UN VBCI

INTEGRITY

As part of Nexter’s Compliance Programme, and in addition to the KNDS Ethics Charter, the Group has adopted a Code of Conduct dedicated to the prevention of corruption and influence-peddling. The Code of Conduct is attached to Company rules of procedure. The content of the Code of Conduct is based on an analysis of the potential risks linked to business activities. This Code of Conduct enables employees to identify complex situations and be fully prepared to apprehend them. It guides employees by providing them with precise definitions and concrete examples, as well as elements of behaviour and responses when facing a difficult situation. The Code of Conduct is made available in educational booklet format for employees and all third parties of the company.

An Alert System is also provided for employees wishing to report facts contrary to the Code of Conduct. Employees who detect or suspect acts contrary to the Code of Conduct can alert, in a confidential manner, the Ethics Correspondent by using Nexter’s Alert Procedure.

The Code of Conduct is complemented by detailed policies which enable all employees to familiarise and appropriate the rules and processes to follow in order to prevent corruption and influence-peddling risks.

KNOWING OUR THIRD PARTIES

Knowing our Partners

Knowing our Partners, whether they are suppliers, customers, intermediaries, industrial partners, joint ventures or any other third parties, is essential to prevent the risk of corruption, particularly indirect corruption.

Nexter has implemented specific and rigorous policies to select its third parties, ensuring their reliability and compliance with Nexter’s integrity commitment.

Partners are subject to pre-contract checks, called "due diligence", among other things to verify their good reputation and to ensure that their business practices comply with the company's requirements. In this process, a great number of criteria is taken into account; notably but not limited to, country risk, market risk, the type of relationship considered, identification of the ultimate beneficial owners and potential criminal records or negative press.

All agreements with third-parties contain a strict and complete compliance clause, which includes anti-corruption duties and obligations to our third parties.

Contracting with sales partners (also called intermediaries, business consultants and distributors) may pose specific risks. For these reasons Nexter has implemented a strict policy governing the selection, verification and payment, if any, of this type of partner.

Third Parties and Sales Partners Principles

ORGANIZATION AND GOVERNANCE

The Compliance Programme is led by the Compliance Department which reports to the Legal and Compliance Department. The General Counsel and Chief Compliance Officer has direct access to Nexter’s Chairman of the Board and CEO. The general orientation of the Compliance Programme is given by the Ethics and Compliance Committee, chaired by the CEO and composed of Nexter’s managing team.  The Committee meets twice a year.

The Group Compliance Officer reports to the General Counsel and Chief Compliance Officer and is responsible for defining and deploying Nexter’s Compliance Programme. The Group Compliance Officer identifies the most adapted compliance policies based on the company’s risk mapping and designs the training programme and communication campaigns necessary to implement the company’s culture of integrity.

The Compliance Department is also in charge of due diligence for third parties considered as high risk following Nexter’s risk mapping.

GIFTS AND HOSPITALITY PRINCIPLES

In the business environment, offering or receiving gifts or invitations is a common and legal practice, subject to certain restrictions. Offering gifts and invitations, especially with a public official, may be perceived or seem like corruption.

In order to avoid misinterpretation and risks, the Gifts and Invitations Policy strictly regulates gift giving and receiving. While not prohibited, gifts and invitations must in no case be made for the purpose of obtaining any undue advantage or influencing the outcome of a decision. Their amount must be reasonable, their occurrence must be exceptional and they must be strictly professional.

Gift and invitations principles

PRINCIPLES ON CHARITABLE CONTRIBUTIONS AND SPONSORSHIP

Donations can be considered as a contribution via funding, in kind or in competence, without equivalent compensation, directly or indirectly, granted to an organisation for the support bought to a mission of general public interest. Sponsorship is material support provided to an event, person, product or organisation with the expectation of gaining direct benefit.

Donations and sponsorship operations carry inherent risks. These contributions may be diverted from their original purpose to conceal the attribution of an undue advantage to an entity or an individual. As a result, Nexter has implemented a strict policy and procedure to regulate donations and sponsorship with the company and ensure that the company only funds causes relevant and consistent with its activities and its commitment to corporate social responsibility.

Donations and Sponsorship Principles

PRINCIPLES ON POLITICAL CONTRIBUTIONS AND FOR SPECIAL INTEREST REPRESENTATIVES

In accordance with French law, Nexter prohibits all forms of political contributions in all countries.

Nexter has implemented a policy regarding special interest representatives enforcing, in addition to the strict application of French law, ethical rules to the special interest representatives. A register of the actions undertaken by special interest representatives is maintained by Nexter and transmitted to the French Authority for the Transparency of Public Life (HATVP).

Political contribution principles

Special interest representatives principles

EMPLOYEE TRAINING AND AWARENESS RAISING

Employees have a key role to play in preventing corruption risks. As such, they are trained to acquire sufficient knowledge and tools to identify complex situations and react effectively and without risk. An intranet section dedicated to Compliance is available to employees, giving them access to all of the Group’s anti-corruption procedures and policies.

Managers and more generally all employees, especially newcomers, benefit from training and awareness sessions:

  • Intensive sessions: employees who may be exposed to difficult situations attend intensive training sessions. These are based on concrete cases and workshops, in order to develop their ability to recognise and react to potentially difficult situations.
  • Awareness raising sessions: for all newcomers and employees to understand the Code of Conduct, the Alert System and the main mandatory policies.

MONITORING AND MANAGING

Nexter’s Compliance Department is responsible for managing the anti-corruption programme. Its role is to continuously enhance the Compliance Programme in light of the legal environment and best practices in the industrial sector and to monitor the application of third-party due diligence rules.

The Compliance Programme includes an internal control component to prevent and detect potential risks in operations.

In addition, the Internal Audit Department conducts specific audits related to the compliance programme, and if necessary provide recommendations to the Compliance Department makes the necessary improvements.

The Ethics and Compliance Committee also ensures the proper implementation of the anti-corruption programme and meet to review the programme in place and to recommend further future steps.