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Code of conduct for employees

Seppic Code of conduct

A code of conduct is directed at all Seppic employees to assist them with developing their activities in keeping with Seppic's ethical standards.

Implementing the code of conduct

The code of conduct is provided to all employees arriving at Seppic, in France and around the world. It is also incorporated into the rules of procedure for our sites in France.

Each year, an e-learning module on the code of conduct is completed by Seppic employees. This module raises awareness of the various provisions of the code of conduct. At the end of the module, each employee commits to adhering to the code in place. The Seppic ethics correspondent is responsible for overseeing the proper implementation of this module. In 2021, the completion rate was 97%, and Seppic's objective is to reach 100%.

Additionally, populations of Seppic employees at higher risk follow an e-learning module every year to raise awareness of the anti-corruption code. In 2021, the completion rate was 100% for this module.

Finally, the outsourced Ethicall alert system, available 24/7 in each local language, has been operational at Seppic since 2015, enabling each employee to report any possible violation of the code of conduct.

The code of conduct

The code of conduct, in compliance with local uses and regulations, is based on 10 fundamental themes.

Respect for laws and regulations

Seppic upholds the highest standards in the manner with which it runs its operations, particularly in respecting human rights, labor laws, and the environment.

In their professional activities, every Seppic employee must demonstrate integrity and abide by applicable laws and regulations under all circumstances.

Respect for people

The safety of its employees is a priority for Seppic. Efficiency should never be sought to the detriment of safety.

  • Safety and health in the workplace

Each employee has the right to work under safe and healthy conditions, and the duty to contribute to these conditions through responsible behavior. Safety policies extend to all employees, subcontractors, and service providers. Each employee must exercise their professional activity while  abiding by the safety, hygiene, and health rules applicable in their workplace, and participating in appropriate training sessions that might be planned concerning these themes.

  • Prevention of discriminatory actions

Seppic is determined to offer its personnel equal opportunities for recognition and career advancement, regardless of their origins, gender, beliefs or physical condition, and will not tolerate any form of discrimination or harassment.

  • Respect for third parties

Each employee must help respect commitments made with Seppic’s partners, particularly customers, suppliers, and public authorities, and must demonstrate objectivity and fairness in their treatment.

Respect for the environment

Respect for the environment and the preservation of natural resources in its operations and those of its customers is a major priority at Seppic.

It is up to each employee, to the extent of their capacities, to contribute to these efforts and commitments by respecting applicable regulations and Seppic’s procedures regarding environmental protection.

Respect for competition law regulations

Competition law is applicable to every aspect of a company’s commercial activity: negotiations with customers and suppliers, contacts with competitors, marketing, and sales promotion.

The following, in particular, are prohibited: any agreement or even discussion with competitors concerning price-setting or other transaction conditions, production capacity, or the distribution of customers or commercial zones.

It is up to each Seppic employee to respect the competition law as violating rules can cause the company, its employees, and its shareholders to incur serious risks.

The law stipulates penalties that can be very significant for private individuals or extremely damaging to legal entities, and that may seriously undermine a company’s reputation.

Respect for rules on insider trading

Any employee with information that, if made public, could influence the Stock Exchange price of the Air Liquide share 

must keep this information confidential and must not undertake, or recommend that a third party undertake or have undertaken, any operations on Air Liquide shares. The employee concerned must abide by the measures in the memorandum on the prevention of insider trading issued by the L’Air Liquide S.A. Legal Department.

Prevention of conflicts of interest

Each employee must commit to avoid any situation that involves a conflict between their personal interests and those of the company.

  • Links to a competitor, customer or supplier

For example, a case where an employee may work simultaneously for a customer, supplier, or competitor and has a major interest in them, either directly or indirectly.

Any employee who could potentially be in a conflict of interest is encouraged to inform their immediate supervisor of this situation.

  • Respect for rules on corruption

It is prohibited to pay for, offer, or grant unwarranted advantages, in any form whatsoever, directly or through an intermediary, to a private party or a representative of public authorities in any country, with the purpose of obtaining favorable treatment or influencing the outcome of a negotiation in which Seppic is involved.

  • Payments, gifts, and advantages

No employee may accept any illegal/inappropriate payment, or gifts or other types of advantages from a competitor, customer or supplier or offer the likes to these. An exception can be made for gifts or invitations of low value that are not paid in cash and are in keeping with current commercial practices without violating any laws or regulations.

Protection of Seppic activities

Each employee must properly protect and maintain confidential any strategic, financial, technical or commercial data or documents that are not public and whose disclosure to third parties could be harmful to Seppic’s interests.

  • Protection of information

Likewise, information concerning a named person, both professional or involving private life, is confidential and must be subject to all the necessary precautions to prevent inaccurate or inappropriate modification or disclosure

The obligation to maintain confidentiality also applies to information provided by Seppic’s partners and customers. It is up to each Seppic employee to respect these rules on the protection of information.

This obligation of confidentiality remains even after the departure of a Seppic employee.

  • Protection of property and resources

Each employee is responsible for the proper use and protection of Seppic property and resources, such as intellectual property rights, installations, equipment, and financial resources or cash. These resources and property must be used in accordance with their professional purpose and in the established framework.

They may not be used for personal ends unless explicit authorization has been granted by a duly authorized individual in the framework of established procedures.

Lastly, it is the responsibility of each employee to protect the property and resources of Seppic against any damage, inappropriate alteration, fraud, loss, or theft.

Transparency and integrity of information

Seppic strives for the greatest transparency and the highest standards of integrity and reliability of the financial, accounting, and management information that is treated or communicated.

Each employee who takes part in the production, analysis, filing, or communication of this information must carry out these operations honestly and transparently.

Internal control and audit

Internal control systems set up within Seppic (respect for laws, regulations, policies or procedures, asset protection, and reliable financial information) help control its activities, operational efficiency, and the efficient use of its resources.

Compliance with laws, regulations, policies or procedures, protection of assets, and reliability of financial information are particularly relevant to this area.

Each Seppic employee must contribute to the efficiency of internal control systems and cooperate with the internal or external audits that are involved in the evaluation of these systems, particularly by showing diligence and transparency in satisfying any requests for information.

Implementation of the code of conduct

If there is any doubt about the interpretation or application, in a given situation, of the rules presented in this document.

Each Seppic employee has every right to inform their immediate supervisor, their Human Resources department, or the “Ethics Officer” of the Air Liquide Group about it.

Additionally, any employee who has, in good faith, pointed out a breach in the rules outlined in this document will not be subject to any disciplinary measures.