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CAPGEMINI: PEOPLE, CORPORATE SOCIAL RESPONSIBILITY (CSR) AND BUSINESS ETHICS

3.1 Our approach

3

106

Registration Document 2016 — Capgemini

the Ethics & Compliance program within their geographic regions

(GC-ECO) for their jurisdictions. They ensure implementation of

and liaise with the CECO.

General Counsels also serve as Ethics & Compliance Officers

policies: the Blue Book

Group fundamental principles, guidelines and

effectively and maintain unity across operations worldwide.

each employee and company service or department to work

created in 1989. It provides a common reference tool, enabling

confidential Blue Book, so-called because of its color, was

policies that govern our daily operations. The Company

essential to have a set of common guidelines, procedures and

In our largely decentralized and entrepreneurial organization, it is

The Blue Book contains:

principles;

objectives, Values, Code of Business Ethics and collaboration

Group fundamental principles: its mission, expertise, main

Group governance and organization;

authorization and approval processes;

sales and production rules and guidelines;

activities;

risk management, pricing and contracting rules in presales

insurance rules and guidelines;

financial management, merger, acquisition, disposal and

human resources policies;

management guidelines;

marketing, communications, Group knowledge and IT

selection; and

procurement policies, including ethical purchasing and supplier

environmental and community policies.

regularly and is available to all employees on the Group’s intranet.

of our Internal Audit process. The Group Blue Book is updated

Assessment of compliance with these guidelines is an integral part

complying with national legal requirements and specificities.

standards that all entities are required to implement, while

These policies, procedures and guidelines comprise the reference

Our business ethics

They rank amongst the most important of all our strategic

among Serge Kampf’s most precious bequests to the Group.

CEO, Paul Hermelin, our seven core Values and our ethics are

As re-emphasized in March 2016 by the Group Chairman and

performance.

today, this reputation is an essential asset to our economic

shaped the Capgemini Group’s reputation in the market, and

dimensions. Our longstanding commitment to our Values has

and maintain this reputation and, in so doing, to further strengthen

The Group launched its Ethics & Compliance program to protect

our competitive advantage. The objectives of the program are to:

and fosters ethical behavior;

develop a sustainable ethical culture, which reinforces integrity

as well as internal policies applicable in Group companies; and

strengthen knowledge and awareness of laws and regulations,

avoiding ethics and compliance breaches.

implement initiatives aimed at reinforcing prevention and

Ethics & compliance program in 2016

Our Code of Business Ethics

with all former IGATE employees in February 2016.

ethical culture, is now available in fourteen languages. It has the

Our Code of Business Ethics, which encapsulates the Group’s

community. It has been updated in January 2016 and was shared

Directors, the Group Executive Committee and the Vice-President

collective and individual support of the members of the Board of

particular, employees are expected to commit to:

core Values and to the principles expressed in this Code. In

Capgemini expects all Group employees to adhere to the seven

respecting applicable laws and regulations;

of a safe, inclusive work environment;

applying health and safety rules and contributing to the creation

accurate commercial and financial information;

acting responsibly in the marketplace, complying with applicable

avoiding conflicts of interest and insider trading, and providing

competition laws and regulations and anti-corruption provisions,

business partners;

building honest, clear relationships with clients, suppliers and

and of any third parties with whom we work;

maintaining the security and integrity of the assets of the Group

which we operate; and

supporting the communities and respecting the environments in

refusing the use of forced labor and child labor.

employees at year-end 2016.

nine languages. This represents close to 88% of the Group’s

At the end of 2016, more than 170,000 employees had taken the

Code of Business Ethics e-learning module, which is available in

the e-learning module on the Code.

principles set out in the Code of Business Ethics and to complete

All new hires are expected to undertake to comply with the

Specific policies

Anti-Corruption Policy

of corruption. At the end of 2016, more than 171,000 employees

languages, outlining its commitment to zero tolerance for any form

In 2011, the Group released a policy, available in twelve

employees at year-end 2016.

six languages. This represents approximately 89% of the Group’s

had followed the related e-learning module, available in

Group Competition Laws Policy

employees had followed the related e-learning module, available in

violate competition laws. At the end of 2016, more than 162,000

to help employees to identify and avoid situations that could

In 2012, the Group released a policy, available in nine languages,

employees at year-end 2016.

five languages. This represents more than 80% of the Group’s

New employees are expected to comply with the principles set

modules.

Competition Laws Policy, and to complete the related e-learning

out in the Group Anti-Corruption Policy and in the Group