38-Compliance and Ethics Policy / 748
Co
mp
liance and
E
t
h
ics
P
olic
y
B-POL-01.0034
Version 01. Original date: 23 December 2013. Version date: N/A. Valid version only on QMS site.
Policy prepared by: Group Compliance Officer. Approved by: COMEX. Validated by: Quality Director of BOURBON.
1 / 1
Co
mp
liance
r
e
qu
i
r
es BOURBON e
mp
lo
y
ees to a
b
ide
by
la
w
s and
r
eg
u
lations as
w
ell as
by
BOURBON sel
f
-
r
eg
u
lato
ry pr
oced
ur
es
& p
olicies
,
inte
r
nal di
r
ectives and et
h
ical
pr
inci
p
les.
Compliance and Ethics Policy
is designed in t
h
e
f
r
a
m
e o
f
BOURBON Co
mp
liance
Pr
og
r
a
m
.
I
t is a ke
y
p
illa
r
o
f
o
ur
s
u
staina
b
ilit
y
.
BOURBON is co
mm
itted to cond
u
cting
bu
siness
w
it
h
integ
r
it
y,
t
r
ans
p
a
r
enc
y
and et
h
ics
,
in
co
mp
liance
w
it
h
a
pp
lica
b
le la
w
s and
regulations and with BOURBON’s policies and guidelines.
B
u
siness
p
a
r
tne
r
s and t
h
i
r
d
p
a
r
ties a
r
e st
r
ongl
y
enco
ur
aged to ado
p
t BOURBON co
mp
liance
standa
r
ds.
The BOURBON Compliance Program was designed to help BOURBON and its employees to secure
business operations. The key elements of
BOURBON’s Compliance Program
are:
x
Tone at t
h
e to
p
–
co
mp
liance c
u
lt
ur
e
: The
COM
E
X
,
V
P,
Di
r
ecto
r
s
and
Manage
r
s
are committed to
promote compliance and to maintain a culture of ethical business decision in respect of laws and
BOURBON’s policies.
Compliance is contributing to the Corporate Social Responsibility efforts of
BOURBON.
x
Risk Assess
m
ent
: The compliance risk assessment is driving constant mitigation plans through the
design and deployment of adequate procedures, which strengthen internal controls activities.
x
P
olicies
,
G
u
idelines and
Pr
oced
ur
es
: They are being developed constantly to address complex
situations (e.g.: corruption and bribery, facilitation payment, conflicts of interests, gifts and business
courtesy, travel expenses for employees and third parties, charitable and political contributions,
sponsoring, donations, insider dealing, etc.). They provide all employees with guidance, instructions and
tools in relation to expected behavior to adopt while conducting business operations and dealing with
business partners and third parties.
x
Co
mmu
nication and T
r
aining
: Regular communication on compliance is settled up. They will remind
constantly employees the proper expected behavior as well as key point of contact to whom concerns
shall
be raised. In addition, compulsory Compliance trainings will be given yearly
to all BOURBON’s
employees. If any concerns arise while conducting business, it is important to address the potential issue
with the highest care together with the Corporate Compliance Team, rather than ignoring it.
x
Monito
r
ing and Revie
w
:
BOURBON Compliance Program is driven by a
G
r
o
up
Co
mp
liance O
ff
ice
r
together with his
Corporate Compliance Team. Compliance chimney at Region/Affiliate level is directly
reporting to the Corporate Central Compliance function.
x
S
anctions
: BOURBON has zero tolerance to fraud and corruption. Any breach will lead to adequate
sanctions for interested employees or business partners.
I
ntangi
b
le
Pr
inci
p
les:
x
Compliance with Laws: BOURBON will conduct its business in accordance with all
applicable international and local laws and regulations.
x
Compliance with Ethics: Maintaining the trust and confidence of our stakeholders,
employees, clients, third parties and business partners is highly connected to the respect of ethics
principles enacted by BOURBON.
x
Compliance with anti-bribery and corruption Compliance guidelines: BOURBON prohibits
the offering, giving, accepting or soliciting of improper payments, whatever its form (gifts, facilitation
payment, donation, sponsoring, conflicts of interests, etc.) whether made directly or indirectly, for
purposes of influencing any act or decision to improperly obtain or gain business.
x
Compliance with Internal BOURBON rules: BOURBON requires all employees to respect
and apply internal guidelines and procedures.
Christian Lefèvre Gaël Bodénès Laurent Renard
Chief Executive Officer Chief Operating Officer Chief Financial Officer
38