CODE OF ETHICS
The Code of Ethics is the reference document to inspire Bureau Veritas choices
and to guide day-to-day actions. Since its fi rst issue it has been approved and is fully
supported by Bureau Veritas Board of Directors.
The Code of Ethics aims to help to understand what is expected of each Bureau Veritas employee by setting out key principles and through practical day-to-day examples. It is a guide to the way we should think, behave and interact with people around the world every day.
It is vital that every Bureau Veritas employee acts in compliance with the Code of Ethics. We are all responsible for making compliance a vital part of our business process and future success, in order to preserve and enhance the reputation of Bureau Veritas as a socially responsible company.
Take the time to read carefully, learn and implement the Code of Ethics in your day-to-day activities and seek immediate assistance from your direct line manager, your Compliance Offi cer or from the Group Compliance Offi cer when you have any concern or question about the application of the Code of Ethics.
ETHICS GOVERNANCE AND ORGANIZATION
ETHICS KEY PRINCIPLES
RIGOROUSLY APPLY OUR CODE OF ETHICS
Our development and our growth are also built on our core principles, which apply, without exception, to all Bureau Veritas directors, officers, employees and business partners (including our intermediaries, joint venture partners, sub-contractors, agents and suppliers). We also take steps to evaluate and mitigate potential compliance risks presented by our client relationships.
"We are all responsible for compliance."
OUR CONDUCT MUST ALWAYS BE GOVERNED BY THE PRINCIPLES OF INTEGRITY, TRANSPARENCY, HONESTY AND FAIRNESS
"No business objective justifies a deviation from the rules."
Many activities are not the subject of laws, regulations or other mandatory requirements. In such cases, principles of integrity, transparency, honesty and fairness will conduct and influence our course of action, whenever laws or regulations do not clearly state what we should do. It is the responsibility of each Bureau Veritas employee to examine each situation against this standard.
WE ARE COMMITTED TO FULLY COMPLY WITH THE LAWS AND REGULATIONS OF THE COUNTRIES IN WHICH WE OPERATE
The reputation of Bureau Veritas for integrity is built on its respect for, and compliance with, those laws, regulations or similar mandatory requirements, that apply to the conduct of its business.
"Never act in a manner which may tarnish the reputation of Bureau Veritas, or which could involve Bureau Veritas in unlawful practices or raise doubts about its ethical integrity."
Bureau Veritas is fully committed to fighting all forms of corruption (including infl uence peddling) in every country in which it operates.
"Be committed to eradicate all forms of bribery and corruption."
In particular, all Directors, officers, and employees of Bureau Veritas are strictly prohibited from giving or accepting bribes, including by:
- Promising, off ering or providing, whether directly or indirectly, anything of value to any person in order to induce the individual to misuse his/her position to provide a benefit for Bureau Veritas (for example, a contract award or favorable government decision), or as a reward for already having done so. A thing of value may include any monetary payment, gift , hospitality, donation, favor, service, or other benefit;
- Soliciting or accepting, whether directly or indirectly, in the course of our duties, anything of value provided by a person seeking to obtain an improper benefit or advantage (for example, a favorable test result in connection with a testing, inspection, or certification process, or a contract to provide goods or services to Bureau Veritas).
ETHICS POLICIES AND RULES
BEING FAIR: Integrity
INTEGRITY OF OUR SERVICESI
Our work must be carried out in a professional, independent and impartial manner
EXAMPLES OF POTENTIAL UNETHICAL BEHAVIORS DURING INSPECTIONS:
- Misrepresentation of data.
- Intentionally taking incomplete or fraudulent samples.
- Bribery/kickbacks (a payment made to, or received from a party, made for the purpose of improperly securing favorable treatment).
- Not taking all temperatures properly (e.g.: taking one temperature and assuming the others are the same – if the temperature is off just a couple of degrees it could drastically aff ect total volume).
- Not regauging (e.g.: skipping second (verifi cation) gauging – carrying over a gauge or not re-gauging because it was only a few hours ago can lead to huge discrepancies).
- Using others data or results.
- Imply that 100% of items have been inspected if work was sample based.
- Taking all the samples from the same tank or compartment (what if you are dealing with
different products or diff erent qualities?).
- Not taking samples properly (e.g.: grabbing a top sample instead of a upper/middle/lower – a top sample may not be a good representation of the entire product because tank or compartment may be stratifi ed).
EXAMPLES OF POTENTIAL UNETHICAL BEHAVIORS IN LABORATORIES:
- Fabrication of data (e.g.: Deletion of data – removal of existing data/Data creation).
- Misrepresenting quality control samples.
- Not following SOPs (Standard Operating Procedures) or industry standards.
- Modifying samples to alter characteristics.
- Manipulating analytical results.
- Substituting samples, files, data.
- Falsifying records of analytical equipment readings.
- Cherry-picking results.
INTEGRITY OF DOCUMENTS AND INFORMATION SUPPLIED
Each Bureau Veritas employee is personally responsible for all the information he/she provides and for all the documents he/she produces, such as, but not limited, to reports, test results and certificates.
INTEGRITY AND INTERNAL CONTROL OF FINANCIAL AND ACCOUNTING INFORMATION
All financial and accounting information must be duly and correctly recorded in Bureau Veritas’ books and accounts and may in no case be the subject of incomplete, erroneous or fraudulent treatment.
CONFLICT OF INTEREST
It is vital for Bureau Veritas employees to be independent and to report any commitment or link which may create a potential conflict of interest.
EXAMPLES OF SITUATIONS THAT WE REGULATE:
To offer or to influence an off er of a job to a family member or to a person with whom you have a close personal relationship, without first having obtained the approval of the person to whom you report.
To have a family or a close personal relationship with a person who is in your reporting line without having informed in writing both the person to whom you report and your Human Resources leader.
To have a family or close personal relationship with a person associated with a Bureau Veritas business partner, client, or competitor (in any case within the area of business in which you work), without having informed in writing both the person to whom you report and your Human Resources leader.
To solicit or accept, whether directly or indirectly, a personal gain granted to you as a Bureau Veritas employee (other than modest gift s and hospitality in accordance with the principles articulated in our Gift s and Hospitality Policy).
To accept appointments outside of Bureau Veritas while employed by Bureau Veritas,
without fi rst having obtained the approval of the person to whom you report.
To acquire, directly or through relatives, friends or intermediaries, an interest in a competitor, supplier or client (or to fail to disclose such existing interests), except as set forth in Bureau Veritas’ internal procedures.
To use any goods or resources of the company that employs you, for your own personal use.
BEING ACTIVE AGAINST CORRUPTION
We categorically reject all forms of bribery, corruption, and influence peddling, and we are committed to full compliance with all applicable laws and prohibitions of such behavior.
EXAMPLES OF CORRUPTION OR INFLUENCE PEDDLING (THIS LIST IS NON-EXHAUSTIVE):
- A Bureau Veritas employee makes a payment to an individual who is on the tender committee of a prospective client, in exchange for confidential tender information.
- A Bureau Veritas Intermediary engaged to liaise with tax authorities makes a payment to a tax offi cial in exchange for a reduction in Bureau Veritas’ tax liability and includes the payment on its invoice to Bureau Veritas as a “government relations fee”.
- A Bureau Veritas employee involved in a certifi cation engagement accepts an all-expenses-paid trip to the Caribbean from the client in exchange for providing a favorable result.
- A customs agent engaged by Bureau Veritas is unable to obtain a customs clearance for laboratory supplies that Bureau Veritas is seeking to import, due to an error in the required paperwork. The agent makes a cash payment to a customs offi cial in exchange for a release of the shipment.
- A Bureau Veritas employee colludes with a supplier to inflate the value of the payments Bureau Veritas makes to the supplier and the supplier pays a portion of the additional profi ts directly to the Bureau Veritas employee.
- A Bureau Veritas employee has a contact who is a close friend of a government official and the government official is in a position to influence a regulatory decision in favor of Bureau Veritas. The employee makes a payment to the contact in exchange for his exerting influence over the government official to make a decision favorable to Bureau Veritas.
GIFTS HOSPITALITY AND ENTERTAINMENT RECEIVED
No gift, hospitality or entertainment should be accepted if they influence improperly or create the appearance of improper influence on business decisions.
GIFTS HOSPITALITY AND ENTERTAINMENT GIVEN
Although giving business gifts hospitality and entertainment may seem customary in many parts of the world, they are the subject of strict controls because they could be perceived to be, or, could actually be, bribes to get someone to do something he or she should not, or, to get someone not to do something he or she should do, in the course of his/her employment.
CHARITABLE DONATIONS SPONSORSHIP AND POLITICAL CONTRIBUTIONS
In certain circumstances the Group wishes to have a positive impact on the communities in which it operates.
DEALING WITH THIRD PARTIES
Through antibribery and anti-corruption policies and procedures we monitor the selection and the ethical behavior of our Business partners (i.e., intermediaries, joint venture partners, sub-contractors, agents, and suppliers), including by requiring them to comply with our Code of Ethics and Business Partner Code of Conduct, which includes requirements to comply with local and international laws prohibiting bribery, corruption, and influence peddling, and by monitoring payments to Business partner s to mitigate the risk of improper payments being channeled through them.
BEING COMPLIANT: Conformity
FAIR BUSINESS CONDUCT AND COMPETITION LAW COMPLIANCE
Bureau Veritas marketing shall be conducted in a manner that is truthful, is not deceptive, that will not mislead or be likely to mislead and that is consistent with applicable laws.
IN CASE OF DOUBT:
An Employee shall seek guidance from his/her line manager (or from the line manager of his/her line manager if more appropriate) who will be responsible for further actions to be taken. If necessary he/she may in turn seek guidance from his/her line manager or directly from the Group Compliance Officer. Any Employee being aware of any violation of these rules shall immediately inform his/her line manager (or the line manager of his/her line manager if more appropriate) who will be responsible to take any appropriate actions and then report to his/her own line manager or directly to the Group Compliance Officer or use the Bureau Veritas Whistleblower Program.
INTERNATIONAL ECONOMIC SANCTIONS AND EXPORT CONTROLS
Bureau Veritas upholds the highest standards in how it runs its activities, notably by complying with international laws and regulations. The reputation of Bureau Veritas for integrity is built on its respect for, and compliance with, those laws, regulations or similar mandatory requirements that apply to the conduct of its business.
Failure to comply with applicable laws and regulations may result in very signifi cant disciplinary, civil and criminal sanctions. In case of doubts or concerns, Employees shall seek advice from their Operating Group Legal & Compliance department. If necessary, the Operating Group Legal & Compliance department will seek guidance from the HO Legal department and/or Group Compliance Officer.
Employees aware of actual or potential breaches of Economic Sanctions shall immediately inform their Operating Group Legal & Compliance department, who will be responsible for taking appropriate preliminary actions and reporting the alleged breach to the HO Legal department and/or Group Compliance Officer.
PROTECTION OF INFORMATION
Information (such as technical, commercial and financial information, data, including personal data, software, methodologies, trade secrets, databases, inventions, know-how and related intellectual property rights) is an asset that is as valuable as physical assets (such as buildings and inventory).
INSIDE INFORMATION AND INSIDER TRADING RULES
COMMUNICATION WITH MEDIA AND INVESTORS
There are a number of mandatory mechanisms, including key internal procedures, systems and controls, relating to our obligations concerning inside information and the prevention of insider dealing. This includes the requirement for the correct identification of inside information; preventing the dissemination of inside information; and the prohibition on dealing whilst in possession of inside information, in the shares (options, or other securities), of the company to which the inside information relates.
BEING RESPONSIBLE: Corporate Social Responsibility
Bureau Veritas is committed to support and respect the protection of internationally declared human rights irrespectively of the country we work in or the activity we do.
HEALTH AND SAFETY
"Avoid any situation which may result in an accident."
Occupational health and safety risk is unique at Bureau Veritas insofar as most of the Group’s inspection services are conducted at the premises of its clients or their suppliers, at sites that Bureau Veritas does not necessarily know and which are not always free from risk. This increases the risks to which the Group’s employees are exposed, particularly when the sites in question do not have their own safety/security plans.
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Bureau Veritas Code of Ethics was approved by the Ethics Committee
and by the Board of Directors of Bureau Veritas. It replaces the previous 2012 version.
Bureau Veritas’ Code of Ethics is aligned with the requirements of the TIC/IFIA Compliance Code (www.tic-council.org ) which itself reflects the requirements of Transparency International & Social Accountability International countering bribery worldwide
Sixth version – December 2019 updated August 2020 – Copyright © 2019 Bureau Veritas – All rights reserved.