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CODE OF ETHICS - Lyreco · 2019-10-28 · 4 CODE OF ETHICS 01. LYRECO CODE OF ETHICS WHO MUST FOLLOW THE LYRECO CODE OF ETHICS? — All company employees worldwide, including all

Jun 19, 2020

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Page 1: CODE OF ETHICS - Lyreco · 2019-10-28 · 4 CODE OF ETHICS 01. LYRECO CODE OF ETHICS WHO MUST FOLLOW THE LYRECO CODE OF ETHICS? — All company employees worldwide, including all

CODE OF ETHICS

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EXCELLENCE RESPECT PASSION AGILITY

VALUES

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01. Lyreco Code of Ethics Who must follow the Lyreco Code of Ethics? ������������������������������������������������������������������� 4 What is expected from employees? ��������������������������������������������������������������������������������� 4 What is expected from managers and directors? ������������������������������������������������������������ 4

02. Integrity concerns Raise your concern ������������������������������������������������������������������������������������������������������������5 Lyreco guarantees �������������������������������������������������������������������������������������������������������������5 How do I report a concern? ����������������������������������������������������������������������������������������������5 Sanctions ���������������������������������������������������������������������������������������������������������������������������5

03. General Business Ethics Hierarchy of Lyreco principles �������������������������������������������������������������������������������������������6 Complying with laws and regulations ��������������������������������������������������������������������������������6 Corporate citizenship ���������������������������������������������������������������������������������������������������������7

04. Relationships with Business Partners Working with Customers ����������������������������������������������������������������������������������������������������8 Working with Suppliers������������������������������������������������������������������������������������������������������8 Working with Governments �����������������������������������������������������������������������������������������������9 Fair competition �����������������������������������������������������������������������������������������������������������������9 Improper business dealings ����������������������������������������������������������������������������������������������9

05. Commitments towards employees Health and safety �������������������������������������������������������������������������������������������������������������10 Diversity ���������������������������������������������������������������������������������������������������������������������������10 Behaviour at work ������������������������������������������������������������������������������������������������������������10 Representing the Company ��������������������������������������������������������������������������������������������� 11 Conflicts of interest ���������������������������������������������������������������������������������������������������������� 11 Substance abuse ������������������������������������������������������������������������������������������������������������� 11

06. Privacy and confidentiality 12

07. Accuracy of company’s financial records 13

08. Use of company resources 14

CONTENT

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01.LYRECO

CODE OF ETHICSWHO MUST FOLLOW THE LYRECO CODE OF ETHICS?—All company employees worldwide, including all managers and directors.No one at any level of the Company has the authority to require or permit any employee to violate any of the standards contained in the Lyreco Code of Ethics.As used in this document, “Subsidiary” means entities in which Lyreco owns directly or indirectly 50% or more of the voting rights. Lyreco will encourage affiliated companies (below 50% of voting rights) and partners to adopt the standards defined in the Lyreco Code of Ethics.In our business dealings, we expect our business partners to adhere to principles consistent with the Lyreco Code of Ethics.Any subcontractor representing Lyreco will be requested to comply with the standards and provide the necessary education and information to its staff.

WHAT IS EXPECTED FROM EMPLOYEES?—To read and to understand the Lyreco policies. Lyreco expects its employees to know the values expected from themTo make sure you gain a detailed knowledge of our policies and proceduresTo seek help and assistance from your manager to understand more if neededTo promptly report any concerns about any violation of Lyreco policiesTo cooperate with any investigation related to a violation of Lyreco policies

WHAT IS EXPECTED FROM MANAGERS AND DIRECTORS?—Managers must comply with and promote the Lyreco ethical culture, but also comply with the law, policies and procedures for themselves and their subordinates:A Manager’s role encompasses additional responsibilitiesSet example of ethical conductInform and educate those reporting to them Be proactive in the compliance with the laws and Lyreco Code of EthicsDetect and investigate any reported violations of laws or Lyreco Code of EthicsEnsure that any employee can report a suspected violation of law or Lyreco Code of Ethics without fear of retaliationTake prompt corrective action to fix identified compliance weaknesses

The Lyreco Code of Ethics describes the standards expected from each Lyreco employee and manager in the course of their business life with Lyreco:

In their relationships with customers and suppliers, in their relationship with their colleagues, in their behaviour towards promoting the company ‘s best interest

All employees are expected to operate within the law and the code of ethics.

The code of ethics provides a non-exclusive summary of specific issues that give rise to business conduct considerations.

Managers and employees will be asked to acknowledge the awareness of The Code of Ethics and to raise concerns about possible violations of law or Lyreco policies.

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02.INTEGRITY(ETHICAL) CONCERN

RAISE YOUR CONCERN —We expect all employees to raise any integrity concern. This principle aims at protecting Lyreco, its employees and its stakeholders. As an employee, you have the responsibility to communicate and inform about any alleged illegal activity or Lyreco Code of Ethics violation.

LYRECO GUARANTEES—Confidentiality: The identity of the employee reporting a violation is strictly protected and will only be communicated on a need to know basis. You can also, if you prefer, communicate with the Group on an anonymous basis.No retaliation: Lyreco does not tolerate any retaliation or intimidation against an employee raising an integrity concern. Respect for the individual is a fundamental Lyreco Value underlying all of our actions.

HOW DO I REPORT A CONCERN?—Reporting an integrity concern in connection with the application of laws or the Lyreco Code of Ethics can be done by contacting any of the persons below:Your managerYour QSS managerYour HR director Your Finance directorYour Managing directorAny member of the Group BoardAs mentioned above, you can also report anonymously to the Lyreco Committee by sending a mail from the Lyreco internet sites or from intranet code of ethics pages, using [email protected]. This address can also be used from outside the company.

SANCTIONS—Violating the law and/or the Lyreco Code of Ethics, withholding information about someone violating the law and/or the Lyreco Code of Ethics, intimidating or threatening of retaliation against someone reporting an integrity concern can lead to disciplinary actions including termination of your contract.Lyreco reserves its right to use legal action to claim damages in compensation of a violation of the law and/or the Lyreco Code of Ethics. Violating the law exposes you to legal actions, fines, including potential prison terms. The Company may not be willing to help you or to represent you in court.

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COMPLYING WITH LAWS AND REGULATIONS—Lyreco operates in a large number of countries, with very different cultures and legal systems. As a general basic principle, Lyreco employees must obey all applicable laws and regulations.

Nobody in the company is authorised to violate the laws.

We expect our managers to understand the legal frame in which they are working. If in doubt over the correct interpretation or the consequences of laws and regulations, one should seek professional advice before acting.

In case of litigations and law suits, managers should report the conflict to their Finance director or directly to the Group legal manager.

The Lyreco Code of EthicsDefine the standards expected from each

Lyreco employee, manager and director in the course of its business life at Lyreco

The Lyreco Procedures, Guides and Best PracticesProcedures and instructions defining the

internal environmental controls. Guides and Best practices to apply the Lyreco Core Model.

The Mission Statement and

The Lyreco Values

HIERARCHY OF LYRECO PRINCIPLES

03.GENERALBUSINESS

ETHICS

Lyreco has developed procedures and instructions in order to reinforce the internal controls in our working environment.— Internal audits are carried-out on a regular basis. —Procedures and standards are improved and modified accordingly.

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03.GENERALBUSINESS

ETHICS

CORPORATE CITIZENSHIP—ENVIRONMENT Lyreco takes its responsibility to the community at large extremely seriously. In 2004, Lyreco signed the Global Compact initiative from the United Nations to promote sustainable development in the area of human rights, labour, environment and anti-corruption. It encourages our stakeholders to join this initiative.All our employees have been informed about the Global Compact initiative and its objectives and we actively continue to promote environmental and social development.

POLITICAL ACTIVITIES Lyreco respects its employees’ right to participate as individuals in political activities as long as they make sure that they do not appear to represent the company. Employees participating in their individual capacity, are not allowed to use company assets and equipment. (phone, fax, mail, E-mail, company computer...)Lyreco as an organisation does not support any political party and does not participate in political activities. Lyreco and Lyreco subsidiaries will not make payments or donations, in money or in kind, to political parties, political organizations or individual politicians.

RIGHT TO ORGANISE The company values its employees as a key resource and their opinion matters. The Company, on a regular basis, conducts opinion surveys with its workforce to understand how to improve its relationship and management.Lyreco wants to have a representation of its employees with whom internal matters can be shared and discussed. This representation can be channelled through labour unions or through personal representation.Lyreco respects (within the frame of local laws and regulation) the right of its employees to be represented by labour unions or other organisations.

LYRECO COMMUNITIESIn line with its corporate values, Lyreco aims to enhance its social and charity initiatives. Lyreco has created “Lyreco for Education”. This program aims at promoting children’s education in developing countries.

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04.RELATIONSHIPSWITH BUSINESS

PARTNERSWORKING WITH SUPPLIERS —Lyreco’s relationship with suppliers is based on legality, efficiency and transparency. Lyreco will strive for a mutually beneficial relationship.Lyreco will favour tendering processes for supplier selection in order to maximize the transparency in the selection process. Suppliers are assessed for their product quality, services and pricing. Lyreco will treat the existing supplier fairly. Under no circumstances, will supplier selection reflect personal interest or friendly relationships. Lyreco will ensure an honest and transparent feedback to failed bids. Information given by suppliers will remain confidential under all circumstances and will not be shared with competition.Lyreco will ensure the application of the terms negotiated and will pay according to the negotiated terms (providing that the supplier performs according to the terms of the contract).Lyreco expects its suppliers to comply with the laws especially in terms of fair treatment of its work force, to prohibit child labour, to ensure health and safety in the work environment and to protect environmental quality. Suppliers are expected to adhere to principles consistent with those in the Lyreco Code of Ethics.

WORKING WITH CUSTOMERS—The customer is at the centre of Lyreco values. Our objective is to develop a long standing relationship with our customers. In all dealings with customers, we expect our sales representatives and account managers to behave with the highest level of respect for the customer and its employees.Lyreco will ensure the application of the terms of our contracts. Lyreco sales staff will ensure that customers are informed of any promotions or commercial actions that it could benefit from.Lyreco staff will avoid developing personal relationships with customer that could put them into a position of conflict of interest. Lyreco sales staff when passing an order for the customer will always make sure that the customer is in agreement with the order and make sure that the order is passed with the best interest of the customer and the company.The sales representatives, customer service operators and the delivery staffs have to respond to our customer needs and make sure that we improve constantly the quality of our services.

Lyreco expects all its employees to adopt a conduct of honesty and integrity with its business partners.

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WORKING WITH GOVERNMENTS—Lyreco conducts business with governments, state-owned companies or institutions, schools, universities and hospitals. Lyreco employees must apply the highest ethical standards to any relationship or transaction with government officials, strictly comply with any specific laws and regulations applicable to these markets.

FAIR COMPETITION —Lyreco respects all the business community including its competitors. Our objective is to grow our business but this growth will not be done at the expense of the company integrity.

Lyreco will not adopt a position that will create unfair disadvantage to its competitors. Nor will Lyreco accept agreements or arrangements that would unfairly limit the competition.

Lyreco employees are not allowed to discuss or exchange confidential information with anyone and especially not competitors. Employees receiving confidential information belonging to a competitor should report to management promptly.

IMPROPER BUSINESS DEALINGS —BRIBERYLyreco will not accept any bribe (cash payments, advantages in kind...) from customers, suppliers or any parties in order to obtain or to facilitate a business opportunity. Lyreco will not engage in any form of bribery in order to gain business opportunities. Lyreco expects its employees to obey to the same principle. Any kind of personal advantage obtained by a Lyreco employee (cash, loans, employment of a family member...) is absolutely not acceptable and will be considered as bribery and can expose Lyreco to legal prosecution. Employees accepting bribes expose themselves to legal prosecution.

GIFTS AND ENTERTAINMENTSEmployees during the course of their activity should not accept any gift (except for nominal values) or invitations to sport or cultural events. Gifts given to employees have to be transferred to the Human Resource department. Business partners have to be informed of the Lyreco standards. Note: “Nominal value” denotes an item of relatively low value that is unlikely to be perceived as improperly influencing the recipient, such as a logo cap.Business meals are acceptable in the normal course of business, provided that they remain reasonable, business oriented and very occasional. Hosting a dinner with a customer has to be done in moderately priced restaurants. Excess drinking is strongly forbidden. Lyreco employees must show professionalism in their attitude and behaviour at all times.Lyreco does not authorize employees to invite customers to inappropriate adult entertainment bars or restaurants. These entertainment places are not in line with the standards of the Company. No expenses for such entertainment can be raised, nor paid.

STAFFS MEALS Managers may organise meals with their employees on an exceptional basis. This is an acceptable practice if it remains occasional and reasonable. The employee of the highest in rank will always take the bill and raise the expense. However this should not be a practice and employees going together for meals are expected to pay for their own lunch or dinner.

SAMPLESSuppliers will give samples for “testing” new products. Sample testing is part of the normal business practice. It should however remain limited and the Marketing department should be made aware. All excess samples have to be sent to product managers. Under no circumstances should samples or gifts be sold by employees for their own benefit.

04.RELATIONSHIPSWITH BUSINESS

PARTNERS

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HEALTH AND SAFETY— Lyreco is continuously working at providing a safe and healthy working environment, to prevent workplace injuries. Employees are expected to behave in a safe and proper manner and to comply with rules on health and safety at work. Lyreco does not tolerate by-passing health and safety procedures.Employees are required to report any incident and/or broken equipment and/or machinery which could create a health and safety hazard. Failure to report exposes the employee to disciplinary action.

DIVERSITY—Lyreco believes in the value of diversity to enrich our work environment and experiences. Employment decisions, promotions or training programmes are based on qualifications, ability, work experience and work quality. Under no circumstances will such decisions be made on gender, age, disability, race, colour, sexual orientation, religious belief, culture or nation of origins. Any discrimination based on gender, age, disability, race, colour, sexual orientation, religious belief, culture or nation of origins should be reported as a violation of the Lyreco Code of Ethics. Lyreco will work with its business partners to develop the fair employment practices.

BEHAVIOUR AT WORK— Lyreco will not permit any harassment (sexual or otherwise) against a colleague, an employee, a customer or a supplier. Harassment is an infringement to the fundamental right of human dignity; Lyreco has decided to adopt a “zero tolerance” policy in this respect. Harassment can take many forms including (for example but not limitative) unwanted sexual propositions or comments, ethnics, racial or sexual jokes as well as unwanted body contacts.Employees are expected to support Lyreco’s zero tolerance policy and to report any unacceptable behaviour quickly in the work place.

05.COMMITMENTS

TOWARDS EMPLOYEES

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REPRESENTING THE COMPANY—When representing the company, employees should always act in the Company’s best interest. Employees should always demonstrate a professional attitude.Employees are not authorized to speak or write on behalf of Lyreco except if previously validated by the Managing director at least. Employees speaking on behalf of the company should make sure that there is no confusion between their personal view and the company’s point of view.

CONFLICT OF INTEREST—Employees should not be, at work or during their free time, in a situation conflicting with the interest of Lyreco. A conflict of interest exists when the employee personal interest and Lyreco’s best interest are different.All employees are expected to act in the best interest of Lyreco.Employees are not allowed to have interests in (directly or indirectly), or relationships with any organisation or individual that may affect his/her objectivity and independence in the decision that he/she would need to take in the normal course of their activity at Lyreco.When an employee has a romantic relationship with another employee reporting directly or indirectly to her/him, she/he will be considered in a conflict of interest position. The same rule applies if the romantic relationship exists with a customer or a supplier dealing directly with the employee.If faced with a conflict of interest concern, employees should inform promptly their manager and refrain from participating in any decision where her/his judgment can be questioned.

SUBSTANCE ABUSE—Lyreco does not tolerate the use of drugs and does not accept the use of alcohol during the course of duty, in a way that can jeopardise the safety and Lyreco’s reputation.Driving under the influence of alcohol or drugs violates the law and exposes you to legal actions, fines, prison terms. The company may not be willing to help you or to represent you in court. When delivering products or driving for the company, employees are expected to be free of alcohol or drugs.

05.COMMITMENTS

TOWARDSEMPLOYEES

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06.PRIVACY AND

CONFIDENTIALITY

Lyreco is committed to handling sensitive information concerning our business partners, employees and other individuals responsibly.

Employees have a duty to take the necessary steps to protect the confidentiality of any information acquired in the course of their employment.

Employees must ensure that information is not disclosed accidentally, for example discussions in public places, sharing sensitive information with friends or family, displaying information on computer screens in public places or leaving documentation lying around.

Confidential information should only be disclosed to people with a legitimate need to know.

Note: “confidential information” means all non public information.

Lyreco also expects that departing employees will return all confidential documentation and will not disclose anything, either relating to Lyreco or any other party, once they have left the company. Similarly, Lyreco will not disclose a previous employee’s confidential information.

Lyreco will, within the legal requirements, delete certain customers or suppliers information if so requested by them.

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Financial records are essential to evaluate the performance of a business. The accuracy of these records ensures the honesty and the legality of the measure of our performance. Every Lyreco employee has the duty to make sure that its actions are correctly and completely reflected in the financial statements and that any wrong doing is promptly reported.Lyreco will never accept fake transactions or misreporting from employees to achieve goals or budget targets. These actions will be considered as fraudulent and the company will apply a zero tolerance policy in this regard. Employees settling arrangements with customers, suppliers or colleagues, in breach of existing procedures, in order to meet individual or collective targets should be promptly reported to management.Any accounting or presentation of wrong information is fraudulent:

EXAMPLESReporting an inaccurate number of customer visits made daily by a sales representative — Spreading costs over various months in the books, because the budget has been overspent — Delaying the input of goods receipts to achieve inventory level objectives

All these practices are considered as a manipulation of the company’s records and are potentially liable to prosecution. Lyreco expects all its employees to help external and internal auditors in their control duties.Employees and managers have to comply with internal procedures for the validation of expenses, capital expenditures and cash transfers.

07.ACCURACY OF

COMPANY’SFINANCIAL RECORDS

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08.USE OF

COMPANY RESOURCES

The assets and resources of the company are used by the employees to develop the Group and to achieve our business objectives. Misusing or wasting the company resources is considered as a fault. Employees should not use the company assets for their personal advantage or friends personal advantages.Only on an exceptional base can the use of company equipment (phone, fax, computers...) be accepted.

EXAMPLESThe use of company delivery vehicles outside working hours or for personal dealings is not acceptable — Employees using company supplies for their home usage without a valid business purpose is not acceptable

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Rue du 19 mars 1962 • 59770 Marly • FranceTel: +33 (0) 3 27 23 64 00 • Fax: +33 (0) 3 27 45 17 97contact: raiseyourconcern@lyreco�com