Bourbon - Offshore - Surf - SMS manual 2016

45/ Compliance and Ethics Policy / 992

Comp liance and Ethics P olicy
B-POL-01.0034
Version 02. Original date: 23 December 2013. Version date: 18 June 2015. Valid version only on QMS site.
Policy prepared by: Group Compliance Officer. Approved by: COMEX. Validated by: Quality Director of BOURBON.
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Compliance requires BOURBON emp loyees to abide by laws and regulations as well as by
BOURB ON self-regulatory procedures and policies, internal directives and ethical principles.
Compliance and Ethics Policy is designed in the fra me of BOURBON Compliance Pr ogram. It is a key
pillar of our sustainability.
BOURB ON is committed to conducting business with integrity, transpa renc y and ethics, in
compliance with applicable laws and regulations and with BOURBON’s policies and guidelines.
Business partners and third parties are strongl y encouraged to adopt BOURBON compliance
standards.
The BOURBON Compliance Program was designed to help BOURBON and its employees to secure
business operations. The key elements of BOURBON’s Compliance Program are:
x Tone at the top – comp liance culture: The COMEX, Vice President, Directors and Managers are
committed to promoting compliance and to maintaining a culture of ethical business decision in
respect to laws and BOURBON’s policies. Compliance contributes to the Corporate Social
Responsibility efforts of BOURBON.
x Risk Assessment : The compliance risk assessment is driving constant mitigation plans through the
design and deployment of adequate procedures, which strengthen internal controls activities.
x Policies, Guidelines and Pr ocedures: They are constantly developed to address complex
situations (e.g.: corruption and bribery, facilitation payment, conflicts of interests, gifts and business
courtesy, travel expenses for employees and third parties, charitable and political contributions,
sponsoring, donations, insider dealing, etc.). They provide all employees with guidance, instructions
and tools in relation to expected behavior to adopt while conducting business operations and dealing
with business partners and third parties.
x Commu nication and Training: Regular communication on compliance is settled up. They will
constantly remind employees of the proper expected behavior as well as key points of contact to
whom concerns shall be raised. In addition, compulsory Compliance trainings will be given yearly to
all BOURBON employees. If any concerns arise while conducting business, it is important to address
the potential issue with the highest care together with the Corporate Compliance Team, rather than
ignoring it.
x Monitoring and Review: BOURBON Compliance Program is driven by a Group Comp liance
Officer together with his Corporate Compliance Team. Compliance chimney at Region/Affiliate level
directly reports to the Corporate Central Compliance function.
x Sanctions : BOURBON has ZERO TOLERANCE to fraud and corruption. Any breach will lead to
adequate sanctions for interested employees or business partners.
Intangi ble Pr inciples:
x Compliance with Laws: BOURBON will conduct its business in accordance with all applicable
international and local laws and regulations.
x Compliance with Ethics: Maintaining the trust and confidence of our stakeholders, employees,
clients, third parties and business partners is highly connected to the respect of ethics principles
enacted by BOURBON.
x Compliance with anti-bribery and corruption Compliance guidelines: BOURBON prohibits the
offering, giving, accepting or soliciting of improper payments, regardless of its form (gifts, facilitation
payment, donation, sponsoring, conflicts of interests, etc .) whether made directly or indirectly, for
purposes of influencing any act or decision to improperly obtain or gain business.
x Compliance with Internal BOURBON rules: BOURBON requires all employees to respect and apply
internal guidelines and procedures.
Chr istian Lefèvre
Chief Executive Officer
Gaël Bodénès
Chief Operating Officer
Nicolas Malg rain
Chief Financial Officer
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