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;
- accounting audits integrated into the Group’s internal control rules to prevent and detect acts of corruption and fraud;
an employee training programme, revised in 2018, providing each employee with a training track tailored to their level of exposure to corruption risk. In 2018, a total of 4,563 individuals had enrolled in the new e- learning training module;
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.