Prevention and Fight against Corruption
Scope of Application
In line with its values of integrity, loyalty, and transparency, the GPO Group, composed of GPO SA and its subsidiaries (hereinafter “GPO Group”), is committed to combating corruption by applying a principle of zero tolerance towards all forms of corruption in the conduct of its business. This commitment is also a determining factor in its adherence to the United Nations Global Compact (Principle 10 – Fight against Corruption).
This policy applies to all employees of the GPO Group, across all legal entities of the Group, regardless of hierarchical level, status, or type of employment contract. Temporary staff (interns, temporary workers, seconded staff, etc.) are subject to the same rules as permanent staff.
Furthermore, any person or organisation with whom an employee is in professional contact – including but not limited to clients, prospects, suppliers, service providers, distributors, commercial intermediaries, agents and representatives, consultants, officials, and public agents – must be informed of the ethical principles contained in this policy and ensure compliance when dealing with the GPO Group or any of its employees. The Group’s General Terms and Conditions of Sale and General Terms and Conditions of Purchase expressly refer to this policy.
The GPO Group’s anti-corruption policy is set out in this Code of Conduct, integrated into the Internal Regulations of the Group’s companies, and has been subject to the consultation procedure with employee representatives.
The Code of Conduct coexists with the pre-existing Ethics and Behaviour Charter, which it complements with respect to commitments in the fight against corruption.
Legal Framework
In line with its commitment to strict compliance with the laws and regulations in force in its business activities, the GPO Group complies with the provisions of French regulations on the offence of corruption (included in the Penal Code) and with the requirements of the Sapin II Law [1] on corruption prevention. The Group undertakes to adopt effective anti-corruption measures in its activities.
More generally, the company and its employees undertake to comply with the provisions of all applicable anti-corruption laws and regulations worldwide, including those of the UK Bribery Act [2] and the US Foreign Corrupt Practices Act (FCPA) [3], which apply internationally.
Each employee must understand that if the GPO Group were found to be involved, directly or indirectly (via an intermediary), in acts of corruption committed in France or abroad, the company could be held liable, incur substantial fines, face restrictions on its activities (including exclusion from certain markets, such as public contracts), and suffer damage to its reputation and image. Employees involved in such acts could themselves, depending on applicable law, face fines, imprisonment, disqualification from office, etc.
What is Corruption?
In general terms, corruption involves offering, promising, or providing to a person (private individual or public official), or soliciting or receiving from such a person, directly or indirectly, an advantage (money, bribe, kickback, hidden commission), gift, invitation, service, or any other benefit in order for that person to perform, delay, or refrain from performing an act within their role or mission.
Examples of corruption include proposing, receiving, or soliciting a payment, service, gift, or invitation with the aim of:
- Obtaining listing, an order, or a contract from a purchaser;
- Considering a supplier’s proposal or offer despite its unfavourable terms;
- Awarding a supplier a contract under non-optimal or unfavourable conditions;
- Sharing details of competitors’ offers with a supplier;
- Providing a supplier with sensitive information to strengthen their negotiating position;
- Influencing a decision-maker in connection with a commercial proposal;
- Setting up an overbilling scheme with hidden kickback;
- Obtaining undue tax treatment or preferential customs duties;
- Granting a customer preferential prices, terms, or payment conditions without valid business justification.
The use of funds or third-party intermediaries to circumvent direct prohibitions is also strictly forbidden.
Influence Peddling, Favouritism, and Other Forms of Corruption
Other breaches of integrity are defined as acts of corruption and are strictly prohibited within the GPO Group:
- Influence Peddling: Accepting or soliciting benefits in exchange for abusing one’s influence over a decision-maker.
- Favouritism: Granting unjustified advantages contrary to laws guaranteeing free competition in public procurement.
- Facilitation Payments: Small unofficial payments to expedite routine administrative actions by public officials – strictly prohibited by the Group.
- Extortion: Obtaining undue advantages through threats or violence – also prohibited by the Group.
Gifts and Invitations Policy
Business gifts and hospitality are common commercial or social practices. However, they may be perceived as bribes if excessive.
The Group allows only modest gifts/invitations, appropriate to circumstances, not exceeding €50 unless expressly authorised in writing by management.
Employees must apply common sense and consider legality, frequency, professional context, and value before offering or accepting gifts.
Donations, Sponsorship, and Patronage
The GPO Group prohibits any funding of political parties, candidates, or trade unions for the purpose of obtaining or retaining advantages.
Charitable donations or sponsorships are permitted only if lawful, aligned with Group values, and formally approved by the Finance Department.
Lobbying
The GPO Group may use lobbyists solely on the decision of its Executive Management and in strict compliance with applicable regulations.
Conflicts of Interest
A conflict of interest arises when an employee’s personal interests could conflict with those of the Group.
Examples include:
- Business dealings with suppliers for personal benefit;
- Family relationships between employee and line manager;
- Close personal ties between an employee and professional counterpart at a client or supplier.
Employees must declare such situations to management for transparent handling.
Accounting and Record-Keeping
The Group must maintain accurate books and records, in line with accounting standards, ensuring justification and legitimacy of all payments.
Unrecorded funds, assets, or transactions, and special invoicing or payment procedures suggesting fraud or corruption, are strictly prohibited.
Employee Responsibility and Sanctions
Any employee, regardless of rank or function, who violates this anti-corruption policy may face disciplinary sanctions up to and including dismissal.
Ethics Alert Mechanism
An Ethics Committee (Finance Director, HR Director, Commercial Directors, Anti-Corruption Officer, Legal Counsel) ensures compliance and impartial handling of alerts.
An Anti-Corruption Officer (Gaëtan BREE, HSE Manager – ethique@GPO.fr) oversees the system.
Alerts may be submitted by email or registered mail. The process ensures confidentiality, protects whistle-blowers (in accordance with Sapin II Law and GDPR [4][5]), and prohibits retaliation.
Last Update
January 2020
GPO Group, SA with a Board of Directors, share capital of €11,952,401, registered office at 190 avenue Thiers, 69006 Lyon, RCS Lyon 955 509 609.