Ethics and anticorruption
Code of Ethics
Manitou Group has adopted a Code of Ethics to express its ethical principles publicly.
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.
Among the measures that have been implemented:
- A corruption risk mapping
- An anticorruption code of conduct endorsed by all controlled entities
- The assessment of the integrity of third party customers, suppliers and intermediaries 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 disciplinary sanctions for violation of the anticorruption code of conduct
- A specific cycle of the internal control questionnaire dedicated to anticorruption
- Specific procedures and policies on various related topics: a gift and hospitality policy, a conflict of interest management policy, a lobbying policy, an ethics committee charter and an alert procedure.
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 thirtheen (13) categories of ethical violations that can be reported:
- Corruption and influence peddling
- Anticompetitive practicest
- Conflicts of interest
- Discrimination and harassment in the workplace
- Falsification and/or destruction of accounting and financial documents
- Endangering the health or safety of employees at work and damage to the environment
- Fraud and misuse
- Human rights violations
- Insider trading
- Computer fraud
- Attacks on the safety of employees or the workplace
- Violations of applicable internal control rules, and in particular, violation of the limits of power of attorney, delegation of authority (DoA) and/or power of attorney (PoA)
- Violations of the Code of Ethics.
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.
