Policy and procedures

The Code of Conduct and Integrity is the reference document for the Group’s compliance policy.

These key principles are set out in a series of procedures designed to prevent and combat fraud, corruption and influence peddling. Their implementation, deployment and control are managed by a dedicated ‘Compliance and Risks’ department reporting to the VALGO Group Chairman.

To ensure that everyone is able to take ownership of this Code of Conduct and Integrity and put it into practice, the Group has taken steps to:

• Promoting commitment at every level
  And more particularly the exemplary behavior of directors and managers.

• Inform, train et prevent
  All employees, particularly those most exposed to this risk, need to be made aware of it and trained. In addition to making the Code of Conduct available on the Group intranet and presenting it in the induction procedure, specific training programs have been set up and deployed at each level of the organization in modules available such as e-learning and face-to-face sessions.
• Enable reporting and support
  Any employee who encounters a situation that is contrary to the principles of the Code of Ethics can raise the matter with his or her line manager or refer it directly to the Compliance and Risks Department. A specific address has been set up to facilitate exchanges . If it is not possible to refer the matter to line management, a system report is available at Group level.
• Penalize
  Every VALGO employee has a responsibility to fight corruption in all its forms. The Group’s policy is zero tolerance. As such, any breach of the principles of the Code of Conduct and Integrity will be sanctioned.