Ethics and Compliance Program

Following regulatory evolutions, especially the Sapin II Law adopted on December 9, 2016, the Group has strengthened its Ethics and Compliance program so as to be in compliance with the new regulatory requirements and business practices.

The anti-bribery program now includes the following:

  • Communications to all employees explaining that a zero-tolerance policy against bribery is part of Technicolor’s core values; and regular updates on the anti-bribery program at the Audit Committee of the Company’s Board of Directors and at the Board itself;
  • Code of Ethics & Anti-Bribery Policy: Updated in 2018, to provide practical examples showing employees how to do the right thing when faced with a dilemma. The Travel and Customer Entertainment policy has also been updated to harmonize processes across businesses;
  • Whistleblowing system: Enables all Technicolor employees and partners to report anything that they suspect to be unethical, illegal or unsafe, through a dedicated website or by phone;
  • Risk mapping: Reviewed in 2020 to identify new risks specific to business conduct and to re-assess all of them;
  • Third-party assessments: The Group’s suppliers are required to respect the Anti-bribery Policy, and the Third-Party policy covering our relationship and engagement with agents, consultants, advisors, among others, has been reviewed and communicated to sales and legal teams, in specific training. The sales agent template contract has been streamlined with new anti-bribery requirements;
  • Training: Courses on anti-bribery are developed and delivered within the Group to the staff categories with the highest level of exposure, including targeted E-learning and on-site training for specific employee categories such as sales, legal, finance or human resources;
  • Accounting control procedures: The internal control and risk management procedures relating to the preparation and processing of financial and accounting information form an integral part of the Group’s anti-bribery measures;
  • Internal control and audit procedures: Internal and external audits are performed on a regular basis, notably covering anti-bribery matters;
  • Tax management: The Group takes a zero-tolerance approach to Tax Evasion or facilitation of Tax Evasion under the law of any city, state or country in which we operate or do business.

Compliance with competition rules and with more general business ethics rules, are at the core of our Code of Ethics. (See chapter 3 of our Universal Registration Document, section “General control environment”).

Product Compliance

Technicolor operates in a worldwide market and thus has to deal with a wide variety of national and regional initiatives governing the environmental performance and risk management associated with its products.

Regarding consumer product health and safety, the Group ensures that all products sold comply with all consumer safety regulations applicable in each country where marketed.

In particular, compliance methods and actions are in place with regard to the RoHS (Restriction on Hazardous Substances), and WEEE (Waste Electrical and Electronic Equipment) European directives, and the REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) European regulation. In other regions, Technicolor complies with similar legislation dealing with the restricted use of hazardous substances within products and systems, and preparing for better end-of-life handling of electrical and electronic equipment waste.

In some emerging markets where safety regulations may not yet be robust, Technicolor applies its knowledge of appropriate product safety regulations to ensure compliance with a higher product safety standard. (Refer to chapter 5 of our Universal Registration Document, section “Product compliance and ban of hazardous materials”).

For more information on Compliance and Compliance Statements, please refer to our CSR Documentation section.

CSR Documentation

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