January GROUP CODE OF CONDUCT

Size: px
Start display at page:

Download "January GROUP CODE OF CONDUCT"

Transcription

1 January 2013 GROUP CODE

2 GROUP COMMITMENT 1 GROUP COMMITMENT Through its retail and corporate & investment banking networks, and through all its business lines based on insurance, investor services, specialised financing and savings management, Société Générale intends to build lasting relationships with its clients, based on trust. To act with a responsible attitude, the Group underpins its development with a shared heritage of values in conducting its business. These values are themselves based on the ethical demands of its employees, clients and stakeholders. Every manager is individually responsible for applying them within their own remit. The actions of Group employees are governed by the Code of Conduct and comply with all Group directives and instructions. 2

3 GROUP COMMITMENT General principles RESPECT HUMAN AND SOCIO-ECONOMIC RIGHTS AND RESPECT THE ENVIRONMENT The Group undertakes its development while abiding by basic human and social rights and respecting the environment everywhere that it conducts its business. It acts in accordance with and cooperates with those international initiatives it has chosen to endorse, which include: the UN Global Compact; the Statement by Financial Institutions on the Environment and Sustainable Development (United Nations Environment Programme); the Equator Principles; the Wolfsberg AML Principles. The Group seeks to improve the impact of its activities on society and the environment in conjunction with stakeholders, to use natural and energy resources economically, and to incorporate environmental and social factors in its financing and investment decisions and in its business lines. COMPLY WITH BUSINESS-RELATED LAWS, REGULATIONS AND STANDARDS The Group and its employees everywhere comply with applicable agreements, laws and regulations, and with international commitments and agreements that the Group has endorsed. Together, they conduct their business while abiding by professional policies and procedures and ethical practice. They ensure the transparency and honesty of information disclosed to the finance community, supervisory authorities, shareholders, clients and the public in general. Business operations, the organisational structure, and procedures must comply with ethical professional practice and policies and procedures set out by senior management. Internal control mechanisms employed by the Group ensure that this is the case. Societe Generale is actively involved in combating both money laundering and financing terrorism, in cooperation with the relevant authorities. To do so, the Group has produced policies and procedures that apply worldwide, including where they are more stringent than local legislation. 3

4 GROUP COMMITMENT ENCOURAGE DIVERSITY AND RESPECT INDIVIDUAL PRIVACY In accordance with the French Diversity Charter which the group endorsed in 2004, every entity encourages diversity and refrains from practising any form of discrimination whatsoever with regard to its staff, job applicants, clients, business partners or suppliers. Every entity ensures its adherence to policies and procedures relating to freedom of association and working conditions, and refrains from making use of forced or bonded labour or child labour in the sense of the International Labour Organisation conventions, even where local legislation so permits. Societe Generale and its employees respect individuals privacy, whether they are clients, partners or staff. They request only that information that is of use in serving the interests of clients and partners, improving the quality of service provision, complying with their statutory obligations or in a contributing towards the management of the company. The Group observes political neutrality and refrains from supporting any political organisations or activities through donations or subsidies, even where local legislation so permits. It respects the commitments of those of its employees who, as citizens, wish to participate in public life. 4

5 GROUP COMMITMENT Commitments TO CLIENTS Heirs to a long tradition of consumer and corporate services, Société Générale Group puts all its energy and skills to use in working towards its primary purpose client satisfaction. Energised daily by its team spirit, the Group establishes and maintains lasting relationships with clients based on trust, expertise and respect for all of their legitimate interests. It intends to establish itself as the benchmark in relationship banking, chosen for the quality and commitment of its staff in supporting the financing of the economy and its clients plans. This intention takes the form of a number of projects all sharing the objective of continuous improvement in quality of service. Societe Generale makes use of its in-depth knowledge of its clients to: offer them products and services appropriate to their situation and requirements, to bring their plans to fruition or anticipate financing needs; advise and inform them, taking into account their level of expertise and the conditions or risks connected to certain transactions. The Group enters contractual relationships only with those clients whose practices are, or aim to be, consistent with its own general principles. It prevents conflicts of interest between its business lines and clients by means of separate structures and thorough procedures. It refrains from acting as an agent where doing so is likely to lead to a conflict of interests with its principal, unless the principal agrees. It guarantees to maintain the confidentiality of inside information that it holds about a company or financial instrument under all circumstances, and to refrain from using or disseminating it for purposes other than those for which the information was disclosed to the Group. Its employees comply with strict rules intended to restrict the circulation of inside information. They adhere to stock market regulations covering their personal transactions involving financial instruments (the duty to disclose or abstain from trading, as notified to every employee to whom they apply). Societe Generale ensures that every employee who might possess inside information owing to their role in the organisation abides by the ethical policies and procedures set down by the Group. 5

6 GROUP COMMITMENT TO EMPLOYEES Societe Generale Group has confidence in the skills, loyalty, integrity and commitment of its employees, who constitute the company s leading asset. The Group knows it can count on their sense of responsibility to govern their behaviour in their working lives. It expects them to avoid any conflict of interest situation. The Group pays particular attention to their working conditions especially as regards health and safety. It involves them in Group governance by fostering dialogue, information and discussion. It respects their privacy. The Group recruits staff solely on the basis of its requirements and each applicant s individual qualities. It develops their professional skills and increases their responsibilities with no discrimination of any kind, and in particular no discrimination based on faith or beliefs, sex, age, ethnic origin, or membership of a political, religious, or trade union organisation or any kind of minority. The group protects them from any form of harassment in the workplace, consistent with the legal and regulatory provisions in individual countries. All employees have regular meetings with their line management during which objectives are set and development plans are drawn up. TO SHAREHOLDERS Societe Generale and its listed subsidiaries aim to deserve their shareholders trust with the objective of ensuring the profitability of their investment and the longevity of the business. It undertakes to maintain a lasting dialogue with them, in particular by means of the shareholders consultative committee. The Group regularly provides shareholders with accurate, full and transparent information. 6

7 GROUP COMMITMENT TO SUPPLIERS AND SERVICE PROVIDERS Societe Generale undertakes to adhere to the abovementioned general principles with respect to its suppliers and service providers. In return, the Group expects them to adhere to principles equivalent to those in the Group s Code of Conduct. Societe Generale ensures that all parties interests are taken into consideration, transparently and in accordance with contract terms. TO COUNTRIES WHERE THE GROUP IS ACTIVE The Group respects the cultures and environment of countries where it operates. Through its business activities, it contributes to the economic and social development of these countries. Working as it does in a regulated industry, the Group undertakes to cooperate fully with public and professional bodies responsible for supervising or verifying the compliance of its activities in those territories where they have jurisdiction and where the Group conducts its business. It ensures compliance with the rules regarding transparency and accuracy of information used by supervisory bodies, the financial community, shareholders, clients and the general public in countries where it conducts its business. 7

8 INDIVIDUAL AND COLLECTIVE CONDUCT GUIDELINES 2 INDIVIDUAL AND COLLECTIVE CONDUCT GUIDELINES The harmonious development of Societe Generale is based on trust; trust between employees and trust between the Group and its employees. Maintaining this trust requires adherence, at all levels, with a certain number of rules regarding conduct. Some clear and well-defined principles make useful benchmarks. They do not cover every ethical situation but serve as guidelines where there is doubt or uncertainty regarding the stance to adopt. All employees always adhere to all agreements, directives and instructions from the Group. 8

9 INDIVIDUAL AND COLLECTIVE CONDUCT GUIDELINES All employees demonstrate loyalty and fairness and foster good relationships with their colleagues. They undertake to act with an ethos of team spirit, responsibility, courage, thoroughness and discipline. They ensure that Group activities dependent on them are conducted in accordance with existing Group policies and procedures as regards protection of health, safety and the environment. They take the social, economic and environmental consequences of their decisions into consideration. Over and above compliance with laws and regulations, all employees act with integrity both inside and outside the company when they are representing it. Restraint is to be exercised when making statements on any Group-related matter outside of the Group, unless authorised to speak on its behalf. Employees contribute towards the implementation of best practices at Societe Generale. They cooperate with internal audit and control processes diligently and transparently. 9

10 INDIVIDUAL AND COLLECTIVE CONDUCT GUIDELINES Maintaining the confidentiality of information Business confidentiality is an essential component of the banker s role. It applies under all circumstances and to all types of media, including new communication channels such as social networks. Individuals are the custodians of and responsible for the confidential information they receive. They may only use such information internally for business purposes and must not disclose it outside the company unless permitted to do so or where required to do so by the law or at the request of the courts or supervisory bodies for the banking profession. Some confidential information may be deemed inside information in the sense of banking and financial regulations. Employees in possession of inside information, either owing to their role or unintentionally, are subject to special confidentiality obligations and a duty to disclose or abstain from trading. Electronic mail is to be categorised on the basis of the confidentiality level of the information it contains. Personal accounts are not to be used for sending confidential information. Confidentiality agreements are required before confidential information can be sent to external business addresses. Dealings with clients and suppliers All employees meet the commitments made in their dealings with the Group s clients, partners and suppliers. Employees treat them fairly and make any choices necessary on the basis of objective criteria. All corrupt practices are prohibited. Any employee subject to pressure or requests from third parties must report it to line management. Gifts to clients or their representatives must be modest and comply with the rules set by Group entities. The same applies as regards individuals in positions of public authority, government officials and similar persons. If need be, employees are to seek advice from their line management on the stance to be adopted. Similarly, employees will strictly adhere to the value limits applying in their entity to gifts or invitations from a client or any other business relationship. To avoid any questionable situation arising, employees are to seek advice if need be from their line management on the stance to be adopted. As part of the anti-money laundering provisions, all employees are continuously vigilant, and follow the identification and know your customer procedures for clients or instructing parties, along with all transaction verification procedures. 10

11 INDIVIDUAL AND COLLECTIVE CONDUCT GUIDELINES Use of resources All employees ensure that the company s tangible, intangible, financial and property assets are protected. Employees use them reasonably in compliance with the policies and procedures governing their use and application, as communicated to staff. Employees must not make excessive personal use of the equipment and services made available to them. They strive to use resources economically and to take account of environmental aspects in their decision making. Conflicts of interest All employees refrain from maintaining personal relationships with clients, partners and suppliers which could compromise their professional duties or place them in a situation of conflict of interest. They are to report to line management any conflict of interest to which they might be subject. Staff must avoid their own interests or those of their immediate circle entering into conflict with the Group s interest. Where there is any doubt about particular transactions or situations with respect to this Code of Conduct or any applicable instructions, employees should seek advice from their line management. All employees must avoid taking any financial interest in a competitor, supplier or client without prior permission in writing from their line management. Where employees may be considered as Group representatives, they refrain from involving the Group or any Group entity in any public activities or responsibilities that they may exercise outside of the Group. 11

12 COMPLIANCE WITH THE CODE 3 COMPLIANCE WITH THE CODE All permanent and temporary employees comply with the Code of Conduct. The Group s senior management ensure this Code is applied and that the actions of all employees comply with it, irrespective of their responsibility level. Compliance with the Code of Conduct is in particular enforced by the application of the internal policies and procedures of the Group and its entities. In particular, an overview of the Group normative documentation relevant to the Code, as at 1 September 2012, is appended to this document. 12

13 COMPLIANCE WITH THE CODE Whistle-blowing Any Group employee is entitled to raise a warning if he or she believes they have good grounds for considering an instruction received, or a planned transaction, or more generally any given situation is not in compliance with the policies and procedures that govern the conducting of the Group s business. This entitlement is limited to the areas covered by the Code of Conduct and the internal and external documents and texts to which the Code refers. How whistle-blowing works Group employees are entitled to raise warnings in the course of their work about any events of which they have direct or indirect knowledge. This right is to be exercised responsibly, with restraint, and in a non-defamatory manner. Warnings may be raised at several levels. The normal and preferred route is to use direct line management, it being understood that matters may also be referred to higher levels. The recipients of a warning judge what subsequent action is to be taken over the issue reported and ensure the protection of whistle-blowing employees. The recipient of a warning is to ensure that the necessary investigations are conducted under the maximum possible confidentiality compatible with the demands of the investigation. Other routes are also available: Direct referral to the Compliance Department or to compliance staff found in subsidiaries or branch offices; where there is no compliance manager in a particular location, referral to a senior manager in the Department designated for the purpose; Lastly, issues can be referred to the Group Corporate Secretary ( either directly or in the last instance, especially if the situation giving grounds for the initial warning persists. Warnings are raised in writing (paper or ) and include the whistle-blower s identity. However, an oral report (telephone or meeting) may precede the written report. 13

14 Ref. (B) Studio Societe Generale +33 (0) /2013

Corporate Code of Ethics

Corporate Code of Ethics FERROVIAL CORPORATE CODE OF ETHICS Corporate Code of Ethics Our complete commitment to the ethics and integrity of our workforce highlights us as a serious company committed to its stakeholders interests.

More information

Business Ethics Policy

Business Ethics Policy Business Ethics Policy The WCH Ltd Ethics Code The business philosophy of WCH has been developed around a core set of values which are fundamental to the organisation s development and success. One of

More information

Macarthur Minerals Limited CODE OF CONDUCT. February 2012

Macarthur Minerals Limited CODE OF CONDUCT. February 2012 Macarthur Minerals Limited CODE OF CONDUCT February 2012 MACARTHUR MINERALS LIMITED AND ITS SUBSIDIARIES (THE COMPANY OR MACARTHUR ) CODE OF CONDUCT 1. INTRODUCTION 1.1 The Macarthur Mineral Limited (including

More information

CHARTER OF ETHICS AND BEHAVIOUR

CHARTER OF ETHICS AND BEHAVIOUR CHARTER OF ETHICS AND BEHAVIOUR Behaviour Principles and Rules P.02 Deployment P.07 The Charter of Ethics was adopted at the meeting of the Groupe Eurotunnel Board Meeting of 28/01/2013 Groupe Eurotunnel

More information

Code of Conduct ACS-DOBFAR

Code of Conduct ACS-DOBFAR Code of Conduct ACS-DOBFAR Board of Directors of 23/10/2012 The success of one company is based on values of transparency, credibility and loyalty, principles that represent the heritage of a company:

More information

Business Ethics Policy

Business Ethics Policy Business Ethics Policy 1 Preface and document control This document is intended to provide information in respect of G4S Group Head Office policy, procedure, standards or guidance and will be periodically

More information

Ethics & Community. Honesty. Respect. Loyalty Fairness. Environment

Ethics & Community. Honesty. Respect. Loyalty Fairness. Environment Ethics & Community Sustainability Integrity Stability Honesty Responsibility Loyalty Fairness Safety Ethics Environment Respect Introduction / CEO message Gemalto s Code of Ethics sets out the standards

More information

CODE OF ETHICS. Code: CRM-CET Approval Date: 11 aprile 2014 Issued by: Board of Directors Rev: 01. Page: 1 di 16. Previous version: n.

CODE OF ETHICS. Code: CRM-CET Approval Date: 11 aprile 2014 Issued by: Board of Directors Rev: 01. Page: 1 di 16. Previous version: n. Page: 1 di 16 CODE OF ETHICS Previous version: n. 00 Issued and approved: Board of Directors of DSN Date: 29 Maggio 2008 Page: 2 di 16 INTRODUCTION d'amico Società di Navigazione S.p.A. (hereinafter the

More information

ICMA Private Wealth Management Charter of Quality

ICMA Private Wealth Management Charter of Quality ICMA Private Wealth Management Charter of Quality Preamble 1. The Private Wealth Management Charter of Quality ( the Charter of Quality ) is a voluntary standard of recommended minimum good market practice.

More information

HORIZON OIL LIMITED (ABN: 51 009 799 455)

HORIZON OIL LIMITED (ABN: 51 009 799 455) HORIZON OIL LIMITED (ABN: 51 009 799 455) CORPORATE CODE OF CONDUCT Corporate code of conduct Page 1 of 7 1 Introduction This is the corporate code of conduct ( Code ) for Horizon Oil Limited ( Horizon

More information

Code of Ethics of Erste Bank Hungary Zrt.

Code of Ethics of Erste Bank Hungary Zrt. Code of Ethics of Erste Bank Hungary Zrt. Contents Introduction 3 Purpose of the Code of Ethics 4 Related legislation 5 (Institutional) commitments of the Bank 6 Conduct towards customers 12 Conduct towards

More information

LVMH GROUP CODE OF CONDUCT

LVMH GROUP CODE OF CONDUCT LVMH GROUP CODE OF CONDUCT I II III FOREWORD PRINCIPLES IMPLEMENTATION AND COMPLIANCE 1 I. FOREWORD The LVMH Group ( LVMH ) aims to be the undisputed leader of the luxury goods sector. Its growth and long-term

More information

JULY 2013 COMPLIANCE POLICY SOCIETE GENERALE BANK & TRUST LUXEMBOURG

JULY 2013 COMPLIANCE POLICY SOCIETE GENERALE BANK & TRUST LUXEMBOURG JULY 2013 SOCIETE GENERALE BANK & TRUST LUXEMBOURG SGBT All employees must perform their assigned duties in a diligent and efficient manner, to the best of their ability. Employees must act loyally towards

More information

Business Ethics Policy

Business Ethics Policy Business Ethics Policy Page 1 of 12 Preface and document control This document is intended to provide information in respect of G4S Group Head Office policy, procedure, standards or guidance and will be

More information

COMPLIANCE CORPORATE POLICY

COMPLIANCE CORPORATE POLICY COMPLIANCE CORPORATE POLICY Policy No: 10.010.N001 Prepared By : Arzu Demir Approve By : Board of Directors Approval Date : 08.06.2015 CONTENTS 1 OVERVIEW... 2 2 COMPLIANCE RISK... 2 3 COMPLIANCE PRINCIPLES...

More information

Corporate Responsibility Policy

Corporate Responsibility Policy Corporate Responsibility Policy 1. Purpose: Celer Soluciones, SL is a company that manages the language resources of its clients in terms of document management, translation and publication of multilingual

More information

Code of Ethics and Business Conduct (CEBC)

Code of Ethics and Business Conduct (CEBC) Code of Ethics and Business Conduct (CEBC) Amadeus Group October 2015 Index _ Preamble... 3 _ Our People... 3 _ Beyond Compliance... 3 _ Commitment to the Environment... 3 _ Conflicts of Interests, Gifts,

More information

Drawn up by the Board of Management on 26 October 2015 and approved by the Supervisory Board on 2 November 2015. Effective as of 1 January 2016.

Drawn up by the Board of Management on 26 October 2015 and approved by the Supervisory Board on 2 November 2015. Effective as of 1 January 2016. Code of Conduct Drawn up by the Board of Management on 26 October 2015 and approved by the Supervisory Board on 2 November 2015. Effective as of 1 January 2016. Introduction The mission of Vastned Retail

More information

CORPORATE ETHICS CODE of JSC TransContainer

CORPORATE ETHICS CODE of JSC TransContainer Annex 4 APPROVED by resolution of the Board of Directors of JSC TransContainer (Minutes No. 41) dated May 18, 2009 Chairman of the Board of Directors D.K. Novikov CORPORATE ETHICS CODE of JSC TransContainer

More information

CODE OF CONDUCT as adopted by the Board of Directors on 20 February 2015

CODE OF CONDUCT as adopted by the Board of Directors on 20 February 2015 GOLDFIELDS MONEY LIMITED ACN 087 651 849 CODE OF CONDUCT as adopted by the Board of Directors on 20 February 2015 1. Purpose This Code of Conduct (Code) clearly states the standards of responsibility and

More information

CODE OF ETHICS renaul DrIVE THE CHanGE

CODE OF ETHICS renaul DrIVE THE CHanGE CODE OF ETHICS renault DRIVE THE CHANGE Contents page INTRODUCTION FROM THE CHAIRMan 1 1 2 3 4 5 PREAMBLE 2 PROTECTION OF EMPLOYEES 3 PROTECTION OF ASSETS 4 PROTECTION OF CUSTOMERS 5 PROTECTION OF SHAREHOLDERS

More information

Life Insurance Charter of Quality

Life Insurance Charter of Quality Life Insurance Charter of Quality PREAMBLE This Life Insurance Charter of Quality is largely inspired by the ICMA Private Wealth Management Charter of Quality, which lists the guiding principles of best

More information

OT AUSTRALIA. Australian Association of Occupational Therapists. Code of Ethics

OT AUSTRALIA. Australian Association of Occupational Therapists. Code of Ethics Introductory Statement The ethos of the occupational therapy profession and its practice requires its members to discharge their duties and responsibilities, at all times, in a manner which professionally,

More information

Code of Conduct Code of Conduct for Business Ethics and Compliance

Code of Conduct Code of Conduct for Business Ethics and Compliance Allianz Group Code of Conduct Code of Conduct for Business Ethics and Compliance Group Compliance Preamble Allianz Group is based upon the trust which our clients, shareholders, employees and public opinion

More information

PHILIPPINE LONG DISTANCE TELEPHONE COMPANY CODE OF BUSINESS CONDUCT AND ETHICS

PHILIPPINE LONG DISTANCE TELEPHONE COMPANY CODE OF BUSINESS CONDUCT AND ETHICS PHILIPPINE LONG DISTANCE TELEPHONE COMPANY CODE OF BUSINESS CONDUCT AND ETHICS Philippine Long Distance Telephone Company ( PLDT or the Company ) is dedicated to doing business in accordance with the highest

More information

Life Insurance Charter of Quality

Life Insurance Charter of Quality Life Insurance Charter of Quality PREAMBLE This Life Insurance Charter of Quality is largely inspired by the ICMA Private Wealth Management Charter of Quality, which lists the guiding principles of best

More information

For personal use only

For personal use only CONTENTS Introduction Objective Scope Standards of Behaviour Work Environment Community Engagement Financial Information and Integrity Company Property and Information Bribery and Corruption Breaches Approval

More information

operated by it (as the case requires).

operated by it (as the case requires). 1 Definitions In this document: ASX Board Chair CEO CFO Company Secretary Corporations Act Director means ASX Limited ACN 008 624 691 or the securities exchange operated by it (as the case requires). means

More information

Australian Ethical Investment Limited and Australian Ethical Superannuation Pty Ltd. Code of Conduct

Australian Ethical Investment Limited and Australian Ethical Superannuation Pty Ltd. Code of Conduct Australian Ethical Investment Limited and Australian Ethical Superannuation Pty Ltd Code of Conduct The Australian Ethical Code of Conduct is intended to provide guidance for Directors and employees on

More information

CODE OF ETHICS AND BUSINESS CONDUCT

CODE OF ETHICS AND BUSINESS CONDUCT CODE OF ETHICS AND BUSINESS CONDUCT This Code of Ethics and Business Conduct ( Code ) has been approved by the Amalgamated Holdings Limited ( AHL ) Board of Directors for use within the AHL controlled

More information

EDF GROUP CODE OF ETHICS

EDF GROUP CODE OF ETHICS EDF GROUP CODE OF ETHICS Electricity is not like any other commodity: that is why its production, transmission, distribution and sale are matters of general public interest. From the outset, EDF s mission

More information

OUR CODE OF ETHICS. June 2013

OUR CODE OF ETHICS. June 2013 OUR CODE OF ETHICS. June 2013 OUR CODE OF ETHICS GUIDING PRINCIPLES Ethical behaviour is an integral part of the way we do business. It's crucial that all our stakeholders are able to trust us to treat

More information

BOARD CHARTER Link Administration Holdings Limited ("Company") ABN 27 120 964 098

BOARD CHARTER Link Administration Holdings Limited (Company) ABN 27 120 964 098 1. Role of the Board BOARD CHARTER Link Administration Holdings Limited ("Company") ABN 27 120 964 098 This Board Charter sets out the principles for the operation of the board of directors of the Company

More information

COLLINS FOODS LIMITED (the COMPANY) CODE OF CONDUCT

COLLINS FOODS LIMITED (the COMPANY) CODE OF CONDUCT COLLINS FOODS LIMITED (the COMPANY) CODE OF CONDUCT 1. Introduction The Company is committed to maintaining ethical standards in the conduct of its business activities. The Company's reputation as an ethical

More information

Group Corporate Responsibility Policy

Group Corporate Responsibility Policy London Stock Exchange Group Group Corporate Responsibility Policy December 2015 WEB VERSION FOR EXTERNAL DISCLOSURE 1 Contents 1.0 Introduction 3 2.0 Objectives 3 3.0 Scope and application 3 4.0 Corporate

More information

CODE OF CONDUCT. for Suppliers and Business Partners

CODE OF CONDUCT. for Suppliers and Business Partners CODE OF CONDUCT for Suppliers and Business Partners Version: 2.0 Applicable as of: January 1, 2015 Contact: MAN SE, Compliance Awareness & Prevention, Oskar-Schlemmer-Straße 19-21, 80807 Munich Compliance@man.eu

More information

Ryanair Holdings PLC Code of Business Conduct & Ethics 2012

Ryanair Holdings PLC Code of Business Conduct & Ethics 2012 Ryanair Holdings PLC Code of Business Conduct & Ethics 2012 1 TABLE OF CONTENTS 1. INTRODUCTION 3 2. WORK ENVIRONMENT 3 2.1 Discrimination & Harassment 3 2.2 Privacy of Personal Information 3 2.3 Internet

More information

GROUP POLICY MANUAL CODE OF CONDUCT AND ETHICS POLICY

GROUP POLICY MANUAL CODE OF CONDUCT AND ETHICS POLICY POLICY NO: 8 (Group) Issued: November 2007 Revision No: 1 GROUP POLICY MANUAL CODE OF CONDUCT AND ETHICS POLICY Original Issued: 22 August, 2003 Effective: November 2007 Date Reviewed: February 2007 By:

More information

ELEMENT FINANCIAL CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS

ELEMENT FINANCIAL CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS APPENDIX I ELEMENT FINANCIAL CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS As of December 14, 2011 1. Introduction This Code of Business Conduct and Ethics ( Code ) has been adopted by our Board of Directors

More information

SOCIAL AND ETHICAL CHARTER FOR OUR SUPPLIERS

SOCIAL AND ETHICAL CHARTER FOR OUR SUPPLIERS SOCIAL AND ETHICAL CHARTER FOR OUR SUPPLIERS CARREFOUR S COMMITMENT FOR RESPONSIBLE TRADE. 4 SOCIAL AND ETHICAL CHARTER FOR OUR SUPPLIERS CARREFOUR SOCIAL AND ETHICAL RESPONSIBILITY The Carrefour group,

More information

PHILIP MORRIS INTERNATIONAL INC.

PHILIP MORRIS INTERNATIONAL INC. PHILIP MORRIS INTERNATIONAL INC. Code of Business Conduct and Ethics for Directors 1. Introduction This Code of Business Conduct and Ethics for Directors ( Code ) has been adopted by Philip Morris International

More information

Evergreen Solar, Inc. Code of Business Conduct and Ethics

Evergreen Solar, Inc. Code of Business Conduct and Ethics Evergreen Solar, Inc. Code of Business Conduct and Ethics A MESSAGE FROM THE BOARD At Evergreen Solar, Inc. (the Company or Evergreen Solar ), we believe that conducting business ethically is critical

More information

2.1.2 The Board has delegated responsibility for overall management of the Group to the Group Managing Director.

2.1.2 The Board has delegated responsibility for overall management of the Group to the Group Managing Director. NATIONAL COMMERCIAL BANK JAMAICA LIMITED BOARD CHARTER National Commercial Bank Jamaica Limited has adopted the following Charter to guide the Bank and its subsidiaries ( The Group ) in the execution of

More information

Code of Business Conduct and Ethics. With Special Message for Senior Business and Finance Leaders

Code of Business Conduct and Ethics. With Special Message for Senior Business and Finance Leaders Code of Business Conduct and Ethics With Special Message for Senior Business and Finance Leaders Index Letter from our Chairman & CEO and from our President Annual Letter to Senior Leaders Introduction

More information

Policy-Standard heading. Social Compliance Policy

Policy-Standard heading. Social Compliance Policy Policy-Standard heading Social Compliance Policy May 2014 Table of contents Introduction... 3 Scope... 3 Policy statement... 3 Approach to compliance... 4 Managing non compliance... 4 Governance structure...

More information

APES 320 Quality Control for Firms

APES 320 Quality Control for Firms APES 320 Quality Control for Firms APES 320 Quality Control for Firms is based on International Standard on Quality Control (ISQC 1) (as published in the Handbook of International Auditing, Assurance,

More information

A Guide to Corporate Governance for QFC Authorised Firms

A Guide to Corporate Governance for QFC Authorised Firms A Guide to Corporate Governance for QFC Authorised Firms January 2012 Disclaimer The goal of the Qatar Financial Centre Regulatory Authority ( Regulatory Authority ) in producing this document is to provide

More information

CODE OF BUSINESS CONDUCT

CODE OF BUSINESS CONDUCT CODE OF BUSINESS CONDUCT POLICY OBJECTIVES 1. This policy constitutes the Code of Business Conduct of companies of the Volga Gas Group (hereinafter called Group companies ). The Code applies to all employees

More information

Code of Business Conduct and Ethics THE WOODBRIDGE WAY. integrity honesty respect responsibility

Code of Business Conduct and Ethics THE WOODBRIDGE WAY. integrity honesty respect responsibility Code of Business Conduct and Ethics THE WOODBRIDGE WAY integrity honesty respect responsibility Reissued June 12, 2015 Code of Business Conduct and Ethics THE WOODBRIDGE WAY INTRODUCTION Woodbridge Foam

More information

CODE OF ETHICS of the RCS Group

CODE OF ETHICS of the RCS Group CODE OF ETHICS of the RCS Group Approved by the RCS MediaGroup S.p.A. Board of Directors at the meeting of 31 July 2003 - 2 - Code of Ethics Aim and Intended Audience The Code of Ethics of the RCS Group

More information

CAMUS GROUP CODE OF ETHICS

CAMUS GROUP CODE OF ETHICS CAMUS GROUP CODE OF ETHICS THE LETTER OF THE PRESIDENT In an ever more global commercial context, our group must develop its activities and geographical presence with, as a consequence, a growing division

More information

Orange Polska Code of Ethics

Orange Polska Code of Ethics Orange Polska Code of Ethics our conviction The fundamental ethical standards and values people should follow in their mutual relations both private and business have been known and unchanging for centuries.

More information

TO GAS TRANSMISSION OPERATOR GAZ-SYSTEM S.A.

TO GAS TRANSMISSION OPERATOR GAZ-SYSTEM S.A. TO GAS TRANSMISSION OPERATOR GAZ-SYSTEM S.A. CONTENTS INTRODUCTION 2 Our commitments and values 2 Objectives 3 Scope 3 Application 4 Compliance 4 Cooperation with Suppliers 5 TO GAS TRANSMISSION OPERATOR

More information

Code of Conduct for Evonik s employees

Code of Conduct for Evonik s employees Code of Conduct for Evonik s employees Table of Contents Scope and Objectives 4 Business Conduct 6 Managing Business Transactions 6 Business Relations 8 Conflicts of Interest 10 Insider Trading 11 Maintaining

More information

OMNI TECHNICAL SOLUTIONS. Business Ethics, Compliance, Anti-Corruption and Anti-Money Laundering Policy

OMNI TECHNICAL SOLUTIONS. Business Ethics, Compliance, Anti-Corruption and Anti-Money Laundering Policy OMNI TECHNICAL SOLUTIONS Business Ethics, Compliance, Anti-Corruption and Anti-Money Laundering Policy Updated: September 2015 Table of Contents 1. Introduction... 2 2. Business Ethics... 3 2.1 Compliance...

More information

Code of Business Conduct and Ethics. Strike Energy Limited ACN 078 012 745

Code of Business Conduct and Ethics. Strike Energy Limited ACN 078 012 745 Code of Business Conduct and Ethics Strike Energy Limited ACN 078 012 745 Approved: 2 December 2014 Contents 1. General... 1 2. Responsibilities to shareholders and the financial community generally...

More information

Code of Business Principles Helping us do the right thing

Code of Business Principles Helping us do the right thing Code of Business Principles Helping us do the right thing Code of Business Principles Helping us do the right thing Contents 01 Foreword 02 Who is the code for? 03 Where to find advice or raise a concern

More information

CODE OF ETHICS FOR EMPLOYEES IN THE PUBLIC SECTOR

CODE OF ETHICS FOR EMPLOYEES IN THE PUBLIC SECTOR CODE OF ETHICS FOR EMPLOYEES IN THE PUBLIC SECTOR CABINET OFFICE OFFICE OF THE PRIME MINISTER MALTA OCTOBER 1994 CONTENTS Page Preface iii Definition 1 A. Introduction to the Code. 3 B. Values Underlying

More information

Amvest Code of Conduct Designed to promote honest, transparent, prudent and socially responsible conduct

Amvest Code of Conduct Designed to promote honest, transparent, prudent and socially responsible conduct Amvest Vastgoed BV Amvest Code of Conduct Designed to promote honest, transparent, prudent and socially responsible conduct 1. The Amvest Code of Conduct obliges and explains 1.1 Part of the contract/employment

More information

1. Understanding and application of Moelven's Code of Conduct

1. Understanding and application of Moelven's Code of Conduct Code of Conduct 1. Understanding and application of Moelven's Code of Conduct Purpose Moelven must act in a sustainable, ethical and socially responsible manner. Our Code of Conduct provides the basic

More information

Code of ethics 17/12/13

Code of ethics 17/12/13 17/12/13 CoNTeNTS I. INTroduCTIoN 4 Article 1. Purpose 4 Article 2. Scope of Application 4 Article 3. Interpretation and Integration of the Code of ethics 4 II. VISIoN ANd VAlueS of THe GrouP Article 4.

More information

Government Owned Corporations. Corporate Governance Guidelines for Government Owned Corporations

Government Owned Corporations. Corporate Governance Guidelines for Government Owned Corporations Government Owned Corporations Corporate Governance Guidelines for Government Owned Corporations Version 2.0 The State of Queensland (Queensland Treasury) The Queensland Government supports and encourages

More information

4 November 2013. Sampo Group. Code of Conduct

4 November 2013. Sampo Group. Code of Conduct 4 November 2013 Sampo Group Code of Conduct 1 Business areas in 2011 CONTENTS GENERAL page 3 CORPORATE GOVERNANCE page 4 CORPORATE RESPONSIBILITY page 5 GENERAL BUSINESS PRINCIPLES page 6 RELATIONSHIPS

More information

California Mutual Insurance Company Code of Business Conduct and Ethics

California Mutual Insurance Company Code of Business Conduct and Ethics California Mutual Insurance Company Code of Business Conduct and Ethics This Code of Business Conduct and Ethics (the Code ) applies to all officers, employees, and directors of California Mutual Insurance

More information

Global Preamble: Codes of Best Market Practice and Shared Global Principles 1

Global Preamble: Codes of Best Market Practice and Shared Global Principles 1 30 March 2015 Global Preamble: Codes of Best Market Practice and Shared Global Principles 1 The wholesale foreign exchange (FX) market is a global market used by banks and other institutions, as well as

More information

Code of Ethics and Conduct

Code of Ethics and Conduct Introduction: Vale s mission is to transform natural resources into prosperity and sustainable development, aiming to be the number one global natural resources company in creating long term value, through

More information

WOLTERS KLUWER COMPANY VALUES AND BUSINESS PRINCIPLES

WOLTERS KLUWER COMPANY VALUES AND BUSINESS PRINCIPLES WOLTERS KLUWER COMPANY VALUES AND BUSINESS PRINCIPLES Mission statement and introduction Wolters Kluwer s customers face critical decisions every day; and the need to get them right. That is why Wolters

More information

Code of Ethics for Pharmacists and Pharmacy Technicians

Code of Ethics for Pharmacists and Pharmacy Technicians Code of Ethics for Pharmacists and Pharmacy Technicians About this document Registration as a pharmacist or pharmacy technician carries obligations as well as privileges. It requires you to: develop and

More information

Code of Practice for Directors

Code of Practice for Directors Code of Practice for Directors This Code provides guidance to directors to assist them in carrying out their duties and responsibilities in accordance with the highest professional standards. 1.0 INTRODUCTION

More information

CODE OF ETHICS AND WHISTLE BLOWER MECHANISM FOR DIRECTORS AND EMPLOYEES Of WHIRLPOOL OF INDIA LTD.

CODE OF ETHICS AND WHISTLE BLOWER MECHANISM FOR DIRECTORS AND EMPLOYEES Of WHIRLPOOL OF INDIA LTD. CODE OF ETHICS AND WHISTLE BLOWER MECHANISM FOR DIRECTORS AND EMPLOYEES Of WHIRLPOOL OF INDIA LTD. BUSINESS WITH INTEGRITY We will pursue our business with honor, fairness and respect for the individual

More information

AlixPartners, LLP. General Data Protection Statement

AlixPartners, LLP. General Data Protection Statement AlixPartners, LLP General Data Protection Statement GENERAL DATA PROTECTION STATEMENT 1. INTRODUCTION 1.1 AlixPartners, LLP ( AlixPartners ) is committed to fulfilling its obligations under the data protection

More information

PRADA Group. Code of Ethics

PRADA Group. Code of Ethics PRADA Group Code of Ethics Index Introduction 2 1. Sphere of application and addressees 3 2. Ethical principles 3 2.1 Application of the ethical principles: obligations of the addressees 4 2.2 Value of

More information

CHARTER FOR RESPONSIBLE ADVOCACY WITH

CHARTER FOR RESPONSIBLE ADVOCACY WITH CHARTER FOR RESPONSIBLE ADVOCACY WITH PUBLIC AUTHORITIES AND REPRESENTATIVE INSTITUTIONS Societe Generale wishes to make an active contribution to the work of regulatory authorities at all levels of governance.

More information

Code of Ethics of Morris Profumi S.p.A.

Code of Ethics of Morris Profumi S.p.A. Code of Ethics of Morris Profumi S.p.A. 1 Contents 1. INTRODUCTION... 3 2. ADDRESSEES... 3 3. ETHICAL VALUES... 4 4. STANDARDS OF CONDUCT... 4 4.1 RELATIONS WITH HUMAN RESOURCES... 5 4.2 MANAGEMENT OF

More information

Sustainable Supplier Charter. UNIT4 Business Procedures

Sustainable Supplier Charter. UNIT4 Business Procedures UNIT4 Business Procedures Table of Contents OUR VISION... 3 IMPLEMENTATION... 3 2. ETHICS: POLICY AND PRINCIPLES... 3 2.1 LOYALTY... 3 2.2 CODE OF CONDUCT... 4 2.3 INDEPENDENCE, BRIBERY AND CORRUPTION...

More information

Code of Ethics. I. Definitions

Code of Ethics. I. Definitions Code of Ethics Old North State Trust, LLC (the Company ) has adopted this Code of Ethics in recognition of the principle that all Supervised Persons (as defined below) of the Company have a fiduciary duty

More information

ETHICS CHARTER SUEZ ENVIRONNEMENT

ETHICS CHARTER SUEZ ENVIRONNEMENT ETHICS charter making the planet sustainable is the Best JoB on earth ETHICS CHARTER SUEZ ENVIRONNEMENT ETHICS charter 4 ETHICS CHARTER SUEZ ENVIRONNEMENT After going public in 2008, SUEZ ENVIRONNEMENT

More information

SCOR Group Code of Conduct

SCOR Group Code of Conduct SCOR Group Code of Conduct Key areas of basic legal and ethical obligations towards clients, shareholders, business partners, the financial markets and towards each other. Effective as of 1 September 2012

More information

Code of Business Conduct and Ethics and Compliance Program Adopted by the Board of Directors

Code of Business Conduct and Ethics and Compliance Program Adopted by the Board of Directors Code of Business Conduct and Ethics and Compliance Program Adopted by the Board of Directors The upholding of a strong sense of ethics and integrity is of the highest importance to AdvanSource Biomaterials

More information

Policy on Prevention of Money Laundering and Terrorist Financing ABH Holding S.A.

Policy on Prevention of Money Laundering and Terrorist Financing ABH Holding S.A. Policy on Prevention of Money Laundering and Terrorist Financing ABH Holding S.A. 2013 CONTENT 1. GENERAL PROVISIONS... 3 2. THE SCOPE AND APPLICABILITY... 3 3. THE PURPOSE OF THE POLICY... 3 4. OBJECTIVES...

More information

Policy Document Control Page

Policy Document Control Page Policy Document Control Page Title Title: Data Protection Policy Version: 3 Reference Number: CO59 Keywords: Data, access, principles, protection, Act. Data Subject, Information Supersedes Supersedes:

More information

LEGISLATION COMMITTEE OF THE CROATIAN PARLIAMENT

LEGISLATION COMMITTEE OF THE CROATIAN PARLIAMENT LEGISLATION COMMITTEE OF THE CROATIAN PARLIAMENT 2300 Pursuant to its authority from Article 59 of the Rules of Procedure of the Croatian Parliament, the Legislation Committee determined the revised text

More information

Code of Conduct of Salzburger Aluminium Gruppe

Code of Conduct of Salzburger Aluminium Gruppe Code of Conduct of Salzburger Aluminium Gruppe The Code of Conduct of Salzburger Aluminium Gruppe (hereinafter referred to as SAG) forms the basis of our everyday activities. It applies to all employees

More information

Group Policy 1. INTRODUCTION 2. BUSINESS INTEGRITY. 2.1. Honesty, Integrity & Fairness

Group Policy 1. INTRODUCTION 2. BUSINESS INTEGRITY. 2.1. Honesty, Integrity & Fairness Corporate Code of Conduct and Ethics Policy Approver: CEO Valid from: 26-11-13 1. INTRODUCTION CRI recognizes its responsibilities as a global services provider, and is committed to being a responsible

More information

HERTSMERE BOROUGH COUNCIL

HERTSMERE BOROUGH COUNCIL HERTSMERE BOROUGH COUNCIL DATA PROTECTION POLICY October 2007 1 1. Introduction Hertsmere Borough Council ( the Council ) is fully committed to compliance with the requirements of the Data Protection Act

More information

STAFF CHARTER AMENDED 24.04.08

STAFF CHARTER AMENDED 24.04.08 STAFF CHARTER AMENDED 24.04.08 Section Human Resources Approval Date 15.11.93 Approved by Directorate Next Review As required Responsibility Chief Executive Key Evaluation Question 6 ITPNZ Quality Standard

More information

KONGSBERG's CORPORATE CODE OF ETHICS BACKGROUND

KONGSBERG's CORPORATE CODE OF ETHICS BACKGROUND KONGSBERG's CORPORATE CODE OF ETHICS BACKGROUND The corporate code of ethics is primarily a tool to describe and influence KONGSBERG's corporate conduct and culture. Our fundamental values are based on

More information

Corporate policy statement on ethical business practices of BCD Travel

Corporate policy statement on ethical business practices of BCD Travel Corporate policy statement on ethical business practices of BCD Travel 1. Statement of policy It is a fundamental policy of the company to conduct its business with honesty and integrity and in accordance

More information

APPROVED Sberbank Supervisory Board decision Minutes No. dated September 2014. Sberbank Corporate Secretary Regulations

APPROVED Sberbank Supervisory Board decision Minutes No. dated September 2014. Sberbank Corporate Secretary Regulations APPROVED Sberbank Supervisory Board decision Minutes No. dated September 2014 Sberbank Corporate Secretary Regulations Moscow, 2014 1 TABLE OF CONTENTS 1. GENERAL PROVISIONS 2. QUALIFICATION REQUIREMENTS

More information

APSO CODES OF PROFESSIONAL PRACTICE INDEX

APSO CODES OF PROFESSIONAL PRACTICE INDEX APSO CODES OF PROFESSIONAL PRACTICE APSO has an important role to play in continuously improving standards and providing guidance to stakeholders on developments and trends in the staffing industry. The

More information

Heijmans. code of conduct. The contents of this code of conduct are based on the policy document Heijmans Code of Conduct.

Heijmans. code of conduct. The contents of this code of conduct are based on the policy document Heijmans Code of Conduct. The contents of this code of conduct are based on the policy document Heijmans Code of Conduct. Heijmans N.V. Group Communications Department Postbus 2 5240 BB Rosmalen The Netherlands Heijmans code of

More information

Little Marlow Parish Council Registration Number for ICO Z3112320

Little Marlow Parish Council Registration Number for ICO Z3112320 Data Protection Policy Little Marlow Parish Council Registration Number for ICO Z3112320 Adopted 2012 Reviewed 23 rd February 2016 Introduction The Parish Council is fully committed to compliance with

More information

Notion VTec Berhad (Company No. 637546-D) Board Charter

Notion VTec Berhad (Company No. 637546-D) Board Charter 1. Introduction In achieving the objectives of transparency, accountability and effective performance for Notion VTec Berhad ( Notion or the Company ) and its subsidiaries ( the Group ), the enhancement

More information

Cofinimmo SA Bd de la Woluwe 58, B-1200 Brussels Tel +32 2 373 00 00 www.cofinimmo.com. Code of Conduct

Cofinimmo SA Bd de la Woluwe 58, B-1200 Brussels Tel +32 2 373 00 00 www.cofinimmo.com. Code of Conduct Cofinimmo SA Bd de la Woluwe 58, B-1200 Brussels Tel +32 2 373 00 00 www.cofinimmo.com Code of Conduct Content 2 Introduction 4 Corporate values 12 Code of Conduct Introduction This document sets out the

More information

Infratil Limited - Board Charter. 1. Interpretation. 1.1 In this Charter:

Infratil Limited - Board Charter. 1. Interpretation. 1.1 In this Charter: Infratil Limited - Board Charter 1. Interpretation 1.1 In this Charter: Act means the Companies Act 1993. Board means the Board of Directors of Infratil Limited. Business means the business of Infratil

More information

Internal Audit Charter

Internal Audit Charter Internal Audit Charter Introduction In accordance with the Public Sector Internal Audit Standards (PSIAS) April 2013, the Head of Internal Audit must formally define the purpose, authority and responsibility

More information

1.2 The conduct of the Board is also governed by the Company's Constitution (Constitution).

1.2 The conduct of the Board is also governed by the Company's Constitution (Constitution). 1. Purpose of the Charter 1.1 This Board Charter (Charter) sets out the role, composition and responsibilities of the Board of Directors of Atlantic Ltd (Atlantic or Company) within the governance structure

More information

UNIVERSAL INSURANCE HOLDINGS, INC. CODE OF BUSINESS CONDUCT AND ETHICS. Revised as of March 3, 2014

UNIVERSAL INSURANCE HOLDINGS, INC. CODE OF BUSINESS CONDUCT AND ETHICS. Revised as of March 3, 2014 I. Statement of Policy UNIVERSAL INSURANCE HOLDINGS, INC. CODE OF BUSINESS CONDUCT AND ETHICS Revised as of March 3, 2014 Universal Insurance Holdings, Inc. ( UIH ) and its subsidiaries (collectively,

More information

Align Technology. Data Protection Binding Corporate Rules Controller Policy. 2014 Align Technology, Inc. All rights reserved.

Align Technology. Data Protection Binding Corporate Rules Controller Policy. 2014 Align Technology, Inc. All rights reserved. Align Technology Data Protection Binding Corporate Rules Controller Policy Contents INTRODUCTION 3 PART I: BACKGROUND AND ACTIONS 4 PART II: CONTROLLER OBLIGATIONS 6 PART III: APPENDICES 13 2 P a g e INTRODUCTION

More information

BUSINESS CODE OF CONDUCT

BUSINESS CODE OF CONDUCT BUSINESS CODE OF CONDUCT PREPARED FOR: ode March 2011 Page 1 Contents 1 BUSINESS CODE OF CONDUCT... 3 2 MISSION STATEMENT... 3 3 PRINCIPLES AND VALUES... 3 4 RELATIONSHIPS... 4 5 BRIBERY AND CORRUPTION...

More information