Partner-Charta

The LOHR Group, a private French group, has been the world specialist in the design, manufacture and marketing of goods and passenger transport systems for over 50 years.

A pioneering spirit and a spirit of innovation are founding principles of the LOHR Group, driving its ambition and development goals. This innovative approach is first and foremost based on the shared trust and humanity of the people working for the company. LOHR employees are united around humanist values (respect, loyalty, solidarity, trust and kindness). They define themselves by their commitment, the quality of their work and their high-level expertise. They are fully committed to customer satisfaction and the fulfilment of every individual within the company. These values, largely inspired by Mr Robert Lohr, its founder, run deep in the Group.

Conscious of their duties towards their customers, their employees and their business partners, the companies in the LOHR Group (hereinafter referred to as “LOHR”) have adopted demanding ethical rules, in particular a Code of Conduct and this Partner Charter.

LOHR expects its partners to share its ethical values, taken, in particular, from the ten principles of the United Nations Global Compact and the eight fundamental conventions of the International Labour Organisation included in the appendix. Partners are also expected to comply with the principles of this Charter (hereinafter referred to as the “Charter”), the aim of which is to describe in detail:

1 – PRIVACY AND CONFIDENTIALITY

The partner undertakes (i) not to use the information supplied by LOHR other than in the context of business discussions with LOHR, (ii) to maintain the strictest confidentiality concerning all information exchanged as part of its relations with LOHR, (iii) to set up adequate data protection measures allowing only authorised people to access this data and ensuring it is protected against any misuse.

The partner recognises that the partner and LOHR each remains the sole owner of their own confidential data and holder of the related intellectual property rights.

2 – COMPLIANCE WITH THE LAWS, REGULATIONS AND STANDARDS RELATIVE TO BUSINESS ETHICS

The partner undertakes to comply with all the laws and regulations currently in force applicable to its business activity and/or its company, in particular:

• The fight against corruption and trading in influence

The partner guarantees that it and its directors, managers or employees do not propose, promise, offer, authorise, ask for or accept any undue payment or other advantage (or allow it to be thought that they will or might act in this way in the future) with the aim of obtaining an undue advantage or obtaining or maintaining a business transaction or preferential treatment. The partner undertakes to take all the necessary measures to ensure that its legal representatives, employees, subcontractors, agents or any third party it may mandate also submit to these same commitments and comply with the national and international laws, regulations and standards currently in force.

• Abstention from any practice constituting money laundering

The partner guarantees that it and its directors, managers or employees shall at all times refrain from any practice directly or indirectly constituting money laundering, being reminded that money laundering is the term applied to the act of concealing the origins of money earned through criminal activities and of releasing it into legitimate business activities.

• Prevention of conflicts of interest

The partner undertakes to avoid any conflict of interest, i.e. any situation which places it, its directors, managers or employees in the centre of decision-making where their objectivity and neutrality could be called into question. Should the partner become aware of such a situation, it undertakes to inform LOHR immediately and take the necessary measures to put an end to this and prevent it reoccurring.

• Abstention from anti-competitive behaviour

The partner undertakes to adopt fair and lawful business practices and to refrain from any anti-competitive behaviour, i.e. any behaviour undermining the general interest of competition which has an impact on the relevant market concerned, such as, for example, restrictive agreements and concerted practice, mergers or abuse of a dominant position.

3 – RESPECT FOR HUMAN RIGHTS

The partner undertakes to respect all the laws, regulations and standards recognised at international level relating to human rights, fundamental freedoms and respect for persons, health and safety, in particular:

• Abstention from any form of discrimination

The partner shall refrain from any form of discrimination (colour, nationality, social background, disability, sexual orientation, political or religious beliefs, gender, age, etc.) and shall promote equal opportunities for its employees.

• Abstention from the use of forced labour, child labour, illegal or concealed employment

The partner shall refrain in all circumstances from directly or indirectly using forced labour, child labour or illegal or concealed employment in any way whatsoever.

• Compliance with the social regulations in force

The partner undertakes to maintain a working environment where all employees are treated with dignity and respect. It undertakes to comply with the social regulations currently in force and to provide its employees with a safe, healthy working environment, to adopt appropriate preventive measures with regard to the health and safety of employees and third parties, and to pay fair wages.

• Compliance with the General Data Protection Regulation

The partner declares that it has set up and continues to implement the necessary actions linked to its compliance with the data protection regulations.

4 – ENVIRONMENTAL PROTECTION

The partner endeavours to achieve the highest standards in environmental protection, constantly seeking solutions and making improvements in terms of energy consumption, the preservation of natural resources and biodiversity, and the limitation of waste products and toxic substances.

5 – COMPLIANCE WITH THE LAWS AND REGULATIONS GOVERNING INTERNATIONAL TRADE AND ECONOMIC SANCTIONS

The partner undertakes to refrain from any activity which contravenes or is likely to contravene the applicable rules with regard to economic trade sanctions, such as embargoes, financial sanctions, etc.

6 – COMPLIANCE OF SUBCONTRACTORS AND BUSINESS PARTNERS WITH THE CHARTER

The partner undertakes to transmit the detailed principles of this Charter to its own subcontractors, service providers or any other business partners, and to ensure they comply with them.

7 – AUDIT

At least once a year, LOHR may carry out an audit, or have one carried out by any auditor which is not a competitor of the partner, in order to check that the partner complies with the principles defined by this Charter. This auditor must sign a confidentiality agreement. The cost of these audits shall be borne by LOHR. LOHR shall give the partner notice of any audit mission at least fifteen (15) working days beforehand.

The partner undertakes to collaborate in good faith with any auditor thus appointed. It shall facilitate the auditors’ access to any document or information or other element required for the smooth running of the audit mission, and shall facilitate their mission, in particular by answering all questions asked and providing access to all the tools and resources necessary for the audit.

If any evidence is discovered during an audit, or through any other of the partner’s documents, that the partner is guilty of breaching the applicable principles defined by this Charter, LOHR shall inform the partner by any appropriate means and shall give it notice to take all the necessary measures within a reasonable timeframe and to keep LOHR informed of the measures taken.

If no action is taken, LOHR may suspend or terminate all relations with the partner.