Code de conduite Anglais 2023

CODE OF CONDUCT GROUPE ADP

CODE OF CONDUCT GROUPE ADP

PÉRIMÈTRE GROUPE ADP

V2 – 07/2023

V2 – 07/2023

PREVENTING INFLUENCE PEDDLING

For example:

I am working on the construction of a new airplane hangar; the authority is delaying the delivery of the building permit. I know the brother of the deputy of this authority who travels a lot. I would like to ask him to speed up, with his brother, the obtaining of the permit in exchange of a parking card of the ADP Group.

Influence peddling consists of soliciting a public person or a private person in charge of a public service mission (such as Aéroports de Paris SA) by providing them with an advantage so that they use their real or supposed influence with another person in order to obtain a favorable decision. The intention alone can be qualified as a crime. Like corruption, it can be active (on the part of the person who solicits) or passive (on the part of the person who uses his influence). The sanctions are the same as for corruption.

Is this acceptable?

This is an act of influence peddling punishable by law and by Groupe ADP.

BEST PRACTISES

BE AWARE  Allow some ambiguity in relationships with business partners.

 In accordance with the disclosure requirements for listed companies, provide only verifiable and up-to-date information.  Prohibit any behavior that could be perceived as a form of influence peddling, in particular by respecting the rules regarding gifts and invitations.  Consult the charter of responsible lobbying which frames the actions of representation of interests.  Share our commitment with our partners in our activities.

STRICLY FORBIDDEN

 Offering an advantage of any kind (money, gift, invitation, service, etc.) to an elected official, a member of an administration, etc., so that they influence an acquaintance with a view to a decision, a vote, etc., in favor of the ADP Group.  Representing interests without being mandated by the ADP Group without following the principles of the responsible lobbying charter.  Make a commitment, on behalf of the Group, to finance political parties.  Use intermediaries (business introducers) without informing the Group's Legal Department.

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