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D
Corporate Responsibility
D.4
Ethical excellence inAtos’ sphere of influence
Trusted partner for your Digital Journey
88
NUMBEROF PEOPLEWHO COMPLETED THE E-LEARNINGON THE CODE OF ETHICS IN 2016
[G4-SO4]
France
Major Events
North America
Germany
Middle East
& Africa
South America
United Kingdom
& Ireland
Worldline
Corporate
Iberia
Cloud &
Entreprise So ware
Central &
Eastern Europe
Benelux &
The Nordics
Asia Paci c
96%
92%
96%
47%
53%
69%
92% 93%
87%
62%
89%
94%
66%
100%
80%
60%
40%
20%
0%
66%
Experts Network).
initiatives taken, within different channels, from highest
executive body (Group Compliance Steering Committee), to all
the General Counsels of the Group (Group Legal Compliance
Board), and through specific expert network (Legal Compliance
the different Business Units Compliance Programs with the
corporate one is made possible through harmonized
communication and awareness on several programs and
or tool is appropriately communicated, with specific
communication and training sessions: during the first semester
of 2016, training sessions on the Business Partner Tool were
organized for all the Business Units. In addition, full alignment of
Group Legal Compliance Team ensure that new policy, procedure
employees who can join a specific community, called “Legal
Compliance Organization”, to learn about Atos policies, be
informed about training sessions, receive compliance newsletter
and interesting information on compliance and ethics.
Through the Atos Enterprise Social Network, Group Compliance
ensures an up-to-date communication channel directly with
Awhistleblowing procedure and internal investigations
protected accordingly.
Data Protection Authority
[G4-57 and G4-58]
. Local General
Counsels, management, and Group Compliance are points of
contact for any employee raising an alert, and ensuring that the
rights of employees, the sender or subject of the alert, are
established in compliance with the requirements of the French
suspected non-compliance with the values and principles of the
Code of Ethics. The Code of Ethics alert system has been
Atos Code of Ethics, as described in Section G.6.2, establishes
the right of all employees to raise an alert in the event of a
local teams and provides clear guidelines on how to conduct
internal investigation.
in 2016, to reinforce the governance of any internal
investigation, enhance collaboration between global function and
Investigations procedure
[G4-49]
. Such procedure was reviewed
Any allegations of non-compliance detected within the Company
are to be reported to the Head of Compliance and/or to the
Group Head of Internal Audit, who will launch the Internal
through the annual review of internal investigations during a
Group Compliance Steering Committee.
Such Internal Investigations are properly tracked at corporate
level, and communicated to Group Executive Committee,
For 2016, 11 alerts were reported and monitored at the Group
Compliance level
[G4-50]
.