Anti-Corruption Code of Conduct

The purpose of this code of conduct (hereinafter the « Code ») is to provide a guide regarding the fight against corruption, to identify and clarify the different forms that corruption may take, to specify the rules to follow to ensure the integrity and the values of IELO, and to specify as well the preventive measures that IELO implements.

IELO’s success is based notably on the trust in professional relationships for all IELO employees, managers and consultants (hereinafter referred to as « IELO Collaborators »), as well as for all third parties with whom IELO may associate with in the course of its business, including its customers, suppliers and subcontractors (hereinafter referred to as « Partners »). We must continue to act with integrity and adopt a fair and irreproachable attitude.

Consequently, compliance with the Code must be everyone’s business, regardless of hierarchical level or location. We all share the responsibility for maintaining a trustworthy, corruption-free environment of which we can be proud of, in line with IELO’s values.

We expect from Partners and IELO Collaborators that they adopt behaviors which reflect IELO’s values and in particular its commitment to comply with anti-corruption rules, and thus that they comply with the principles set out in the Code.

IELO also reminds that the types of behaviors described in the Code are punished by French law. The applicable sanctions in terms of corruption are very significant and may take different forms, such as: fines, imprisonment, disciplinary sanctions for IELO Collaborators in accordance with IELO internal policy, disqualification of public call for tenders, termination of Partners’ contracts…

The Code does not list all the prohibited behaviors in an exhaustive manner. In case of doubt, and for any question, IELO Collaborators and Partners are invited to reach out to IELO’s Legal team (juris@ielo.net).

All reports regarding potential corruption events will be examined and investigated, if needed, and shall be treated with the highest possible degree of confidentiality. IELO will not apply retaliatory measures against people who have made a good faith report.

In this Code, « IELO » means IELO-LIAZO GROUP and all its affiliated companies.

1. Corruption, influence peddling, and facilitating payments: the prohibited behaviors within IELO

The purpose of this section is to describe (not exhaustively) the main behaviors prohibited by law and not tolerated by IELO, and to provide some examples of those behaviors.

1.1 Corruption

Corruption may appear in the private or public sector.

Corruption in the private sector is the fact for a person (i) to offer or grant something (ie : invitation to sports events/shows, journeys, prestigious restaurants, money, hiring of family members…) in exchange of an undue advantage (ie : signature of a contract, disclosure of confidential information, preferential treatment…) and/or (ii) to ask for, accept, or receive something to provide an undue advantage.

Within the public sector, corruption means to promise, offer, or grant to a public agent, directly or indirectly, an undue advantage, for this public agent to accomplish or refrain from accomplishing, an act in the performance of official duties. The fact to grant undue advantages to a family member of a public agent is also a form of corruption.

A public agent may be defined as a person (i) holding a legislative, executive, administrative or judicial office, (ii) elected or appointed to provide a public service and/or exercising a public function, (iii) candidate to a political mandate or holding a high ranked office, with discretionary power, in a political party.

Example of corruption : if you are in charge of a project for which you organize a call for tenders with several suppliers, and if one of those suppliers invites you to attend the final game of a prestigious sport tournament, or offers you a ski trip for you and your family, in exchange of the granting of the call for tenders, then accepting this invitation would be an act of corruption.

1.2 Influence peddling

Influence peddling is the fact (i) to offer or grant to a person, directly or indirectly, an undue advantage for this person to abuse of its effective or supposed influence in order to obtain an undue advantage from an administration or a public authority and/or (ii) to ask for or accept from a person, directly or indirectly, an undue advantage to abuse from its own effective or supposed influence in order to obtain for that person an undue advantage from an administration or a public authority.

Example of influence peddling: IELO would like to participate to a call for tenders of a public institution, you meet a person who indicates knowing the public agent in charge of making the final decision for the granting of the call for tenders of this public institution, and this person further indicates that if you provide him/her with tickets to a prestigious sport tournament, or if you offer him/her a certain amount of money, this person will highlight IELO’s offer to the public agent, to influence the public agent’s decision. If you accept such proposition, this is an act of influence peddling.

1.3 Facilitating payments

Facilitating payments is the fact to pay, directly or indirectly, in an undue way, a public agent for the performance of administrative formalities, which should be obtained by standard legal ways (ie: issuing of an authorization or a permit).

All those types of behaviors are prohibited within IELO. In case of doubt, please reach out to IELO’s Legal Department.

2. Gifts, invitations, entertainments (offered or received): applicable rules within IELO

The granting or acceptance of gifts, invitations to events or to the restaurant, or any other advantages of the same nature (hereinafter the « Gifts ») is part of business life and may contribute to establishing or developing business relationships.

Nevertheless, this type of advantage may violate the Code and the applicable laws when its purpose is to influence certain transactions or to obtain an undue advantage, and/or when the amounts at stake are disproportionate.

In order to evaluate the risk associated with each advantage, IELO provides the following recommendations:

• The value of the Gifts must be equal or inferior to 200 euros.
• The Gifts must be occasional.
• The Gifts must be made in a transparent manner.
• The Gifts must be declined if their purpose is to influence an imminent decision.

Also, invitations to restaurants must be made in a standard business relationship manner and be of a reasonable amount.

In a general manner, any involved person must ask himself/herself the following questions: is the value of the Gifts reasonable? Is the frequency of the Gifts reasonable? Does the recipient of the Gifts have any influence on the execution of future contracts? What intent is pursued with those Gifts?

Prior to accepting or offering Gifts, any person must ensure to act in compliance with the Code. Any IELO Collaborator must obtain prior written agreement from his/her director and may reach out to the Legal Department in case of doubt (juris@ielo.net).

3. Preventive measures implemented by IELO

Information and advice: any person with questions relating to corruption may reach out to his/her director or to the Legal Department (juris@ielo.net).

Training: IELO will regularly organize sensibilization trainings for IELO Collaborators.

Publication of the Code: IELO makes the Code available to the IELO Collaborators and the Partners, for each person to be able to identify and prevent corruption risks in the course of his/her activities, and to ensure that IELO’s position on the matter is clearly communicated and easily accessible.

Reports: IELO Collaborators and Partners have the responsibility to help implementing IELO’s policy in favor of the fight against corruption.

IELO implements a system to collect reports. Any person can activate this system by sending an e-mail to juris@ielo.net. IELO takes violations of the obligations of this Code very seriously and undertakes to deal promptly with all reports.

The identity of the person who made the report, the nature of the communicated information, and the identity of the persons mentioned in the report, shall remain confidential as much as possible. A person who made a report through this system shall not be sanctioned if such report was made in good faith.

Responsibility of managers: IELO expects from all managers that they comply with the Code and promote a work environment in accordance with IELO’s values, free from any form of corruption. Like any other IELO Collaborators, managers are bound to act in compliance with the Code and will be subject to disciplinary measures if they ignore, tolerate, or act in violation of the Code. Furthermore, if a IELO Collaborator or a Partner makes a report directly to a manager, the manager must notify immediately the Legal Department of such report (juris@ielo.net). It won’t be tolerated that managers do not transfer a report or adopt behaviors of retaliation towards a IELO Collaborator or a Partner which made a report.

4. Evolution of the Code

IELO reserves the right to modify this Code at any time. The last currently available version of the Code can be obtained upon written request to IELO.

Code version: v1.0 – January 8th, 2025