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.
KNDS France has implemented specific and rigorous policies to select its third parties, ensuring their reliability and compliance with KNDS France’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 KNDS France has implemented a strict policy governing the selection, verification and payment, if any, of this type of partner.
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.
KNDS France has implemented specific and rigorous policies to select its third parties, ensuring their reliability and compliance with KNDS France’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 KNDS France has implemented a strict policy governing the selection, verification and payment, if any, of this type of partner.
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 KNDS France’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 KNDS France’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 KNDS France’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 KNDS France’s risk mapping.
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 KNDS France’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 KNDS France’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 KNDS France’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 KNDS France’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.
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, KNDS France 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.
PRINCIPLES ON POLITICAL CONTRIBUTIONS AND FOR SPECIAL INTEREST REPRESENTATIVES
In accordance with French law, KNDS France prohibits all forms of political contributions in all countries.
KNDS France 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 KNDS France and transmitted to the French Authority for the Transparency of Public Life (HATVP).
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.
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
KNDS France’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.
KNDS France’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.