292 / 334
G
Corporate governance and capital
G.6
Code and charts [G4-15] et [G4-56]
Trusted partner for your Digital Journey
292
Protection of Atos assets – Fraud
G.6.2.4
The assets owned by Atos which consist in material such as
used only for conducting Atos business and pursuant to the law
hardware, or intellectual property rights or financial equity are
quality, reliable and relevant, translating exactly the activities of
and rules defined by the Group: reporting must be of high
the Company.
Duty to act in Good Faith, Protection of confidentiality and privileged information
G.6.2.5
Atos to its clients and misappropriating the use of Atos services and assets for personal benefit.
rules in order to prevent insider trading and misconduct. In addition, Atos ensures that in their decisions and actions, Atos employees
Atos protects both its own confidential information and that provided by its customers, suppliers or partners. Moreover, Atos sets up
act in good faith, such as refraining from acting in an inappropriate manner of any kind, including disparaging the services provided by
Alert system – employees’ rights and duties on
G.6.2.6
regulation or one of the principles set out in the Code of Ethics
immediate superior or to his/her GBU General Counsel or to the
has been or is about to be breached, a right to report to his/her
done in accordance with the regulations applicable in the country
Group Head of Compliance, his/her concerns. This reporting is be
Atos has established for any employee who believes that a law,
in which he/she is employed.
The employee who raises the alert is assured complete
confidentiality in relation to the alert.
relating to the alert prove inaccurate or no action is
faith and without the intention to cause harm, even if the events
be assured, on his/her request, by mobility within the Group.
subsequently taken. If necessary, the employee’s protection may
The employee shall not be subject to any penalty or retaliatory
measure or discrimination, provided that he/she acted in good
material shortcomings in internal controls result in corrective
All alerts that reveal fraudulent behavior, significant lapses or
Anonymous reports are not considered, except if permitted by
measures and/or disciplinary measures and/or legal action.
local laws.
Other applicable provisions
G.6.3
comply with these rules regarding delegation of authority,
Group governs the activities of each employee, who must
mandatory contractual clauses for client and supplier contracts,
The Code of Ethics’ principles are not the only mandatory
established by the different departments and adopted by the
provisions applicable within Atos. A standard of policies
the selection of potential employees and their training or the
requirements.
selection process for business partners, among other
Privileged Information and insider trading
G.6.4
that can be found in the Prevention guide.
securities, the Company aims at providing its investors and
In order to ensure market transparency and integrity in Atos SE
on its activities and performance. The Company requires all
shareholders, under conditions that are equal for all, information
information to follow the insider trading rules and regulations
senior managers or employees having access to critical
Insider trading
deal in Atos SE securities when he or she is in possession of any
employee may disclose any inside information to third parties or
inside information.
market regulation or legal violation which are liable to criminal,
The use or disclosure of inside information constitutes a stock
Market Authority) and civil proceedings. Accordingly, no
regulatory (
Autorité des Marchés Financiers
, the French Financial