CHARTER OF PROFESSIONAL CONDUCT OF THALES INTERNATIONAL OFFSETS.

Transcription

1 CHARTER OF PROFESSIONAL CONDUCT OF THALES INTERNATIONAL OFFSETS

2 2 FOREWORD As a global technology leader serving the public safety and security markets, Thales has made its commitment to corporate responsibility a central pillar of Group strategy. For several years, the cornerstone of this commitment has been the Thales Code of Ethics, which lays down rules of conduct applicable to all Group employees. Thales also subscribes to the United Nations Global Compact and its principles in the areas of human rights, labour, the environment and anti-corruption. In addition, the company applies the OECD Guidelines for Multinational Enterprises and its recommended practices on human rights, employment and industrial relations, environment, combating bribery, consumer interests, science and technology, competition and taxation. Accordingly, Thales applies these principles of responsible business conduct in all its operations, including the indirect offsets programmes (1) conducted by Thales International Offsets (TIO). The present Charter is a formal statement of the relevant rules of professional conduct that Thales International Offsets applies on a day-to-day basis as part of its commitment to transparency and disclosure. (1) These indirect offsets programmes are designed to foster economic returns to the purchasing country that are not directly connected to the contract including the offsets obligation.

3 3 RULES OF PROFESSIONAL CONDUCT 1 Scope TIO reports to the Group Financial Department and works primarily for Thales entities. Its activities are thus contingent upon the award of an export contract to one of the entities in the Group. TIO s countries of operation are all countries with which Group entities conduct commercial operations. 2 Commercial partners TIO s commercial partners may be industrial contractors, commercial intermediaries, introducing brokers, etc. In all cases, before any cooperation begins, TIO s commercial partners undergo a Level II or III evaluation by ADIT (ADIT is France s leading strategic analysis agency. Set up by the French State in 1992, it provides operational support, including due diligence services, to secure companies international development plans.) They all undertake to comply with international and national laws pertaining to international trade and to abide by the terms of the present Charter. 3 Indirect offsets programmes The indirect offsets programmes drawn up by TIO are governed by the rules imposed by client countries; the local authorities of these countries systematically check the eligibility of the offsets operations involved. For reasons of transparency, fi nal approval of these programmes is given by senior national bodies, often inter-ministerial committees with representatives of the ministries for defence, the economy and foreign affairs. The offsets programmes are therefore implemented in strict compliance with national law and standards of business ethics. 4 Payments Payments for services rendered under indirect offsets programmes approved by the local authorities in the countries concerned are only made upon presentation of the corresponding invoices and for the amounts specified in advance in a contract. TIO does not pay advances on invoices except when the practice is mandated by local regulations to meet pre-qualification requirements or against receipt of a bank guarantee. Waivers to this rule are only granted in exceptional cases and must be documented in a special report indicating the amounts involved.

4 4 All these operations are carried out responsibly by duly qualified experts. They are conducted in complete transparency with respect to the Group Financial Department and to the Group Audit and Internal Control Department. Finally, to make payments for the various services rendered, TIO uses reputable fi nancial institutions that are not domiciled in tax havens. 5 Application of rules of professional conduct The present Charter is applicable both to the legal entity TIO and to its employees. Bruno LALLEMENT Chief Executive Officer Thales International Offsets Dominique LAMOUREUX VP, Ethics and Corporate Responsibility Thales

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