Code of conduct
Committed to Ethics &
Committed to Ethics & Transparency
We are committed to maintaining high ethical standards in all our business activities, whether conducted internally by our employees or externally by the third parties we work with and engage.
Our suppliers’ business activities should also be guided by the interests of all stakeholders, including our clients and our employees.
Due care must also be taken by our suppliers to avoid any conduct that could discredit or harm our clients, our company, our employees or the interests of our profession.
This Code of Conduct has been written for all our subcontractors, suppliers and service providers (our “Suppliers”) to explain and help them understand and adhere to the same standards and rules as adopted by our group.
In agreeing to provide goods or services to us directly, or indirectly to our clients, our Suppliers acknowledge that they have read and understood all provisions of this Code of Conduct and unconditionally agree to comply with it, in all business dealings related to the Mazarine Group.
Our Suppliers also agree to communicate these standards to their own subcontractors, providers and staff performing services for us or our clients.
Any questions may be raised with the relevant project team, our upper management or our HR Department and any potential violations of these standards should also be reported to them.
Code of conduct
01. Human Rights
Our Suppliers must commit to implementing fair, ethical working conditions that respect fundamental human rights recognised worldwide, including the Universal Declaration of Human Rights, all international commitments and the Conventions of the International Labour Organization.
Our Suppliers must effectively promote and respect the free exercise of human rights, not only those relating to the workplace and working conditions but also those relating to freedom of speech and association.
No forced, involuntary or hazardous labour may be used and employees must not be ill-treated for disciplinary purposes.
Employees and staff must be treated with dignity and respect and provided with a healthy, safe working environment free from any discriminatory practices, harassment or abusive conduct based on race, religion, beliefs, gender, nationality, ancestry, citizenship, political affiliation, union membership, sexual orientation, disability, age, gender identity or expression, pregnancy, personal appearance or family responsibilities or on protected veteran, military, parental or marital status, or any other protected status.
No Child Labour
Work by children under the age of 16 is strictly prohibited. In countries where local laws set a higher age for child labour or set an age for completion of compulsory education higher than 16, the highest age is applicable.
Any work that could jeopardise a child’s physical, mental or moral health, safety or integrity should not be done by anyone under the age of 18.
Any children working as performers (models/actors) for our Suppliers must be hired in strict compliance with all local regulations governing young workers in this industry (age requirements, working time and periods, minimum wage, payment terms, health and safety and general working conditions).
No Forced Labour
Any use of forced labour, undeclared workers, slavery, servitude or trafficking in human beings by our Suppliers, any withholding of identity papers or work permits, any practices requiring workers to deposit a bond and the use of any other type of constraint is strictly prohibited.
All workers are entitled to accept or leave their employment freely. Our Suppliers may not require workers to work to repay a debt owed to them or to a third party.
We expect our Suppliers to treat all workers equally and fairly.
Our Suppliers may not engage in any kind of discrimination (in particular with regards to wages, hiring procedures, access to training, promotions, maternity protection, retirement or dismissal or redundancy procedures) based on sex, race or ethnic origin, religion, age, disability, sexual orientation, political affiliation or beliefs, union membership, nationality, gender identity or social background.
Freedom of Association and Political Involvement
Our Suppliers must respect and recognise the freedom of association of workers and their right to negotiate collectively and create or join the labour organisations of their choice without any sanction, discrimination or harassment
Our Suppliers should also respect the personal political commitments of their staff and ensure that they only act in that respect in their own personal name and never as a representative of our Suppliers, our company or our clients.
No Harassment or Abusive Conduct
We expect our Suppliers to treat their employees with respect and dignity.
Our Suppliers should not tolerate or engage in any form of violent or abusive behaviour such as corporal punishment, physical, sexual, verbal or psychological harassment, workplace bullying or any other type of abusive conduct. Our Suppliers are committed to avoiding any practices that could create an intimidating, hostile, demeaning, humiliating or offensive environment.
02. Labour Law & Social Responsibility
Our Suppliers are expected to exhibit exemplary social responsibility in their conduct and to ensure safe and healthy working conditions.
Working and production conditions, including health and safety in the workplace, pay, working time and minimum age requirements must comply with all applicable regulations and laws.
No Illegal, Clandestine or Undeclared Employment
Our Suppliers are required to comply with all applicable regulations to prevent illegal, clandestine and undeclared employment.
Wages and Benefits
Our Suppliers must comply with all local laws and regulations governing working time.
The total number of hours worked each week, including overtime, may not exceed the maximum number imposed by law.
The employees of our Suppliers must be entitled to the rest periods and the minimum number of days of leave under applicable laws.
Health and Safety in the Workplace
Our Suppliers are expected to provide their employees with a safe, healthy workplace environment to avoid any accidents or injuries caused by, related to, or resulting from their work, including when using equipment, tools and business premises and when on business trips.
Our Suppliers must provide clear information on the applicable safety measures. They should also set up procedures and run training sessions to detect, avoid and minimise any hazards that could affect the health or safety of staff.
Our Suppliers must comply with all applicable local and international regulations and laws in this respect. These same principles apply to any housing provided by our Suppliers.
03. Transparent, Responsible Communications
We are committed to honesty, accuracy and transparency in communications.
We strive to build up public trust by providing all information necessary for informed, responsible decision-making. We expect the same high standards from our Suppliers in this respect.
We expect our Suppliers to adhere to the highest standards of accuracy, honesty and truth in the information shared or released.
Our Suppliers should not intentionally disseminate false, misleading or incomplete information, to avoid any misinformation.
Our Suppliers must take all reasonable steps to evaluate the reliability of and basis for claims, or other information provided, before releasing it.
Our Suppliers agree to take prompt action, after coordinating with us and/or our clients, to appropriately respond to any crisis or public controversy in which we may be implicated.
A lack of transparency in communications can damage the reputation and integrity of our Suppliers, our company or our clients and create an unacceptable level of risk.
Our Suppliers must not act in any way that could appear to be an attempt to deceive public opinion when presenting their business activities or special offers, performing services or taking a public stand.
We encourage our Suppliers to always be as transparent as possible.
Our Suppliers should be extremely attentive to their public statements, particularly those made online and when using social media, and must ensure that any statements made are not attributed to us or our clients.
All communications must strictly comply with our Suppliers’ commitments regarding confidentiality and professional secrecy.
Our Suppliers are required to provide clear, accurate information about the methods and resources used, production sites and the characteristics of the products or services supplied, and should not make any misleading statements.
04. Confidentiality & Ethical Conduct
We often have access to confidential information as part of our work, that is not publicly available and could seriously harm our interests or those of our clients if disclosed.
Our Suppliers must protect confidential and other sensitive information about us and our current, former and potential clients. They may not use this information to further their own interests or in breach of applicable insider trading regulations.
We apply a zero-tolerance policy for money laundering, bribery and corruption and trading in influence.
Protection of Deliverables and Intellectual Property Rights
Our Suppliers must respect and protect our intellectual property rights and those of our clients, in the relevant marketplaces.
Our Suppliers should take all necessary steps to protect our resources and assets (electronic and non-electronic graphics delivered) and those of our clients, including intellectual property rights, and are committed to preventing counterfeiting through a strategy of prevention, cooperation and communication.
For example: all finished or semi-finished products bearing distinctive signs owned by us or our clients that have not been ordered or have been refused or discontinued, must be destroyed.
Protection of Personal Data
Our Suppliers must comply with all applicable personal data protection and privacy laws and regulations, including the European Union’s General Data Protection Regulation (GDPR) and any applicable laws relating to the collection, storage, transfer and processing of personal data.
Our Suppliers should take all necessary steps to protect the confidentiality of any trade secrets or other non-public information received in the course of our business relationship. They must agree to prevent any access by unauthorised third parties, using appropriate security measures.
Prevention of Insider Trading
We require our Suppliers to comply with all applicable insider trading laws and legislation. They should not use confidential information for personal purposes, including to sell or buy our client’s shares or any related derivative financial instruments, based on insider information, either directly or indirectly.
No Bribery or Corruption or Money Laundering
Our Suppliers are expected to comply with all applicable bribery and corruption laws and to take appropriate steps to prevent, detect and sanction any bribery or corruption or trading in influence, whether direct or indirect, within the scope of their business activities.
We ask our Suppliers to take all appropriate steps to prevent their operations from being used as vehicles for money laundering.
Gifts, Invitations and Improper Incentives
Our Suppliers must not directly or indirectly accept, offer, provide or give any staff members of our company or our clients or any government officials or public officials any gifts, bribes or anything else of value, any personal incentive or any advantage that could be interpreted as an attempt to directly or indirectly obtain a service, business or advantage or influence our business decisions or those of our clients.
Business gifts and entertainment must meet applicable legal, ethical and cultural standards.
They may be considered acceptable expressions of courtesy for good business relations if limited in scope and value, given transparently from time to time and permitted under applicable local laws and provided that they are not restricted under the client’s own policies and are not offered with an expectation that something will be received in return.
05. Honest Relationships & Trading
We require exemplary integrity from our Suppliers in the conduct of their business activities. We expect them to conduct their business in full compliance with local, national and international laws.
Rules of Engagement
Our Suppliers must respect the customs, rules, practices and codes of conduct applicable in our industry and practice areas in all countries where we operate, including those related to our clients, colleagues and partners.
Prevention of Conflicts of Interest
We ask our Suppliers to comply with all applicable conflicts of interest laws and to make every effort to prevent situations arising that create a conflict of interest within the scope of their business relationship with us and our clients.
Our Suppliers should avoid any conduct and circumstances that appear to compromise the ability to make sound business decisions or create actual, potential or perceived conflicts between personal and professional interests, within the scope of their business relationship with us and our clients.
They should spontaneously disclose to us any personal relationships they, or any of their employees, have with any of our employees, officers or directors or any employee, officer or director of one of our clients for which the Supplier has agreed to provide a service, or any other potential conflict that may be identified.
Respect for Competition
Promoting healthy, fair competition between professionals preserves an ethical climate while fostering a robust business environment.
Our Suppliers must be committed to ensuring compliance with the applicable competition law. This includes prohibiting any abuse of a dominant position, concerted practices and unlawful agreements between competitors.
Qualifications and Expertise
Our Suppliers should only accept work for which they are suitably skilled and experienced. Where additional expertise is required, they should collaborate with our project team to determine the best way of obtaining the necessary skill base or resources to serve our clients’ needs.
Our Suppliers should stay informed and educated about practices in the profession to ensure ethical conduct and a delivery of quality products and services for us and our clients.
Environmental Impact - Sustainable Development
We encourage our Suppliers to consider the environmental impact of the goods and services provided in their business dealings with us. This includes, but is not limited to, a commitment to always use the tools and resources with the smallest environmental footprint: minimising our carbon footprint through effective travel, use of recycled materials and recycling of waste products, responsible wastewater and solid waste disposal, resource utilisation reduction and so on.
We expect our Suppliers to support staff development and constantly seek to improve team cohesion and the work environment.
Customs and Security Authorities
We require our Suppliers to comply with applicable customs laws, including those relating to imports and the ban on the transhipment of goods to the importing country.
06. Inspections and Audits
We reserve the right to confirm compliance with all the principles set out in this Code of Conduct by conducting compliance audits at the premises of our Suppliers and their own business partners, suppliers and subcontractors.
Our Suppliers must provide all necessary information and facilitate access by our representatives tasked to check compliance with the requirements set out in this Code.
Our Suppliers must strive to improve or correct any problems identified.
We may also support our Suppliers in implementing and applying best practice in order to resolve minor non-compliance issues.
Accurate Records and Access to Information
Our Suppliers are required to keep appropriate records, back-ups and lists to demonstrate compliance with this Code of Conduct.
They must provide our representatives with access to complete, original and accurate records.