responsibility.

  • 9/

    Encourage the development and dissemination of environmentally- friendly technology.

Anti-Corruption

  • 10/

    Work against corruption in all its forms,including extortion and bribery.

Summary