The core commitment of
an Ethics and Compliance
programme.

To protect against corruption and influence peddling, which are a major risk for businesses, Aubert & Duval has established a corruption risk prevention policy compliant with international standards, including the Declaration of Human Rights, the United Nations Convention Against Corruption, and the OECD Convention on Combating Bribery of Foreign Public Officials.

The policy is based on:

• a specialised governance that has led to the development of an Ethical Charter, an Anti-Corruption Code of Conduct, and the deployment of an ‘Ethics & Compliance’ organization, notably supported by a network of ambassadors,
• principles established by the President and members of the executive committee, which are shared with all employees,
• the publication and dissemination of an Anti-Corruption Code of Conduct that outlines the issues surrounding the prevention of corruption and influence peddling, and highlights the various types of conduct to be avoided;a corruption and influence peddling risk map,
• a system for assessing the integrity of third parties (primarily clients, suppliers, subcontractors, and partners),
• accounting controls integrated into the company’s internal control rules aiming at preventing and detecting corruption and fraud,
• a training program for employees in positions exposed to risks of corruption and influence peddling,
• an internal whistle-blowing system to enable reporting on conduct or situations contrary to the Ethical Charter or the Anti-Corruption Code of Conduct.

By ‘lobbying’ or representing interests, Aubert & Duval means the provision, in full transparency, of useful information that may inform public decision-making. The aim is to foster and raise awareness of the company’s activities for public decision-makers so they have the benefit of reliable, comprehensive information.

Aubert & Duval conducts this activity at both national and supranational levels, in compliance with the regulations in force.

A Responsible Lobbying Charter – intended for employees likely to engage in interest representation activities with French public officials – summarises the ethical and reporting obligations applicable in France and describes the procedure to follow.

Aubert & Duval is committed to carrying out these lobbying activities transparently and with integrity, and in particular to:

• applying a zero-tolerance policy towards corruption and influence peddling,
• complying with national regulations, ethical rules, and the regulations of the institutions it interacts with,
• registering on the interest representative lists of the institutions with which it conducts lobbying activities.

Most Aubert & Duval activities have strategic value and are therefore subject to a specific regulatory framework. To ensure full compliance, the company has established rigorous processes as part of its continuous improvement approach.
The export and re-export of military-use products or dual-use goods require licenses issued in advance by the authorities of the exporting countries.
The company exports its products in accordance with very strict rules designed to protect the national security of democratic states and to combat the proliferation of weapons of mass destruction worldwide. Compliance with export control regulations, embargo programs, and economic sanctions is therefore a crucial issue for Aubert & Duval.

As part of the supply chain and in accordance with the Dodd-Frank Act, Aubert & Duval is committed to disclosing and complying with legal provisions related to ‘Conflict Minerals’. It therefore requires adherence to all obligations and an appropriate level of transparency throughout the supply chain. Relations with suppliers are continuously evaluated to ensure compliance with this policy.

Driven by this commitment to transparency, the company is able to provide an up-to-date report on ‘Conflict Minerals’.