Anti-bribery Framework
Code of Ethics
Manitou Group has adopted an ethical charter as an expression of its values. Deployed at all levels of its organization and in all of its business activities, it was conceived as a frame of reference for Manitou Group to conduct both of its internal and external business activities with integrity, responsibility and in a socially responsible manner.
Anti-bribery measures
Manitou Group pays particular attention to compliance with current legislation and the actions required to comply with and adapt its activities to new regulations as well as national and international standards. Thus Manitou Group has organized itself to adapt its practices and procedures in order to comply with the French law related to transparency, fight against corruption and modernization of economic life (article 17 of the law 2016-1601, known as law Sapin) dated December 9, 2016.
Manitou Group, in addition to its internal audit department, has set up a risk and compliance department.
A working group, under the responsibility of the Compliance Vice President, has been established to implement the eight pillars described in the Sapin 2 law.
Among the measures that have been implemented:
• A risk mapping carried out by an independent expert
• An updated code of conduct and its endorsement by all controlled entities
• The evaluation of third party customers and suppliers and the implementation of a sustainable monitoring system
• The reinforcement of accounting controls on risky expenditures
• Online and face-to-face training for group employees
• An internal and external alert system managed by an independent service provider
• A list of sanctions formalized in the "règlement intérieur"
• A specific cycle of the internal control questionnaire dedicated to anti-bribery
In addition:
• The working group was informed of the recommendations of the AFA (Agence Française Anti-corruption).
• The Middlenext anti-corruption code was adopted by Manitou Group, a gift and hospitality policy, an ethics committee charter and an alert procedure were deployed by the group
Code of Conduct for the Manitou Group Employees
The whistleblowing system
In addition to the usual existing channels, Manitou Group has set up an outsourced alert system that allows employees and external actors to report, within the limits of what is authorized by law, any violation of the five (5) categories of ethical matters that may be the subject of a report:
- Fight against corruption;
- Anti-competitive practices;
- Conflicts of interest;
- Combating discrimination and harassment in the work environment;
- Violation of the applicable internal control rules of the Group and in particular the violation of the limits of power of attorney (PoA), and/or delegation of authority (DoA).
This system, which offers confidentiality and anonymity (when permitted by law), is available 7 days a week, 24 hours a day.
Manitou Group guarantees the protection of the whistleblower when the report is made in good faith.
Charter of good practices governing the relationships between large customers and SMEs
Charter of the "10 Commitments for Responsible Purchasing":
- Ensure financial fairness to the suppliers
- Foster the collaboration between major customers and strategic suppliers
- Reduce the risks of reciprocal dependencies between the customers and suppliers
- Involve the large customers in their sector
- Evaluate the total cost of the purchase
- Integrate environmental issues
- Ensure the territorial responsibility of its company
- Purchases: a function and a process
- A Purchasing function responsible for the overall management of the supplier relationship
- Set a consistent purchaser remuneration policy
Joining the United Nations Global Compact
Since 2015, Manitou Group has been a signatory to the United Nations Global Compact. Initiated by the UN, the initiative seeks to integrate ten universally recognized principles relating to human rights, working conditions, the environment and the fight against corruption into the company's strategy and activities.
