ALTEN ETHICS & COMPLIANCE
Prevention of corruption
A “zero tolerance” policy concerning corruption
The ALTEN Group has a “zero tolerance” policy regarding corruption and strives to disseminate this message to all its stakeholders. In addition, the ALTEN Group carries out its activities in compliance with the national and international standards to which it is subject regarding the prevention and the detection of corruption acts.
ALTEN has defined and carries out its anti-corruption policy in compliance with the eight pillars prescribed by the Sapin II Law. This policy is formalized by a set of reference documents, guides and policies reaffirming the Group’s commitment and the guiding principles in the prevention of corruption.
A supervised practice of gifts and invitations offered or received
ALTEN Group acknowledges that invitations and gifts offered or received can play an important role in developing good business relationships. However, these practices can sometimes be seen as a factor that influences business decisions, constituting therefore an act of corruption or leading to a conflict of interest. In order to monitor these behaviors, ALTEN has issued a gift and hospitality policy that reaffirms the guiding principles, set out the criteria for granting or accepting gifts and invitations, and provides employees with recommendations when confronted to potentially risky situations.
Are you a direct witness to an act of corruption, to an unethical behavior committed by ALTEN ?
In such case, you can use our whistleblowing system by logging into the secure platform: https://alten.integrityline.com/
Prevention and management of conflicts of interest
Each ALTEN’s employee must perform his/her duties objectively. This is why the Group promotes transparency towards any situation that could give rise to a potential or proven conflict of interest.
The Group has a practical guide on conflicts of interest in order to increase employee awareness. The Group also provides several channels of information/communication to report situations of potential or proven conflicts of interest.
The Group’s policy on conflicts of interest is also reaffirmed in the Anti-corruption Code of Conduct and in the Ethics and Compliance Charter.
Management of lobbying and interest representation
The ALTEN group undertakes to carry out its lobbying activities in accordance with applicable national and international laws and conventions, as well as its compliance policy.
The lobbying rules are reaffirmed in the Anti-corruption Code of Conduct. The Group ensures that lobbying activities are clear and transparent and do not aim at obtaining information in a dishonest manner. ALTEN also ensures that the information provided is up-to-date, complete and accurate. To do so, lobbying actions require Management’s prior approval.
To date, the ALTEN Group does not carry out any lobbying activity, which is why it does not appear in any register.
Should ALTEN start developing this practice, it undertakes to comply with all of these obligations.
Compliance with international sanctions
The ALTEN group operates in strict compliance with international sanctions regimes.
The Group’s compliance policy also covers prevention of risks in terms of violation of international sanctions. This is referred to in the “Ethics & Compliance in a nutshell” guide, distributed to all Managers and Ethics & Compliance ambassadors.
The due diligence of third parties, which has been implemented as part of anti-corruption measures, is also intended to prevent risks in terms of violation of international sanctions by the ALTEN Group.
Compliance with competition rules
ALTEN Group and its employees comply with French, European and international competition law and the laws applicable in each of the countries in which the Group conducts its activity.
ALTEN Group and its employees refrain from directly or indirectly hindering freedom of competition in all commercial transactions.
They also refrain from adopting any unfair trading practices towards competitors and from striking any unlawful deals.
In order to achieve this objective, the Group disseminates practical sheets so as to make all employees aware of the necessity to comply with competition rules. The Group’s principles are also reaffirmed in the Ethics & Compliance Charter.
The ALTEN group provides employees with several information/communication channels to report non-compete situations.
Protection of personal data
ALTEN takes all the necessary precautions to ensure that personal data is processed securely and in accordance with regulations.
The Group has a dedicated organization and governance and has created a Group DPO position. The Group DPO reports to ALTEN’s Ethics & Compliance Group department and is involved in all matters in connection with the processing of personal data.
The DPO has all the necessary means to carry out his duties and has access to processing operations. He does not receive any instructions relating to the performance of his duties from the company and reports directly to the highest level of management of the company.
The Group DPO is responsible for coordinating and deploying, through a network of Data Protection Officers (DPOs) or Data Protection correspondents, the Group’s policies and processes in terms of personal data protection.
As such, a group personal data protection policy has been put in place in order to ensure consistency in the procedures and processes for the protection of personal data within the Group.
ALTEN also mobilizes significant resources to train all its employees on issues relating to data security and confidentiality as well as the protection of personal data, whether through e-learning, face-to-face training or through the distribution of guides and guidelines.