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Key principles of Code of Conduct

SEPPIC implements an employee Code of Conduct. This code of conduct is intended for all the employees to help them develop their activities while respecting SEPPIC’s ethical principles. In compliance with local uses and regulations, they are based on 10 fundamental themes.

Respect for laws and regulations

SEPPIC upholds the highest standards in how it runs its activities, notably by respecting human rights, labor laws and the environment.

In professional activities, each 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. Safety should never suffer from the search for efficiency.

Safety and health in the workplace

Each employee has the right to work under safe and healthy conditions, and the duty to contribute to them by responsible behavior. Safety policy extends to all employees, subcontractors and service providers. Each employee must exercise their professional activity in abiding by the safety, hygiene and health rules applicable in his or her workplace and participating in appropriate training sessions that might be planned in these areas.

Prevention of discriminatory actions

SEPPIC is determined to offer personnel equal opportunities for recognition and career advancement, whatever 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 partners, in particular, customers, suppliers and public authorities, and must also 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 of SEPPIC.

It is up to each employee, in the limit of its functions, to contribute to the efforts and commitments of SEPPIC by respecting application regulations and SEPPIC 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, 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 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 for conflict of interest

Each employee must commit to avoiding any situation that involves a conflict between his or her personal interests and those of SEPPIC.

Links to a competitor, customer or supplier

For example, a case where an employee may work simultaneously for a customer, supplier or competitor or holds a major interest in these latter, either directly or indirectly.

Any employee who could potentially be in a conflict of interest is encouraged to inform his or her 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 the 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 from a competitor, customer or supplier of SEPPIC or offer to these latter any illegal/inappropriate payment, or gifts or other types of advantages. An exception can be recognized for gifts or invitations of low value that are not paid in cash and are in keeping with current commercial practices and do not violate 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 the interests of SEPPIC.

Protection of information

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

The duty 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 duty on confidentiality continues even after the departure of an 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 except if 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 in this area.
Each SEPPIC employee must contribute to the efficiency of the internal control systems and cooperate with the internal or external audits (that are involved in the evaluation of these systems), especially 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 his or her immediate supervisor, or his or her Human Resources Department or the “Ethics Officer” of the Air Liquide Group about it.

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