Alstom complies with all laws and regulations, as well as the international standards that apply to the conduct of business in all countries. Some practices that occur in business environments can put Alstom and its employees at risk. They require clearly defined instructions to guide any of the employees in complying with the law and respecting Alstom's values and rules.
Gifts & Hospitality
In some cultures, good business relations may sometimes involve the exchange of symbolic gifts and hospitality.
Offering gifts and hospitality, especially with a public official, can appear as bribery. The acceptance or offering of gifts is also related to the issue of conflicts of interest and can expose Alstom and its employees to accusations of unfairness, partiality or deceit.
Alstom employees must not offer, accept or authorise a family member or relative to accept gifts, money, loans, invitations or any other form of special treatment from anyone involved in business with Alstom, if the ultimate goal is to influence business decisions.
Employees may accept or offer, on behalf of Alstom, an occasional business meal invitation or an occasional non-pecuniary symbolic gift of low value if it can be reciprocated on another occasion. Any employee required to offer or to accept a gift or invitation of value as a result of protocol, courtesy or other reasons must first inform his or her Unit manager and the Legal department.
Political contributions are often subject to national laws and vary from country to country.
Even when legally permitted, such contributions can be a source of abuse or otherwise perceived as a questionable practice. Political contributions can be used to disguise an improper advantage in order to obtain or retain a business. In simpler words, a political contribution can be or appear as bribery, direct or indirect.
Alstom's policy is not to make contributions, financial or in kind, to political parties or organisations, or to individual politicians.
Alstom respects the rights of its employees to participate as individuals in their community and civic affairs. This must be done at a personal level, in their own time and at their own expense, consistent with applicable laws.
Employees need to carefully separate their own political activities from Alstom activities and avoid any conflict of interest.
Charitable contributions are commendable ways to be associated with environmental, cultural, educational, welfare or other non-profit making activities.
Charitable contributions can be used to disguise an improper advantage. They can be diverted from the purpose for which they have been made and be used for private gain. This risk is greatest when charitable organisations are controlled by politicians, public agents or their relatives, or when a politician or a public official benefits indirectly from the charitable contribution.
Charitable contributions made in the Alstom’s name or using its financial resources are permitted as long as they comply with applicable laws and regulations. Contributions should have relevance to the community in which Alstom operates and must effectively serve the purpose of the charitable organisation concerned while enhancing Alstom’s reputation as a good citizen. Charitable contributions must not be made without prior written approval and must be properly recorded.
Alstom sponsors cultural and sporting events as well as conferences every year.
Sponsorship allows a company such as Alstom to strengthen its notoriety by associating its image with events that reflect the Alstom's values.
Like charitable contributions, sponsorship can be used to disguise an improper advantage. It can be diverted from the purpose for which it has been made and be used for private gain. This risk is greatest when sponsored events or activities are controlled by politicians, public agents or their relatives, or when a politician or a public official benefits indirectly from the sponsorship.
Sponsorship is part of the marketing and communication strategy. It is authorised in compliance with applicable laws and regulations and solely within the framework of the Alstom's communication policy.
Ethics & Compliance Principles
In addition to our Code of Ethics and to the Instructions that are designed to prevent any situation that could jeopardise the company's integrity, Alstom applies Ethics & Compliance Principles in all its operational procedures and in particular to managing conflicts of interest, dealing with sales partners and dealing with consulting companies, the laws and regulations and solely within the framework of the Alstom's communications policy.