Code de conduite Anglais 2023

CODE OF CONDUCT GROUPE ADP

CODE OF CONDUCT GROUPE ADP

PÉRIMÈTRE GROUPE ADP

V2 – 07/2023

V2 – 07/2023

of such a commitment, a violation of European Union law, or a violation of the law or regulations. A whistleblower benefits from legal protection against any reprisals (from his or her employer, for example) and any criminal prosecution.

MONEY LAUNDERING Money laundering is the act of ‘cleaning’ illicit gains (from drug trafficking, theft, fraud or tax fraud, etc.) by funneling them into legal activities (property, restaurants, etc.). In France this offence is punishable by 5 years’ imprisonment and a fine of € 375,000, and in more serious cases by 10 years’ imprisonment and a fine of € 750,000. OBSTRUCTIONIST MANEUVERS Obstructionism means an act of deliberately destroying, falsifying, altering or concealing any evidence in an investigation, or making false statements to investigators in order to materially interfere with an investigation. UNLAWFUL TAKING OF INTEREST An unlawful taking of interest occurs when a person with public authority, responsible for a public service mission, or vested with publicly elected powers directly or indirectly takes, receives, or keeps an interest of any kind in a company or concern, while being at the time partly or wholly responsible for the monitoring, running, liquidation or payment of said company or concern. In France this offence, committed by a physical person, is punishable by 5 years’ imprisonment and a fine of € 500,000, or in some cases double the profit made from the crime. For a legal entity, the fine is €2,500,000, which can also be increased to twice the proceeds of the offence.

USURPATION OF IDENTITY OR FUNCTION The fact of making use of one or more data of any nature allowing to usurp the identity of a third party, to identify him in order to disturb his peace or that of others. The usurpation of function is the fact by any person acting without title, to interfere in the exercise of a public function by accomplishing one of the acts reserved to the holder of this function. STAKEHOLDERS A stakeholder is a person or group of people who can influence or be influenced by the company's achievement of its objectives. Stakeholders can have a direct or indirect relationship with the company. Stakeholders can be internal (managers, employees, directors, etc.) or external (shareholders, partners, customers, suppliers, competitors, and so on). TENDERER A tenderer is an economic operator who submits a bid in the context of a procedure for the award of a public procurement contract. WHISTLEBLOWER A whistleblower is a physical person who reports or discloses, without direct financial compensation and in good faith, information concerning a crime or misdemeanor, a threat or prejudice to the general interest, a violation or attempted concealment of a violation of an international commitment duly ratified or approved by France, a unilateral act of an international organization taken on the basis

LOBBYING According to Transparency International (a coalition of which Groupe ADP has been a member since 2008), lobbying is “any written or oral communication between the representative of an interest-group and a public decider intended to influence decision-making”. MISUSE OF COMPANY ASSETS The misuse of company assets is an offence that may be committed by company managers who use company goods or credit in bad faith and in the knowledge that their use is contrary to the company’s interests, either for personal gain or to benefit another company or entity in which they have a direct or indirect interest. In France this offence is punishable by up to 5 years’ imprisonment and a fine of €375,000. MISAPPROPRIATION OF PUBLIC PROPERTY OR FUNDS Misappropriation of public funds is the unlawful use of public money or property for purposes other than the public good. The fact that an agent destroys, embezzles or removes public funds or property that has been given to him/ her by virtue of his/her duties or mission. This offence, committed by a natural person, is punishable by 10 years' imprisonment and a fine of €1,000,000, which may be increased to twice the amount of the proceeds of the offence. When it affects the financial interests of the European Union, the fine is €2,000,000, which can be increased to twice the amount of the proceeds of the offence. For a legal entity, the fine is €5,000,000, which can be increased to twice the amount of the proceeds of the offence.

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