RUBIS - 2019 Universal Registration Document

4 CSR AND NON-FINANCIAL INFORMATION - Working responsibly and with integrity

4.4 Working responsibly and with integrity

Operating its businesses responsibly and with integrity is a key issue for Rubis in terms of fulfilling its commitments and protecting its image, its reputation and its employees. The Group is built on values that have fashioned its culture and driven its success: integrity, respect for others, professionalism and trust are all principles that the Group aims to apply across all its activities to ensure its sustainability. These internal principles, rooted in its strong corporate culture, also encourage employees to become involved in the social and economic fabric surrounding them, by adopting responsible and supportive behavior.

Due to the fact that it operates on an international level in 40 or so countries in Europe, the Caribbean and Africa, the prevention of corruption is a major issue for the Group (section 4.4.1.1). The Group is also endeavoring to extend its principles

of responsibility to its value chain and to gradually introduce a responsible purchasing policy with the aim of common standards of exemplary actions (section 4.4.1.2). Lastly, the Group’s subsidiaries attach great importance to dialog with stakeholders and encouraging

momentum in the regions where they operate, both in terms of the economy and employment and in terms of culture and “living together” (section 4.4.2).

4.4.1 RUBIS’ ETHICS POLICY Ethics is seen as one of the Group’s assets, key to its reputation and loyalty. Integrity is one of the central pillars of the Group’s ethics approach (section 4.4.1.1), as is the Group’s commitment to respecting its employees’ fundamental rights (section 4.4.1.2).

• compliance with rules regarding health and safety conditions at work, as well as those pertaining to environmental protection; • management of relationships with external service providers; • requirements in terms of the reliability, transparenc y and auditabilit y of accounting and financial information; • protection of the Group’s image and reputation. In each of these fields, Rubis details the overall principles to be adhered to by employees in performing their duties. This Code of Ethics is given to new arrivals. Subsidiaries organize training sessions to explain its contents and to answer employee questions. The Compliance and CSR Department, within the Rubis Corporate Secretariat, is the point of contact for subsidiaries and employees when it comes to ethical issues.

an ethical framework for all the Group’s subsidiaries so that its rules of conduct are shared and respected by all. This Code of Ethics (accessible to the general public on the Group’s website: www.rubis.fr) lays down the values that Rubis considers fundamental: • compliance with all applicable laws and regulations wherever the Group operates; • f ight again s t cor r uption, f r aud, misappropriation of funds and money laundering; • prevention of conflicts of interest; • c omp l i a n c e w i t h c omp e t i t i o n , confidentiality and insider trading rules, as well as with specific laws relating to war and/or embargo zones; • respect for people, including fundamental rights and human dignity, protection of privacy, as well as the fight against discrimination and harassment;

4.4.1.1 FAIR PRACTICES

“Personal integrity is key to ensuring exemplary collective behavior. It is a safeguard against any wrongdoing that could be harmful to the Group, to employees, to business relations or to any other external public or private operator.” Gilles Gobin and Jacques Riou, Rubis Group Managing General Partners Extract from the Code of Ethics RUBIS’ CODE OF ETHICS Collective and individual commitment is key to adopting ethical behaviors in line with the Group’s values. Rubis has formalized

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