Code Of Conduct Policy

Our Values and our Commitments

Through all our activities, we intend to build a lasting relationship with our clients, based on trust. We are underpinning our development with our shared values:

TEAM SPIRIT

In our fast-changing world, clients want an IT Solutions provider that is a responsible, trustworthy and flexible partner. We can meet their requirements by working as a team, thanks to our spirit of service, enhanced by the diversity of each person’s skills and knowledge. We want to become the benchmark in the Business Intelligence services industry and work with our clients in the same way as we work with one another, through listening, co-construction, transparency, encouraging contributions, and showing solidarity both in the case of successes and problems.

INNOVATION

We want to continually improve our clients’ experience by taking action together, so we can adjust our solutions, practices and relationships to the uses of the future, in particular by taking advantage of technological innovations. In keeping with our entrepreneurial spirit, we are changing our working methods while fostering a spirit of sharing, experimentation and thinking outside the box. We learn from our successes as well as from our failures.

RESPONSIBILITY

As Business Consultants and IT Professionals, we contribute to the economic, social and sustainable environmental development of the regions wherewe work. We want to help our clients to complete their projects, while remaining attentive to all types of risk. Our responsibility and our ethical standards consist in meeting our clients’ requirements quickly, and in protecting the long-term interests of all of stakeholders, while strictly complying with all the rules governing our businesses. Our responsibility is also reflected in our courage to take responsibility for our actions and decisions, and to express our opinions in a transparent manner. Lastly, responsibility means attaching as much importance to the manner in which results are achieved as to the results themselves.

COMMITMENT

Our commitment is driven by the long-term satisfaction of our clients, and by the pride that we take in our businesses and in our Company. We seek to make a difference on a daily basis, in order to contribute to our clients’ success as well as that of our own projects. We encourage the involvement and professional fulfilment of all our staff. We maintain relationships based on trust and mutual respect externally and internally.

General Principles

RESPECT HUMAN AND SOCIO-ECONOMIC RIGHTS AND RESPECT THE ENVIRONMENT

• We are undertaking the Company’s development while abiding by basic human and social rights and respecting the environment everywhere that we conduct our business.
• We act in accordance with and cooperate with those international initiatives we have chosen to endorse, which include the United Nations Global Compact.
• We are developing our business activities while respecting society and the environment. In conjunction with our stakeholders, we use energy and natural resources economically and we incorporate environmental and social factors in our business decisions.

COMPLY WITH BUSINESS-RELATED LAWS, REGULATION, AND STANDARDS

• We comply with applicable agreements, laws and regulations everywhere we operate, and with additional international commitments and agreements that we have endorsed.
• Together, we conduct our business while abiding by professional policies and procedures and ethical practice.
• We ensure the transparency and honesty of information disclosed to our clients, investors, supervisory authorities and the public in general.
• Business operations, our organisational structure and our procedures comply with ethical professional practice and policies and procedures set out by the Company.

ENCOURAGE DIVERSITY AND RESPECT INDIVIDUAL PRIVACY

• Each of our entities encourages diversity and refrains from practising any form of discrimination whatsoever with regard to its staff and job applicants.
• Each of our entities adheres 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 accordance with the International Labour Organisation conventions, even where local legislation permits such practices.
• We respect individuals’ privacy, whether they are clients, partners or employees. We request only information which is of use in serving the interests of our clients and partners, improving the quality of our service provision, complying with statutory obligations, or in contributing toward our company’s management.
• We observe political neutrality and refrain from supporting any political organisations or activities through donations or subsidies, even where local legislation so permits.
• We respect the commitments of those of our employees who, as citizens, wish to participate in public life.

Our Commitments

To Our Clients

• We put all our energy and skills to work to serve our primary purpose – client satisfaction.
• Energised daily by our values, we establish and maintain lasting relationships with our clients based on trust, expertise and respect.
• We make use of our in-depth knowledge of our clients to offer them products and services appropriate to their situation and requirements
• We enter into contractual relationships only with those clients whose practices are, or aim to be, consistent with our own general principles.
• We are aware of the importance that our clients place on retaining control over their personal data. This is why our Company is reaffirming its commitment to being responsible in its data processing activities: we undertake to secure and protect this data, and to use it in an ethical and transparent manner in order to provide our clients with the best possible service.

To Our Employees

• We are confident in the skills, loyalty, integrity and commitment of our employees, who are our company’s leading asset. We know that we can count on their sense of responsibility to govern their behaviour in their working lives. We expect them to avoid any conflict of interest.
• We pay particular attention to their working conditions especially with regards to health and safety.
• We involve them in Company governance by fostering dialogue, information and discussion.
• We respect their privacy.
• We recruit staff solely on the basis of our requirements and each applicant’s individual qualities.
• We develop their professional skills and increase 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.
• We protect our employees from any form of harassment in the workplace.
• Each of our employees has regular meetings with their line management during which objectives are set and development plans are drawn up.

To Our Suppliers and Service Providers

• We undertake to adhere to the above mentioned general principles with respect to our suppliers and service providers. In return, we expect them to adhere to principles equivalent to those in our Code of Conduct.
• We ensure that all parties’ interests are taken into consideration, transparently and in accordance with contract terms.

To Countries Where We Are Active

• We respect the cultures and the environment of the countries where we operate. Through our business activities we contribute to the economic and social development of these countries.

Individuals and Collective Conduct Guidelines

• The harmonious development of our Company is based on trust, both between employees and between the Company 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.
• Each of us always adheres to all agreements, directives and instructions in force within the Company.
• Everyone demonstrates loyalty and fairness and fosters good relationships with our colleagues. They undertake to act in accordance with our Company’s values.
• Everyone ensures that the activities dependent on them are conducted in accordance with our Company’s existing policies and procedures as regards the protection of health, safety and the environment.
• Each of us takes the social, economic and environmental consequences of our decisions into consideration.
• Over and above compliance with laws and regulations, everyone acts with integrity both inside and outside the company when they are representing it.
• Restraint is to be exercised when making statements on any Company related matter outside of the Company.
• Everyone contributes toward the implementation of our best practices and co-operates with any audits diligently and transparently.

Maintaining the Confidentiality of Information

• Business confidentiality is an essential component of our role as Business Consultants and IT Professionals. 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.
• Electronic mail is to be categorised on the basis of the confidentiality level of the information it contains.
• The sending of information of a professional nature outside the Company via messaging services or other external media that are unrelated to the professional environment is prohibited in principle. In exceptional cases, information of this kind may be sent, primarily via a personal messaging service, under the conditions provided for in internal procedures.

Conflicts of Interest

• Each of us refrains from maintaining personal relationships with our clients, partners and suppliers which could compromise our professional duties or place us in a situation of conflict of interest. We report to our line management and the Compliance department any conflict of interest to which we might be subject.
• We must avoid our own interests or those of our immediate circle entering into conflict with our Company’s interest.
• Where there is any doubt about particular engagements or situations with respect to this Code of Conduct or any applicable Instructions, we should seek advice from our line management and the Compliance department.
• Where one of us may be considered as a Company representative, he or she must refrain from involving our Company or any Company entity in any public activities or responsibilities that he or she may exercise outside of the Company.

Dealings with our Clients and Suppliers

• We must all meet the commitments made in our dealings with our clients, partners and suppliers, treating them fairly and making any choices necessary on the basis of objective criteria.
• All corrupt practices are prohibited. Those of us who are subject to pressure or requests from third parties must inform their line management.
• Gifts to our clients or their representatives must be modest and comply with the rules set by our Company’s entities. The same applies as regards individuals in positions of public authority, government officials and similar persons.
• Similarly, each of us will strictly adhere to the value limits that apply in our entity to gifts or invitations from our clients or any other business relationship.
• To avoid any questionable situation, if necessary each of us must seek advice on the stance to be adopted from our line management.
• As part of the provisions relating to the prevention of money laundering, terrorist financing and tax evasion, and in compliance with national and international rules on sanctions and embargos, everyone is continuously vigilant, and must follow customer identification and ‘know your customer’ procedures for all clients.

Use of Resources

• Each of us ensures that our company’s assets are protected and uses them reasonably, in compliance with the policies and procedures governing their use and application, as communicated to us.
• No one must make excessive personal use of the equipment and services made available to them.
• Everyone strives to use resources economically and to take account of environmental aspects in their decision making.

Compliance with the Code of Conduct

• Every one of us, both permanent and temporary employees, must comply with the Code of Conduct, thereby contributing to the protection of our Company’s most important asset, namely its reputation.
• We collectively and individually ensure this Code is applied and that all of our actions comply with it, irrespective of our position within the Company.
• Compliance with the Code of Conduct is in particular enforced by the application of the internal policies and procedures of our Company and its affiliates.
• Everyone assumes their responsibilities on a day-to-day basis, and must not hesitate to share their questions and concerns, where applicable, in order to prevent any kind of risk.