Company

Code of Conduct and Action

Verallia Group has developed a Code of Conduct and Action confirming the principles which have guided all the Companies and all members of its management and its employees over the years, shared by all of them.

The purpose of this document is to make a public statement of Verallia Group adherence to the principles of the Code.

These principles are not intended to be exhaustive, but to address the essential areas as a minimum requirement, and maybe further complemented by some specific rules having regard to local conditions, matters or particular positions of responsibility without detracting from their basis.

People at every level of the Group are individually responsible for applying the Code.

Adherence to these principles is a requirement for belonging to the Group.

 

Principles of Conduct

The Verallia Group considers that the basic values shared by all members of its management and employees alike are: respect for others, professional commitment, integrity, loyalty, and solidarity.

Respect for others

It is an absolute prerequisite for the professional and personal development of each person. It applies throughout the Group worldwide. It implies an acceptance of pluralism, multi-culture, acceptance of all origins. It is reflected by a readiness to listen to others, to take into account others opinion, and to engage in a respectful dialogue.

Professional commitment

It means mobilizing to the best of one’s ability the knowledge and know-how of the individual to perform its duty. It requires active personal involvement and corresponding willingness to match the requirements of the professional tasks, request and acquire necessary knowledge through experience and training offered by the Company, and adapt to the evolving challenges. It implies the effective contribution of each person in caring particularly for the environment and for health and safety.

Integrity

It requires a rigorous probity in all professional activities. It means that no individual may compromise the interests of the Group entrusted to that individual in favour of his or her own private interests – whether in dealing within the Group or in dealing on behalf of the Group with third parties, whatever local practices might be. Specific rules of conduct may be adopted for certain professional categories depending on the nature of their responsibilities.

Loyalty

It requires honesty and fairness in dealing with superiors, colleagues, subordinates and third parties dealing with the Group. In particular, it is incompatible with the pursuit of self-interest. It implies the adherence to the guidelines and internal rules of the Group and its individual companies.

Solidarity

It is based on a sense of individual responsibility at work, which prevails over self-centered thinking. It encourages team work, support to others. It means rejecting self-oriented management or operational methods geared more to the self-satisfaction of given individuals rather than the collective interests of the Group.

Principles of Action

The principles of Action (1) govern the activity of all members of the Group in the exercise of their responsibilities, regardless of the country involved. They help us to achieve a responsible and sustainable growth, in accordance with the Group’s long-term strategy.

Respect for the law

All Group companies must apply in all areas all laws and regulations of the countries where they do business. Particular attention is drawn to the areas described below.
All Group companies must prohibit all actions which might breach applicable norms of competition law. All Group companies must refuse any form of financing political parties or activities, even if allowed under local law. They must also reject any form of active or passive corruption whether in domestic or international transactions(2).
Furthermore, Group companies must not exploit loopholes or inadequacies in any such laws or regulations where this would mean non-compliance with the norms of the Verallia Group.

Caring for the environment

Group companies are to actively promote the protection of the environment. All company sites belonging to Verallia Group, wherever they are located, must set clear environmental targets and regular monitoring of environmental performances against those targets.
Group companies must strive to raise the main relevant environmental performance standards of their own sites to the level of particularly effective performance standards found in best in class companies of the Group for comparable sites – even if that means going beyond the requirements of local legislation.

(1) They are intended to embody the OECD Guidelines for Multinational Enterprises, adopted in June 2000 as revised in May 2011.
(2) Covered by the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions of 17th December 1997.

Worker health and safety

Group companies are to take all measures necessary to ensure the best possible protection against health and safety risks in the workplace.
Group companies must adopt risk reduction policies and follow-up on the due application of the same, checking permanently results against the applicable standards. Such policies apply both to their own employees and to employees of sub-contractors, when the latter are working on a Group site.
Group companies must strive to raise the main relevant health and safety performance standards of their own sites to the levels of particularly effective performance standards found in best in class companies of the Group for comparable sites – even if that means going beyond the requirements of local legislation.

Employee rights

Group companies must scrupulously ensure that employees’ rights are respected. They must promote an active dialogue with their employees and legal representatives.
In addition, and without limitation, they must respect the following rules, even if not provided for by applicable local law.
Group companies must refrain from any form of recourse to forced labour, compulsory labour, or child labour(3), as well as any form of harassment – whether directly or indirectly or through sub-contractors when the latter are working on a Group site. Group companies must refrain from any form of discrimination with respect to their employees, whether in the recruitment process, at hiring, during or at the end of the employment relationship.

(3) As defined by the applicable Conventions of the International Labour Organisation.

The general management of the Group will implement awareness and training programs in order to promote this Code across the Group.
In any case each member of management and each employee of Verallia Group is personally responsible for applying these principles.