A structured and enhanced “zero tolerance” anti- corruption policy
To prevent corruption and bribery, which represent a major risk for multinationals, Thales introduced a corruption risk prevention policy at the end of the 1990s that is constantly being improved. This policy is regularly evaluated and has been readjusted to take into account the entry into force in June 2017 of the Sapin II law, which relates to transparency,anti- corruption and the modernisation of economic activity. It is based on:
- principles clearly defined by the Chairman and Chief Executive Officer and shared with all employees;
- the publication and dissemination of a Code of Conduct – Prevention of corruption and influence peddling, defining the various types of behaviour to be prohibited;
- a corruption risk map, drawn up in accordance with the Group’s general methodology for mapping risks;
a system for evaluating third parties (mainly customers, suppliers, subcontractors and partners), including preventive measures proportionate to the risks (this process is renewed every three year, unless specific event require to renew it sooner).
This process includes various points of attention, including Sanctions check list, Analysis of links with Public Officials / Public Entities, Adverse media (digital press international, national, local), search on direct shareholder(s), search on ultimate beneficiary(ies), search on litigation / dispute resolution...;
- accounting audits integrated into the Group’s internal control rules to prevent and detect acts of corruption and fraud;
an employee training programme, providing each employee with a training track tailored to their level of exposure to corruption risk;
an extensive alert system that falls within the scope of France’s Sapin II law and Duty of Care law.
The main pillars of this anti- corruption compliance programme are integrated into the various operating processes of Thales’s Chorus 2.0 management system.
Our policy forbids the use of agents except in a limited number of countries, where the local laws strictly impose that a foreign company contracts with an act through a local "agent" for withdrawing tender documents and commercial proposals submissions in the name or on behalf of the said company.
Remuneration policy of business advisors
Remuneration of Business Advisors is systematically the subject of an analysis and justification memo. This point is, inter alia, verified twice a year by internal and external auditors. In addition, our policies and processes forbid the recourse to success fees alone.