Ethics

Comprehensive Ethical Business Practices at the Heart of our CSR Policies

The success of our business and CSR strategies is inextricably linked to how we are perceived by all our stakeholders and our ability to demonstrate the highest ethical standards in our business practices.

Vantiva Code of Ethics

Created in 1999 and regularly updated, the Code of Ethics establishes the foundation of the Group’s core values. It requires all employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities – based on the following basic principles:

• Respect for People & our Stakeholders
• Respect for the Environment
• Valuing Integrity

The Code of Ethics details specific rules to guide employees in their day-to-day activities. Several additional key policies – including a Whistleblower Policy; Anticorruption Policy and Manual; and Ethical Sourcing Policy – underline our reputation for uncompromising integrity.

Financial Ethics Charter

Vantiva has published an Ethics Charter specific to Finance personnel and activities, as an extension of the Company’s Code of Ethics. The Financial Ethics Charter was first published in December 2005, is signed by the Chief Executive Officer and the Chief Financial Officer, and is distributed to key persons within the Finance organization.

This policy promotes the following rules:

• acting honestly and with integrity and avoiding conflicts of interest;
• providing accurate, complete and objective information;
• compliance with all rules and regulations, public and private, to which the Group is subject;
• acting in good faith without misrepresenting material facts or allowing one’s judgment to be unduly influenced;
• respecting confidentiality of information;
• sharing and maintaining appropriate knowledge and skills;
• promoting ethical behavior in one’s environment;
• using and controlling responsibly assets under one’s supervisions; and
• reporting known or suspected violations of the Charter.

A copy of the Code of Ethics and the Financial Ethics Charter is available on the Company’s website or upon request to the Company.

Ethics Compliance Committee

The Group also created an Ethics Compliance Committee in 2006, which is responsible for all ethical issues related to Vantiva’s activities and which is governed by the Code of Ethics and the Charter for the Ethics Compliance Committee. This includes implementing any new policies if needed, training on existing policies, and investigating any and all reports of unethical behavior. It meets at least four times per year and more frequently when required.

As of September 28th, 2022, the composition of the Ethics & Compliance Committee is as follows:

• Dan Zambrano (Chair)
• Aline Bourcereau (Secretary)
• Olga Damiron
• Olivier Le Balle
• Alejandro Monge
• Anurag Sharma
• Tom Sipher
• Cindya Williams

Ethics Programs and Initiatives

Over the last several years, the Group has deployed many ethics training programs. Several online training sessions were launched to educate employees on various ethical rules and obligations, including bribery, competition and fraud. Some dedicated training sessions were also organized on specific sites or for specific functions and via teleconferencing.

Whistleblower Policy

The Vantiva Whistleblower Policy, launched in 2006 and revised in 2017, is designed to make it easier for employees and partners to share questions, concerns, suggestions or complaints about financial, accounting, banking or anti-bribery matters. The whistleblowing system enables all Vantiva employees and partners to report anything that they suspect to be unethical, illegal or unsafe, through a dedicated website or by phone.

Anti-bribery Policy

The Vantiva Whistleblower Policy, launched in 2006 and revised in 2017, is designed to make it easier for employees and partners to share questions, concerns, suggestions or complaints about financial, accounting, banking or anti-bribery matters. The whistleblowing system enables all Vantiva employees and partners to report anything that they suspect to be unethical, illegal or unsafe, through a dedicated website or by phone.

Vantiva’s commitment to prevent corruption is formalized in our Anti-bribery policy, which seeks to not only comply with recent anti-corruption and anti-bribery regulations, but to avoid even the appearance of questionable conduct in connection with Vantiva operations.

The Vantiva Anti-Bribery Policy, updated in 2018, provides practical examples showing employees how to do the right thing when faced with a dilemma. The Travel and Customer Entertainment policy has also been updated to harmonize processes across businesses.

Data Protection Policy

A formal Data Protection Policy issued by the Vantiva Ethics Compliance Committee governs legal compliance aspects. This policy ensures that Vantiva, its staff, contractors, suppliers and other people working on its behalf comply with any applicable provisions of the European General Data Protection Regulation where and when appropriate, as well as with any applicable other legislation when processing personal data.

Vantiva Data Control Organization is in place worldwide, to support compliance to Vantiva Privacy Policy and the General Data Protection Regulation.

As a French company with headquarters in Paris, the Group has also nominated a global Data Protection Officer (DPO) to the French Data Protection Authority (CNIL).