RIGHTS & RESPONSIBILITIES

What is at stake?

International Perimeter of Groupe ADP is committed to conducting business with integrity, transparency and ethics, in compliance with the strictest global laws and regulations and with internal policies and guidelines. Compliance is an essential way of acting for everyone who works for or with any company of the International Perimeter of ADP, at any given time.

International perimeter of ADP compliance program has 6 main steps:

1. “Tone at the top” commitment from leadership and top management
2. Risk assessment
3. Policies & code of conduct
4. Communication & training
5. Monitoring
6. Sanctions

The ADP International
perimeter code of conduct

Our code of conduct defines the foundations of our compliance program: legal and ethical rules, regulations, business considerations and expected behaviors. We have chosen to design ADP International perimeter compliance program in accordance with the highest international standards and have made them applicable to all of our sites in every country.
Regular updates to this code of conduct will add new rules.

Application of the code of conduct

Our code of conduct applies to every employee of the international perimeter of Groupe ADP: entry-level workers and top management, staff at our headquarters as well as to anyone working on behalf of ADP International perimeter (sub- contractors, interim employees, etc.).

Our code of conduct also applies to our business partners and our suppliers everywhere in the world. We will consider ending business relationships with companies who do not meet our standards of compliance and ethical behavior; and when feasible, we include compliance benchmarks and boundaries in the terms of our contracts with third parties.

In short, we expect everyone who works for or with ADP International perimeter to understand and respect our code of conduct. Regular updates to this code of conduct will add new rules.

The Rights & Responsibilities of ADP International perimeter employees

All ADP International perimeter employees –including new employees– are expected to know, understand and fully respect our code of conduct. ADP International perimeter will ensure a training related to Compliance.

The document is always available for consultation at every ADP International perimeter site. Disregard of code of conduct cannot and will not be excused by claiming ignorance, or by stating that a colleague or manager gave an order to do so. If ever any ADP International perimeter employee is concerned that our code of conduct is not being respected, he or she must speak up: first to the line manager and then to the managing director. Alternatively, if an employee wishes, he can speak directly to the ADP International perimeter compliance team by sending an e-mail to: ethic.compliance.international@adp.fr.
Our goal is to achieve a state where everyone who works for or with ADP International perimeter behaves in a fully compliant way, naturally and instinctively.

The Rights & Responsibilities of ADP International perimeter managers

ADP International Perimeter managers transmit the right tone from the top, delivering consistent and clear messages.
They lead by example, with both their words and their behavior.

Our managers understand that being compliant is no longer just about doing the right thing. It’s also about mitigating risks, ensuring operational excellence, and ultimately being financially successful, which is why they lead by example, with irreproachable behavior.

Managers are both accountable to and responsible for their teams. They must do everything to create a fully compliant workplace. They must ensure all team members understand the way that our code of conduct guides their work. Managers are not in charge of training their teams, but they are expected to accompany the team members through the training process. Managers must also ensure that their teams feel free to speak out about concerns or code violations without repercussions or retaliations, and they must deal with any issues that are raised by team members swiftly and completely.

Deviations & Sanctions

For ADP International Perimeter employees, deviations of compliance are ranked from 1 to 4. Sanctions, if any, will be handled on a case by case basis and according to the disciplinary rules of the company to which the employee is belonging.

Summary