1
Exemplary management
Every member of the Executive Committee has agreed to roll out the Ethics and Compliance Programme throughout their scope of responsibility in an engagement letter to the Chairman.
2
Independent and accessible contacts
The Ethics Director of Groupe ADP reports directly to the CEO. The Ethics and Compliance Contacts have been appointed at the subsidiaries and report to senior management. They are available to all employees by request.
3
The spread of an Ethics and Compliance culture
Groupe ADP formally established codes of conduct (in France and abroad) based on common rules to follow, illustrating them with best practices, things to be aware of and prohibited behaviours.
Each of the Group’s employees is further encouraged to adopt best practices via e-learning. Awareness-raising measures are also carried out in person.
4
A whistleblowing system
During the program’s roll out, all employees are encouraged not to take on difficult situations by themselves. Their primary contact is their manager.
As soon as deemed necessary, employees can reach out to their Ethics and Compliance Contact directly.
The whistleblowing system is accessible at all times from the intranet or on the internet by clicking on the following link: https://report.whistleb.com/en/adp.
5
Prevention and detection
Ethics and Compliance risks are included in the Group's risk map.
Procedures help employees learn how to use best practices on a daily basis. These procedures safeguard against the major risks to which Groupe ADP is exposed, notably corruption, bribery, invitations, conflicts of interest, facilitation payments, third-party evaluations and more.
They are disseminated and accessible to all employees via the intranet.
In addition, security checkpoints are established to detect incidents and ensure that the program is properly rolled out.
6
Monitoring of the program’s progress at the meetings of the following
• the Executive Committee: information biannually
• the Works Committee, notably regarding the whistleblowing system
• the Board of Directors and its Audit and Risks Committee: information biannually
• For the subsidiaries, specific monitoring is carried out by the Boards of Directors on which ADP sits.