54 PROMOTE EXEMPLARY BUSINESS ETHICS PREVENT THE RISKS OF CORRUPTION In accordance with the regulations and its founding values, Cerba HealthCare is firmly committed to conducting its activities ethically and with the utmost integrity and probity across all its entities. COMPLY WITH GUIDELINES ON THE PREVENTION OF CORRUPTION In a context where the fight against corruption and influence peddling is the subject of increasing worldwide attention, and in order to fulfil local regulatory obligations (the Sapin 2 law in France), Cerba HealthCare has developed a corruption prevention programme for application throughout the Group. This programme is governed by an Ethics and Business Conduct Charter and is accompanied by the launch of the new whistleblowing procedure. Any collaborator can therefore raise a concern or report unethical behaviour within the Group via the new secure platform, in addition to his or her direct line-management contacts. These necessary measures to prevent risks are accompanied by the reinforcement of applicable sanctions. FORMALISE POLICIES COMMON TO THE WHOLE GROUP The Ethics and Business Conduct Charter and the Policies appended to it are incorporated into the Rules of Procedure of all our entities that have them. They cover the following topics: anti-corruption, conflicts of interest, gifts, entertainment and hospitality, whistleblowing procedure, third-party approval procedure. These documents define the Group's commitments to fighting corruption and influence peddling and the related expectations we have of our collaborators and third parties with whom we work. RAISE AWARENESS AND MOBILISE ALL OUR TEAMS Our approach that was defined and launched in 2022 is gradually extending over the course of 2023 to include all entities of our Group. It is based on the following priority areas of action: • Corruption risk mapping (Europe in 2022, Africa in 2023); • The roll-out of the Ethics and Business Conduct Charter and its Policies to all our collaborators and in several languages; • A training programme for our collaborators on anti-corruption issues, in the form of e-learning modules; • The implementation of a secure digital platform, accessible to all our collaborators, enabling: – access to all programme documentation; – access to training modules; – management of declarations of conflicts of interest and gifts received or offered; – implementation of the whistleblowing procedure; – implementation of the third-party assessment procedure. By the end of the first quarter of 2023, our anti-corruption compliance programme had reached over 9,000 collaborators.
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