E&C terms definitions
Set of reporting channels that any employee or any person or third party in relationship with Alstom may use, in accordance with the laws and rules applicable in the country where they live or work, if they have reason to suspect a violation of anti-corruption, competition and securities or accounting laws and regulations.
Access the Alert Procedure
A sum of money that is paid illegally, above the agreed price, to obtain or conclude a deal. Bribery is a form of corruption that Alstom battles and firmly condemns.
Gift of money, goods or services to an organisation of charitable nature. Charitable contributions are a commendable way of being associated with environmental, cultural, educational or other charities that are not for profit. Contributions to a charitable organisation can be revealed to be, or be considered as, direct or indirect corruption, or raise other issues such as conflict of interest, fraud, misuse of public funds or money laundering. Consequently, Alstom employees must be highly vigilant.
Conflict of interest
A conflict of interest stems from a situation in which a person employed by a public or private organisation owns private interests which could influence, or seem to influence, the performance of his or her official duties. Personal interest can be direct or indirect; concern the individual alone or their close relations; or be of economic, financial, political, professional, denominational or sexual order.
To protect employees themselves as well as Alstom from real or apparent conflicts of interest, employees must not make or hold investments in any of Alstom's suppliers, clients, competitors or consultancies, nor in any of the Alstom's partner companies if these interests are likely to influence business decisions made in Alstom's name. An employee must not work directly with a business partner – client, supplier, agent, consultant or other third party – if he, or any member of his family, holds interests in these companies. Should the case arise, the employee must inform his or her unit leader of the situation with transparency and obtain written approval.
Corruption & Bribery
Can take many forms that vary in degree from the minor use of influence to institutionalized bribery. Transparency International's definition of corruption is "the abuse of entrusted power for private gain."
For further information, please visit the 10th Principles of the United Nations Global Compact.
Act by which a public official misappropriates, for their own benefit or the benefit of others, goods, money or valuables that belong to the State or to an individual, and that have been entrusted to them, in line with their function, to manage, keep or other (United Nations Convention against Corruption).
Ethics & Compliance Ambassador
An employee that volunteers to promote a culture of integrity. He/she organises awareness sessions and is point of contact for E&C questions. The E&C Ambassador comes mainly from Legal, Human Resources or Finance functions.
A breach of confidence that is made against the law or rules and that harms the rights of others.
Any payment, gratuity, bonus, present, advantage (pecuniary or not) that is given or received. In business practices, the term 'gift' includes:
- Presents, goods, merchandise, equipment;
- Personal discounts, commissions or other forms of remuneration;
- Cash, gratuities, payments, loans or advances, or cash equivalencies such as gift certificates, vouchers or gift cards;
- Stock options, shares, equity securities;
- Free services such as insurance, school fees, repairs, building-improvement or any preferential treatment.
In some cultures, good business relations may sometimes involve the exchange of symbolic gifts. However, these gifts could be interpreted as a means (intentional or not) to influence a decision or a result. 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 dealings with Alstom, if the ultimate goal is to influence business decisions.
Some employees have access to information that could influence the Alstom's share value, options or other assets if they are made public.
When someone obtains from someone else an invitation to participate in an activity that may have an indirect link with business matters. A few examples from a business perspective: meals, hotel accommodation, transport, conferences, conventions, invitations to sports, cultural or social events.
In certain cultures, good business relations can include an exchange of invitations. Invitations can however be interpreted as a real or intentional form of influence over decisions or results and it is against the rules for any Alstom employee to offer, accept or authorise a member of their family to accept invitations or any special treatment on behalf of anyone that has business relations with Alstom, if the intention is to influence a business decision.
Against the rules or laws. Irregularity can be intentional or be the result of ignorance.
A punishable act of greed made while performing a duty, a job or the fulfilment of a mandate.
Money laundering is a crime that consists of hiding funds issued from illegal activities. According to anti-money-laundering law, Alstom choses business partners with proven track records. Employees must be vigilant to detect any irregularity regarding payments, especially with partners whose business practices are suspicious.
Any payment, gift, loan, differed gift, deposit of money, financing of political meetings, events or campaigns, goods, services or any other participation of value that is made in favour of a political party, a political organisation or a candidate. In principle, Alstom's policy is not to give any contribution, financial or in nature, to organisations or political parties, or to political figures, even if this is legal in some countries. Indeed, even if they are legal in some countries, these contributions can lead to abuse or seem to reflect poor practice.
Sponsorship is defined as providing goods or money to pay some or all of the costs of a commercial organisation's events – such as seminars, conferences, sports, arts or shows – in order to benefit from any business potential associated with these activities. Sponsorship is part of the company's marketing and communications strategy. There are inherent risks to sponsorship: much as for charitable contributions, sponsorship can be used to hide an unfair advantage. It can be misappropriated and used for personal profit. This risk is accrued when sponsored events or activities are controlled by political figures, public officials or their relations, or should a political figure or public official profit indirectly from the sponsorship. Consequently, Alstom asks its employees to be highly vigilant in the matter.