PREAMBLE
The Haulotte Group’s policy is to carry out its business successfully while upholding the highest ethical standards and in full compliance with all applicable legal provisions.
Our Group’s culture is based on the recently reaffirmed values that guide our behavior both internally and towards our customers and suppliers:
- Respect,
- Commitment,
- The quest for Performance.
Corruption is illegal and entirely contrary to the values of the Haulotte Group. Consequently, we are committed to fighting against all forms of corruption within our entities and subsidiaries. As a responsible company, the Haulotte Group therefore strictly prohibits its employees from engaging in any act of corruption, whatever the form or objective, in accordance with the following code of conduct.
While not exhaustive, this code aims to specify to employees the different areas and circumstances in which these principles apply and the behavior to adopt to prevent any risk of corruption and influence peddling.
Group employees are required to comply strictly with these standards in the course of the tasks entrusted to them by the company. The belief that one is acting in the interest of the Group cannot justify behavior that conflicts with the provisions described. Managers must inform their employees of the content and requirements of this code and ensure that it is applied.
Any questions relating to this code of conduct can be addressed to the Group’s legal department.
I would like to thank all Haulotte Group staff for striving to fully familiarize themselves with and implement this code of conduct issued by the senior management of the Group.
Alexandre Saubot
Chief Executive Officer
ANTI-CORRUPTION CODE OF CONDUCT
The Haulotte Group has chosen to adopt the Middlenext anti-corruption code, which is freely available on the website www.middlenext.com
This code is an integral part of the company’s rules and regulations. It applies to all Haulotte Group employees.
I - FRAMEWORK AND SCOPE OF APPLICATION
The code of conduct applies to all Haulotte Group employees.
All employees must behave in an exemplary manner within the company and not do anything contrary to the behavioral rules set out in this code.
Any questions from employees on the application or interpretation of the code should be raised with their line manager or sent to https://report.whistleb.com/haulottegroup
Definitions:
- Corruption is a behavior whereby a person (public official or private individual) offers, requests or accepts, directly or through an intermediary, a donation, offer or promise, gifts or benefits of any kind with a view to
performing, delaying or omitting to perform an act directly or indirectly within the framework of their duties in order to gain or maintain a commercial or financial advantage or influence a decision.
There are two types of corruption:
- Active corruption when the act of corruption is initiated by the person who corrupts
- Passive corruption when it is initiated by the corrupted person, i.e. the person who performs or does not perform an act in exchange for consideration.
Corruption can take many forms under the guise of common business or social practices such as invitations, gifts,sponsorship, donations, etc.
- Influence peddling: a person cashing in on their position or influence, real or supposed, to influence a decision to be made by a third party. It involves three operators: the beneficiary (people who provides advantages or gifts), the intermediary (people who use the credit they enjoy due to their position) and the target person who holds the decision-making power (public authority or administration, magistrate, etc.…).
Principle and rules
Haulotte Group employees must not commit acts of corruption and must not use intermediaries, such as agents, consultants, advisors, distributors or any other business partners, in order to commit such acts.
If an employee is faced with a proposal, they must ask themselves:
- Does it comply with the laws and regulations?
- Does it comply with this code of conduct and the interest of Haulotte?
- Is it free of self-interest?
- Would I be uncomfortable if my decision were made public?
If an employee faces a risk of corruption in the course of their business, they can report it by following the whistleblowing procedure attached to the company rules and regulations.
Specific rules for public officials
‘Public official’ means a person in a position of public authority, entrusted with a public service remit or elected to public office, on their own behalf or on behalf of a third party.
Corruption of a public official is subject to harsher sanctions. Any relationship with a public official must comply with the regulations governing it. If not prohibited by law, any benefit granted to a public official must be completely transparent to the company and subject to the prior consent of management.
Gifts and invitations
Gifts are benefits of any kind, given by someone as a token of gratitude or friendship, without expecting anything in return.
Gifts are benefits of any kind, given by someone as a token of gratitude or friendship, without expecting anything in return.
Offering or being offered meals, accommodation or entertainment (shows, concerts, sports events, etc.) is considered an invitation.
Gifts may amount to or be seen as acts of active or passive corruption. Care must be taken with regard to gifts, displays of courtesy or hospitality and invitations to events that help to build good relationships but may be considered as a means of influencing a decision, or favoring a company or an individual.
Donations to charities or political organizations
Gifts and donations are benefits given in the form of money and/or contributions in kind. They are earmarked for a specific purpose such as research, training or the environment (sustainable development), for charitable or
humanitarian purposes.
Gifts and donations are benefits given in the form of money and/or contributions in kind. They are earmarked for a specific purpose such as research, training or the environment (sustainable development), for charitable or
humanitarian purposes.
Requests for gifts, donations or contributions must be carefully considered, particularly those made by persons in a position to influence the company’s activities or who could benefit personally if the donation were made.
Requests for donations must be approved in advance by a line manager, who must be at least a direct subordinate of a member of the Executive Committee and subject to the rules of delegation.
Any political contribution, whether monetary or otherwise, aimed at supporting political parties, politicians or political initiatives, must be expressly authorized by Alexandre Saubot, in his capacity as Chief Executive Officer of the Haulotte Group.
Sponsorship
Through sponsorship, Haulotte seeks to provide financial or material support to projects or social, cultural or sporting activities in order to communicate and promote its values.
Through sponsorship, Haulotte seeks to provide financial or material support to projects or social, cultural or sporting activities in order to communicate and promote its values.
This must be done without seeking a specific advantage from the beneficiary other than the promotion of the company’s image.
Requests for donations must be approved in advance by a line manager, who must be at least a direct subordinate of a member of the Executive Committee and up to a limit of €50,000 per year, subject to the rules of delegation.
Facilitation payment
Facilitation payments are unofficial payments (as opposed to legitimate and official duties and taxes) made to facilitate or speed up administrative formalities such as applications for permits, visas or customs clearance.
Facilitation payments are unofficial payments (as opposed to legitimate and official duties and taxes) made to facilitate or speed up administrative formalities such as applications for permits, visas or customs clearance.
Haulotte does not accept ‘facilitation payments’ unless there are compelling reasons to do so (e.g. the health and safety of an employee)
Monitoring of third parties (suppliers, partners, customers)
Monitoring applies to third parties, natural or legal persons, with whom the company interacts and who may in some cases pose a specific level of risk with regard to corruption.
The following are considered third parties: business partners, suppliers, service providers, agents, customers, intermediaries, etc.
Monitoring applies to third parties, natural or legal persons, with whom the company interacts and who may in some cases pose a specific level of risk with regard to corruption.
The following are considered third parties: business partners, suppliers, service providers, agents, customers, intermediaries, etc.
Haulotte strives to ensure that third parties respect these principles and values and to carry out appropriate checks, if necessary.
Conflicts of interest
Conflicts of interest arise from any situation in which employees’ personal interests conflict with their duties or responsibilities.
Conflicts of interest arise from any situation in which employees’ personal interests conflict with their duties or responsibilities.
If circumstances give rise to a potential or proven conflict of interest, the employees concerned must report it.
Accounting entries/internal control
Haulotte ensures that its accounting departments and/or internal and/or external auditors are alert to the concealment of acts of corruption in the books, records and accounts when carrying out their checks.
Haulotte ensures that its accounting departments and/or internal and/or external auditors are alert to the concealment of acts of corruption in the books, records and accounts when carrying out their checks.
Persons carrying out accounting control tasks (audits, certification of accounts) must be particularly vigilant with regard to the accuracy and reliability of accounts.
II – SCOPE OF APPLICATION
3-1 Training
Employees are required to read this code carefully and participate in training sessions organized by Haulotte to raise awareness of the fight against corruption. New employees are made aware of this from their first day of employment through the e-learning available on Haulotte Academy.
Employees are required to read this code carefully and participate in training sessions organized by Haulotte to raise awareness of the fight against corruption. New employees are made aware of this from their first day of employment through the e-learning available on Haulotte Academy.
3-2 Reporting of non-compliant practices and protection of whistle-blowers
By following the procedure set out by Haulotte in the company rules and regulations, any employee can express doubts and/or ask questions to their line manager and/or point of contact:
By following the procedure set out by Haulotte in the company rules and regulations, any employee can express doubts and/or ask questions to their line manager and/or point of contact:
- If they face a risk of corruption and/or a situation jeopardizing their probity,
- If they believe in good faith that a violation of the code has been, is in the process of being or may be
- committed,
- If they discover that someone is the subject of reprisals for submitting a report in good faith.
Please refer to the whistleblowing procedure set out in the company rules and regulations (see Chapter 4, article 19)
Sanctions in case of violation of this code
In the event of non-compliance with the rules, employees will be held personally liable and will be subject to sanctions,
including criminal penalties under the applicable law.
In the event of non-compliance with the rules, employees will be held personally liable and will be subject to sanctions,
including criminal penalties under the applicable law.
- The company undertakes to:
- Consider all reports;
- Investigate alerts effectively;
- Assess the facts objectively and impartially;
- Take corrective action and appropriate disciplinary sanctions.
Implementation: responsibility and monitoring
The onus is on all employees to implement the code as part of their responsibilities relating to their duties.
The onus is on all employees to implement the code as part of their responsibilities relating to their duties.
The company carries out regular checks (internal audits, accounting controls, etc.) to verify the compliance of practices.
The governance bodies of the Haulotte Group regularly review the monitoring of implementation and the following up of alerts