THE CODE OF CONDUCT OF OR CORPORATE SOCIAL RESPONSABILITY
MESSAGE FROM THE CHAIRMAN
The success and good reputation of our company are based on the mutual trust that exists between LOHR Group, its employees and the people with whom they interact (customers, suppliers, consultants, experts, public authorities and the public in general). We want to satisfy this trust in all respects, and the purpose of this Code of Conduct is to preserve and strengthen it.
The LOHR Group Code of Conduct formalises the rules in terms of ethics, integrity and respect for the law in the conduct of our business.
These rules are also an opportunity for the LOHR Group to assert its identity and develop its business in line with its fundamental values. I invite you to familiarise yourself with them and adopt the good practices.
All LOHR Group’s employees and managers have a duty to prevent any involvement of LOHR Group in unethical practices either in France or abroad, particularly with regard to corruption and influence peddling.
If you have any questions, please contact your line manager or the Legal Department, to whom I am entrusting the responsibility for deployment of the LOHR Group compliance programme.
If you are a witness to or confronted with inappropriate behaviour, use the Internal Whistleblowing Process (see page 24). This procedure ensures your action is confidential. I will ensure that no employee or manager of LOHR Group suffers any reprisals due to exercising their right to raise the alarm.
It is of paramount importance for our development that all LOHR Group’s employees and managers exemplify the ethical rules in this Code of Conduct and disseminate the principles within our teams and among our partners.
François LHOMME – CEO of LOHR SAS
A commitment at the heart of our CSR approach
Since 2016, LOHR Group has been engaged in establishing and implementing a formal CSR approach based on three areas of focus:
- Enshrine the fundamental principles underpinning the Group and encourage a spirit of conquest,
- To continue to be a pioneer and stay ahead of the competition,
- And finally to consolidate LOHR’s operational performance.
As a benchmark on its markets, LOHR Group has been anticipating, diversifying and adapting to new needs and usages since it was founded in 1963. In an increasingly open and connected world, LOHR Group makes sure it remains a step ahead to develop tomorrow’s solutions 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 second edition of the Code of Conduct, updated following a risk mapping produced by an independent third party, is a fundamental and integral part of the LOHR Group CSR approach. The Code of Conduct aims to express, formalise and share our values and principles in terms of ethics, integrity and respect of the law in the conduct of our business.
It is available to every manager and employee of LOHR Group. Everyone is invited to nourish it and nurture it on a daily basis.
1 – OUR VALUES AND PRINCIPLES FOR ACTION 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 everyone in the company.
LOHR Group’s managers and employees (referred to hereafter as “LOHR Group employees”) are united around humanist values (respect, loyalty and solidarity). They are committed to a strong work ethic, particularly to the value of work well done (an appreciation of hard work, savoir-faire and 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 the law, and an unquestionable code of ethics.
Integrity and respect of the law are opposed, in particular, to any form of corruption, both active and passive. They also seek to reject unfair business practices, avoid conflicts of interest and respect the confidentiality of sensitive information.
Ethics set respect and dignity as guiding principles and do not tolerate any form of discrimination.
These principles are at the core of our Code of Conduct.
2 – OBJECTIVES AND CONDITIONS OF THE CODE OF CONDUCT
The practical objective of the Code of Conduct is to help LOHR Group’s managers and employees, whatever their position, to know the rules in force, comply with them and be aware of the procedure to follow to ask for assistance or report a breach.
The Code of Conduct commits LOHR’s employees to running the group’s activities in compliance with the laws and regulations in all countries where it is present. In particular, corruption cannot be tolerated and is prohibited in any form.
All the necessary support will be systematically given to employees who place respect of our values above other interests.
The behaviour proscribed in this Code, and more generally any behaviour which does not comply with the commitments and the principles of the company in terms of prevention and detection of corruption, will result in disciplinary sanctions.
An internal whistleblowing process enables every employee to report any behaviour deviating from the rules set out in this Code. 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 reprisals after reporting any breach of the Code.
LOHR Group undertakes to monitor the effectiveness of these internal procedures and to improve them where necessary and possible.
3 – SCOPE OF THE CODE OF CONDUCT
This Code is applicable, in all circumstances and without exception, to LOHR Group’s management and employees, regardless of their hierarchical position, their function, their status (permanent, external or temporary), or the country where they work. It therefore applies to all its subsidiaries and the companies it controls without prejudice to the application of more demanding laws or local regulations if applicable.
The Code also covers relations between LOHR Group and its customers, suppliers, and more generally, all of its partners.
4 – THE APPLICABLE RULES
4.1- FIGHT AGAINST CORRUPTION AND INFLUENCE PEDDLING: “ZERO TOLERANCE”
In a globalised world, we are witnessing the appearance of an increasing number of measures to prevent corruption and control business ethics and transparency .(1)
It is particularly important that LOHR Group employees are familiar with and respect all the national and international laws and regulations relative to the fight against corruption and influence peddling.
Corruption and influence peddling are not only illegal and contrary to the fundamental values of LOHR Group, but they also restrict competition and have an impact on economic development.
It is the responsibility of LOHR Group employees wherever they are, both in France and abroad, to:
- Prevent any involvement of any company in LOHR Group in France or abroad in any corrupt practices and trading in influence, and if applicable,
- Report any act of corruption, attempted corruption or influence peddling, even suspected, both in France or abroad.
Any act of corruption committed in the context of relationships with private or public partners, as well as any breach of our “Zero Tolerance” policy in the fight against corruption and influence peddling will result in disciplinary sanctions, in accordance with the law and the Internal Rules and Regulations.
(1) France: The so-called “Sapin 2” law of 2016 relative to transparency, the fight against corruption and the modernisation of economic life / European Union: Council of Europe Conventions of 1999 / OECD: Anti-corruption convention of 1997 and recommendations of 2009 /United States: Foreign Corrupt Practices Act (FCPA) of 1977, amended by the International Anti-Bribery Act of 1998 / United Kingdom: United Kingdom Bribery Act (UKBA) of 2010
4.A- HOW DO YOU RECOGNISE CORRUPTION?
Corruption is a behaviour by which a person working in the public or private sector seeks or accepts any advantage, goods or services (money, travel, gifts, etc.) in return for performing or refraining from carrying out an act falling within their duties (granting of an administrative authorisation, obtaining a contract, etc.).
E.g. one of your suppliers promises you a holiday with your family if a contract is signed.
4.B – HOW DO YOU RECOGNISE INFLUENCE PEDDLING?
Influence peddling is the act by which a person abuses the real or assumed influence that they exercise with a public authority to obtain a decision favourable to a third party.
E.g. you agree to pay an elected member of the town where your plant is located so that they use their influence to obtain the issuance of a building permit.
4.C – HOW CAN YOU PREVENT ACTS OF CORRUPTION OR INFLUENCE PEDDLING?
It is prohibited for the companies and all the employees in LOHR Group to:
- give, offer or promise to give any advantage, either directly or indirectly, to any person with the aim of making that person perform or refrain from carrying out an act in the exercise of their functions (corruption);
- abuse the real or assumed influence of the beneficiary of an advantage to obtain a distinction, job, contract or any other favourable decision from an authority or public administration (influence peddling);
- ask for or accept any advantage, either directly or indirectly, from or on behalf of any person in relation to the undue accomplishment of a function or an activity in a company or for a company in LOHR Group (corruption or influence peddling from which LOHR Group may benefit).
4.D – IN WHAT SITUATIONS SHOULD YOU BE PARTICULARLY VIGILANT?
Be particularly vigilant if:
- The relations concern politically exposed or public persons,
- The relations concern a new partner about whom little information is available,
- The relations concern intermediaries,
- The relations occur in a period of preparation or awarding of contracts,
- The project or partner are based in a State classed as having a high risk of corruption,
- The structure of the relationship with the partner is unusual,
4.E – WHAT SHOULD YOU DO IF YOU ARE CONFRONTED WITH ATTEMPTED CORRUPTION OR INFLUENCE PEDDLING?
Corruption and influence peddling may take very varied forms. All employees are requested to comply with the instructions and procedures implemented within LOHR Group.
Any LOHR Group employee who is confronted with corruption or influence peddling in France or abroad is asked to contact the Legal Department or use the “Internal Whistleblower Procedure” (see page 24).
Case study :
As an employee of LOHR Group, you meet the representative of a business with a view to potentially referencing them as a supplier. You decide to meet them to find out more about their company and its range of products. During this discussion, the representative lets you know that if you assist them in becoming referenced by our business, “they will show gratitude”.</p
LOHR Group has adopted a zero-tolerance policy towards any behaviour contrary to integrity in general and any risk of corruption in particular.
Therefore, you must:
- inform the person that such a practice is completely contrary to LOHR Group’s values and its commitment to conducting business in total conformity with the applicable laws and regulations,
- inform your line manager and the Legal Department of the content of this discussion or use the “Internal Whistleblower Procedure” (see page 24).
4.F – GIFTS AND INVITATIONS
Although the exchange of business gifts or invitations is a relatively widespread practice in business relations, you should bear in mind that offering and accepting such advantages, depending on the circumstances, may be considered as acts of corruption or influence peddling.
These gifts and invitations should under no circumstances have the effect of influencing a decision or obtaining an undue advantage of any kind whatsoever. That is why LOHR group’s 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 law, the applicable regulations or the values of LOHR Group (gambling or activities contrary to the respectful treatment of human beings cannot be accepted),
Invitations and gifts offered or received must be:
– of a reasonable value,
– appropriate to the circumstances (e.g. it is unacceptable to give a present to a client immediately or after negotiating a tender) and appropriate to the recipient’s situation (position, etc.),
– received or offered in a professional context on behalf of a company in LOHR Group,
– gifts given must be paid for by a company in LOHR Group and not by the employee themselves,
- Invitations and gifts offered must be exclusively paid for by a company in LOHR Group. They must appear on an expense sheet validated by the manager and the recipient must be recorded by name in the books and registers of a company in LOHR Group.
- All invitations and gifts received must be recorded in a register provided for that purpose in the company’s Intranet (Lotus portal / Our Company / CSR or Lotus portal / tools / Declaration of gifts and invitations). The instigator of the gift or invitation will be mentioned in the register as well as the recipient. The line manager must also be informed.
- For any question or if there is any doubt about the rules applicable in the matter, ask your line manager, the Legal Department or the Human Resources Department for advice.
In an international context (beneficiary or donor outside France), any business gift or any invitation may only be given or received after having checked their legality in accordance with the local legislation.
Case Study :
One of our main suppliers contacts you. They wish to invite you in the very near future to lunch in a luxury restaurant. As their contract with a company in LOHR Group is nearing its end, they say that they “want 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 (their contract renewal period) could potentially undermine the independence of your decision in the selection process for this business partner. Accepting such an invitation is contrary to the values and rules of conduct set by LOHR Group.
Therefore, you must:
- Mention this exchange to your line manager and check with them if you can accept or refuse.
- In case of refusal: politely decline the invitation, explaining to this supplier that accepting their invitation would be contrary to the rules of conduct set by LOHR Group in this area. If necessary, you can also provide them with this Code of Conduct to support your response.
Gifts and invitations: ask yourself the right questions
4.G – RELATIONSHIPS WITH OUR BUSINESS PARTNERS
In certain situations, LOHR Group could be held responsible for acts of corruption committed by one of its business partners acting on its behalf (consultant, sales representative, distributor, dealer, joint-venture partner, etc.).
More generally, it is the responsibility of LOHR Group to ensure the integrity of third parties (customers, suppliers, service providers, etc.) with which it may be in relations or may wish to enter into relations.
For this reason, LOHR Group has set up a Partners Charter (), in which our values, ethical rules and the terms of this Code of Conduct are included.
To ensure our values and ethical rules are respected and to ensure the efficiency of the third-party evaluation procedure, all employees, executives and managers of companies in LOHR Group who become aware of a non-ethical practice on the part of a LOHR Group partner, either in France or abroad, are asked to contact their line manager, the Legal Department or the Human Resources Department, or to use the “Internal Whistleblower Procedure” (see page 24).
Case Study 1 :
You go to visit the representative of a company with a view to possibly referencing it as a supplier. During the visit of the premises, you notice that the basic rules for employee safety are not respected, or you suspect that forced labour, illegal employment or child labour are being used.
LOHR You are required to inform your line manager of your observations so that they can be taken into account in the evaluation process for this potential partner.
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 customers. While your team is currently busy finalising the drafting of this contract, the customer lets you know that he would like to come and sign the contract at our headquarters. He specifies that he expects his travel and accommodation expenses to be 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 customer in return for the award of the contract to a LOHR Group company, and therefore could constitute an act of corruption. LOHR group cannot justify unlawful behaviour to obtain a commercial advantage.
Therefore, you must:
- Explain to the customer that our policy on gifts and invitations does not allow you to cover of the travel and accommodation expenses of his family members,
- Inform your line manager and the Legal Department or use the “Internal Whistleblower Procedure” (see page 24).
4.H – 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.).
French law considers facilitation payments to be an offence and strictly prohibits this. Facilitation payments, whatever their frequency and amount, whether in France or abroad, are liable to criminal prosecution for corruption.
Tolerance to facilitation payments in certain countries exposes LOHR Group to prosecution. The group could be held liable.
For this reason, LOHR Group’s employees are asked to refuse facilitation payments except in the case of payments demanded under duress or putting the employee’s physical integrity or safety at risk. In the latter case, the employee subject to duress must report this to their line manager as soon as the risk to their safety is no longer imminent.
Case Study :
As an employee of LOHR group, you are responsible for the completion of the administrative formalities with the customs authorities of a foreign State. A local customs official offers “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 a justified request or not,
- Refuse to make the requested payment if it is not justified, explaining that such a practice would be contrary to French law and the rules of conduct of LOHR Group,
- Inform your line manager and the Legal Department of this request.
4.I – CASH TRANSACTIONS
Cash transactions are prohibited on principle.
In exceptional cases, a cash payment may be accepted, provided that the amount is compliant with the applicable legislation and provided that the third-party payer has been evaluated with the support of your line manager, the Legal Department and the Finance Department.
4.J – PATRONAGE AND SPONSORSHIP
Patronage activities (support with no direct return from the beneficiary of a project or 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.
LOHR Group is aware that patronage or sponsorship activities carried out in its name or using its financial means could be diverted from their original purpose to conceal an unfair advantage. Employees must therefore 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 can be made without having previously been duly approved by the Chairman of the LOHR SAS executive board, who will ensure and approve its compliance with LOHR Group’s values. An appropriate written agreement must be drafted,
- The actual payment of any contribution will be preceded by a control, proportionate to the risks involved, notably in order 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 Group 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 Group in accordance with the applicable rules.
4.K – FINANCING OF POLITICAL ACTIVITIES
While LOHR Group 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.
Financing activities 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 group’s employees are required to comply with the following rules of conduct:
- Only engage in political activities outside their working time,
- Refrain from speaking in the name of or on behalf of LOHR Group in connection with political activities,
- Never use LOHR Group’s resources to this effect,
- Contact their line manager or the Human Resources Department with any question on this subject.
Case Study :
You are an employee of LOHR Group and 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 save money, he asks you to use the photocopiers available to you at your place of work to print all the documents composing the welcome booklet which will be given to all participants at the next symposium organised by your local federation.
Accepting such a request can be considered to be a political contribution. You must then explain to your contact that LOHR Group’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.
4.L – 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 Group, these activities are supervised by the Executive Board.
To prevent the risk of corruption or influence peddling, LOHR Group’s lobbying activities may only be conducted in compliance with the following rules of conduct:
- Comply with all the applicable laws and regulations,
- 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 actions carried out as part of these activities and inform your line manager.
Case Study :
You are an employee of LOHR group. 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 she can influence the decision of the principal by providing them with confidential information disqualifying the offer of one of LOHR Group’s competitors.
She offers to “put her expertise at the service of your interests”.
LOHR Group cannot accept such actions. Therefore, you must:
- Indicate to your contact that LOHR Group 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,
- Report this discussion to your line manager and the Legal Department
4.2 – CONFLICTS OF INTEREST
In a professional setting, a conflict of interests may arise if an employee’s personal interests conflict with, or may be interpreted by third parties as conflicting with, the interests of LOHR Group.
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 person only or include relatives (parents, brothers and sisters, etc.),
- Of any nature (economic, financial, political, professional, etc.).
For example, the following circumstances may generate a conflict of interest:
- Being in a position to award a contract to a company while a spouse occupies a leadership position within that company,
- Holding a political mandate while in a position that could lead the individual to favour the interests of LOHR Group as part of this political activity,
- Using one’s internal influence to hire a relative or partner’s family member without following the applicable procedure, etc.
Such situations could lead to LOHR Group 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 Group’s interests,
- Consult their line manager or the Legal Department if they have the slightest doubt on this subject,
- Approach their line manager and the Legal Department to report any apparent or recognised personal interest,
- Remove themselves from any decision-making process they are associated with in case of a proven conflict of interest.
Case Study :
You are a buyer within LOHR Group. 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 in his company.
Accepting such a proposal could be considered as corruption and, in all events, create a conflict of interest for you. Therefore, you must:
- Thank him but reject his offer because it would be contrary to LOHR Group’s Code of Conduct,
- For any questions, contact your line manager or the Legal Department.
4.3 – 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 Group 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.
Every employee in LOHR Group is required to be vigilant in the exercise of their activities in order to:
- Respect the retention and archiving rules regarding documents showing the origin of funds for all transactions concluded,
- Identify any potential irregularities and, if applicable, report it to their line manager, the Legal Department or the Finance Department.
Case Study :
An intermediary requests the payment of their commission to an offshore bank account that does not correspond to the information provided by them when they entered into a contractual relationship and unrelated to the place of performance of the service.
Accepting such a proposal may mean LOHR Group can be held liable. You must therefore contact your line manager, the Legal Department or the Finance Department.
4.4 – COMPLIANCE WITH COMPETITION LAW
Competition law ensures effective competition between companies, and 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 group is committed to acting in strict compliance with the competition laws applicable in all the countries in which it operates.
To this end, LOHR Group’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/customers, etc.),
- To immediately contact the Legal Department in case of doubt regarding the applicable rules.
Did you know? :
Discussions with competitors concerning sensitive information such as product characteristics, R&D activities, margins, and the sales or pricing policy are prohibited insofar as they may undermine competition.
Be particularly vigilant during meetings in the context of a professional association and during breaks or meals. If you witness this type of discussion, inform the people that this type of conversation is prohibited and leave the meeting after asking the secretary for the session to record the fact that you have left the meeting and to specify the reason.
Even if you do not say anything, the simple fact of being present during these discussions can mean that you and also LOHR Group can be held liable.
4.5 – COMPLIANCE WITH DATA PROTECTION AND PRIVACY RULES
LOHR Group makes sure to protect the personal data of its employees, the employees of its customers, suppliers and partners, and any other people whose personal data may be processed by LOHR Group.
Personal data means all data allowing a physical person to be identified directly (e.g. last name, first name), or indirectly (e.g. telephone number, car registration plate). A person may be identified by a single piece of data (e.g. a name) or by a combination of several pieces of data (e.g. date of birth + profession + company name).
Therefore, all employees are required to limit the collection of personal data to the strict minimum (the data minimisation principle) and in general, to comply with all the security rules introduced by LOHR Group for processing personal data (limited retention time, access and rectification rights, transfer to third parties under strictly controlled conditions, etc.).
For any questions, LOHR Group employees are invited to consult the Legal Department.
4.6 – ENVIRONMENTAL PROTECTION
LOHR Group is mindful of its impact on the environment. It is committed to conducting its business in a way which best preserves and safeguards the environment for life to flourish on earth now and in the future, particularly by developing offers and products which can provide solutions, notably in terms of sustainable mobility.
Therefore, every employee must reflect this value in their personal behaviour and contribute to the protection of the environment, the fight against climate change and the preservation of natural resources while respecting the environmental standards applicable to their activities and their behaviour in the workplace.
4.7 – RESPECT FOR AND PROTECTION OF PERSONS
LOHR Group is particularly committed to respect for human rights. The same applies to the health and safety of its employees.
Thus, any form of discrimination, harassment or any behaviour of a nature likely to affect the physical or moral integrity of any person cannot be tolerated.
To this effect, in accordance with the national and international laws and regulations in force, LOHR Group’s employees are required to implement appropriate measures to:
- Treat all employees and all its partners’ 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 necessary precautionary measures to prevent and reduce the frequency and the severity of accidents at work and occupational diseases as much as possible with the aim of eradicating them,
- Respect the privacy of its employees and ensure the confidentiality and protection of their personal data.
It is everyone’s responsibility to contribute to making their place of work a safe environment where individuals are respected. Any behaviour contrary to the applicable rules and principles will lay the perpetrator open to disciplinary measures or even penal sanctions.
In addition, LOHR Group subscribes to the principle of neutrality, as specified in its Internal Rules and Regulations. While respecting the political, philosophical and religious beliefs of individuals, LOHR Group 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.
4.8 – RESPECT FOR AND PROTECTION OF MATERIAL AND IMMATERIAL ASSETS
LOHR Group employees have an individual and collective responsibility for the preservation of the assets and goods placed at their disposal.
It is therefore the responsibility of each LOHR Group employee 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 Group’s assets, whether they are 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 confidentiality of all data, information and documents entrusted to them as part of their professional activity. In particular, they must refrain from taking any photographs of any equipment, prototype or building unless duly authorised, and must not communicate any document or information relative to LOHR Group activities to any unauthorised third party, even orally,
- Take all the necessary precautions to prevent the risk of unauthorised access to LOHR Group’s assets, and the risk of loss, alteration and destruction of LOHR Group’s assets
- Never transmit to third parties information belonging to LOHR Group 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 Group’s intellectual property rights,
- Not infringe the intellectual property rights of others of which they have knowledge,
- Not respond to solicitations from third parties aiming to obtain confidential information unless duly authorised or entitled,
- 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 their professional activities (landline phone, mobile phone, computer or laptop, tablet, etc.) for their personal use (personal internet browsing, sending personal e-mail messages, etc.),
- Comply with the provisions of the Internal Rules and Regulations and the Digital Services Usage Charter,
- Immediately contact their line manager or the Legal Department with any questions relating to LOHR Group assets or to report an incident.
IT security: did you know? :
Human error is behind 75% of all IT security incidents.
It just takes a single episode compromising the information system and the entire functioning of the company can be brought to a halt.
- Never communicate sensitive information by email or over the telephone: no serious administration department or commercial company would ask you for your passwords by email or on the telephone.
- Before clicking on any questionable links, hover your mouse over the link, without clicking. This will display the address to which it really points so that you can check if it seems plausible. Alternatively, go directly to the website of the organisation in question using a “favourites” link you have created yourself. Check the address of the website displayed in your browser. If it does not correspond exactly to the site in question, it is probably a fraudulent site. Sometimes just a single character might be different in the website address to deceive you. If you have the slightest doubt, do not provide any information and close the corresponding page immediately
- Do not open attachments if you are not able to check the reliability of the sender.
- Report the incident to email@example.com.
- In case of doubt, contact the organisation in question directly to confirm that the message or call you have received really is from them.
- Use different, complex passwords for each website and application to avoid the theft of one of your passwords compromising all your personal accounts.
- If the website allows it, check the date and time of the last connection to your account to detect any fraudulent access.
- If the website allows it, activate two-factor authentication to secure your access.
- Alert the IT department in case of doubt.
- Strictly comply with the rules of caution set out in the Digital Services Usage Charter.
4.9 – INTEGRITY OF FINANCIAL INFORMATION
LOHR Group ensures that its books and records are kept in accordance with 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 Group.
Any action undertaken by an employee aiming to falsify, omit, conceal or misrepresent the financial information contained in LOHR Group’s books and records will be sanctioned.
5 – INTERNAL WHISTLEBLOWER PROCEDURE
All permanent and temporary employees or external partners who, during their activities with LOHR Group, observe behaviour or situations which appear contrary to the provisions of this Code of Conduct are invited to use the Whistleblower Procedure implemented by LOHR Group.
This system also provides guidance to staff wondering what behaviour to adopt in a specific situation.
Your access to the Whistleblower Procedure:
Lotus Portal / Our company / CSR
Code of conduct alert (CONFIDENTIAL)
Aurélie Denonnin, Group Legal Manager
29 Rue du 14 juillet, 67980 HANGENBIETEN
Nicolas Marson, Human Resources Manager
Avenue de la Concorde – ZA Bruche, 67120 DUPPIGHEIM
Permanent or temporary employees of LOHR Group can also contact their line manager who will guide them and advise them appropriately. The managers of LOHR Group can also be contacted directly on these subjects if the employees concerned are unable to use the reporting lines or whistleblower procedure.
To ensure the protection of individuals using the whistleblower system or who are the subject of a report, LOHR Group makes every effort to ensure:
- The confidentiality of the identity of the whistle-blower, the persons covered by the report, the facts contained in the report and all the information collected in this context,
- That no retaliatory action will be taken against a person who, under the rules set out in this Code of Conduct, has exercised their whistleblowing right/duty.
Any person who takes (or attempts to take) retaliatory action against an employee of LOHR Group for having exercised their whistle-blowing rights is liable to disciplinary sanctions.
6 – DISCIPLINARY SANCTIONS
Failure to comply with the ethical principles set out in the Code of Conduct will incur the application of disciplinary measures in accordance with the applicable local rules, i.e. the Internal Rules and Regulations if it concerns LOHR Group employees linked to French companies.
WHO CAN YOU CONTACT FOR FURTHER INFORMATION?
For any questions concerning the rules set out in this Code of Conduct and/or in case of doubt as to the “correct behaviour to adopt”, you are invited to contact your line manager.
You can also contact the Legal Department or the Human Resources Department for this purpose or for any additional suggestions:
Group Legal Manager
Tél. : +33 (0) 3 88 38 98 41
Human Resources Manager
Tél. :+33 (0) 3 88 48 53 55