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SGS Code of Integrity
Dear Colleagues, Integrity is at the core of the business of the SGS Group, it is the common thread through all our activities. The purpose of this Code of Integrity and Professional Conduct is to lay down our rules of behaviour in all our dealings for the SGS Group and to provide guidance in our day-to-day business. These rules apply to all employees of the SGS Group. Our joint venture partners, agents, intermediaries, consultants and subcontractors shall also be required to comply with them. It is the responsibility of all of us, at all levels of our organisation, to comply with, and live by, our Code. No deviation can or will be tolerated and no employee will suffer any adverse consequence for having complied or for reporting suspected violations. Our Code of Integrity and Professional Conduct reflects the Business Principles for Countering Bribery issued by Transparency International and Social Accountability International. However, it expresses our values and standards in our own way. It has been approved by our Board of Directors and the Operations Council. Its rules are fairly simple. However, if you have any difficulty in a particular situation, you should apply the following common sense principles:
Sergio Marchionne Chris Kirk
All findings and results shall be accurately documented and not be improperly changed. Reports and certificates shall reflect these results and findings and the professional opinions obtained.
All records must be retained in accordance with applicable laws and Group policies.
The following are examples of conflict of interest situations which must be avoided:
Whenever feasible, orders of a certain importance must be reviewed and awarded by a group of 2 or more individuals pursuant to a proper tendering process.
Improper advantages are advantages granted to influence governmental or corporate decisions or actions in violation of duty. They may take the form of bribes, gifts, excessive entertainment or kickbacks. They also include political contributions unless they are disclosed, comply with local law and have obtained prior clearance. Improper advantages are often granted by agents, intermediaries, consultants or contractors claiming to perform a bona fide service or by joint venture partners or suppliers. We therefore do not deal with these parties if we know or have reasons to believe that they engage in granting improper advantages. In addition, in order to prevent any misuse of funds, all payments for goods or services must be made to the person who supplied them and cash payments must be avoided and may be made only in accordance with Group policies. Clearance must be obtained for the remuneration of agents, intermediaries and consultants. Gifts, hospitality and entertainment must always be related to a genuine business purpose. They may not be intended or appear to be intended to influence a decision or action and must be kept within what is socially acceptable and legally permissible. For charitable contributions or sponsoring of events, prior clearance must be obtained. Facilitation payments are modest payments customary in certain countries to expedite the performance of routine actions which the proposed recipient has a clear and non-discretionary obligation to perform. Facilitation payments must be minimised and avoided wherever possible. They may only be made if there is a clear entitlement to the action to be performed and must be appropriately accounted for.
All employees are expected to respect their fellow employees. Sexual harassment and bullying are unacceptable practices which have no place in a work environment. Employees must also be open, transparent and truthful in dealing with their fellow employees, subordinates and superiors.
We never engage in discussions or enter into agreements with competitors on prices and market allocations. We do not exchange competitive information. We conduct our marketing, including any references to our competitors or their services or to third parties, in a manner which is truthful, and neither deceptive, nor misleading or likely to mislead. We present ourselves in a fair manner and ensure that presentational information, including descriptions of our network and affiliations, resources employed and services provided is accurate and unambiguous.
This confidential information must not be disclosed to others and may not be used for personal benefit. When confidential information relating to the business of the SGS Group must be disclosed in the course of business, all measures must be taken to protect its confidentiality. Confidential information relating to others may only be disclosed with the approval of the person or entity involved.
Each employee is responsible to comply with the Code in his/her area of activity. All employees shall be informed about the Code and shall receive training on integrity issues. Any report or request for clearance or advice under the Code should be addressed to the Chief Compliance Officer. You should also report any suspected violation of the Code as well as any solicitation from a third party or offer by a third party to you of an improper advantage, to the Chief Compliance Officer or to any other member of management with the request to inform the Chief Compliance Officer. Unless you have violated the Code or are acting maliciously or in bad faith, and to the extent that we will be able to, we will protect you against any form of reprisal and will keep your identity confidential at your request. You may make suggestions on the implementation of the Code at any time by submitting comments to the Chief Compliance Officer or to any other member of management for transmission to the Chief Compliance Officer. You may contact the Chief Compliance Officer at your choice by post, telephone, fax, e-mail or by using our hotline : Chief Compliance Officer Tel.: +41 22 739 91 00 Parties other than SGS employees may utilise these contact details as they deem appropriate. |
