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A
Corporate and social responsibility report
Annex III -
Being an ethical and fair good player in business
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Worldline
2016 Registration Document
between the Sales and Marketing (S&M) and the Customer
applied at Worldline SA/NV, and the allocation of responsibility
principles of AML, the “Know Your Customer” (KYC) principle as
(overseen by the local banking regulator). It sets out the general
Services (CS) Divisions.
anti-money laundering (AML) policy in place since 2011
Worldline SA/NV, the Group’s Belgian subsidiary, has had an
de-activation and back-up systems.
risks, such as geo-blocking, real time blocking, fall back
Detection & Reaction (FD&R) application that allows the
to address these risks. The Group has developed a Fraud
department has implemented various policies and procedures
money laundering risks. The Group’s Fraud Risk Management
enhanced with additional features to better manage the residual
application. The Group’s risk mitigation process has been
detection of fraud in near real time based on a data analysis
the organizations that issue PCI certifications and address
ensure compliance with payment security rules established by
breaches. In its role as commercial acquirer, the Group must
in place (e.g. PCI certification) to minimize the risk of data
taken all necessary measures, in accordance with best practices
Fraud risk management: the Group as an issuer processor has
The Code of Ethics
A.4.1.1.4
January
1, 2011.
been included in every employee’s employment contract since
approved by the Board of Directors. This Code of Ethics has
of Ethics, which was overhauled in 2015, after having been
The Company’s Code of Ethics is based on the Atos group Code
the backbone of the Group’s corporate strategy: responsibility,
to clients, innovation, wellbeing at work and excellence.
trust, sustainable competitiveness, service quality and listening
and Worldline corporate values, establishing ethical practices as
The Code of Ethics introduces a direct reference to Atos group
actions deemed inconsistent with the values and principles of
the right of any Group employee to disclose behaviors or
sustainable business. Additionally, the Code of Ethics introduces
operations, to protect the Worldline brand and to ensure
the Code of Ethics.
function in providing leadership and guidance to global
The Code of Ethics enhances the role of the compliance
operations in early 2016. Strong involvement by the Human
The Code of Ethics began to be rolled out across all global
several European countries.
representatives of employee councils to be involved, such as
implementation,
particularly
in
countries
requiring
Resources department has ensured a consistent and thorough
adopted a slightly modified Code of Ethics, particularly with
laws and regulations. Consequently, certain countries have
content of the Code of Ethics to ensure alignment with local
Additionally, the Legal department of each country reviewed the
Ethics will continue throughout 2017.
whistleblowing systems. The deployment of the new Code of
respect to issues carrying legal implications, such as national
[GRI 205-1]
Risk assessment andmapping process
A.4.1.1.5
Contract Management department and relevant non-legal
well to understand how the risks identified are perceived within
implement adequate remediation actions where necessary as
risks (i.e. risks with a legal cause) that allows Atos entities to
stakeholders (Human Resources, IT, security) of a series of legal
the organization.
process, which was fully integrated to the enterprise risk
Atos has put in place a legal and compliance risk management
evaluation by members of the Atos Legal, Compliance and
management in 2016. This risk management exercise consists in
the Audit Committee of the Group, with a clear mapping of the
results of the legal risk management exercise are presented to
As integrated to the Atos enterprise risk management, the
legal risks of the Group.
business opportunities is an important part of the overall risk
In addition, the review of core compliance issues in assessing
Rainbow Process, which sets out defined steps and escalation
systems for credit, commercial and legal risks, through the
transactions is well established within Atos, similar to the review
assessment framework. The compliance review process of
procedures [GRI 205-1].
Anti-Corruption]
Internal Investigations
[GRI 103-2
Awhistleblowing procedure and
A.4.1.1.6
raise an alert in the event of a suspected non-compliance with
internal control system, establishes the right of all employees to
Atos Code of Ethics, as described in 16.6.1.3 Components of the
102-17]. Local General Counsels, management, and Group
requirements of the French Data Protection Authority [GRI
Ethics alert system has been established in compliance with the
the values and principles of the Code of Ethics. The Code of
subject of the alert, are protected accordingly.
alert, and ensuring that the rights of employees, the sender or
Compliance are points of contact for any employee raising an
Investigations procedure [GRI 102-33]. Such procedure was
to the Group Head of Internal Audit, who will launch the Internal
Company are to be reported to the Head of Compliance and/or
Any allegations of non-compliance detected within the
conduct internal investigation.
and local teams and provides clear guidelines on how to
investigation, enhance collaboration between global function
reviewed in 2016, to reinforce the governance of any internal
Group Compliance Steering Committee.
through the annual review of internal investigations during a
level, and communicated to Group Executive Committee,
Such Internal Investigations are properly tracked at corporate
processes
[GRI 103-2 Anti-Corruption]
Improved compliance tools and
A.4.1.1.7
Worldline has implemented several measures to prevent bribery
within the Atos group [GRI 205-3].
relating to business integrity, in line with the practice followed
and corruption, in support of its Code of Ethics principles