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D
Corporate Responsibility
D.4
Ethical excellence inAtos’ sphere of influence
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Ethical excellence inAtos’ sphere of influence
D.4
Ethical excellence within the entire group
D.4.1
Compliance
D.4.1.1
[G4-DMA-Anti-corruption] and [G4-DMA-Compliance]
Tone from the Top
approved the Compliance Strategy plan to be deployed in all
Atos Business Units on December 7, 2016.
of Atos on 2015, the Group Compliance Steering Committee,
composed of Group Executive Committee members and key
Directors, focuses on strategies and priorities of Atos Compliance
program, as defined by the Group Legal Compliance Team. It
Having received mandate from the Group Executive Committee
monitoring compliance matters into the local operations.
Compliance Committees at Business Unit level ensure a
consistent approach to Compliance at Atos, by rolling-out and
Group Legal Compliance Team:
Atos enhanced the compliance governance framework by way of
several concrete measures initiated and implemented by the
Group Legal Compliance Team;
creation of a Global Legal Compliance Board involving all the
•
General Counsels of Atos, aiming to strengthening the local
leadership of compliance matters under the guidance of the
development of Country Compliance Dashboards, composed
•
of compliance KPIs, aiming to improve the reporting to the
Group Compliance Steering Committee, and the monitoring of
the effectiveness of the compliance program within the
Business Units Compliance Committees.
Code of Ethics
highest level of Atos Group (detailed information on the Code of
Ethics in section G.6.2). The Code has been attached to all
employment contracts concluded as from January 1, 2011.
Atos Code of Ethics which introduces Atos’ commitment to
comply with highest standards of business integrity, business
ethics and latest regulations, was approved by Atos Group Board
of Directors, demonstrating promotion of ethical excellence at the
Human Resources Director and the Global Legal Compliance
team. In revising the Code of Ethics, this Committee was
consulted and several recommendations were incorporated into
the new Code of Ethics, deployed in 2015 and 2016.
highly respected external professionals, has been created with
the mission to strategize on the role of ethics generally, and
particularly within Atos’ operations. The Ethics Committee is
sponsored by the Group Chief Compliance Officer, the Group
Since 2012, an Ethics Committee, composed of independent and
[G4-56], [G4-57] and [G4-58]
Policies, processes and Internal controls to prevent
non-compliance risk
Participant since 2010 to the UN Global Compact, Atos has
implemented several internal policies:
AP11 Contributions Policy;
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AP16 Dawn raids Policy;
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AP19 Export Control Policy;
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AP20 Anti Fraud Policy;
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AP35 Competition in business;
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AP36 Roundtable Policy;
•
AP38 Business Partners Policy.
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corruption, in support of Atos’s Code of Ethics principles relating
to business integrity
[G4-SO5]
.
Atos has implemented several measures to prevent bribery and
will be rejected by the BPT.
matches with any of the main international sanction lists, it
addition, Atos strictly complies with international sanction
laws and regulations and in the event a business partner
process by the Business Unit Head of Sales for low-risk
business partners to complex approval processes by the
Group CFO and Group General Counsel, in addition to the
Business Unit management, for high risk business partners. In
various elements necessary for the assignment of a risk
assessment to the business partner, as well as the requisite
validation process. The level of risk assessment will identify
the appropriate validation process, involving a simple approval
developing and retaining its business are subject to a due
diligence and validation process supported by an automated
tool, the Business Partner Tool (BPT). The BPT collects the
Atos Business Partners, including agents, intermediaries,
•
consortium partners and consultants assisting Atos in
accepting or offering any disproportionate gift, invitation,
hospitality package or any other similar contribution. When in
doubt, an employee is required to seek approval from
management.
In addition, the AP11 Atos Contribution Policy further
•
enhances the compliance efforts relating to bribery and
corruption. The Policy prevents Atos’ employees from