ABOUT ETHICS AND COMPLIANCE AT COMPAGNIE DES ALPES:
As a responsible economic operator, integrity and probity are at the heart of everything we do.
They are an absolute priority that form part of our stated intention to collectively respect all stakeholders, such as our customers, employees, partners, and the public authorities. It is consequently of the utmost importance for us to make every effort to ensure that our business operations are lawfully carried out, in an ethical and responsible manner.
This conviction that ethical values and integrity should guide all Group employees’ actions and decisions requires us to demonstrate exemplary conduct, honesty and loyalty, in full transparency, and in compliance with laws and regulations.
It is therefore essential that we share the same principles with the persons with whom we collaborate.
The credibility of our image, the quality of everyone’s work, the sustainability of our business operations and our customers’ trust depend on the implementation of these values and contribute to our mutual development.
The rules set out in this Code of Business Integrity consequently represent an indispensable aspect of our business relationship, which you accept to comply with by working with us, to cooperate on a long-term basis in the development of ambitious and responsible projects.
Dominique Thillaud
Chief Executive Officer
READING GUIDE
Compagnie des Alpes Group has decided to adopt the Middlenext1 Anti-Corruption Code of Conduct as its code of reference (see Section II.). This code defines the risks of corruption and influence peddling and lays down the general principles whilst taking into account changes in this area.
To guide Group employees in the performance of their duties, response sheets (see Section III.) describe high-risk situations and positions, and the conduct to adopt when faced with a risk of corruption or influence peddling in the scope of our business operations. These sheets reflect high-risk situations in the Group.
This Code applies to all Group employees2 and the legal representatives of Group entities.
In accordance with the requirements of the Law 2016-1691 of 9 December 2016, referred to as the Sapin 2 Law, the Company’s Anti-Corruption Code of Conduct forms an integral part of the Company’s and its subsidiaries’ Internal Policies and Procedures. Non-compliance with the principles laid down in this Code is subject to disciplinary sanctions up to and including dismissal.
In accordance with the Sapin 2 Law, the Group has adopted a whistleblowing alert mechanism, which enables every employee and all third parties to report incidents of a certain severity. This procedure exists in its own right and covers incidents other than corruption and influence peddling.
It is one of the components of the corruption prevention plan and is available on the Company’s intranet and extranet websites.
The Legal Affairs and Compliance Director has been appointed
Group Ethics Officer
In this respect, the Group Ethics Officer is the custodian of this Code and is available to respond to any question on its interpretation or application.
1 French independent professional association exclusively representing mid-cap listed companies. 2 Group employee means any person who has an employment contract or equivalent (professional training contract, work-study contract, etc.) with a Group company.
MIDDLENEXT CODE OF CONDUCT
Middlenext Anti-Corruption Code of Conduct
Introduction
The Middlenext Anti-Corruption Code of Conduct (the Code) refers to the United Nations Convention against Corruption and seeks to combat all forms of corruption.
The Code constitutes an integral part of the Company’s internal policies and procedures.
A document cannot, however, address all cases of corruption and influence peddling that may arise in the course of day-to-day activities; everyone must accordingly exercise their own judgement and common sense. In event of doubt about what conduct should be adopted, each company relies on the support and advisory tools it has put in place and an internal alert system.
This Code may be revised.
Framework and scope
The Code applies to all employees of the companies and/or groups that adopt the Middlenext Anti-Corruption Code of Conduct.
Each employee must behave in an exemplary manner within each company and must not do anything which is at odds with the behavioural rules set out in this Code. Any questions from an employee regarding the application or interpretation of the Code must be referred to the employee’s line manager or the contact person appointed by the company.
Basic rules and variations
Definitions
- Corruption is any behaviour whereby a person (whether a public official or a private individual) proposes, requests or accepts, directly or through an intermediary, any donation, offer or promise, gift or benefit in return for performing, delaying or failing to perform an act which, directly or indirectly, falls within their duties in order to obtain or maintain a commercial or financial advantage or influence a decision.
There are two types of corruption:
- Active corruption occurs when the act of corruption is initiated by the person on the giving end.
- Passive corruption occurs when the act of corruption is initiated by the person on the receiving end, i.e., the person who performs or does not perform an act in exchange for some reward.
Corruption may take many forms under the guise of common business or social practices; it may, for example, involve such things as hospitality, gifts, sponsorships, donations, etc.
Influence peddling refers to a person monetising their position or influence, whether real or supposed, in order to influence a decision which is to be made by a third party.
It involves three participants: the beneficiary (the one who provides benefits or gifts), the intermediary (the one who uses the influence they enjoy by virtue of their position) and the target person who has the decision-making power (a government authority or agency, a judge or prosecutor, an expert etc.).
Principle and rules
Employees must not engage in acts of corruption and must not use intermediaries such as agents, consultants, advisers, distributors or any other business partners for the purpose of committing such acts.
Individuals faced with a proposal must consider the following:
- Does the proposal comply with laws and regulations? Is it consistent with the Code and the interests of the company? Is it devoid of personal interest? Would I be embarrassed if my decision were made known to others?
Each company that uses the Code as a reference has developed an internal alert procedure that enables employees faced with a choice involving ethical or business-related considerations to discuss any concerns they may have in a totally confidential setting.
Rules applying specifically to public officials
Definitions
The term "public official" denotes a person who holds a position of public authority, is entrusted with public service responsibilities or occupies an elected public office, for themselves or on behalf of others.
Principle and rules
Corruption of a public official is punishable by more severe penalties1.
Any relationship with a public official must comply with the regulations governing that relationship (i.e., the regulations that apply in the specific country of the public official or which are imposed on them by their employer). While it is not prohibited by law, any benefit granted to a public official must be totally transparent vis-à-vis the company and subject to prior authorisation by the senior management.
Gifts and hospitality
Definitions
Gifts are benefits of any kind given by someone as a token of gratitude or friendship, without any expectation of receiving something in return.
Offering or being offered meals, accommodation and entertainment (shows, concerts, sports events, etc.) is considered to be an invitation.
Principle and rules
Gifts and hospitality may be related to or be perceived as acts of active or passive corruption, so care must be exercised with regard to gifts, gestures of courtesy and hospitality (received or given) and invitations to entertainment that contribute to good relationships but can be seen as a means of influencing a decision or favouring a business or a person.
The Group has implemented a Gifts, Hospitality and Donations Policy applicable to everyone which forms part of the Group’s corruption prevention plan. It clarifies and supplements the principles set out in the Anti-Corruption Code of Conduct.
Donations to charitable or political organisations
Definitions
Grants and donations are benefits given in the form of money and/or contributions in kind; they are granted for a specific purpose: research, training, the environment (sustainable development), for charitable or humanitarian purposes, etc.
Political contributions - whether monetary or otherwise - are intended to support political parties, leaders or initiatives.
Principle and rules
Requests for grants, donations or contributions must be carefully considered, particularly requests from those who are in a position to influence the company’s activities or who could, if the grant were agreed to, derive personal benefit therefrom.
Requests for donations must be approved by a line manager.
The Group has implemented a Gifts, Hospitality and Donations Policy applicable to everyone which forms part of the Group’s corruption prevention plan. It clarifies and supplements the principles set out in the Anti-Corruption Code of Conduct.
Patronage, sponsorship
Definition
Through patronage or sponsorship, the Company wishes to provide financial or material support to charitable organisations or social, cultural or sports actions as a means of communicating and promoting its values.
Principles and rules
They must be carried out without seeking any specific benefits from the beneficiary other than the promotion of the corporate image.
Corruption Code of Conduct. Facilitation payments
Definition
Facilitation payments are unofficial payments (as opposed to legitimate and official fees and taxes) that are paid to facilitate or expedite any administrative formalities such as applications for permits, visas or customs clearances, etc.
Principle and rules
The company does not accept to make “facilitation payments” unless there are compelling reasons (health or safety of an employee, etc.).
The Group has implemented a Gifts, Hospitality and Donations Policy applicable to everyone which forms part of the Group’s corruption prevention plan. It clarifies and supplements the principles set out in the Anti-Corruption Code of Conduct.
Monitoring of third parties (suppliers, service providers, customers)
Definition
Monitoring concerns third parties, natural or legal persons with whom the company interacts and who may, in certain cases, present a particular level of risk in terms of corruption.
The following are considered third parties: business partners, suppliers, service providers, agents, clients, intermediaries etc.
Principle and rules
Each company will endeavour to ensure that third parties comply with its principles and values and will, where appropriate, carry out due diligence.
The Group has implemented a Code of Business Integrity for Partners and a Third-Party Evaluation Policy which form part of the Group’s corruption prevention plan. These documents clarify and supplement the principles set out in the Anti-Corruption Code of Conduct.
Conflicts of interest
Definition
Conflicts of interest arise from any situation in which employees' personal interests conflict with their duties or responsibilities.
Principle and rules
If circumstances give rise to a potential or actual conflict of interest, the employees concerned must report this.
Accounting records/Internal controls
Definition
The company must ensure that its accounting departments and/or its internal and/or external auditors are vigilant in checking for concealment of corruption in books, records and accounts.
Principle and rules
Persons undertaking audit assignments (audits, certification of accounts) must be particularly vigilant with regard to the accuracy and veracity of the accounts.
Applying the Code
Training
Employees are required to read this Code and participate in the training sessions organised by the company to raise awareness on the fight against corruption. New employees are made aware of the Code and its provisions immediately on joining the company.
Reporting practices that are in breach of the Code and whistleblower protection
Employees, while observing the procedure laid down by the company, can express their concerns and/or ask questions to their line manager and/or the designated contact person:
- If they find themselves faced with a risk of corruption;
- If they genuinely believe that a violation of the Code has been, is being, or may be committed;
- If they discover that someone is experiencing reprisals after having filed a whistleblowing alert in good faith or facilitating a person to file an alert in good faith.
Any employee who, in good faith and without being influenced by personal interest or advantage, that is to say, being sincerely persuaded that their statement is accurate, reports a violation or a risk of a violation of the Code to their line manager or the contact person, will be protected from all forms of reprisals. The identity of any such employee and the facts of the matter will be treated confidentially, in accordance with applicable laws and regulations.
Furthermore, while a genuine error will not result in any disciplinary action, allegations that are deliberately false or made with malicious intent will be penalised.
Whistleblowing alert mechanism and personal data protection
Employees must be informed of the existence of the mechanism.
In accordance with the rules applying to the protection of personal data in force in most of the countries in which the company operates and, in particular, within the European Union, any persons identified in the scope of a whistleblowing alert mechanism, whether as the author or the subject of a such a report, may exercise their right to access the data relating to them.
Likewise, anyone may also request the correction or deletion of personal data if it is inaccurate, incomplete, ambiguous or out-of-date in accordance with the same procedure.
You also have a right to restrict processing and you may object to such processing in some circumstances.
The Group has implemented a whistleblowing alert mechanism applicable to everyone which forms part of the Group’s corruption prevention plan. It clarifies and supplements the principles set out in the Anti-Corruption Code of Conduct.
Penalties for breaches of this Code
Non-compliance with the rules triggers the personal liability of the employee and exposes them to penalties, in particular penal sanctions2, in accordance with applicable legislation.
- The company undertakes to:
- Take all statements into account;
- Diligently investigate whistleblowing alerts;
- Assess the facts objectively and impartially;
- Take appropriate corrective and disciplinary measures.
Implementation: accountability and oversight
It is incumbent upon each employee to implement the Code as part of the responsibilities attached to their position.
The company carries out periodic checks to confirm that work practices comply with the Code.
The company and/or Group governance bodies provide regular updates on the monitoring of the Code and any follow-up arising from whistleblowing alerts.
RESPONSE SHEETS
The mapping of risks linked to corruption and influence peddling identifies: (i) "high-risk” operations, i.e., operations during which Group employees are more inclined to be faced with acts of corruption or influence peddling, and (ii) the most exposed positions.
Some situations are described below and alert employees about the main high-risk situations involving corruption in the Group.
HIGH-RISK OPERATIONS:
SKI DOMAINS
o Obtaining, renewing or amending a public service delegation contract;
o Relations with shareholders, public entities;
o Invitations for visits to Compagnie des Alpes sites (municipalities, sports federations, etc.) and distribution of packages/free admission tickets/passes/VIP cards;
o Purchases of equipment, ski lifts;
o Decisions on installation of new ski lifts, creation of new ski slopes;
o Obtaining commissioning permits (STRMTG, BEA);
o Works (applications for building permits);
o Real estate projects;
o Obtaining a label (e.g., GreenGlobe);
o Hiring (favour granted to a family member of an elected official or member of an influential organisation);
o Donations to associations, patronage;
o Contractual negotiations with the SRM, municipality and/or ski school;
o Participation in work by professional bodies (DSF);
o Trading in goods;
o Relations with local residents;
o Relations with environmental protection bodies;
AMUSEMENT PARKS
o Obtaining, amending or renewing a lease (land);
o Relations with shareholders, public entities;
o Obtaining operating permits (links with the prefecture, municipalities, fire service, etc.);
o Invitations for visits to Compagnie des Alpes sites (municipalities, sports federations, etc.) and distribution of packages/free admission tickets/passes/VIP cards;
o Purchases of equipment, attractions;
o Obtaining a licence (show licence);
o Works (applications for building permits);
o Real estate projects;
o Trading in goods;
o Participation in work by professional bodies (SNELAC, IAAPA);
o Relations with local residents;
o Relations with environmental protection bodies;
DEVELOPMENT DEPARTMENT
o M&A deals (acquisitions, equity investments, transfers, etc.);
o Invitations for visits to Compagnie des Alpes sites (municipalities, sports federations, etc.) and distribution of packages/free admission tickets/passes/VIP cards;
o Links with public organisations (such as embassies) in countries where we are prospecting;
o Prospecting customers/partners/investors in countries with high risks of corruption (China, Russia, Turkey, etc.);
o Obtaining administrative permits (visas, work permits, etc.);
o Request by a supplier to help promote its products/equipment by recommending it to a Compagnie des Alpes customer;
o All types of purchases (services, hardware, supplies, software, etc.);
HOLDING COMPANIES
o All types of purchases (services, hardware, supplies, software, etc.)
HIGH-RISK POSITIONS
o Executive Management
o Operations Director
o Finance Department
o Works Manager
o Development Managers (prospective customer relations)
o Buyer
o Seller (negotiations with our BtoB customers)
o All positions involved in the buying process
o Administrative Assistants (obtaining a visa, work permit)
The following section contains questions and answers aimed at providing guidance to employees on day-to-day issues. The situations included are those with which Group employees are most likely to be faced in the performance of their duties.
However, this section is not exhaustive. Other situations may involve risks of corruption or influence peddling.
Each employee must refer to the Anti-Corruption Code of Conduct in the performance of their duties and, if in doubt, refer to their line manager or the Ethics Officer.
RULES APPLYING SPECIFICALLY TO FRENCH OR FOREIGN PUBLIC OFFICIALS
Can I offer a gift to a public official4, invite them to a restaurant or offer them a free admission ticket?
Public officials who engage in acts of corruption face particularly severe penalties, i.e., ten years’ imprisonment and a fine of €1 million. The amount of the fine may be increased to double the proceeds of the offence for individuals and €5 million for legal persons, the amount of which may be increased to ten times the proceeds of the offence.
You must not give or offer a gift, invitation to an event, free admission ticket or other benefit to a public official, for example a member of a federation, municipality, administrative authority, if they are directly participating in decisions relating to the Group (issuing a building permit or any other administrative permit) and if discussions are in progress concerning these decisions.
You may give a gift, invite a public official to an event, etc. outside of any discussions in progress between the Group and the entity for which this public official works, and insofar as this remains infrequent, the expense incurred by Compagnie des Alpes is moderate and it is only for the public official and not their family.
You should systematically ask yourself if this gift or benefit may compromise the public official’s independence of judgement.
RULES APPLYING SPECIFICALLY TO FRENCH OR FOREIGN PUBLIC OFFICIALS
Can I invite a public official to visit one of our sites?
Visits to Compagnie des Alpes sites are justified when they are aimed at presenting Compagnie des Alpes sites, services offered and know-how and promoting a site or the Group. This applies to DS and DL site visits, for example by a member of a municipality, federation, etc. They are no longer justified when they result in influencing a third party’s decision.
Can I hire a family member of a public official?
Awarding a trainee contract to a family member of a public official or with close personal ties with a public official is not automatically forbidden but special care must be taken and validation by the corporate officer concerned must be granted.
Hiring a family member of a public official or with close personal ties with a public official, whether requested or not by the public official, may constitute a case of passive corruption, insofar as the benefit granted to the new employee may lead the public officer to be more favourable to the Group’s interests
If a public official asks you to accept a family member or person with whom they have close personal ties for a trainee contract or employment contract in the Group, you should ask yourself if it is the right time to accept this type of request, i.e., if the Group is in discussion with the organisation to which the public official is attached and if, for example, a Group entity is awaiting a response regarding an administrative permit (public service delegation contract, operating permit, building permit, etc.).
GIFTS AND HOSPITALITY
Can I offer a gift or benefit to a prospective customer or customer?
Each employee must refrain from offering any gift, invitation or benefit to a third party that may compromise such third party's independence of judgement now or in the future, whether in the scope of a call for tenders (call for tenders to provide services or goods) or in the scope of contractual negotiations (contracts for the sale of tickets or services, etc.).
Can I receive a gift or benefit from a third party?
Each employee must refrain from receiving any gift, invitation or benefit that may compromise their independence of judgement now or in the future, whether in the scope of a call for tenders (purchase of goods or services from a supplier), signature of a contract (purchase contracts for supplies or services, etc.).
DONATIONS TO CHARITABLE OR POLITICAL ORGANISATIONS
Donations to associations or charitable or other organisations are sensitive expenses insofar as they are considerably unrelated to our core business and granting a donation may be qualified as active corruption, for example if a person working for this organisation may be able to influence a decision giving preferential treatment to the Group.
PATRONAGE/SPONSORSHIP
Patronage expenses (for example, financing or participating in the financing of a sports event) are also sensitive expenses. Participating in this type of financing may be qualified as active corruption (regardless of whether the third party requested the financing or not) if it is established that the entity which incurred the expenses sought to obtain any benefit whatsoever from the organisation concerned.
FACILITATION PAYMENTS
In the scope of obtaining an administrative permit (visa, etc.), what should I do if I am asked to make a payment (“facilitation payment”)?
All employees must refrain from offering any sum, gift, invitation or benefit to a third party which is aimed at obtaining an administrative permit of any kind (permit to operate a ski lift, an attraction, obtain a visa).
Any such request by an administrative authority must be immediately reported to the corporate officer of your entity, who will give you instructions on the conduct to adopt.
MONITORING OF THIRD PARTIES
In the performance of my duties, I need to purchase a product or services from a third party.
What conduct should I adopt with regard to this third party?
It is important to evaluate if the suppliers with which the Company has business relations or is about to enter into business relations are also committed to combating corruption. Whether business relations can continue or be launched will depend on this evaluation.
The Group has implemented a Third-Party Evaluation Procedure, distributed using the standard channels in the Group, which defines the situations in which it is necessary to conduct a supplier evaluation and the information to be obtained before entering into business relations. Each employee undertakes to follow this procedure.
In the performance of my duties, I am about to negotiate a trading, commission and distribution contract for the sale of tickets with a new customer. What conduct should I adopt regarding this customer?
It is important to evaluate if the companies we are prospecting and with which we are about to enter into business relations are also committed to combating corruption.
The Group has implemented a Third-Party Evaluation Procedure, distributed using the standard channels in the Group, which defines the situations in which it is necessary to conduct a prospective customer evaluation and the information to be obtained before entering into business relations. Each employee undertakes to follow this procedure.
CONFLICTS OF INTEREST
When should I ask myself if I am confronted with a conflict of interest and what conduct should I adopt?
A conflict of interest may arise, for instance, in the following situations:
o Holding financial interests in an external company which has professional relations or wishes to develop professional relations with the entity to which I am attached or which is competing with the latter entity;
o Acting as intermediary on behalf of a third party in relations concerning the entity to which I am attached;
o Using confidential information or physical or intellectual property owned by the entity to which I am attached for personal purposes or on behalf of a third party;
o Working for another company during working hours.
The Group has implemented a Conflicts of Interest Prevention and Management Policy which is distributed using the standard channels in the Group.
As a conflict of interest may affect all employees, each employee undertakes to comply with the policy and be transparent in this respect.
When faced with a potential or established conflict of interest situation, the employee must promptly consult the Chief Executive Officer of their company and the Ethics Officer and may request to be removed from the project.
Any personal involvement in a transaction, negotiations or contract on behalf of the Group with an entity in which you or your close relations have direct or indirect interests - without first obtaining written approval from your line manager - is forbidden.
ACCOUNTING RECORDS/INTERNAL CONTROLS
One way offenders try to protect themselves from legal action for acts qualified as corruption or influence peddling involves concealing sensitive expenses in traditional accounts.
In the scope of implementing the Sapin 2 Law, employees in finance and internal control positions are made aware about acts of corruption and influence peddling.
Internal procedures have been implemented to verify that the corporate accounts are not used to conceal any acts of corruption.
Groupe CDA
CODE OF BUSINESS INTEGRITY FOR PARTNERS
Values and convictions
CDA’s model is founded on the values of probity, compliance and integrity. This is why the Group is very vigilant in its choice of partners.
The objective of the Code of Business Integrity for Partners is consequently to make sure that the Group’s values align with its partners’ values and, by extension, ensure that partners comply with the rules set out in this Code.
This Code applies to CDA’s subcontractors, clients, providers and suppliers, and its sales agents, consultants and representatives on assignments in France and worldwide.
By collaborating with us, you also commit to require that your co-contractors, subcontractors and suppliers working for you or with you on the same project comply with the rules set out in the Code.
When a CDA partner already has its own code of conduct, a comparison of the provisions contained in the codes is carried out to check that they are consistent.
Our rules of conduct
CDA commits to comply with national laws and regulations. CDA requires its partners to obtain precise information on the laws and regulations that apply to their business operations and comply with the laws and regulations in force in the countries where they are established, in the countries where they operate, in addition to international laws and regulations, including those relating to international sanctions.
Any action by a partner must consequently be carried out with professionalism, impartiality, transparency and probity, and must be fairly and accurately documented.
1) ACTS OF CORRUPTION
CDA has established the fight against corruption as one of the core focuses of its compliance policy.
CDA partners must not propose, request or accept, directly or through an intermediary, any donation, offer or promise, gift or benefit in return for performing, delaying or failing to perform an act which, directly or indirectly, falls within their duties in order to obtain or maintain an unjustified commercial or financial advantage, influence a decision, or give the impression of influencing a decision.
CDA has a zero tolerance policy to any conduct that may be qualified as corruption and has implemented a corruption prevention plan.
CDA insists on the need for partners to refrain from engaging in conduct that may be assimilated to corruption, regardless of the intended goal.
2) CONFLICTS OF INTEREST
A conflict of interest may arise when interference exists in a professional situation between the position performed in the company and a personal interest in such a way that this interference influences or alters the loyal, impartial, independent and honest performance of the position on behalf of the company.
Therefore, there is a potential conflict of interest when a person’s interests conflict in one way or another with the interests of the Group and/or its employees, partners, etc. A conflict of interest is an established fact, a situation; it does not constitute a criminal offence or wrongful act.
Various measures to prevent and detect high-risk situations have been implemented by the Group to avoid potential conflicts of interest (reporting, awareness-raising, etc.).
Partners therefore have a duty to act honestly and transparently and must promptly inform the Contact Person at CDA if they identify an actual or apparent conflict of interest so that a reasoned and documented decision can be taken.
3) UNRESTRICTED COMPETITION
Competition law seeks to fight anti-competitive practices such as unfair competition, unlawful cartels and abuse of a dominant position by implementing rules to guarantee that competition is unrestricted as well as healthy and fair.
The Group consequently places particular importance on its partners’ compliance with the rules of unrestricted competition (prohibition on unlawful cartels, etc.).
4) GIFTS AND HOSPITALITY
A gift is an item offered for no payment, an offer of accommodation or a meal, an invitation or any other benefit enjoyed by the beneficiary for free and which has a value. Gifts and hospitality are an ordinary part of doing business and do not in themselves constitute acts of corruption. A gift must be given out of courtesy in accordance with the customs in the country where it is given.
CDA has defined principles and set out expected conduct by Group employees in a specific policy. Accepting or offering gifts or hospitality should prompt each employee to ask whether they are acting appropriately to prevent their integrity and the company’s integrity being called into question.
CDA consequently requires its partners to apply equivalent precautions mainly by refusing any gift, invitation or benefit that may compromise their independence of judgement.
Gifts must consequently remain reasonable, modest and proportionate to the situation. Partners must demonstrate transparency in this respect.
5) SPONSORSHIP, PATRONAGE AND POLITICAL CONTRIBUTIONS
Through sponsorship or patronage, CDA provides financial or material support to charitable organisations or social, cultural or sports actions to back initiatives with no specific advantage other than promoting the image of the Group and its values.
CDA consequently prohibits its partners from offering donations, political contributions or carrying out sponsorship in its name.
When they do so in their own name, partners of the Group must ensure that this action cannot influence or give the impression of influencing decision-makers or customers in relations with CDA.
6) CORPORATE SOCIAL RESPONSIBILITY
Human rights and rights at work
CDA requires that partners comply with human rights and rights at work in accordance with ILO fundamental Conventions: prohibition of forced labour and child labour, no discrimination at work, equal pay for equal work, organisation completely focused on hearing employees’ concerns.
Health and safety
With around 5,000 employees, the Group seeks to encourage innovative initiatives in the social sphere and constantly reinforce social dialogue.
CDA consequently hopes that its partners strictly respect very high level safety rules (appropriate equipment, in good working order, essential safety instructions, etc.) and also workplace health and safety rules.
Environment
Respect and protection of the environment are core values that CDA wishes to affirm and promote. In this respect, the Group constantly pursues its efforts, in relation to energy, water management, biodiversity and visual pollution which are its major challenges in terms of its environmental footprint. The Group also wants its partners to contribute to reducing the negative impact that may be caused by our business operations on the environment by taking appropriate measures.
Implementation of the Code
PARTNER COMMITMENTS AND IMPLEMENTATION OF THE CODE
Compliance with this Code is required by all CDA partners and their own partners and subcontractors.
By working with CDA, our partners commit to:
- Comply with this Code of Business Integrity throughout the assignment,
- Accurately and fully complete CDA’s Questionnaire and provide all documents required to conduct preliminary due diligence.
In the event of any breach of this Code, CDA Group may be required to take sanctions ranging from terminating the business relationship to bringing civil or criminal proceedings, if justified by the circumstances, in accordance with an escalating procedure:
First, CDA may raise reasoned and documented comments, questions and observations.
The partner may respond and provide any document that it considers relevant, to promptly find a corrective solution to the non-compliance.
In the event where CDA continues to have serious doubts at the end of this exchange, or if the solution proposed by the partner does not seem appropriate to it, an audit of the partner may be conducted by the Group on the relevant matter.
If the partner refuses to undergo the audit or the audit results in an adverse opinion, or in the event of serious misconduct, CDA may terminate the contract with the partner, and even launch legal proceedings.
WHISTLEBLOWING POLICY
Any employee or any person engaging in relations with CDA can submit a whistleblowing alert in the event of breach of the provisions of this Code.
To this end, CDA has implemented a whistleblowing alert mechanism and provides a dedicated email address, platform and telephone line:
· conformite@compagniedesalpes.fr
· https://report.whistleb.com/compagniedesalpes
· FRANCE 0800 916 095 Code 7356
All whistleblowing alerts will be handled in complete confidentiality ensuring that these persons are provided all legally required protection.