ETHICS IN PRACTICE - SUEZETHICS GUIDELINES SUEZ ENVIRONNEMENT ETHICS IN PRACTICE 13 Asking a...

ETHICS INPRACTICE

MAKING THE PLANET SUSTAINABLE IS THE BEST JOB ON EARTH

ETHICS GUIDELINESSUEZ ENVIRONNEMENT

ETHICS INPRACTICE

The SUEZ ENVIRONNEMENT Group Ethics Chartersets the general framework for professional conduct for each of its employees.

The objective of “Ethics in Practice” is to detail the terms and conditions for the application of the general framework.

Due to its condensed format, these guidelinesmake no claim to cover all the situations which may be encountered.

ETHICS GUIDELINES SUEZ ENVIRONNEMENT ETHICS IN PRACTICE4


1 .......A DEMANDING ETHICALCOMMITMENT ........................ p. 6

2 .......HOW TO DEAL WITH AN ETHICAL PROBLEM? .... p. 11

3 .......KEY DAY-TO-DAY ETHICALREFERENCE POINTS ........... p. 15

TABLE OF CONTENTS

ETHICS GUIDELINES SUEZ ENVIRONNEMENT ETHICS IN PRACTICE 5


1 ....A DEMANDING ETHICALCOMMITMENT



It is up to all employees in their day-to-day behaviour, in the way theydo their jobs and in their businessdealings with others to apply theGroup’s values and ethics principles,which are:

• Acting in accordance with lawsand regulations,

• Establishing a culture of integrity,

• Behaving fairly and honestly, and

• Respecting others.

Each person should seek to use goodsense and judgment in his/her actions,which is why it is normal and natural todiscuss the ethical questions and dilem-mas inherent in any professional activitywith colleagues and line managers. Identifying ethical conduct and avoidingmistakes are processes that contributeto the pursuit of excellence. Ethical be-haviour require both personal and teamcommitment.

Because of the specific responsibilitiesthey exercise, managers must conveySUEZ ENVIRONNEMENT’s ethical princi-ples to the employees under their au-thority. They are also responsible fordeploying and implementing the “Ethics”policy in the organization of the opera-tional and functional sectors of theGroup’s entities. Managers are thereforeobliged, not only to give their employeespractical information on the rules thatthey must follow, but also to ensurethat these rules are understood.

They are aimed at theemployees (permanent or temporary) of the SUEZ ENVIRONNEMENT Groupcompanies, regardless of their job title, and at anyperson seconded from anoutside company to a Groupentity. They are also aimed atany person acting on behalf of the Group.

TO WHOM ARE THESE

PRACTICAL GUIDELINES AIMED ?


They must also provide guidance andencourage their employees to discusstheir ethical concerns and their questionsregarding the application of the rules.They should not hesitate to inform theirline manager or the entity’s ethics officerof any difficulties encountered in applyingthis policy. Finally, it is up to managersto verify that their employees correctlyfollow the rules they are supposed toapply.

However, it is primarily through the example of their own behaviour thatmanagers communicate the messageof ethical practice and the meaning ofcompliance to their employees.

Everyone, regardless of their position,is responsible for their own behaviourand has to accept the consequences oftheir decisions. If an employee commitsan unethical act, depending on the circumstances, he or she is liable todisciplinary, administrative, or legal (civilor criminal) action, pursuant to localand international regulations. In the caseof an unethical instruction, both theperson carrying it out and the persongiving it are at fault. Anyone pressurized to act against theprinciples of SUEZ ENVIRONNEMENT oragainst their own conscience shouldfeel free to speak about it to someonewho can give them guidance and mayin particular contact the Ethics Officerin the home entity.

The Group’s ethicaldocuments set down rulesand general principles. Groupentities are expected to applyand adapt them under theprinciple of subsidiarity, inkeeping with local rules andthe policies set by themanagement of the entity.

For example, the Groupaccepts the principle of gifts,provided that they arereasonable; there shouldnever be any doubt as to thehonesty, independence andobjectivity of the donor and ofthe recipient. However, it isobvious that this rule will beadapted into a policy againstgiving of gifts in countrieswhere the law prohibits suchpractices. The Group policycan also be adjusted toincorporate caps on the valueof gifts, within the discretionof an entity’s management.

Locally, managers must givetheir employees clearinstructions regarding thecaps on the value of gifts.

APPLYING THE PRINCIPLE

OF SUBSIDIARITY


Each person is required toobey laws and regulations.For Group-specific rules,however, entities may chooseto adapt the way they areimplemented, for example inorder to fit in with laws orcertain aspects of local culturein which customs differ fromour practices. In this case, suchadjustments need to be agreedby the home entity before aspecific policy is applied.

The rule governing suchexemptions is called the“comply or explain” principle. If an exemption is made, thereason for it must be explainedand formally accepted inadvance by the home entity’sethics officer. Under nocircumstances may thisexemption entail violating the law.

The explanation must be clearand properly reasoned, be setout in writing and beconsistent with the law andthe Group’s ethical principles.

COMPLY

OR EXPLAIN

SUEZ ENVIRONNEMENTADHERES TO THE HIGHESTETHICAL STANDARDS

SUEZ ENVIRONNEMENT’s principles ofaction are rooted in international reference models, such as:

• The Universal Declaration of HumanRights and Additional Protocols.

• The standards of the InternationalLabour Organization (ILO).

• The Guidelines for Multinational Enterprises laid down by theOrganization for Economic Co-Operationand Development (OECD), and

• The United Nations Convention againstCorruption.


THE PRINCIPLES OF ETHICSSTATED ABOVE APPLY ATTHREE LEVELS, WHICH ARE:

THE RELATIONS WITHIN THE GROUP,CONSISTING OF ITS EMPLOYEES, ITSOPERATIONAL ENTITIES, AND ITSSHAREHOLDERS;

THE RELATIONS WITH THE MAINPLAYERS ON OUR MARKETS: OURCUSTOMERS, OUR SUPPLIERS AND OUR COMPETITORS;

THE RELATIONS OF THE GROUPWITH THE ENVIRONMENT IN WHICH IT OPERATES: CIVIL SOCIETY, AND,IN GENERAL, ALL ITS STAKEHOLDERS.

2 ....HOW TO DEAL WITH AN ETHICAL PROBLEM?



All the documents relevant to the charter and to theseGuidelines are accessible to all Group employees on theGroup’s intranet site.

DID YOU KNOW? W ithin the Group, the answeror solution to an ethical problem can materializethrough different channels:

• providing reference documentation,

• discussions through the chain of command,

• through the Ethics Officer,

• through the ethics e-mail.

Employees have access to a number ofdocuments that explain the objectivesand content of the Group’s ethics policyand that give concrete examples. However,the variety and diversity of circumstancesmakes it impossible to foresee all possiblecases. To find a solution that meets ourethical standards, it is sometimes neces-sary to seek advice. Depending on thenature of your questions, you can approacha work colleague, the management line –starting with your direct supervisor oranother manager with skills relevant toyour question (human resources, safety,legal, etc.), a personnel representative, iflegally permitted, and, of course, an ethicsofficer.

Training courses for functionaland operational managers are available in live or onlineformat. The topics covered inthose courses mainly concern:

• Induction into the ethicalprinciples of the company;

• Business ethics;

• Competition rules in theEuropean Union;

• Anticorruption measures in international development;

• Ethics in relation to publiccontracts;

• Management responsibility,ethical risk, internal control,audits.

For any additional information,consult the ethics officer foryour entity or your humanresources department.

LEARNING ABOUT ETHICS


Asking a question of an ethical nature isoften tricky. So it takes courage, evenboldness, to tackle these subjects anddescribe the dilemma. However, it is theonly way to put an end to unacceptablepractices and to begin the process ofimprovement

Anyone who in good faith expressesconcerns relating to ethical matters willnot be exposed to any sanction as aconsequence of their initiative. Any employee who is a victim of or witness to practices against this rulemay refer them to their entity’s ethicsofficer or the Group’s ethics officer, whothen has a duty to work with manage-ment to find the means to protect or re-establish the legitimate rights of thepeople concerned. In all circumstances, ethics officers areobliged to strictly maintain the confi-dentiality of information communicatedto them.

THE ETHICS OFFICER

The Ethics Officer has three roles:

• To participate in the design of thegroup’s ethics policy.

• To communicate and explain the different points in the policy. To leadinitiatives for training and communica-tion by answering employee questionsand conducting information sessions.

• To track ethical risks and cases of lackof compliance. May be involved in handling cases of breaches in ethicsin conjunction with line managers andpotentially the human resources andlegal divisions.

Within SUEZ ENVIRONNEMENT, there is anetwork of Ethics Officers assigned tothe Group’s main entities (roughly 30 ofthem). This network is led by the Group’sEthics Officer. The contact information forthe Group’s ethics officer is available onthe intranet site.


THE ETHICS E-MAIL,A TARGETED DEVICE

SUEZ ENVIRONNEMENT provides its em-ployees with an e-mail address on whichthey can contact the Group Ethics Officerif they are not sure what to do or haveobserved violations of the ethics andcompliance rules.

This procedure is not an alternative toother existing reporting channels (linemanagement, personnel representatives,public body, etc.), but an additional chan-nel. It should be used in accordancewith local regulatory requirements, sincecertain regulatory regimes may imposecompulsory procedures.

The primary target of the procedure isany violations relating to accounting, financial audit and the fight against corruption, as well as other serious infringements that may threaten thevital interests of the Company or thephysical or moral integrity of its employees. Other violations are likelyto be dealt with under local regulations.Alerts may be addressed to entity ethicsofficers and/or the Group Ethics Officerby any means, in particular by e-mail tothe following address:

[email protected]

Any abusive use of the procedure mayresult in prosecution and, conversely,no proceedings may be taken against auser acting in good faith. The identity of the user and that of anyaccused person is kept confidential, andpenalties may be applied if confidentialityis not maintained.

You are not sure what to do or what procedure to follow.

You want advice.

You think that the company’srules are in the process or onthe verge of being violated.

You think that you are or are going to be involved in an action that goes againstyour company’s rules.

In all these circumstances,consult someone you can trust:your colleagues, your linemanager, the legal department, a personnel representative iflegally permitted, the ethicsofficer, and so on.

WHO YOU SHOULD FIRST

CONTACT?

3 ....KEY DAY-TO-DAYETHICAL REFERENCEPOINTS



COMMUNICATION

In their communication policy, Groupentities work to ensure that the information they provide is accurate,complete, precise, comprehensible andtimely. Apart from their managers, onlyduly authorized people have the rightto speak on behalf of Group entities.

An employee who wishes to speak inpublic, publish or give an interview on asubject affecting a Group entity musttherefore receive permission to do sofrom an authorized person or his entity’sCommunication department (except inspecial circumstances defined by theregulations). Any employee not so authorized may nevertheless speak freely,provided that they first specify that theyare speaking or writing in a personalcapacity and not on behalf of their entity.In particular, they should ensure thatthey do not associate their entity with apartisan position, and that they do notuse their position in the entity to lendcredibility to their personal views.

a b c d e f g h i j k l m n o p q r s t u v w x y z


Question

In response to an article on environmental companies on the internet, I was shocked to discover comments criticising the scandalous behaviourof large groups in the sector. Some even claim that our Group does not respect existing regulations and that it pollutes with impunity. I resolved to defend my company, and decided to respond to thesemalicious rumours.

Does this present an ethical problem?

Answer

There is no impediment to you airing your opinion or expressing your point of view on a subject which involves SUEZ ENVIRONNEMENT. However, be very careful. Your opinions are your own, and, unless dulyauthorized, you may not speak on behalf of your entity or use your positionwithin the entity to justify your statements. Moreover, all your arguments must be based on public information, i.e.,drawn from official Group publications or releases. If in doubt, do not hesitate to talk to your line managers.

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COMPETITION

The Group attaches the greatest impor-tance to respecting the rules of compe-tition and rejects all anti-competitivepractices. Its employees are expected to behaveimpeccably in their relations with com-petitors, clients, suppliers and prospectiveclients. Proscribed activities notably include: illegal competition agreements, abuseof dominant position, acts of corruption,the exchange of insider information, discriminatory, excessive or predatorypricing, etc.

Group employees use only legal andethical methods to find out informationabout their competitors. By way of example, the use of intrusion and falseidentity is prohibited. They do not slanderor denigrate their competitors and refrainfrom taking advantage of inaccurate,falsified or distorted information. Finally,when a Group entity is operating in aregulated market, it must ensure thatemployees are informed of the provisionsthat apply to them and monitor theirimplementation.

It is generally deemed to be anti-competitive and thereforeprohibited to consult with one or more competitors with, for example, the effect orintention of:

Submitting agreed bids..

Dividing up or segmentingmarkets, outlets or sources of supply, whether on thebasis of geographical territory,client type or any othercriterion.

Eliminating a competitor, a client, a supplier or a market newcomer.

PROHIBITING ALL UNFAIR

PRACTICES



Question

My cousin, who works for a competitor, is offering to help me fast-trackmy career by giving me his company’s answer to a call for bids on whichmy department has been working for several weeks.

Considering that my interests and those of the group are the same, whyshouldn’t I accept the offer?

Answer

SUEZ ENVIRONNEMENT’s principle is to respect the rules of competitionand rejects any exchange of information which could compromise it. As an employee of the Group, you must adhere to ethics rules above all else. Moreover, a breach in ethics could be very costly to your career.Your cousin probably does not realize he is asking you to participate in an anti-competitive and unfair act. In his interest, in yours and in that ofthe Group, turn down this type of information exchange.

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CONFIDENTIALITY

In the course of their work, all employeesare required to manage or hold largeamounts of information. This may relateto clients, personnel, their Company or,more generally, their company’s eco-nomic, commercial or legal environment(commercial or financial partners, sup-pliers, government bodies, other Groupcompanies, etc.). As a general rule, anyinformation that has not been madepublic should be considered confidential.Information for which there are specificregulations in some of the Group’sspheres of activity, such as commercially

All documents issued withinthe Group must display adegree of confidentiality inaccordance with the followingscale: “confidential”,“restricted”, “internal”,“public”.

When a document is notclassified, it is considered for“internal” use, by default.

FOUR LEVELS OF CONFIDENTIALITY

sensitive information, should be treatedwith particular care.

Both within and outside SUEZ ENVIRON-NEMENT, employees are advised to main-tain maximum discretion with regard toinformation, of any kind, originating fromor relating to their company. If you needto communicate such information to another person to enable them to dotheir job, make sure that you only givethem the specific information they require, particularly if such informationoriginates wholly or partially with a thirdparty or service provider. In addition, tellthem the level of confidentiality of theinformation communicated to them.

A large proportion of the confidentialinformation to which employees haveaccess is in electronic form, which is whythe Group has set rules on informationsystems which everyone must follow.


I will not leave sensitivedocuments on printers ormeeting rooms and I will keep to the tidy desk policy by storingitems under lock and key.

I will be responsible for thevisitors that I receive and I will never leave them alone on Company premises.

I will switch on the securescreensaver whenever I leavemy office.

I will not open any attachmentson suspicious emails and will not respond to such messages.

SOME GOOD PRACTICES WITH

RESPECT TO INFORMATION SYSTEMS

AND CONFIDENTIALITY


CONFLICTS OF INTEREST

A conflict of interest is a situation inwhich the judgment of a person who isacting in a professional capacity may beexcessively influenced by a secondaryinterest, distinct from that of the company.This is the case, for example, when anemployee finds him or herself in a situationwhere they might take a decision not onthe grounds of their company’s interests,but of their own interests, or those of arelative or friend.

If in doubt, employees are advised tocheck with their line manager that thereis no conflict of interests. This advice isparticularly pertinent if you, or someoneclose to you, have interests in a companyor body that is a client, competitor orsupplier of the company. It is also pertinent if you are engaged in aprofessional or optional activity outsidethe company. In particular, if you have responsibilities in nonprofit bodies orcommunities that are clients of a Groupentity, you should abstain from participatingin discussions and from voting on matterspertaining to awarding contracts to aGroup entity or from making a decisionabout such a contract. For their part, SUEZ ENVIRONNEMENT’sfinancial officers are required to reportany potential or actual conflicts of intereststo their line manager or their entity’sethics officer, in accordance with theGroup’s “Code of Conduct for FinancialOfficers”.

Question

My entity is working on aproject to respond to a call forbids issued by a municipalitywhere my wife is a municipalcouncillor.

Is this a conflict of interest?

Answer

These circumstances require you to demonstrate the highestlevel of professionalism andvigilance. Your decisions couldbe influenced by the nature ofyour connection with a commonclient; your wife may also be in a delicate situation in relation to your entity. In order to avoidany ambiguity, you shouldinform your line manager or the ethics officer of your wife’s function within themunicipal council.

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If you answered yes to one of the five questions below, you may be facing aconflict of interest.

1 Do I or anyone close to me, outside the Company to which I belong within SUEZ ENVIRONNEMENT, hold a position of executive, owner,manager, employee or consultant in a company:

• that supplies services or goods to my company or a Group entity?

• that is in competition with my company or a Group entity?

2 Do I or anyone close to me, outside the company to which I belongwithin SUEZ ENVIRONNEMENT, have a direct or indirect financial interest ina company:

• that supplies services or goods to my company or a Group entity?

• that is in competition with my company or a Group entity?

3 Do I or anyone close to me have the opportunity to contribute to adecision or to give a recommendation regarding relations between a SUEZ ENVIRONNEMENT entity and a company external to the Group that meets the criteria set out in questions 1 and 2?

4 Do I or anyone close to me have the opportunity to contribute to a decision or to give a recommendation regarding a SUEZ ENVIRONNEMENTentity in exercising my role within a political or voluntary organization?

5 Have I or anyone close to me accepted a gift, a trip or any other material or financial benefit from a supplier, a client or a competitor?

CASE STUDIES: ASSESSING A POTENTIAL CONFLICT OF INTEREST



CORPORATE PATRONAGEAND PARTNERSHIPS

Corporate patronage and partnershipinitiatives are permitted under theGroup’s policy on sponsorship and partnerships . They reflect a civic-minded and sociallyresponsible approach. Only people dulyauthorized by their line manager canorder or initiate these operations. Employees are required to check theappropriateness of these initiatives,which should not create conflicts of interests or constitute a covert form offunding.

Moreover, any large partnership projectmust be authorized by the SUEZ ENVIRONNEMENT Sponsorship Committee(see procedure available on the Groupintranet site).

Question

While a water treatment plantwas being built in a developingcountry, volunteers from anassociation asked us to helpwith the construction of a school in a neighbouring village. This initiative seems to beconsistent with the values and commitments of SUEZ ENVIRONNEMENT.

Can we help them with theirwork?

Answer

SUEZ ENVIRONNEMENTsupports and encourages theinvolvement of its employees ingeneral interest initiatives.However, this involvement mustremain in the private realm andbe decided upon by everyone.Your commitment must bepersonal and must not interferewith your professional work.You may not use companyresources (machines, materials,etc.) without prior approvalfrom a line manager authorizedto enter into a partnership withthe association you wish tohelp.

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Has joined the United NationsGlobal Compact, whose 10th principle relates to thefight against corruption.

Is an active member of the French section of theTransparency InternationalNGO.

TO DEMONSTRATE

ITS COMMITMENT TO THE FIGHT

AGAINST CORRUPTION, THE GROUP


CORRUPTION

SUEZ ENVIRONNEMENT forbids corruptionin all its forms, whatever the time, theplace or the circumstances.Corruption constitutes an attack on thedemocratic principles which are valuedby the Group and adversely affects thedignity and integrity of those who sufferthe consequences. It is also an impedimentto the proper functioning of the companydue to the costs and risks (financial, criminal, commercial and reputation) that they create and the violation of rulesgoverning markets that the company supports.

In general, there are two general categories of corruption:

• Active corruption consists in offeringsomeone an advantage in order to influence a decision-making mechanism(license, right, supply, contract, etc.);

• Passive corruption consists in acceptingan advantage in return for using one’sinfluence to affect a decision. Passivecorruption can happen without activesolicitation. It can include practicesas serious as extortion.


?Question

A public officer suggested that I call one of his acquaintances to put an endto the administrative red tape that is slowing down the site for which I amresponsible. Since I was tired of waiting, I contacted the person who assuredme that the work could resume in less than a week if I pay a significantamount of money in cash.

What should I say?

Answer

You should immediately be suspicious of the situation. You should follow theprocedure for using business intermediaries and find out about the personbefore making contact. Regardless of local custom, SUEZ ENVIRONNEMENTpolicy is to formally refuse any undue payment for a public service. Accordingly, it is out of the question for the services of an intermediary to be used if you have questions about their integrity and the use of the fundsthat will be paid.


Corruption takes concrete form throughactions of different kinds such as gratuities,misappropriation, unwarranted paymentfor a public service, etc.

The last case is an example of extortionwhich is a form of corruption. Extortionconsists in making the award of a contract or license conditional on theprovision of an unwarranted considerationin return, through the exercise of pressure that can extend from occasionalor daily demands for money, to exaggerated administrative red tape, oreven physical threats to individuals andtheir families.Acts of corruption are sometimes facilitated through the use of businessagents in the attempt to mask or concealthe acts from prosecution. To preventsuch arrangements, the Group has established an internal framework procedure for the engagement of business agents that is compulsory inits application.

The business agents used by the Group must:

Have a good reputation,recognized professionalcompetence and knowledgeof the laws, the context andlocal customs.

Not be employees or officialagents of a local authority, a political party, a potentialclient or a competitor.

Have a binding commitmentto work in compliance with their regulations.

Be chosen and approved in accordance withprocedures applicablewithin the Group.

THE PRINCIPLES FOR SELECTING

BUSINESS AGENTS



DELEGATION OFAUTHORITY

Whether a manager or employee, eachperson contributes to the Company’sglobal performance and has a share ofresponsibility corresponding to the scopeof their role. In this respect, in order toguarantee that skills, obligations and responsibilities are properly distributed,management must ensure that delega-tions of authority and the necessarysignatures are effectively establishedand operational, according to the prin-ciples defined by the Legal Departmentof the Group.




Question

I’ve noticed that somewastewater quality controlprocedures considerably slowdown my work and that ofmy colleagues. Moreover, thestandards set bymanagement are much morestringent than those requiredby local regulations.

Won’t these proceduresimpede the competitivenessof our company?

Answer

The procedures andstandards put in place makeit possible for our activities to meet the quality standardsof the Group. As a responsible company,SUEZ ENVIRONNEMENT iscommitted not only torespecting local regulationsbut also to promotingbusiness that is sustainableand which respects peopleand the environment. The competitiveness of our Group also depends on the promotion of thesevalues.

?ENVIRONMENT, HEALTHAND SAFETY

SUEZ ENVIRONNEMENT is careful aboutthe impact of its activities on all itsstakeholders and the natural environ-ment. That is why our Group has developed arigorous environmental and health andsafety policy. Personal involvement andvigilance are needed for this policy to progress into lasting, increasingly ambitious and firm commitments, reflecting a respect for individuals, societyand the planet.


FRAUD

Corporate fraud is a sensitive subjectand its impact is often understated.However, fraud generates financial coststhat can be high and hard to recoverand, more broadly, it represents a riskfor any individual and any company.

For SUEZ ENVIRONNEMENT, fraud, in allits forms, is unacceptable. Any fraudulentact is punishable by the penalties laiddown in international or local law andby the Group’s internal rules.

Fraud is considered to be any deliberateand concealed action or omission, committed with the intention of deceiving or bypassing existing laws orthe Company’s rules, in order to obtainunwarranted material or moral advantage for the perpetrator of thefraud or for a third party.

Fraud takes multiple forms: theft ofmoney, goods, data, or equipment thatbelongs to the company, deliberate falsification, concealment or destructionof documents, false entries or declara-tions, manipulation of accounts, coun-terfeiting, money-laundering, swindling,corruption, etc.

Question

During negotiations with aclient, the client asked me topay for a portion of the contractin cash.

Can I accept these conditions?

Answer

Cash payments are not anoption unless they are for small amounts. You cannotaccept a payment if its originsare potentially fraudulent at the risk of participating in amoney laundering operation.If in doubt, inform the EthicsOfficer before agreeing to this type of payment.

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FUNDING OF POLITICALACTIVITIES

The Group’s policy is to refrain from anyfunding of political activities.

In countries where this type of fundingis allowed, the Group may, under certainconditions, consider contributions orforms of support.In any case, these should be reduced toa minimum and remain the exception,while avoiding any semblance of partisanor biased attitudes.

The Group’s Ethics Officer or the ethicsofficer of the relevant legal entity mustbe informed in advance of any donations. SUEZ ENVIRONNEMENT entities mustrefrain from contributing to the fundingof institutions, parties or candidatesholding extremist views.

Question

For several years now, my teamand I have been trying to obtaina waste services managementcontract in a country that is notvery open to foreign companies.During an informal meeting, apolitical consultant implied thatthere was a good chance thatthe long-awaited contractwould be signed if thecandidate he supports wins. Inexchange, he would need to behelped with settling somedifficulties related to thefinancing of his campaign.

What should I say?

Answer

Obtaining a contract cannot becontingent on providing afinancial advantage at the riskof being implicated incorruption. Accordingly, youmust refuse these conditions.

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GENUINENESS ANDTRUTH OF DOCUMENTS,TRACEABILITY

It is generally advisable to documentthe main steps leading up to a decisionor initiative for which an entity or anemployee may be potentially liable, sothat these steps may be traced later ifrequired. This may apply to any documentused to establish scientific, technical,administrative, accounting or financialresults. These documents must be retained incompliance with applicable regulations.

The documents we establish, as well asthose archived, must accurately reflectthe facts, places and dates of whichthey are a record. All employees shall refrain fromestablishing false documents or falsifyingdocuments. Anyone who suspects theexistence of such a document mustimmediately inform their line manager, orthe ethics officer for their entity. Finally, these documents and othercorporate records must be retained forthe term and in the form required byapplicable laws and regulations.


GIFTS, INVITATIONS AND TRIPS

As a general rule, the Group seeks tominimize the number and cost of giftsand invitations, be they offered or received by Group employees. Their fre-quency and amount must be decidedby management. To find out how thispolicy is applied in their entity, employeesshould ask their line manager.

Gifts and invitations are marks of cour-tesy, so they need to match local tastesand customs. Never accept to give orreceive a gift or an invitation which, forone reason or another, makes you feeluncomfortable or is likely to make theother party or the people around youfeel uncomfortable. Finally, any trip offered or accepted byan employee, in or for the exercise of his or her functions, must first be authorized by management.

Professional buyers and all employeesin the procurement and logistical servicesare particularly solicited by suppliers. In this regard, they are prohibited fromaccepting gifts, invitations or trips. The Group’s policy on gifts must becommunicated regularly to existing andpotential suppliers.

An example of good practicewith regard to invitations,insofar as they are permittedby local law, is never to invite a client to a place where they would not be in a position to return theinvitation.

THE RECIPROCITY PRINCIPLE

Before accepting oroffering a gift, ask yourselfthese three questions:

• Is this gift likely to change my attitude to the person or the Company?

• Has my line manager agreed that I should offer (receive) this gift?

• Will I be comfortable talking about this gift with my colleagues, friends and family?

Don’t forget to also checkthe rules specific to your entity.

ACTION POINT



Question

Since I regularly stay in hotels in the same chain on my business trips,a customer service representative called and offered me a family holiday package during the next school break.

Can I accept the offer without breaking the ethics rules of SUEZ ENVIRONNEMENT?

Answer

Such an offer, because of its value, by far exceeds the threshold set by the ethics rules. It should be turned down. Don’t forget that gifts, whether given or received cannot be such that they alter your relationshipwith the people around you. Gifts must be small in value. If they are not, or if you are in doubt, ask for authorization from your line manager before giving or accepting the gift.

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Question

I heard rumours claiming thatone of our subcontractors isusing forced labor and childlabor on the worksite of one ofthe Group’s plants. I contactedour subcontractor regarding this and he assured me, withsupporting official documents,that he was complying with the legislation.

Answer

Observing human rights is anabsolute priority for the Group.You did the right thing byverifying the legitimacy of theserumours. Even if the laborlegislation varies from onecountry to another it is anabsolute requirement that oursubcontractors comply withinternational standardsregarding respect for workersand work by minors. Make sureof what the situation is andensure that in any situation the dignity of individuals isrespected on the sitesconcerned. Inform your linemanager of these rumours andof the actions you have taken.

?HUMAN RIGHTS

The Group has identified respect forothers as one of its fundamental ethicalprinciples. For this reason, it places particular emphasis in each of its activities on respect for the spirit andletter of the 1948 Universal Declarationof Human Rights. Employees are askedto consider the impact of their actionsand decisions on people, and to ensurethat people are not damaged either intheir integrity or in their dignity throughthe actions of a Group entity or one ofits employees.The Group is also particularly vigilantwith regard to the sensitive situationsto which it may be exposed in its activities,such as the respect for displaced populations or compliance with the ruleson the protection of property in sensitiveareas.

In this respect, every SUEZ ENVIRON-NEMENT employee must refrain frompractising discrimination of any kind,whether by word or deed, in particularwith regard to age, gender, ethnic, socialor cultural origin, religion, political orunion activity, personal lifestyle choice,physical appearance or disability.




INSIDER INFORMATIONAND INSIDER TRADING

Insider information is deemed to be anyspecific information that has not beenofficially made public relating directlyor indirectly to a listed company, which,if it were made public, could have animpact on the stock price of that company or on the financial productslinked to that stock (shares, bonds, loans,options to buy or sell, etc.). Some privileged information may also relateto financial instruments.

A person who holds insider informationis called an insider. The law on “insidertrading” prohibits anyone who handlesinsider information about a listed company from buying or selling thestock of that company, or even advisingor suggesting that a third party shouldbuy, sell or retain that stock, for periodsdetermined by local regulations.

This prohibition applies to the stock ofthe company in which that person worksas well as the stock of any other listedcompany about which he or she mayhold insider information.

Question

My manager often leaves hisdoor ajar, and I heard himtalking to someone in thefinancial division aboutpayment of an extraordinarydividend this year.

Wouldn’t this be the idealtime to buy company shares?

Answer

The information you obtainedwas neither official norpublic. Accordingly, it is privilegedinformation, and falls intothis category even if youobtained it by accident. Accordingly, you cannot carryout any market transactioninfluenced by thisinformation or ask anyone tocarry out such a transactionfor you. In addition, you shouldsuggest to your manager that he better protect theconfidentiality of hisinformation.

?



Question

An employee who is a movieenthusiast often downloadsfilms while he is working thenwatches them in the eveningwith his family. I stronglydisapprove of the illegaldownloads, but as a manager, I don’t see the harm he is doingsince he is watching the moviesoutside his work hours.

Can I prevent him fromdownloading the movies at work?

Answer

You certainly can and shouldprevent this type of behaviour.Piracy and failure to respectintellectual property cannot be allowed within the Group. You should remind theemployee that he is usingcompany equipmentfraudulently and is infringing on rules on intellectual property which you cannottolerate.

?INTELLECTUAL PROPERTY

Just as employees have the obligationto protect the Group’s intangible assets,they must also respect both the Group’sintellectual property and that of others.For example, they should not makeunauthorized use of patents and copy-rights or engage in unauthorized copyingor plagiarizing of brands, studies, projectsor publications belonging to others.



LOBBYING

The Group defines lobbying as the promotion of the interests of its entitiesthrough objective information from opinion leaders and/or the leaders ofthe communities in which those entities operate, in technical, economic and socialareas. The aim is to raise awarenessabout the Group, promote its image, values, lines of business and services,and to defend its interests. If an institution or country regulates theactivities of lobbyists, the entities mustrespect their regulatory obligations anduse only professional lobbyists who doso. Similarly, if there is a code of conductor ethics, lobbyists acting on behalf ofGroup entities must comply with it.In all cases, lobbyists must always disclosethe identity of the persons or organizationson whose behalf they are working whilethey are lobbying. Similarly, they shallnot provide or request information inexchange for payment.The Group draws particular attention tothe risks of conflict of interest and of corruption. All employees must bevigilant about not leaving the impressionthat the Group or the entity they arerepresenting is seeking to unduly influencethe country’s domestic political affairs.


PROCUREMENT AND SUPPLIERS

Employees with third-party business relationships should show particularvigilance in terms of ethics. This includesemployees who work with suppliers,service providers and subcontractors:product advisers, buyers, supply-chainconsultants and, more generally, anyoneinvolved in the act of buying. Thesepeople must follow the principles laidout in these guidelines, and also complywith the ethical rules of the Group’s procurement policies that apply to themin the day-to-day performance of theirfunctions.

1Comply with laws, regulations,external standards, Group valuesand internal procedures.

2Treat suppliers with equity,transparency and impartiality.

3Ensure that mutual commitments are kept.

4Keep the confidentiality of all information exchanged.

5Ensure that the Group’scommitments with regard toethical standards, sustainabledevelopment and corporateresponsibility are known andmaintained.

6 Avoid any conflict of interestswhich may undermine objective and independentdecision-making.

7Report any situations which are in breach of these rules.

8Select and award contracts based on objective criteria.

9Respect the free activities of competition.

SUPPLIER RELATIONS:

NINE ETHICS PRINCIPLES



Question

One of my colleagues usually applies an aggressive policy with respect toprocurements. He does not hesitate to disclose the content of offers bycertain suppliers in order to motivate others to revise their pricing andtheir type of delivery. Admittedly, this approach is often effective but itseems unfair.

Is this method of negotiating acceptable?

Answer

Employees who interact with suppliers or sub-contractors must ensurethat their conduct remains above reproach. Regardless of the resultsobtained by your colleague, they do not justify the use of such anapproach. The confidentiality of proposals from our partners must bemaintained and all suppliers should receive the same information. Do not hesitate to remind your colleague of the rules of ethics or even to alert your line supervisor.

?


Question

A colleague offered to help memove using a company utilityvehicle outside work hours,should I accept the offer?

Answer

Unless specific authorization is given, company propertymust be used in a contextstrictly related to yourprofessional activities.

Your colleague’s offer is nodoubt well intended; however,you cannot accept it, especiallysince the vehicle is probably not insured for private use.

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PROTECTION OF THE COMPANY’SASSETS

The assets of Group entities must beused solely for professional purposes, inlegitimate conditions and with the rightpermits. It is the responsibility of all employeesto do what they can to protect andmake effective use of these assets, toavoid damaging them and to ensurethat they are not used fraudulently. Thisrule applies equally to tangible assets(properties, premises, equipment,supplies, etc.) and intangible assets(patents, information, image, software,brands, reputation, manufacturingsecrets, etc.).

An employee who observes thatprotective measures are inadequatemust inform his or her line manager, anddo the same in the case of theft orattempted theft, piracy, espionage,sabotage or vandalism.


Ethics is an evolving field.

Documents relating to ethical

practices are subject to constant

revision and update to incorporate

best practices under the imperatives

of continuous improvement.

All ethics-related

SUEZ ENVIRONNEMENT documents

are accessible on the Group’s

intranet site and at

www.suez-environnement.com

To receive information or guidance

on ethical practices and compliance:

[email protected]


March 2010 – Printed on coated paper certified by the Forest Stewardship Council (FSC™).It was produced in ISO 9001 and ISO 14001 (environment) certified plants. This paper is made up of 60% recycled fibers and 40% FSC™ virgin fibers. This document was printed with mineral solvent-free inks, by a printer certified by Impri’m Vert.

DESIGN, LAYOUT AND PUBLICATIONLES ÉDITIONS STRATÉGIQUES

SUEZ ENVIRONNEMENTCOMMUNICATIONS DEPARTMENT1, RUE D’ASTORG - 75008 PARIS - FRANCETEL +33(0)1 58 18 50 00 - FAX +33(0)1 58 18 51 68

WWW.SUEZ-ENVIRONNEMENT.COM

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