Anti-corruption Code

Anti-corruption Code

OUR GROUP IS CURRENTLY IN THE PROCESS OF ADOPTING THE MIDDLENEX « ANTI-CORRUPTION » CODE OF CONDUCT.

THIS DOCUMENT SUMMARISES AND PRESENTS THE PRINCIPLES AND CONVICTIONS ON WHICH THIS CODE IS BASED.


Business integrity is key to the Group's reputation. The Group attaches the highest importance to acting irreproachably with its stakeholders.

This code of conduct is designed to guide business behaviour and provide practical advice, examples and links to other useful information.

  • It will address all employees, Executive and Management Committee members, and the Group's corporate officers.
  • It will set out the principles that employees must respect when conducting their professional activities. It complements the rules, procedures and standards defined in each country, which employees must continue to follow.
  • Any person acting on behalf of the Group must comply with this code of conduct, whatever the site and nature of their work.
  • The Group will ensure that its partners share the same values.

The detailed code describes the fundamental rules, particularly concerning the following subjects:

  • Gifts, signs of courtesy and hospitality, entertainment.
  • Specific rules for public officials.
  • Donations to charitable or political organisations.
  • Patronage, sponsorship.
  • Facilitation payments.
  • Third-party monitoring commitment.

Nevertheless, no document can cover and provide for all cases of corruption that might arise in the course of the daily activities of Group employees.

This Code does not obviate the need to exercise personal judgement and common sense.

In the event of doubt as to the correct conduct, the Group will provide assistance and advice tools.

Compliance with the code of conduct is a condition of employment for all Group employees, and no violation will be tolerated. The code will be communicated to all employees joining our Group, and distributed to all current employees. Each employee must read, understand and follow it. The employees are aware of the serious consequences that violating the code of conduct could have for our Group and for themselves.

Given that any misdemeanour or failure to comply with the rules contained in this code could seriously harm our image and cause financial damage, the employees must be extremely vigilant in their respect of the rules contained in the Code.

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