Code of business conduct

OUR COMMITMENT TO INTEGRITY

Republic Technologies, its subsidiaries and affiliates companies in Europe, (hereafter called the “Group”) are active in a wide range of business segments throughout the world. Through this rich diversity, the Group and its employees share action principles and common values.
To meet the expectations of its customers, suppliers, shareholders, and employees, the Group is committed to ensure compliance with the following values :

• Professionalism : to consistently deliver high-quality products and services to customers;
• Teamwork : to foster enterprise, innovation, creativity, synergy and unity throughout our organization;
• Partnership : to develop fair and transparent relationships with all stakeholders;
• Social responsibility;
• Strict compliance with all applicable laws;
• Environmental responsibility.

This code of business conduct, which is the body of common references of the whole Group, specifies basic principles and values to be respected by the staff , employees and workers while exercising their functions.
Republic Technologies is committed to the Universal Declaration of Human Rights adopted by the General Assembly of the United Nations in 1948 and is in compliance with the values of the Global Compact adopted by the United Nations on July 26th, 2000.

Principle 1 : Compliance with legal and ethical requirements

The Group’s employees and it’s representatives must be in compliance with all applicable law and regulations in each country or context in which the Group conducts business. Additionally, the principles, objectives and commitments set out in this code of conduct must be observed at all times.

This code of conduct is communicated to all Group employees/workers. Each employee/worker is conscious that violation of any of those code’s precepts will be exposed to personal liability.

All actions and activities performed by the Group must meet the highest ethical standards. They must allow the implementation and the diffusion of comprehensive, reliable and verifiable information on Group’s activities.

Principle 2 : Respecting individuals in human resources management

The Group aims to ensure equal opportunity in recruitment, employment, personal and professional development and promotion, without distinction of gender, race, age, nationality, religion or culture.

To foster each employee’s personal development and fight against social exclusion, the Group provides initial and ongoing training to assist employees/workers in performing their duties and ensuring their career development. The Group places particular emphasis on the integration and career development of disabled people.

The Group seeks to safeguard lasting employment for its employees within the Group, wherever possible, it gives preference to employee redeployment and retraining in the implementation of restructuring plans.

In accordance with the international conventions of the International Labour Organization, the Group prohibits any direct or indirect recourse to child labour or forced labour.

In collaboration with its employees/workers, the Group strives to promote and maintain healthy and safe working conditions and encourages its staff to inform and to keep informed their supervisors/managers of any workplace risks.

Principle 3 : Ethical business relations

Each staff member must perform with loyalty and integrity in all business relations and negotiations with its customers and/or suppliers. For this purpose each employee/worker prevents himself/herself from engaging in any dishonest conduct and notably any active or passive corruption.

This prohibition notably extends to any direct or indirect payment of bribes, as well as any gift with a value greater than an ordinarily admissible, used to influence the establishment or continuation of business relations with a customer and/or supplier.

Similarly, each employee shall prevent himself/herself from receiving, directly or indirectly any gifts, bribes or hidden payments, in respect with its responsibilities and functions within the Group.

Principle 4 : Struggle against illicit trade

The Group and its employees/workers are aware of an existing illicit market and are committed to avoid any contact and/or any implication, directly or indirectly, with this illicit trade.

As such, each employee/worker must ensure that all those with whom he/she has business dealings, in particular customers and suppliers, share the same values as the Group in terms of integrity and honesty.

The Group’s products are manufactured with the highest quality standards. Our brands represent a guarantee of quality and safety expected by our customers. Counterfeit products do not provide these guarantees and can jeopardize the Group’s products reputation.

Each employee is invited to inform his/her manager, once he/she is aware of any existing illegal trade, including counterfeiting and/or smuggling acts, which may involve, directly or indirectly, the Group’s products.

Immediately after been notified, the Group may use all legal means to stem, jointly with the competent authorities and in the law in force, any illicit trade involving its products, such as counterfeiting and/or smuggling.

Principle 5 : Maintaining honest and irreproachable relations with public authorities

The Group exclusively prohibits professional contacts with civil servants, government organizations, public administrations or public services representatives to employees/workers who have not obtained the necessary clearance to enter into such contacts in the course of their work.

No gift or favour of any kind may be accorded to public administrations, civil servants or representatives of public organizations save where these are in strict compliance with ethical and legal requirements as well as ordinary business practice. No gifts may be used to compromise the integrity or reputation of either party.

Principle 6 : Maintaining the Group’s reputation

The Group’s employees/workers must consistently strive to preserve and enhance the Group’s reputation. In this respect, the Group places particular emphasis on ensuring that its external partners also adhere to these principles.

Principle 7 : Safeguarding company property

Each employee/worker is responsible for conserving and protecting the Group’s assets and resources. These resources and assets are entrusted to employees who are committed to use them according to the purpose of performing the Group’s business. All employees/workers shall constantly ensure that the Group’s assets and resources should not be stolen, damaged or subject to any malicious act.

Principle 8 : Integrity in reporting

All Group information, including financial and accounting information, is founded in respect of elements enabling objective analysis and control.

Financial statements are audited by one of the major international audit firms.

Principle 9 : Choosing suppliers according to objective criteria

Decisions regarding the choice of suppliers, or the setting of purchasing conditions are exclusively based upon objective evaluations of quality, cost and supplier’s capability to provide and guarantee adequate services. Moreover, Group’s suppliers shall take appropriate measures to comply with legal requirements such as in tax and social matters, in order to avoid any employment of illegal workers.

Principle 10 : Avoiding conflicts of interest

Staff members must avoid any situation or activity that may lead to a conflict with the Group’s interests or which may interfere with their ability to take impartial decisions to the best of the Group’s interests.

Employees must request approval from their hierarchical superior before accepting any appointment, notably as a company director, to any organization outside the Group. This requirement does not apply to appointments within humanitarian, charity, and religious bodies.

In the event of a conflict of interest, the concerned employee will immediately inform his or her hierarchical superior and will refrain from taking any decision alone.

Principle 11 : Non-disclosure of confidential information

No information on the Group’s activities which is of a confidential nature may be used, communicated or divulged without the express authorization of the Group’s management.

This requirement notably applies to all research and development efforts in science or technology as well as manufacturing processes and proprietary knowledge related to strategic planning, financial planning or information contained in employee records.

Employees/workers holding confidential information are prohibited from disclosing such information to any unauthorized person and must avoid using such information, either directly or indirectly, for personal profit.

The same policy applies to confidential information disclosed to Group’s employees/workers by Customers.

Principle 12 : Protecting the environment

The Group scrupulously abides by applicable environmental standards in each of its sectors of activity and is committed to prioritising the use of methods to limit the environmental impact of its operations.

Group’s practices with respect to sustainable development and environment are described in our “Environmental Code of Practice”.