Ethics

In accordance with the Sapin II law of December 9, 2016, reinforced by the Waserman law of March 22, 2022, Altavia has set up a reporting system to bolster its ethical commitments and enable everyone to play an active role in risk prevention.

This system enables a wide range of stakeholders, including employees, customers and suppliers, to report in good faith and without financial compensation any behavior that is contrary to the code of conduct.

The areas covered are varied, ranging from corruption and fraud to health, safety, environmental and human rights issues, harassment, discrimination and breaches of competition or data protection rules.
The person reporting 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 defense secrecy, medical secrecy or the secrecy of judicial deliberations, it complements existing whistle-blowing channels and requires whistle-blowers to provide evidence to support their report, while complying with the laws applicable in their country of activity.

In accordance with the Waserman law, this system enables whistleblowers to submit an objective, detailed report via the Whispli platform, with the option of remaining anonymous.

Whistle-blowers 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 having access to information on the person who reported the incident.

Depending on the seriousness of the facts reported, various measures can be taken, ranging from the reinforcement of internal procedures to disciplinary sanctions or legal action.

The whistleblower will not be penalized for reporting an alert in compliance with the sapin II law of December 9, 2016. Enhanced protection measures have been deployed with the Waserman Act of March 22, 2022.

Any person obstructing 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 euros.

In the event of non-compliance with the law in the above-mentioned areas, disciplinary action may be taken, up to and including dismissal, and legal proceedings may be instituted. Data relating to alerts will be stored or destroyed in accordance with legal provisions.

Reports must under no circumstances be motivated by malice or bad faith, or they may result in disciplinary action.

In accordance with Article 122-9 of the French Penal Code, whistleblowers are not criminally liable if they infringe a secret protected by law, provided that such disclosure is necessary and proportionate to safeguard the interests at stake, and that it complies with the reporting conditions defined by the Sapin II law.

Whistleblowers are not civilly liable for damage caused by their reporting or public disclosure, if they had reasonable grounds for believing 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, salary reduction, 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.

Read our policy on processing ethical reporting

Ethical conduct is a fundamental commitment at Altavia. We maintain high standards of integrity and social responsibility.

At Altavia, we adhere to the values of:

• Universal Declaration of Human Rights (1948)
• The French Penal Code (1994)
• Conventions of the International Labor Organization (1919)
• Provisions of the French Labor Code (1910)
• Sapin II anti-corruption law (2016)
• Waserman law (2022)
• The General Regulation for the Protection of Personal Data (RGPD) (2018)

We uphold these values and principles and ask our suppliers, service providers and business partners to respect them. The ethical code of conduct sets minimum standards for fair, safe and healthy working conditions, the prevention of corruption and responsible environmental management.

At Altavia, we maintain the highest standards of ethics and integrity in all our operations. We have implemented an anti-corruption program in line with the requirements of the Sapin II law, reinforcing our commitment to integrity, transparency and ethics.

The Sapin II law, relating to the fight against corruption and the modernization of economic life, is based on 8 main pillars: the code of conduct, the internal alert system, risk mapping, control procedures, third-party assessment procedures, employee training, the internal control and audit system and disciplinary sanctions.

We adopt a zero-tolerance policy towards corruption. All our employees, as well as our business partners, are bound by the code of ethical conduct.

We encourage an environment where ethics and honesty are paramount values, and we take strict measures to ensure that these principles are respected in all our operations.

Our business partners, be they suppliers, customers, service providers or others, are bound by our strict conflict-of-interest policy.

In our dealings with suppliers, we do not accept any special discounts or rebates from them on a personal basis.

Any activity that improperly favors Altavia’s interests, such as illegally obtaining a contract, paying money to a private or public person, or to a government 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 kickbacks of any part of a contract price to employees of the co-contractor, to their families or to persons close to them.

The personal interests of business partners must under no circumstances influence the choice of a supplier, subcontractor or employee to recruit.
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 business partners work.

In case of doubt, business partners must examine the offer with the manager of their Business Unit or zone and, if necessary, courteously refuse it, 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 manager of the Business Unit or zone concerned.

Altavia provides appropriate training to those partners most exposed to the risks of corruption and influence peddling, so that they can familiarize themselves with or supplement their knowledge in this area.