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Our ethics

Alstom's ethical commitments

“Alstom’s reputation and integrity can be built only by continuously strengthening ethical rules and procedures. Our growth is underpinned and guided by our fundamental principles of integrity and transparency, applied scrupulously and without exception with regard to employees, shareholders, customers in the public and private sectors, suppliers, competitors and partners. Our Code of Ethics is essential and all employees, in their day-to-day work, need to observe the same rules of personal and collective conduct that define Alstom as an ethical company.”  Patrick Kron, Chairman & CEO

The Alstom Code of Ethics was updated in 2010 and issued in the main languages of the Group to all employees and to all our stakeholders worldwide.

The Code of Ethics:

• Provides official guidelines on key principles and commitments that must be met by individual employees and by the Group as a whole every day.
• Emphasises that the Group must fully comply with laws, regulations and requirements in all countries where it operates.
• Stresses the need for transparency, integrity and loyalty, as well as fair and honest behaviour in relations with customers, suppliers, competitors, shareholders, employees, governments, regulatory institutions and the public.
• Highlights our three fundamental rules with regard to competition law, prevention of corruption, and accuracy and disclosure of financial information.
• Introduces the Alstom Integrity Programme, implemented and monitored throughout the Group under the responsibility of the SVP Ethics & Compliance.
• Details the Alert Procedure which allows any employee to report violations of anti-corruption, competition and securities and accounting laws and regulations.

Alstom, an ethical company, with rules and control procedures at the best international standards

At the beginning of the 2000’s, Alstom put into place ethical rules which have been continually reinforced since then. These rules provide for the strict respect of laws and regulations in force in all countries where the Group operates, with prevention of corruption measures as a priority concern, and compliance with competition, securities or accounting laws and regulations. These rules also address the way Alstom deals with the relationship with governments and public authorities, customers, suppliers and sales consultants; export and trade controls; money laundering; conflicts of interest; gifts and hospitality; political or charitable contributions; sponsorship; protection of the environment; health and safety; security of employees; social relations; equal opportunity and diversity; career management of employees; data privacy; confidential information; intellectual property; use of communication resources; insider dealing; communication with the media and investors.

A constantly strengthened culture of integrity

Alstom has invested a great deal of effort in the deployment and integration of these ethics rules across the organisation. A Code of Ethics was produced in April 2007 and distributed to all employees throughout the world. Updated and containing more detailed information, it was re-issued in 14 languages at the beginning of 2010. The Code of Ethics booklet is included in the information pack given immediately to all new employees. Also available on Alstom’s intranet and public internet site, it is progressively being supplemented by very detailed guidelines for each topic, widely distributed to management. Furthermore, all 35,000 Alstom Managers are required to complete before September 2010 a compulsory online training course named “e-Ethics” available in 8 languages. Finally, the Group has implemented an Alert Procedure which allows any employee to report violations of prevention of corruption, competition and securities regulations, or accounting laws and regulations.

The Ethics & Compliance Department, in charge of the Alstom Integrity Programme, set up a network of approximately 200 Ethics & Compliance Ambassadors in all countries where Alstom operates. Recruited on a voluntary basis, these ambassadors (often the Country Presidents in charge of governance in their country and managers in the Legal, Financial or HR functions) are each charged with the deployment of ethics rules, using all appropriate means, including specific meetings, and ensuring the integration of these ethics rules in the day-to-day life of the Group.

A strict control of the contracts with external consultants

The measures regarding the prevention of corruption hold an important place in this plan. In addition to the constant familiarisation of the rules which is managed at an in-depth level with all concerned employees, mainly those in the sales force, the measures are founded on extremely rigorous processes concerning contracts with commercial consultants. Like all infrastructure companies operating in highly complex markets worldwide, Alstom may need to work with specialised commercial consultants who bring their particular knowledge to their market, with its own laws, regulations and decision-making process.

The Group’s commercial managers can use commercial partners that are approved beforehand by the Ethics & Compliance department only after a detailed assessment of the need to contract with them, a thorough due diligence audit (reputation, references, financial and banking check, …) and a verification of the compliance between the expected services and the level of the fees. Payments are only made after comparing the work implemented and the invoices presented. Moreover, the management of these payments is centralised through “Payment and Control” dedicated companies.

Ethics rules rated at the best international standard

To assess the relevance of these rules, Alstom called on the “Ethic Intelligence International” organisation to audit and validate its procedures governing relations with sales and marketing consultants and agents. The audit was conducted between September 2008 and March 2009 by the Swiss audit company, SGS, and a concluding report was issued by a pool of international recognised experts. The audit concluded that the rules and procedures implemented by the Group corresponded to international best practices both in definition and execution. As a consequence of this positive review, the Group was awarded a certificate on 12 March 2009, granted for two years.

04 May 2010