The code of conduct of or Corporate Social Responsability
A commitment at the heart of our CSR approach
Since 2016, LOHR has been formalising and implementing a CSR approach based on three themes:
- Establishing the key fundamentals that constitute the group while promoting the spirit of conquest,
- Continue to act as a pioneer and keep a leading position,
- And finally, consolidate the operational performance of LOHR.
A leading player in its markets, the LOHR Group has constantly anticipated, diversified and adapted itself to new requirements and usage patterns since it was founded in 1963. In an increasingly open and connected world, the LOHR Group seeks to stay one step ahead to develop the solutions of tomorrow, today.
Corporate Social Responsibility (CSR) is one of the drivers selected to meet this challenge, a central theme connecting human, environmental and social issues for ever greater sustainable performance.
This code of conduct is one of the first publications completely and fundamentally in line with the CSR approach of LOHR. Its aim is to express, formalise and share our values and principles in terms of ethics, integrity and the respect of the laws in the conduct of our activities.
It is available to every manager and employee of the LOHR Group. Everyone is invited to nourish it and nurture it on a daily basis.
1 – OUR VALUES AND ACTION PRINCIPLES ON A DAILY BASIS
The pioneer spirit and spirit of innovation are the founding values of LOHR Group, serving its ambition and its development objectives. This process of innovation is based primarily on a trust and humanity that is shared by the women and men of the company.
LOHR’s employees come together around humanist values (respect, loyalty, solidarity), they are bound by their commitment and in particular the quality of their work (effort, know-how, excellence). These values, which now permeate the whole Group, were largely inspired by Mr Robert Lohr, its founder.
Our values inspire and guide the way we conduct business, both in our interactions within the company and with our ecosystem and our partners. They are reflected accordingly in several fundamental principles: Integrity, the respect of individuals and laws and a certain code of ethics.
Integrity and the respect of the laws are opposed, in particular, to any form of corruption, both active and passive. They also seek to reject unfair business practices, the avoidance of conflicts of interest and the respect of the confidentiality of sensitive information.
Ethics set respect and dignity as principles and does not tolerate any form of discrimination.
These principles are at the core of our code of conduct.
2 – OBJECTIVES AND TERMS OF THE CODE OF CONDUCT LOHR’S MANAGEMENT AND EMPLOYEES
La finalité pratique de ce Code de conduite est d’aider les collaborateurs du groupe LOHR, quelle que soit leur fonction, à connaître les règleThe practical objective of this Code of conduct is to help the employees of the LOHR Group, whatever their position, to know the rules in force, help them comply with them and be aware of the procedure to follow to ask for assistance or report a breach.
This Code of conduct commits LOHR’s management and employees to drive the Group’s activities in compliance with the laws and regulations in all countries where it is present.
Corruption cannot be tolerated and is prohibited, in any form.
All the necessary support will be systematically given to the employees who place the respect of our values above other interests.
The behaviours proscribed in this Code, and more generally any behaviour not complying with the commitments and the principles of the company in terms of prevention and detection of corruption will result in disciplinary sanctions.
An internal alert system enables every employee to report any behaviour deviating from the rules set out in this Code. The LOHR Group undertakes to ensure that the confidentiality of the process is respected and therefore guarantees the protection of any whistle-blower. No employee will suffer retaliation because of his reporting.
The LOHR Group undertakes to monitor the effectiveness of these internal procedures and to improve them if necessary and possible.
3 – SCOPE OF THE CODE OF CONDUCT
This Code is applicable, in all circumstances and without exception, to LOHR’s management and employees, regardless of their hierarchical position, their function, their status (permanent, external or occasional), or the country where they exercise their activity. And this, without prejudice to the application of more demanding laws or local anti-corruption regulations if applicable.
It also applies to all its subsidiaries and companies that it controls and is also implemented in the relationships it has with its clients, suppliers and, more generally, all of its partners.
4 – THE APPLICABLE RULES
4.1 – Fight against corruption and trading in influence: “zero tolerance”
In the course of its activities, LOHR undertakes to comply with all laws, regulations and other obligations, national or international, applicable in the fight against corruption.
LOHR is committed to comply with all laws and regulations in force in the fight against corruption and trading in influence.
Any act of corruption, committed in context of relationships with private or public partners, as well as any breach of our “Zero Tolerance” policy in the fight against corruption will result in disciplinary sanctions.
As corruption and trading in influence can take different forms, it is requested that all employees:
- follow the instructions and procedures in place within LOHR,
- immediately contact their line manager or the Human Resources Department with any questions on these specific topics.
Corruption is the behaviour by which a person working in the public or private sector seeks or accepts any good or service (money, travel, gift, etc.) in return for realising or refraining from carrying out an act falling within his duties (granting of an administrative authorisation, obtaining a contract, etc.).
(For example: One of your intermediaries offers you to “hand back part of his remuneration” to one of your clients in order to “ensure the renewal” of a contract).
Trading in influence is the act by which a person abuses the real or assumed influence that it exercises with a public authority to obtain a decision favourable to a third party.
(For example: You agree to pay an elected member of the town where your plant is located so that he uses his influence to obtain the issuance of a building permit.
Behaviours inconsistent with the commitments and principles of LOHR on the prevention and detection of corruption and trading in influence expose their authors to disciplinary sanctions defined by law or applicable rules.
a – gifts and invitations
While the exchange of business gifts or invitations is a common act of courtesy in the context of trade relations, it should be borne in mind that the offer and the acceptance of such benefits cannot be allowed if the objective is to obtain an unfair advantage.
In addition, such a practice may be prohibited or regulated by some locally applicable legislation or by the beneficiary’s company. These gifts and invitations should under no circumstances have the effect to influence a decision or to obtain an undue advantage of any kind whatsoever. That is why LOHR employees are required to comply with the following rules of conduct:
- No employee may give or receive a gift or an invitation that is against the laws, regulations or the values of LOHR (money games or activities inconsistent with the respectful treatment of humans cannot be accepted),
- Invitations and gifts offered or received must always be:
– of a reasonable value,
– appropriate to the circumstances (e.g. It is unacceptable to give a present to a client immediately or after leading negotiations for a tender) and to the recipient’s situation (nationality, position, etc.),
– received or offered in a professional context on behalf of LOHR,
– offered gifts must be paid by LOHR not by themselves,
- invitations and gifts should be an expense approved by the manager and recorded in the books and records of LOHR,
- invitations and gifts with a value greater than 50 euros must be recorded in a register provided for that purpose on the company intranet (Portail Lotus / Notre Société / RSE ou Portail Lotus / outils / Déclaration cadeaux et invitations). The instigator of the gift or invitation will be mentioned in the register. A manager must be informed for invitations and gifts with a value greater than 150 euros,
- for any question or if there is any doubt about the rules applicable in the matter, ask your line manager or the Human Resources Department for advice.
Case Study: :
One of our main suppliers contacts you. He wishes to invite you in the very near future to lunch in a luxury restaurant. His contract with Lohr maturing soon, he says that he “wishes to catch up with you regarding the prospects of its renewal”. >
Such an invitation in terms of the selected location (a luxury restaurant) and current context (his contract renewal period) could potentially undermine the independence of your decision in the selection process of this business partner. To accept such an invitation could be contrary to the values and rules of conduct set by LOHR.
Therefore, you must:
- • mention this exchange with your line manager and validate with him your acceptance or refusal.
- • In case of refusal: politely decline the invitation, explaining to this supplier that accepting his invitation would be contrary to the rules of conduct set by LOHR in this area. If necessary, you can also provide him with this Code of conduct to support your words.
b – Relationships with our business partners
In some situations, a company can be held responsible for acts of corruption committed by one of its business partners (a consultant, an agent, a joint venture partner, etc.) acting for LOHR or on its behalf. This is the reason why LOHR ensures that it works with business partners who share its values and rules of conduct and are committed to follow them when doing business.
LOHR is committed to incorporate a reference to the code of conduct in its business contracts.
Case study 1 :
An employee of LOHR, you meet with the representative of a business with a view to potentially reference them as a supplier to our organisation. You decide to meet with him to find out more about his company and its range of products. During this exchange, the representative lets you know that if you assist him to become referenced by our business, “he will show gratitude”.
LOHR has adopted a zero-tolerance policy toward any behaviour contrary to integrity in general and any risk of corruption in particular.
Therefore, you must:
- respond to your interlocutor that such a practice is completely contrary to LOHR’s values and its commitment to conduct business in perfect conformity with the laws and regulations applicable,
- inform your line manager and Human Resources Department of the content of this exchange.
Case study 2 :
After months of negotiations, you come to a financial agreement for the renewal of a service contract with one of our major clients. While your team is currently busy finalising the drafting of this contract, the client lets you know that he would like to come and sign the contract at our headquarters. He specifies that he expects that his travel and accommodation expenses are fully covered and that he will come accompanied by his wife and two children.
Accepting such a request could be perceived as granting a benefit to this client against the award of the contract to Lohr, and therefore could constitute an act of corruption. Lohr cannot justify unlawful behaviours to obtain a commercial advantage.
Lohr cannot justify unlawful behaviours to obtain a commercial advantage.
Therefore, you must:
- explain to the client that our policy on gifts and invitations does not allow you to take care of the travel and accommodation expenses of his family members,
- mention this incident to your line manager and the Human Resources Department.
c – Facilitation payments
Facilitation payments are low amount, unofficial payments made to ensure or to facilitate the execution of regular and non-discretionary administrative formalities (obtaining a license, a visa, a permit, etc.). If such payments are practised in some countries, they are prohibited in others where they equate to acts of corruption.
That is why, in any doubt, the employee must ask his manager or the Human Resources Department.
Case study :
An employee of LOHR, you are responsible for the completion of the administrative formalities with the customs authorities of a foreign State. A local Customs official offers to “to take care of the processing of your application” against the payment of the equivalent of 150 euros.
Such payment may be considered as a facilitation payment. Therefore, you must:
- check the purposes of this payment to determine whether it is or not a justified request,
- refuse to make the requested payment if it is not justified, explaining that such a practice would be contrary to the rules of conduct of our company,
- inform your line manager of this request.
d – Transactions in cash
Transactions in cash are the subject of a specific regulation which varies from one country to another. Hence LOHR requests its employees to only accept transactions in cash if it is the only option available, within the limit of the amount legally authorised and after authorisation by their manager.
e – patronage and sponsorship/sponsoring
Patronage activities (support with no direct return from the beneficiary, to a project or to a person for the performance of activities of general interest) and sponsorship (material support given to an event, a person, a product or an organisation resulting in direct benefits) are subject to legislation and a specific regulatory framework.
Aware that patronage or sponsorship activities carried out on behalf of LOHR or by using its financial means could be diverted from their original purpose to conceal an unfair advantage, employees must comply with the following rules of conduct:
- no contribution may be paid to gain an unfair advantage or in exchange for a benefit unduly received (examples of benefit: establishing/maintaining a business relationship),
- no payment may not be made without first having been duly approved by a member of the Executive Board who will ensure it is consistent with the values of the company. An appropriate written agreement must be drafted,
- the actual payment of any contribution will be preceded by a control, proportionate to the risks involved, in order notably to verify the identity and integrity of the recipient(s) of this contribution, to ensure the absence of conflicts of interest and ensure that its activities comply with the values and rules of conduct that Lohr complies with,
- all expenses incurred in this context must be recorded for accounting and all subsequent costs and receipts shall be recorded in the accounting records of Lohr in accordance with applicable rules.
f – Financing of political activities
While LOHR respects the right of its employees to individually invest themselves in the political and civic life of their countries, any financial or contributions in kind to organisations, parties or political figures cannot be paid by one of its entities or on its behalf.
Political contribution means any direct or indirect contribution to provide support to a political organisation, a candidate or an elected official. This contribution may consist of a payment of money or any other advantage (sponsorship of a campaign meeting or a fund-raising dinner, gifts, the provision of facilities or services free of charge or at a reduced price – offices, photocopying, etc.).
That is why LOHR employees are required to comply with the following rules of conduct:
- only engage in political activities outside of their working time,
- refrain from speaking in the name of or on behalf of Lohr in connection with political activities,
- never use Lohr’s resources to this effect,
- contact their line manager or the Human Resources Department with any question on this subject.
Case study :
An employee of LOHR, you campaign a few hours per week within a political party. One day, your supervisor informs you that the local federation is experiencing some financial difficulties because of the loss of several members. To achieve savings, he asks you to use the copiers available to you at your place of work to print all the documents composing the welcome booklet which will be given to all participants to the next symposium organised by your local federation.
To do so could be considered as a political contribution. You must explain to your interlocutor that LOHR’s policy on the financing of political activities does not allow you to use the equipment at your disposal to exercise your professional activities to this effect.
g – Representation of interests / lobbying.
For an organisation, the representation of interests or lobbying is the transfer of any information to public officials, policy-makers or elected officials for the purposes of informing their decision-making.
Within LOHR, these activities are supervised by the Executive Board.
To prevent the risk of corruption or trading in influence, LOHR’s lobbying activities may only be conducted in compliance with the following rules of conduct:
Afin de prévenir les risques de corruption ou de trafic d’influence, les activités de lobbying de LOHR ne peuvent être conduites que dans le respect des règles de conduites suivantes :
- comply with all the laws and regulations applicable in the matter,
- act with professionalism and integrity,
- comply with the rules of conduct laid down in this Code, which in particular includes our “zero tolerance for corruption” policy, our rules relating to our policy on gifts and invitations and to the prevention of conflicts of interest,
- document the actions carried out as part of these activities.
Case study :
An employee of LOHR, you are in a call for tender phase with a principal in the public sector and you are contacted by a consultant working within a public affairs consulting firm. This consultant informs you that he can influence the decision of the principal by providing him confidential information disqualifying the offer of one of LOHR’s competitors.
He offers to “put his expertise at the service of your interests”.
LOHR cannot accept such actions. Therefore, you must:
- indicate to your interlocutor that LOHR conducts its lobbying activities in accordance with its values and the applicable laws and regulations and follows a clear and transparent process in the matter. That is why you cannot respond favourably to such an approach. If necessary, refer to the provisions of this Code of conduct to back up your position during your conversation,
- mention this discussion to your line manager and the Human Resources Department.
h – Conflicts of interest
In the professional sphere, a conflict of interest can occur if the personal interests of one of our employees are conflicting or could appear to be conflicting with the interests of LOHR.
The concept of personal interest must be understood very broadly. In effect, this conflict may be:
- directly or indirectly linked to one’s activities,
- relating to the single person or include relatives (parents, brothers and sisters, etc.),
- of any nature (economic, financial, political, professional, etc.).
For example, the following circumstances can generate a conflict of interest:
- to be in a position to award a contract to a company while a spouse occupies a leadership position within that company,
- to hold a political mandate while in a position that could bring the individual to favour the interests of Lohr as part of this political activity,
- to use one’s internal influence to hire a supplier’s family member without following the applicable procedure, etc.
Such situations could lead to Lohr obtaining an unfair advantage and therefore expose it to heavy penalties. It is therefore the responsibility of each employee to:
- identify any situation in which personal interests interfere or could interfere with Lohr’s interests,
- consult their line manager or the Human Resources Department at the slightest questioning on this subject,
- approach their line manager and the Human Resources Department to report any apparent or recognised personal interest,
- remove oneself from any decision-making process he is associated with in case of proven conflict of interest.
Case study :
A buyer within LOHR, you mention in a discussion with the sales manager of one of your key suppliers that as part of her studies your daughter is looking for an internship. He offers to “do you a favour” by taking her within his company.
To accept such offer could be qualified as corruption. Therefore, you must:
- thank him but reject his offer because it would be contrary to the Code of conduct of the company,
- for any questions, contact your line manager or the Human Resources Department.
4.2 – Compliance with the competition Law
Ensuring the effectiveness of competition between companies, competition law promotes and encourages productivity, innovation and excellence. In fact, to stay competitive in a context of free and undistorted competition, a company must innovate and constantly improve the quality of the products and services it offers to its clients.
LOHR is committed to act in strict compliance with the competition laws applicable in all the countries in which it operates.
To this end, Lohr’s employees are required in particular:
- not to exchange sensitive information (price, profit margins, costs, profits, etc.) with current or potential competitors,
- not to conclude an agreement with a competitor with the purpose and/or effect of restricting competition (agreement on the price of sale, distribution of customers/markets, territories/clients, etc.),
- to immediately contact Legal Services in case of doubt on the rules applicable in the matter.
4.3 – Environmental protection
LOHR, mindful of its impact on the environment, undertakes to carry out its activities by integrating environmental concerns and developing offers and products that can bring solutions, notably in terms of sustainable mobility.
Therefore, every employee must reflect this value in his personal behaviours and contribute to the protection of the environment, the fight against climate change and to the preservation of natural resources while respecting the environmental standards applicable to his activities.
4.4 – Respect for and protection of persons
LOHR is particularly committed to the respect of the human rights recognised both on the national and international level. The same applies to the health and safety of its employees.
Thus, any form of discrimination, harassment or behaviour of a nature to affect the physical or moral integrity of its employees cannot be tolerated.
To this effect, in accordance with the national and international laws and regulations in force, Lohr’s employees are required to implement the appropriate measures to:
- treat all employees equally, with dignity and respect, from their recruitment and throughout their career,
- comply with all laws and regulations in force for health and safety at work,
- take the precautionary measures necessary to prevent and reduce the frequency and the severity of accidents at work and occupational diseases,
- respect the privacy of its employees and ensure the confidentiality and the protection of their personal data.
It is everyone’s responsibility to contribute to make their place of work a safe environment, respectful of the individual. Any behaviour contrary to the rules and principles in the matter will expose its author to disciplinary sanctions.
In addition, LOHR subscribes to the principle of neutrality, as specified in the Internal Rules and Regulations. While respecting the political, philosophical and religious beliefs of individuals, LOHR is above all a place of work and each employee must abide by its rules of operation. No exceptions will be granted for political, philosophical and religious practices.
4.5 – Third party relations
LOHR is committed to maintain a fair attitude consistent with professional ethics in the relations it enjoys with all its business partners (clients, suppliers, subcontractors, intermediaries), and expects the same in return.
LOHR expects all its business partners to:
- adhere and comply with the values and rules of conduct presented in this Code, apply equivalent principles and rules to those defined in this Code of conduct in their activities.
4.6 – Respect for and protection of material and immaterial assets
Each employee is responsible, as part of his duties, for the proper use and protection of the material and immaterial assets of LOHR.
It is the responsibility of each of Lohr’s employees to:
- act in accordance with the legal and regulatory provisions applicable (personal data protection, prevention of invasion of privacy, etc.),
- take all the measures required to protect LOHR’s assets, would they be material (vehicles, computer equipment, etc.) or immaterial (private data, know-how, inventions, creations, etc.),
- take all the necessary security measures to ensure the protection and the confidentiality of all data, information and documents entrusted to him as part of his professional activity,
- take all the necessary precautions to prevent the risks of unauthorised access to LOHR’s assets, and the risk of loss, alteration, destruction of LOHR’s assets,
- never transmit to third-party information belonging to LOHR and that is not accessible to the public,
- never communicate confidential information received from customers, suppliers or other business partners to a third party, without having previously obtained the written agreement of the third party concerned or being forced to do so by the law or the regulations in force,
- preserve LOHR’s intellectual property rights,
- not infringe the intellectual property rights of others he has knowledge of,
- not respond to solicitations from third parties aiming to obtain confidential information unless duly authorised,
- never use confidential information for personal benefit or the benefit of an unauthorised person, or for an unauthorised purpose,
- use in a fair, reasonable and proportionate way the means of communication provided as part of his professional activities (fixed phone, mobile phone, computer or laptop, tablet, etc.) for his personal use (personal internet browsing, sending personal e-mail messages, etc.),
- comply with the provisions laid down in the Internal Rules and Regulations and the IT Charter,
- immediately contact his line manager or the Human Resources Department with either any question relating to the assets of LOHR or to report an incident.
4.7 – Integrity of financial information
LOHR ensures that its books and records are kept in accordance and respect of the accounting rules and principles in force. Its employees are therefore required to ensure the management, retention, archiving and destruction of data in accordance with the legal deadlines and the applicable procedures implemented within LOHR.
Any action undertaken by an employee aiming to falsify, omit, conceal or misrepresent the financial information contained in LOHR’s books and records will be sanctioned.
4.8 – Fight against money laundering and the financing of terrorism
Money laundering is the process used to disguise the origin of assets derived from illicit activities by giving them a legitimate appearance. LOHR undertakes to conduct its activities in compliance with the laws and regulations applicable in the field of the fight against money laundering and the financing of terrorism.
Each employee of LOHR must ensure that this issue is considered by being vigilant when conducting his activities in order to:
- respect the retention and archiving rules of documents showing the origin of funds for all transactions concluded,
- identify any potential irregularities and, if applicable, report it to his line manager, the Legal Department or the Finance Department. (e.g. Intermediary requesting the payment of his commission to an offshore bank account that does not correspond to the information provided by him when he entered into a contractual relationship and unrelated to the chain of performance of the service, payment made on behalf of a customer by a third party to the contract, etc.).
5 – HOW TO REPORT A BREACH?
All permanent, casual or external collaborators that, within his activities with Lohr, observe behaviours or situations which appear contrary to the provisions of this Code of conduct is invited to use the Alert Procedure implemented by Lohr.
This system also provides guidance to staff wondering what behaviour to adopt in a specific situation.
To this effect, any employee is invited to contact the Human Resources Department via the following email address or mailing address:
Portail Lotus / Notre Société / RSE
Alerte code de conduite (CONFIDENTIEL)
Avenue de la Concorde – ZA de la Bruche
Permanent or temporary employees of Lohr can also contact their line manager who will guide them and advise them appropriately except if they are the actual source of the offending behaviour.
To ensure the protection of individuals using the alert system or the subjects of a report, LOHR makes every effort to ensure that:
- the confidentiality of the identity of the whistle-blower, the persons covered by the report, the facts subjects of the report and all the information collected in this context,
- no retaliatory action is taken against a person who, in the conditions laid down by the law, has exercised his whistleblowing rights.
Any person who takes (or attempts to take) retaliatory action against an employee of Lohr for having exercised his whistle-blowing rights is exposed to disciplinary sanctions.
Who do I contact for additional information?
For any question on the rules set out in this Code of conduct and/or if in doubt about the “good behaviour to adopt”, you are invited to contact your line manager.
You can also contact to that effect, or for any additional suggestions, the Human Resources Department:
Nicolas MARSON, HRD.