GEISMAR CODE OF ETHICS

GEISMAR operates in a complex global environment and, in so doing, respects cultures and regulations.

All of our employees have an obligation to show respect, exemplarity and responsibility on the basis of the common values and principles which we have shared since the creation of GEISMAR in 1924.

The Code of Ethics is the formulation of the values that each employee must embody, on a daily basis, by his activity and his behaviour regardless of his position. The objective of the Code of Ethics is to help each one adopt the proper behaviours and make the right decisions in real life working conditions.

The Code of Ethics not only serves as a reminder of the obligation to comply with the rules and regulations where we operate but also to offer our employees and those who work with them a guide of the rules that cannot be waived.

Each one of us has the responsibility and the obligation to be aware of these values. This Code of Ethics meets this objective and its application is the responsibility of all.

OUR COMMITMENTS

Respect for the Rights of Individuals

Respect for individuals has been at the heart of GEISMAR’s priorities since its creation. GEISMAR places its employees at the centre of its concerns regardless of their position in the hierarchy. GEISMAR is committed to ensuring that its employees are driven by solidarity, mutual trust, information sharing for the benefit of the collective interest and exemplarity.

Equality – Diversity – Fight against discrimination.

GEISMAR pursues a human resources policy that guarantees equality between men and women and commits against all forms of discrimination, be they racial, age-related, disability or otherwise.

GEISMAR is committed to promoting actions which:

• Improve gender diversity in recruitment in order to increase the employment rate of women in the company;
• Promote balanced representation of men and women at all levels of responsibility;
• Guarantee equal pay for men / women for equivalent positions and responsibilities;
• Fight sexual and moral harassment.

Social and environmental responsibility

GEISMAR reaffirms its commitment to the following principles of social responsibility, including:

• The application of national laws and applicable international conventions that protect the dignity, respect and freedom of employees;
• A safe and healthy work environment that ensures physical and mental integrity; the health and safety of its staff being a top priority;
• The right for employees to organize and take part in collective bargaining;
• The employment of a permanent staff whose workforce is adapted to the sustainable level of activity, professional training, compliance with regulations on working time, employee participation in a process of continuous improvement.

GEISMAR is committed to reducing and controlling its environmental footprint, promoting safety at work, ensuring social cohesion and employee development.

The preservation of the health and physical integrity of its employees is ensured by GEISMAR by putting in place a strong and ambitious policy for the prevention and reduction of work accidents and occupational diseases

Compliance with export and trade control rules

All employees involved in international business operations shall comply with the laws and regulations governing export restrictions on products and services. Employees may request the support of Management if necessary.

Political activities

The legislation on the financing of political parties varies from country to country. In this context and in order to avoid any ambiguity, the payment of funds and / or the provision of services on behalf of GEISMAR to a political party or organization and political figures is prohibited.

Image and brand of the company

The GEISMAR brand is an asset that every employee must protect. It makes us unique vis-à-vis our stakeholders. It reflects the identity, not only through our visual communications but also through the individual and collective behaviours of our employees.

Each employee must act as a brand ambassador and protect the reputation of GEISMAR and ensure the consistency of its communication with all stakeholders.

Fight against corruption

Any act of bribery (including kickbacks, retro-commissions and abuse of corporate property) is strictly prohibited. GEISMAR practices fair competition based on the quality of its technology, services and excellent performance. GEISMAR rejects bribery in any form and does not make or accept undue payments for obtaining or maintaining contracts with public or private sector entities, or as a reward for contracts awarded to subcontractors or suppliers. The OECD Convention of 17 December 1997 on the fight against corruption, the law of 9 December 2016 (SAPIN Act 2) and most national laws and regulations prohibit offering or promising to provide, directly or indirectly, any benefit, financial or otherwise, to a representative of the public administration or to a public official, with a view to obtaining or maintaining a market or influencing the behaviour of an administration.

Gifts and hospitality

Entertainment can be an opportunity to build or strengthen relationships with customers or to better know our main subcontractors or suppliers. There are, however, some forms of gifts that may be considered inappropriate and constitute acts of corruption.

Only gifts with a symbolic and modest value are allowed, in accordance with the commercial practices and the legal and regulatory environment of each country.

GEISMAR forbids its employees:

• from soliciting or accepting gifts or invitations which puts them in a position of obligation, so as not to compromise their integrity or independence;
• to offer gifts or invitations the frequency of which might give the appearance of an irregularity when they are totalled;
• to offer gifts, entertainment or travel to public officials without prior approval of their supervisor.

Donations and contributions to charities

Management must give its prior approval before any support actions to sports associations or sponsorship for museums or humanitarian or cultural events.

Agents / Commercial Intermediaries

GEISMAR authorizes contractual relations with agents or commercial intermediaries on the basis of mutual respect of the highest standards of integrity; the use of these agents, especially in cases where our presence is limited, must always be assessed on the basis of specific professional skills and to the extent that these agents provide defined and measurable services.

The employees in charge of these partnerships have the obligation to supervise the services actually performed by its partners, and to ensure that they comply with the laws and regulations.

Agreements – Tenders

The prices and conditions of the contracts entered into with a customer are the result of the sole negotiation between the Company and the customer, without any consultation or agreement with competitors. No information concerning the prices or conditions of performance of a contract may be exchanged with a competitor.

If the answer to a call for tenders is to be made by bringing together the skills of several companies (consortium, joint venture) the legal department drafts a working document which establishes the legal framework for this cooperation.

Conflicts of interest

A conflict of interest may arise when an employee has a financial, professional or personal interest or activity that interferes or appears to interfere with the interests of GEISMAR.

The Employee is required to make professional decisions that best safeguard the interests of the company. Any situation in which his or her personal interests or those of his or her family are entering or appear to conflict with the activities of GEISMAR should be avoided.

 Respect for privacy and personal data

Personal data refers to any information concerning an identified or identifiable person. GEISMAR is committed to protecting the personal data stored in its computer systems by designing and implementing appropriate security and access control measures. Access to personal data is limited to employees with appropriate permissions who have a defined need to access this information for professional reasons.

Protection of intellectual property

Technical and commercial secrets, including, for example, inventions and know-how are valuable assets of the company. GEISMAR invests significant human and financial resources in the development of its equipment. Each employee is required to contribute to the protection of his information. Confidential information must be kept secret under all circumstances and may only be used for business purposes. In particular, confidential information should not be disclosed to unauthorized persons, including family members or friends. Technical and commercial secrets must also be protected from unauthorized disclosure.