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.
- Casino Group’s anti-corruption commitment is driven at the highest level of the Group: the Chairman and Chief Executive Officer is providing Casino Group with the appropriate structures to ensure that the law is respected both in spirit and to the letter and that a culture of corruption prevention is created.
- The anti-corruption organisation is supervised by the Group’s Board of Directors. The Governance and CSR Committee from which it stems, oversees in particular implementation of anti-corruption procedures and guidelines within the Casino Group.
- A Group Ethics Committee was formed on the initiative of Casino Group’s General Management to promote and disseminate the anti-corruption policy within Casino Group’s management and daily practices. It is mainly tasked with:
- Defining the framework of the ethical system and the associated procedures,
- Promoting the presentation, understanding and implementation of the Group’s ethical system, particularly when it comes to anti-corruption,
- Monitoring the implementation of the network of compliance officers within the Group,
- Ensuring that training and awareness-raising initiatives are carried out by the operational entities.
- The Group Risk and Compliance Department (DRCG) is responsible for drawing up and proposing the basic principles of Casino Group’s anti-corruption policy to the Group Ethics Committee and for monitoring implementation thereof. The Group Risk and Compliance Officer is delegated authority by the Chairman and Chief Executive Officer and chairs the Group Ethics Committee. He also coordinates the network of Compliance Officers who relay his tasks and those of the Group Ethics Committee to the various Casino Group entities. The Group Risk and Compliance Officer reports to the Governance and CSR Committee and the Group Audit Committee on the policies and action plans deployed every six (6) months.
For further information, the Groupe Risk and Compliance Officer can be reached at the following e-mail address: firstname.lastname@example.org
- The Compliance Officer is responsible for ensuring the implementation of the anti-corruption programme defined by the Group Ethics Committee within the boundaries of his or her entity. As a facilitator and coordinator, he or she contributes to the prevention of corruption risks by encouraging professional practices that comply with the Group’s commitments.
- The managers of the Casino Group entities are responsible for disseminating the anti-corruption compliance programme to their employees and for ensuring that they are aware of it and apply it in their daily work. In addition to the teams in charge of the anti-corruption compliance programme, the internal audit and/or compliance departments in certain Casino Group entities (Corporate, Monoprix, Cdiscount, IGC, international entities, etc.) may be called upon to take charge of or monitor certain activities relating to the programme.
Each employee must integrate the principles of Casino Group’s anti-corruption compliance programme in the course of his or her work.
Alongside the 9 principles of the Group Ethics Charter, a Code of Ethics and Business Conduct, rolled out throughout the Group, sets out the rules of conduct, principles of action and ethical obligations. It is supplemented by policies and procedures specific to certain high-risk activities or sensitive processes.
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 : email@example.com.