
Code of Ethics and Conduct
The New Lachaussée Code of Ethics and Conduct reflects our dedication to ethical excellence and sustainable growth in every aspect of our business. The principles that guide our commitment to integrity, fairness, and responsibility across all operations include:
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Working Conditions: Ensuring employee safety, equal opportunities, and fair treatment while fostering career development and compliance with labor standards.
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Fair Competition: Promoting ethical business practices and rejecting collusive or anti-competitive behavior.
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Brand Image: Protecting the company's reputation through confidentiality, transparency, and responsible communication.
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Data Confidentiality: Safeguarding sensitive information through secure handling and compliance with legal standards.
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Political Neutrality and Sponsorship: Maintaining impartiality in political matters and using sponsorships to enhance our brand responsibly.
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Conflict of Interest Prevention: Avoiding personal interests that could compromise professional duties or the Group's objectives.
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Fraud Prevention: Enforcing transparency, accuracy, and adherence to ethical financial practices.
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Anti-Corruption Measures: Combatting all forms of corruption and promoting ethical relationships with clients, suppliers, and partners.
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Third-Party Relations: Ensuring due diligence with clients, suppliers, and subcontractors to uphold shared ethical standards.
1. Create and maintain optimal working conditions
The New Lachaussée (NLC) group is particularly sensitive and attentive to the working conditions of all its employees. The group is committed to ensuring fair treatment of each of its employees and to guaranteeing their physical integrity as well as the respect of all their Fundamental Rights.
In parallel, we expect total loyalty from the employee towards their colleagues, hierarchy, and/or subordinates. That is why our Human Resources department has committed to an approach based on the following principles of action, which are largely inspired by international standards:
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All employees, regardless of their hierarchical level, must refrain from any act of disparagement towards a colleague or subordinate.
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Each Group employee must daily contribute to respecting the commitments made in this Code of Ethics and Conduct, and ensure their own safety conditions as well as those of their colleagues.
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Supervisory staff must treat each member of their teams fairly, in accordance with the principles outlined in this Code of Ethics.
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The Group strives to combat all forms of discrimination and is committed to offering equal opportunities to each of our employees.
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The Group promotes the development of its employees by considering their career advancement wishes, particularly by offering them the opportunity to train.
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The Group promotes good working conditions at the sites of our operational staff, completely banning the risks of forced, hidden, or undeclared labor.
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The Group maintains and guarantees social dialogue within the company, particularly by respecting employee representation bodies and freedom of association, in accordance with current regulations.
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Employees must insist with our suppliers, subcontractors, and business partners on the strict adherence to national and international labor law standards, which are applied at NLC.
2. Fair competition
The group commits to adopting ethical behavior by declining all offers of illicit agreements, and generally all collusive practices. Business partners must be treated, without exception, with fairness in all the countries where our Group operates. In order to combat these collusive practices, all employees are requested to:
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Do not exchange sensitive information, whether commercial or not, strategic or not, with competitors or interested third parties. This may concern, for example, our pricing grids, the names of our clients, development projects, or capacity reduction plans.
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In the event of market delineation, assess from a legal standpoint the risks and NLC's position in the market, in order to avoid any infringement.
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Do not boycott a client or supplier in a concerted manner to distort competition and gain an advantage.
In the event of non-compliance with ethical rules by a third party (client, competitors, suppliers), it may be considered to file a complaint with the competent authorities, provided that sufficiently concrete evidence can be presented to these authorities.
3. A strong and protected image
The Group has a brand image that must be protected at all times. In order to enhance its reputation and the quality of its image, the Group has decided to implement the following measures:
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Each employee must know the values that structure us, and the principles attached to them, namely respect, trust, exemplary behavior, and of course the quality of customer service and the services provided.
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Each employee is the guardian of the Group's assets, which alone reflect the good health of our company.
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Each employee is subject to a duty of confidentiality, so they must not, during their tenure and even after their departure, disseminate information that could harm our company's brand image.
Finally, the communication of professional information is the responsibility of the Group Management, which alone is empowered to share the life of our company in the media and social networks.
4. Data confidentiality
The management of information and data collected by the Group is a matter of ongoing attention, requiring responsible behavior from each of the Group's employees. In order to comply with our legal obligations and also to protect our information, the Group has decided to implement the following measures:
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Each employee holding information is responsible for its protection and dissemination, both internally and externally. Our employees are encouraged to limit the disclosure to only those individuals who have a legitimate interest in knowing. Only strictly necessary information should be disclosed. In general, our employees are encouraged to exercise the utmost discretion both in their work environment and in their private sphere. All data must be stored on a secure medium.
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All data must be stored on a secure medium. - The acquisition of information must be done in compliance with the legal framework. The acquisition of information must be done in compliance with the legal framework. Information can be obtained through legal means: monitoring tools, note-taking, brochures, websites...
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Any information that is not public must be protected. This is even more true when our company collects or receives personal data belonging to employees or third parties.
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The Group is committed to a continuous improvement process of our IT systems to avoid all the disastrous consequences of a cyber-attack or intrusion. The Group is committed to a continuous improvement process of our IT systems in order to avoid all the disastrous consequences of a cyber-attack or intrusion. To this end, the Group is constantly seeking to improve the protection of sensitive information. Similar attention is required from all our business partners.
5. Political neutrality and sponsorship
Our Group has decided to adopt total political neutrality, so all political contributions made by a Group entity or in its name are prohibited. Similarly, all in-kind benefits offered to political figures or parties are prohibited. The Group is not engaged in any lobbying activities aimed at influencing in any way the legislative process or the decisions of a government or an institution in favor of a cause related to our activity. On the other hand, our Group intends to promote its brand image by supporting a number of events, particularly in the sports field. Sponsorships therefore hold an important place in the Group's communication, which is why these activities must be approved by the Group's Management.
6. Prevention of conflicts of interest
A conflict of interest arises whenever an employee is faced with a private or personal interest that can influence them in the performance of their duties and compel them to act against the interests of the Group. This personal or private interest must be understood in a broad sense, and it encompasses both the direct interests of the employee and those of their family or close associates.
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All employees are bound by a duty of loyalty to the Group. Thus, and as far as possible, each employee is invited to limit all external activities that could directly or indirectly place them in a situation of conflict of interest with the Group. It is prohibited, without the Group's consent, to work, directly or indirectly, for the benefit of an existing or potential competitor.
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When the context surrounding the decision-making raises doubts for the employee regarding impartiality or integrity, they must, in full transparency, inform the management.
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A transaction between the Group and another company in which one or more employees have private or professional interests, direct or indirect, must be subject to prior authorization from the hierarchical supervisor. A transaction between the Group and another company in which one or more employees have private or professional interests, direct or indirect, must be subject to prior authorization from the hierarchical supervisor. Particular attention will be paid to transactions involving former employees of the Group, in order to avoid any risk of favoritism.
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Special attention will be given to transactions involving former Group employees, in order to avoid any risk of favoritism. All employees are prohibited from using their position within the company to obtain privileged information about the Group for personal gain or to benefit a third party.
7. Refusal of any form of fraud
Fraud can be defined as behavior aimed at deliberately deceiving others with the intent of obtaining an illegitimate profit or evading a legal obligation. Fraud is therefore characterized by an intentional element and a desire to conceal the unauthorized act. Without distinction, fraud can be characterized either by an action or by a voluntary omission. For example, typical cases of fraud include the diversion of products, materials, or confidential information, the falsification of the company's financial data to conceal figures or, conversely, to present more favorable accounts, and the production of false expense reports. This list is not exhaustive, and many other cases can be cited as examples. In order to remain true to its principles of transparency and integrity, the Group will not tolerate any cases of fraud. To this end, the Group is committed to enforcing the following principles.
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Under no circumstances will fraudulent circumvention of the law be tolerated or valued within the company.
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We ensure the production of reliable and sincere accounting and tax information, while maintaining traceability of all our operations to prevent any participation in activities that could be classified as money laundering or financing of terrorism. We ensure the production of reliable and sincere accounting and tax information, while maintaining traceability of all our operations to prevent any participation in activities that could be classified as money laundering or financing of terrorism. If such a case were to arise, we would cooperate in a completely transparent manner with the competent authorities.
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Regular checks of our processes are carried out to secure all transactions and to make the applicable rules within the company known. Regular checks of our processes are carried out to secure all transactions and to inform about the applicable rules within the company.
8. Fight against corruption
The Group is committed to preventing and combating all acts of corruption, unfair influence peddling, bribery, illegal conflict of interest, embezzlement of public funds, unfair favoritism, or any other breach of integrity. Corruption can be defined as an act by which a person, invested with a specific public or private function, solicits or accepts a gift, an offer, or a promise with the aim of performing, delaying, or omitting to perform an act that falls, directly or indirectly, within the scope of their duties. Corruption, because it taints all our relationships with suppliers, clients, and even the administration, must not be tolerated within the Group. To this end, we have sought to implement at the Group level:
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Increased oversight from the governing bodies over all commercial transactions with our clients, the selection of our commercial agents and subcontractors, and generally, any third party we may deal with;
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Involvement of human resources from the recruitment of a new employee and throughout the employee's career within our Group (regular and tailored training, dissemination of company values, monitoring and sanctioning of dubious behaviors, etc.);
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Internal audits of the different entities to analyze all ongoing contracts, practices, and the assimilation of expected rules;
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An increased duty of vigilance towards our main suppliers, subcontractors, clients, and commercial agents in the form of "due diligence" in particular, in order to wisely choose our business partners;
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The promotion of collective initiatives to establish procedures adapted to field constraints;
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An invitation to each employee for great transparency towards their hierarchy and business partners, in order to avoid any behavior or act that could be qualified as active or passive corruption, complicity in influence peddling, or favoritism.
9. Our relations with third parties
Due diligence procedures are implemented with respect to all third parties with whom we collaborate.
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Clients: In our relationships with our clients, we constantly strive to offer the highest quality of services and products. This involves a continuous evaluation of our processes through inspections and the constant improvement of our technologies or procedures. We systematically refuse any business relationship that could directly or indirectly lead to a breach of the ethical and conduct commitments we have made.
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The Administration: In the conduct of our activities, we are sometimes required to interact with the public administration of a State. To this end, we prohibit all our employees from directly or indirectly granting any public official any undue advantage or favor in order to gain preferential treatment through their actions or behavior. Also, transparency is a fundamental condition for the success of these principles, and we therefore strive to conduct our activities in cooperation with the administration of the different states in which we operate, for example, by offering our assistance during investigations or providing honest information regarding our financial situation.
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Suppliers and subcontractors: Our commitments to integrity require that special attention be given during the selection of our suppliers and subcontractors. We expect them to adhere to standards at least equivalent to those we uphold today. We ask our subcontractors and suppliers to be particularly attentive to their standards and procedures regarding respect for Human Rights, especially concerning the working conditions of their employees.
We are committed to not entering into business relationships with a supplier, distributor, or subcontractor that has been convicted, at the company or its executives' level, for acts of corruption, non-compliance with Human Rights, money laundering, etc.
Our subcontractors or suppliers are required to sign a Supplier Code of Conduct to commit to ensuring that their own subcontractors adhere to principles equivalent to ours and to accept being audited so that we can verify the compliance of their procedures. Anti-corruption clauses are included in our standard contracts and general terms and conditions of sale.