Ethics alert system, Code of conduct, Corruption, Conflicts of interest.
Ethics alert system.
In accordance with the Sapin II Act of 9 December 2016, reinforced by the Waserman Act of 22 March 2022, Altavia has set up a whistleblowing system in order to strengthen its ethical approach and enable everyone to play a part in risk prevention.
Scope of application
This system enables a wide range of stakeholders, including employees, clients and suppliers, to report in good faith and without financial compensation any behaviour that is contrary to the code of conduct.
The areas covered are varied, ranging from corruption and fraud to breaches of health, safety, the environment and human rights, harassment, discrimination and breaches of competition or data protection rules.
The person making the report may be a victim, a direct witness or have personal knowledge of the facts reported. Although the system excludes information protected by certain professional secrets such as national defence secrecy, medical secrecy or the secrecy of judicial deliberations, it complements existing whistleblowing channels and requires whistleblowers to provide evidence in support of their reports, while complying with the laws applicable in the country where they operate.
Procedure
In accordance with the Waserman Act, this system enables whistleblowers to make an objective and detailed report via the Whispli platform, with the option of remaining anonymous.
Whistleblowers receive an acknowledgement of receipt within 7 working days and a unique code to track the progress of their report in their personal Whispli space.
The alert is processed within 3 months, guaranteeing the protection of personal data and the anonymity of the whistleblower, while the person concerned is informed within a maximum of one month, without being able to access information about the person making the alert.
Depending on the seriousness of the facts reported, various measures may be taken, ranging from the strengthening of internal procedures to disciplinary sanctions or legal action.
Protection of whistleblowers
Whistleblowers will not be penalised for reporting an alert in compliance with the Sapin II Act of 9 December 2016. Enhanced protection measures have been deployed with the Waserman Act of 22 March 2022.
Any person who obstructs the transmission of a warning in any way whatsoever may be punished by up to one year’s imprisonment and a fine of €15,000.
If there is evidence of behaviour that does not comply with the law in the above-mentioned areas, this may give rise to disciplinary action, up to and including dismissal, and legal proceedings. Data relating to alerts will be retained or destroyed in accordance with legal provisions.
Alerts must under no circumstances be motivated by malice or bad faith, failing which disciplinary action may be taken.
In accordance with article 122-9 of the French Penal Code, whistleblowers are not criminally liable if they disclose a secret protected by law, provided that such disclosure is necessary and proportionate to safeguard the interests in question, and that it complies with the reporting conditions defined by the Sapin II law.
Whistleblowers are not civilly liable for damages caused by their reporting or public disclosure, if they had reasonable grounds to believe that such action was necessary to safeguard the interests at stake, in accordance with the conditions laid down by law.
Extensive protection is offered to whistleblowers against various forms of professional reprisal, including dismissal, demotion, reduction in salary, harassment and discrimination. This protection also applies to those involved in the investigation.
Details of the whistleblowing scheme and the procedure to follow are available on the Whispli ethical whistleblowing platform.
Find out more about our ethics alert policy ↗
Code of conduct.
Ethical behaviour is a fundamental commitment at Altavia. We maintain high standards of integrity and social responsibility.
At Altavia, we adhere to the values:
- The Universal Declaration of Human Rights (1948)
- The French Penal Code (1994)
- Conventions of the International Labour Organisation (1919)
- The provisions of the Labour Code (1910)
- The Sapin II anti-corruption law (2016)
- Waserman law (2022)
- The General Data Protection Regulation (RGPD) (2018)
We uphold these values and principles and ask our suppliers, service providers and business partners to respect them. The code of conduct sets minimum standards for fair, safe and healthy working conditions, prevention of corruption and responsible environmental management.
Discover our code of conduct ↗
Corruption.
At Altavia, we maintain the highest standards of ethics and integrity in all our operations. We have implemented an anti-corruption programme that complies with the requirements of the Sapin II law, reinforcing our commitment to integrity, transparency and ethics.
The Sapin II law on the fight against corruption and the modernisation of economic life is based on 8 main pillars: the code of conduct, the internal whistleblowing system, risk mapping, control procedures, third-party assessment procedures, employee training, the internal control and audit system and disciplinary sanctions.
We have adopted a zero-tolerance policy towards corruption. All our employees, as well as our business partners, are required to respect the behaviour described in the code of conduct.
We encourage an environment where ethics and honesty are paramount, and we take strict measures to ensure that these principles are respected in all our operations.
Conflicts of interest.
Our business partners, whether suppliers, customers, service providers or others, are required to comply strictly with our policy on conflicts of interest.
In our dealings with suppliers, we do not accept any special discounts or rebates from them on a personal basis.
Any activity that improperly promotes Altavia’s interests, such as illegally obtaining a contract, paying money to a private or public person, or to a public official in an attempt to circumvent laws and regulations, is strictly prohibited.
No undue advantage may be given to public or private clients, including facilitation payments, financing or illegal donations to third parties with the aim of influencing commercial decision-making.
It is forbidden to provide for a retro-commission of part of the contract price to employees of the co-contractor, to their families or to their close relations.
The personal interests of business partners must under no circumstances influence the choice of a supplier, sub-contractor or employee to be recruited.
Specific measures are put in place when working with customers, suppliers or intermediaries: for example, it is necessary to check the reputation and background of the people and companies with whom our commercial partners are asked to work.
If in doubt, commercial partners must examine the offer with the manager of their Business Unit or zone and, if necessary, courteously refuse it by invoking our internal rules.
If collaboration is envisaged with a partner having a personal link with an Altavia employee, express prior agreement must be sought from the Head of the Business Unit or zone concerned.
Altavia provides appropriate training to the partners most exposed to the risks of corruption and influence peddling, so that they can familiarise themselves with or supplement their knowledge in this area.