2.4.3 Acquiring personal advantages and fraud

Conflicts of interest can take various forms, such as (but not limited to):

• Making use of the company’s assets, information or using the position occupied within the company to acquire personal earnings is prohibited. The company’s employees shall not use its name or any other resources belonging to the company to obtain or enhance their personal advantages of any kind;
  
  
• A situation in which an employee claims, receives or accepts the promise, either personally or through a third party, including through a member of their family (relative, spouse, alliance) in order to benefit* from unjustified personal benefits as a result of their position within the company, is considered to be an acquisition of personal unjustified benefits;
  
  * Personal benefit means any kind of gift with a value of more than 100 euros, favour, service, loan, fee, compensation, discount, gratuity, amount of money, material or image benefits, etc.;
  
  
• The company considers acceptable only the modest and occasional attentions, usual in the business environment, so-called ‘business courtesies’ (promotional materials, protocol, etc.). If these attentions become excessive and repeated, they may create a sense of obligation on the part of the recipient. This sense of obligation may be contrary to everyone’s responsibility to act in the best interests of the company and at some point, generous attention may be / become inappropriate, interpretable and with unintended consequences.
  
  
• The situations described above provide a basis for guidance for identifying potential conflicts of interest;
  
  
• In case of any doubts on the matter, the employees may contact the direct supervisor or the Human Resources Department;
  
  
• Requests for personal favours and / or any other form of conduct that are presented as if they were to be performed for a direct superior constitute an abuse of authority.

The Company does not tolerate any fraud actions. Fraud includes any action, as well as failure to act, with the aim of deceiving others (company, partners, public or investors), to take actions that cause economic damage to them.

Thus, theft, falsification of expense reports or timekeeping, improper use of a computer, telephone or company equipment by providing passwords or facilitating access to other employees, suppliers, customers, etc. or improper use of the employees’ discounts or converting them into material / pecuniary form (such as the sale of company products, samples, etc.) are all considered forms of fraud.