“Technicolor’s Code of Ethics and related policies guide and support our employees each day in accomplishing the Company’s business objectives with ethical integrity.”
-Sophie le Ménahèze, Ethics Compliance Committee Secretary
Comprehensive Ethical Business Practices at the Heart of our CSR Policies
The success of our business and CSR strategies is inextricably linked to how we are perceived by all our stakeholders and our ability to demonstrate the highest ethical standards in our business practices.
Code of Ethics
Created in 1999 and regularly updated, the Code of Ethics establishes the foundation of the Group’s core values and requires all employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. The Code of Ethics details the specific rules to guide employees in their day-to-day activities. Technicolor has also adopted several additional key policies including a Whistleblower Policy, Anticorruption Policy and Sourcing Ethics Policy. Ethical behavior and observance of laws are two main ingredients in building our reputation for uncompromising integrity.
The Code of Ethics, which is distributed to all Technicolor employees, has four basic principles:
- Respect for People
- Respect for the Environment
- Valuing Integrity
- Valuing Creativity
- Corporate Social Responsibility
- Principles of Disclosure
- Human Rights
- Development & Diversity
- Health & Safety
- Eco-Design, Materials and Waste Management
- Suppliers, Sub-Contractors, and Responsible Purchasing
- Citizenship Initiatives
Ethics Compliance Committee
The Group also created an Ethics Compliance Committee in 2006, which is responsible for all ethical issues related to Technicolor’s activities and which is governed by the Code of Ethics and the Charter for the Ethics Compliance Committee. This includes implementing any new policies if needed, training on existing policies, and investigating any and all reports of unethical behavior. It meets at least three times per year and more frequently when required.
Ethics Programs and Initiatives
Over the last several years, the Group has deployed many ethics training programs. Several online training sessions were launched to educate employees on various ethical rules and obligations, including bribery, competition and fraud. Some dedicated training sessions were also organized on specific sites or for specific functions and via Webex conferencing. These training sessions involved more than 10,000 employees from 2010 through 2016.
Financial Ethics Charter
To reinforce awareness of the ethical dimension of finance activities, Technicolor has published an Ethics Charter specific to Finance personnel and activities. It is an extension of the Company’s Code of Ethics, which applies to all employees. The Financial Ethics Charter was first published in December 2005, is signed by the Chief Executive Officer and the Chief Financial Officer, and is distributed to key persons within the Finance organization.
The revised Technicolor Whistleblower Policy, launched in May 2006, is designed to make it easier for employees to share questions, concerns, suggestions or complaints about financial, accounting, banking or anti-bribery matters with an appropriate person.
Like the Code of Ethics, the Whistleblower Policy is widely communicated to all Technicolor employees.
The comprehensive Technicolor commitment to prevent corruption, formalized in our Anti-corruption policy, seeks to not only comply with the U.S. Foreign Corrupt Practices Act (“FCPA”) and other anti-corruption and anti-bribery regulations like the UK Bribery Act and the French Criminal Code, but to avoid even the appearance of questionable conduct in connection with Technicolor operations.
Data Protection Policy
A formal Data Protection Policy issued by the Technicolor Ethics Compliance Committee governs legal compliance aspects. The purpose of this policy is to ensure that Technicolor, its staff, contractors, suppliers and other people working on its behalf comply with any applicable provisions of the Data Protection EU Directive where and when appropriate, as well as with any applicable other legislation when processing personal data. An independent Data Privacy Officer is also registered with the French CNIL.
For more information on Ethics, please refer to our CSR documentation below.
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