Ethics is a cross-company axis of our CSR policy. Since 2015, the Group has specifically rolled out an Ethics Charter and all employees have been made aware of its contents and trained in ethical concepts by their managers.
“With its continued growth, the Group enjoys [...] great visibility in many countries and in increasingly diverse markets. Our position as leader in several of our industries and our ambition for tomorrow involve increased responsibilities that we wish to assume. In fact, the success of our business will only endure if we clearly assert our requirements as an ethical and responsible business.”
The Group therefore wants to maintain the requirement for exemplary behaviour on a day-to-day basis. As such, the Ethics Charter is intended to serve as a point of reference in terms of individual and collective behaviour and will guide our day-to-day activities enabling us to embody our values. It is a common and unifying document, which guides us in our decision-making; a tool for the promotion of dialogue between employees so that ethics is an open matter understood by all. Somfy and its employees particularly seek to respect the regulations of the countries in which it operates in relation to organisation of work, whilst subscribing to the principles and objectives of the fundamental conventions of the International Labour Organisation (ILO) and by aiming to adopt the practices of a responsible and management respectful of everyone. A role of the network of HR Officers is to ensure the respect of Human Rights, particularly examining within their scope rights and concerns relating to racial discrimination, torture, enforced disappearances, disabled people and the rights of women, children, migrants, minorities and indigenous peoples.
This is reflected in a commitment to:
In addition to this Ethics Charter and following the enactment of the law on transparency, the fight against corruption and the modernisation of the economy(2), Somfy has chosen to adopt the Middlenext Anti-Corruption Code of Conduct. This Code of Conduct is designed to guide business behaviour. The Group has decided to supplement it with several appendices in order to provide practical advice, examples and links to other procedures. In addition to these documents, e-learning materials are currently being rolled out and face-to-face training has also been introduced for those employees expected to be the most exposed. The Whistleblowing procedure introduced in 2015 to escalate non-ethical behaviours was extended to meet the requirements of the French “Sapin 2” anticorruption legislation. Accounting controls were also implemented to detect potential fraudulence. The entire anti-bribery program and its governance is described in the Group's Anti-Bribery Policy.
Business integrity is part of the Group's good reputation, and the Group attaches the greatest importance to acting in an irreproachable manner with its stakeholders.
The Code of Conduct is designed to guide business behaviour and provide practical advice, examples and links to other useful information.
The detailed code describes the basic rules with regard to the following subjects in particular:
However, no single document can deal with and anticipate all cases of corruption that may occur in the daily activities of the group's employees. This Code does not exempt the use of personal judgment and common sense. In case of doubt about the appropriate course of action, the group sets up support and advice tools. Compliance with the code of conduct is a condition of employment for any employee of the group who will not tolerate any violation thereof. The code is given to all employees who join our group and distributed to all employees. Each employee must read it, understand it and respect it.