This Non  Corruption Codex is an integral part of internal regulations (hereinafter “Internal Regulations”).

This Non Corruption Codex applies to all Employees, regardless of their functions. All of them must comply with all of the obligations set out therein, under penalty of sanctions.

It is also up to the Employees to ensure that:
– when selecting their producers, artists, distributors, suppliers, customers, service providers, intermediaries and, generally, all our co-contractors (hereinafter “Business Partners”), they comply with the principles set out in this Anti-Corruption Code
– that all contracts with Business Partners include anti-corruption provisions

This Non corruption Codex does not purport to be exhaustive and is not intended to cover all situations that Employees may face. It sets out the principles that must govern their decisions. It is up to everyone to read it carefully to apply the rules and to exercise judgment and good sense in the face of the various situations that may arise.

Corruption is said to be public when it involves persons performing a public service. The concept of Public Official must be interpreted broadly and refers to any person who is a custodian of the public authority, entrusted with a public service mission or entrusted with elected public office. Any other person considered as such under the national law of a country in which we operates shall also be classified as a Public Official.

Corruption is private when it concerns natural or legal persons working in the private sector. The offence of corruption is established by the mere promise of an undue benefit, even if this benefit is ultimately not granted. Offences of active corruption (conferring an undue benefit on a person) and passive corruption (receiving an undue benefit) are criminally sanctioned.

Influence peddling is defined as offering, requesting, accepting or handing over any benefit whatsoever to a person so that he or she abuses his or her actual or supposed influence in order to obtain from a public authority or administration honours, jobs, contracts or any other favourable decision. It involves three players: – the person who provides benefits or gifts; – the person who uses the recognition that he has as a result of his position; – the person who holds the decision-making power (public authority or administration, magistrate, etc.). Offences of active and passive influence peddling are sanctioned by the Criminal Code