2.1 2 PREVENTING CORRUPTION
2020 CSR REPORT
BOLLORÉ LOGISTICS
AND INFLUENCE PEDDLING
66
A specific focus on geographical areas and the exposure of various Bolloré Logistics activities to the risks of corruption
An ethical compliance and anti-corruption management system in line with global regulatory frameworks
Bolloré Logistics, a global supply chain player, operates on all f ive continents and works regularly with thousands of suppliers and subcontractors. The company acts as an aggregator of transport and logistics solutions (purchase and sale of freight capacity, logistics, multimodal transport, etc.) and must therefore be continually vigilant with regard to all third party partners to prevent any risk of corruption or human rights or environmental violations.
To ensure compliance with the laws governing business ethics, the Bolloré Group’s Ethics and Compliance Department, and therefore Bolloré Logistics, have rolled out a compliance program inspired by the relevant international standards, namely the guidelines of the AFA (the French anti-corruption agency), the American FCPA (Foreign Corrupt Practices Act), the American OFAC (Office of Foreign Assets Control) and the British Serious Fraud Office. This system aims to prevent, detect and dissuade, based on the following pillars:
The French law of December 9, 2016, known as Sapin II, requires French companies employing at least 500 employees with turnover or consolidated turnover of more than 100 million euros to take measures to prevent and detect corruption and influence peddling. Corruption risk mapping ser ves t wo purposes: understanding the factors liable to affect the activities and their performance, with the aim of guarding against the legal, human, economic and financial consequences resulting from an insufficient duty of care and fostering greater knowledge and in turn better control of these risks. A risk management tool, corruption risk mapping helps to identify corruption risks, compare and assess the existing handling of corruption risk, identify residual corruption risk after the implementation of mitigation strategies, and mobilize the organization through a shared method and tool determined by the adaptation project described below. It is the cornerstone of the Bolloré Group’s corruption risk management strategy under article L. 233-3 of the French commercial code. Specific focus was given to geographical areas and the exposure of various Bolloré Logistics activities to the risks of corruption. It should be noted that the charges brought against the Bolloré Group holding during the investigation into suspicions of corruption in the acquisition of port concessions in West Africa did not affect the Bolloré Logistics business unit (for more information on the investigations/inquiries and the allegations in question against the company and its representatives, see the comments on page 131 of the Bolloré Group’s 2019 Universal Registration Document, available online).
•T he commitment of the governing body: the Bolloré Logistics governing bodies condemn corruption and influence peddling, anti-competitive practices, monitor compliance with economic sanction programs and prevent damage to the environment; •A code of conduct: to comply with the commitment of the Bolloré Logistics governing body, the Code of Conduct defines and illustrates the various types of prohibited behavior. Integrity in our business practices is a key element of the Code of Conduct to which all subsidiaries, representatives, Group employees and commercial partners acting on behalf of the Group must comply; •A whistleblowing system: This professional whistleblowing system allows staff members at Bolloré Group companies and occasional Group employees to report a crime or offence, a manifest and serious infringement of the law or regulation or a threat
