Governance of anti-corruption compliance
Ethical values are at the core of Casino Group’s strategy and development. The Group believes that acting with integrity, fairness and honesty is key to sustainable success.
To achieve this, the governance of anti-corruption compliance clearly defines the responsibilities of the various stakeholders involved in its design, deployment and monitoring.
- The Casino Group’s commitment to fighting corruption is driven at the highest level of the Group: the CEO has chosen to provide the Casino Group with appropriate structures to ensure that the law is respected in both spirit and letter and that a culture of corruption prevention is maintained.
- The Group’s Board of Directors, assisted by its Governance and CSR Committee, ensures the implementation of anti-corruption procedures and standards within the Casino Group and the effectiveness of the system.
- A Group Ethics Committee, created on the initiative of Casino Group’s Executive management, aims at promoting and spreading the anti-corruption policy within the management and daily practices of the Casino Group. This Committee validates the scope and framework of the anti-corruption compliance program and related procedures. The Group Ethics Committee is chaired by the Group Compliance Officer.
- The Group Compliance Department (DCG) is responsible for developing and proposing the mechanisms, standards, and procedures of the Casino Group’s anti-corruption policy to the Group Ethics Committee and for monitoring their implementation through action plans.
- To ensure the deployment and effectiveness of the compliance mechanisms necessary for the management of the Casino Group’s anti-corruption policy, the Group Ethics Officer, within the Group Compliance Department, leads a network of Ethics Officers who monitor the deployment of the compliance program within the relevant entities/affiliate of the Casino Group.
- The Ethics Officer is responsible for ensuring the implementation of the anti-corruption program within the local entity/affiliate. As a facilitator and leader, he/she contributes to the prevention of corruption risk by promoting professional practices that are consistent with the Group’s commitments.
- The managers of Casino Group entities/subsidiaries are responsible for disseminating the anti-corruption compliance program to their employees and ensuring that it is respected, with the aim of enabling them to understand and apply this program in their daily work.
Each employee is expected to comply strictly with the laws and regulations and the Group’s anti-corruption compliance programme.
Each employee is required to demonstrate loyalty and honesty and to behave with exemplary personal and professional ethics.
Each employee must ensure compliance with the rules set out in the Code of Ethics and Business Conduct and the procedures that supplement it, the main principles of which are outlined below.
Conflict of interest
Each employee must exercise his or her responsibilities in good faith and with loyalty to the Group. They must take care to avoid any situation of conflict of interest.
Fight against corruption and influence peddling
The Group condemns corruption in all its forms and ensures that its employees strive to uphold this principle. The Group is firmly committed to strictly complying with the regulations on the fight against corruption and influence peddling in France and in the countries where it operates, to deploying a continuous improvement approach to detect and prevent the risks of corruption and influence peddling, and to sanctioning reprehensible or non-compliant practices. As part of their duties, the Group Ethics Committee and the Group Compliance Officer ensure that an anti-corruption and influence peddling system that complies with the legal requirements is put in place and that it functions properly.
Respect for free competition
The Group prohibits any practice aimed at restricting competition.
Confidentiality of information
All confidential or sensitive non-public information, of any nature whatsoever and on any medium whatsoever, must be protected, even in the absence of a formal obligation of confidentiality or secrecy, whether it concerns information relating to the Group, its employees or third parties (in particular partners, customers, suppliers or service providers).
Protection of personal data
The Group is very careful to respect the privacy of its employees and that of third parties with whom it has relations (customers, suppliers, etc.) as well as the protection of personal data. This data must be used fairly for a precise, explicit and legitimate purpose and only be kept for the time necessary for the purpose of processing.
Respect and protection of the Group’s assets
Each employee must safeguard the Group’s tangible and intangible assets and, in this regard, ensure that none of its assets are damaged, stolen, used or destroyed inappropriately. They must use the Group’s assets in the course of their duties, in accordance with their professional purpose and in compliance with the laws, regulations and charters and procedures in force within the Group.
Accuracy and reliability of business and financial data
The Group must have accurate business and financial data. The books and records of each Group entity must be kept in sufficient detail and accuracy to reflect all transactions correctly. Controls and approval procedures must be consistently applied.
It is the responsibility of each employee concerned to ensure that financial and business reports, as well as information on any medium supporting the data contained in such reports, are accurate, reliable and complete. In particular, all information relating to payments made or received by any Group entity must be accurately reported and retained in accordance with applicable law.
Prevention and alert
Those people wishing to report or disclose information or facts, under the conditions of the Law n° 2016-1691 of December 9th, 2016 (Sapin II Law) as amended by the Law n°2022-401 of March 21st, 2023, may contact their Compliance Officer and use the specific confidential ethics alert lines set up within each Group entity or contact directly the Group Compliance Officer at the following email address : contact75c@deontologue.com.