Anti-bribery program 

Following regulatory evolutions, especially the recommendations issued by the French Anti-corruption Agency in January 2022, the Group has strengthened its Ethics and Compliance program so as to be in compliance with the regulatory requirements and business practices.

The anti-bribery program includes the following:

• Communications to all employees explaining that a zero-tolerance policy against bribery is part of Vantiva’s core values; and regular updates on the anti-bribery program at the Audit Committee of the Company’s Board of Directors and at the Board itself;
• Code of Ethics & Anti-Bribery Policy: to provide practical examples showing employees how to do the right thing when faced with a dilemma;
• Whistleblowing system: enables all Vantiva’s employees and partners to report anything that they suspect to be unethical, illegal or unsafe, through a dedicated website or by phone;
• Risk mapping: reviewed in 2022 to identify new risks specific to business conduct and to re-assess all of them;
• Third-party assessments: the Group’s suppliers are required to respect the Anti-bribery Policy, and the Third-Party policy covering our relationship and engagement with agents, consultants, advisors, among others, has been reviewed and communicated to sales and legal teams, in specific training. The sales agent template contract has been streamlined with new anti-bribery requirements;
• Training: courses on anti-bribery are developed and delivered within the Group to the staff categories with the highest level of exposure, including targeted E-learning and on-site training for specific employee categories such as sales, legal, finance or human resources;
• Accounting control procedures: the internal control and risk management procedures relating to the preparation and processing of financial and accounting information form an integral part of the Group’s anti-bribery measures;
• Internal control and audit procedures: internal and external audits are performed on a regular basis, notably covering anti-bribery matters;
• Tax management: the Group takes a zero-tolerance approach to Tax Evasion or facilitation of Tax Evasion under the law of any city, state or country in which we operate or do business.

Compliance with competition rules and with more general business ethics rules, are at the core of our Code of Ethics. (See chapter 3 of our Universal Registration Document, section “General control environment”).