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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
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Group governance and organization;
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authorization and approval processes;
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sales and production rules and guidelines;
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activities;
risk management, pricing and contracting rules in presales
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insurance rules and guidelines;
financial management, merger, acquisition, disposal and
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human resources policies;
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management guidelines;
marketing, communications, Group knowledge and IT
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selection; and
procurement policies, including ethical purchasing and supplier
environmental and community policies.
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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
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as well as internal policies applicable in Group companies; and
strengthen knowledge and awareness of laws and regulations,
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avoiding ethics and compliance breaches.
implement initiatives aimed at reinforcing prevention and
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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
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accurate commercial and financial information;
acting responsibly in the marketplace, complying with applicable
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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
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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
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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