A commitment at the heart of our CSR approachSince 2016, LOHR Group has been engaged in establishing and implementing a formal CSR approach based on three areas of focus: Show
As a benchmark on its markets, LOHR Group has been anticipating, diversifying and adapting to new needs and usages since it was founded in 1963. In an increasingly open and connected world, LOHR Group makes sure it remains a step ahead to develop tomorrow’s solutions today. Corporate Social Responsibility (CSR) is one of the drivers selected to meet this challenge, a central theme connecting human, environmental and social issues for ever greater sustainable performance. This second edition of the Code of Conduct, updated following a risk mapping produced by an independent third party, is a fundamental and integral part of the LOHR Group CSR approach. The Code of Conduct aims to express, formalise and share our values and principles in terms of ethics, integrity and respect of the law in the conduct of our business. It is available to every manager and employee of LOHR Group. Everyone is invited to nourish it and nurture it on a daily basis. 1 – OUR VALUES AND PRINCIPLES FOR ACTION ON A DAILY BASIS The pioneer spirit and spirit of innovation are the founding values of LOHR Group, serving its ambition and its development objectives. This process of innovation is based primarily on a trust and humanity that is shared by everyone in the company. LOHR Group’s managers and employees (referred to hereafter as “LOHR Group employees”) are united around humanist values (respect, loyalty and solidarity). They are committed to a strong work ethic, particularly to the value of work well done (an appreciation of hard work, savoir-faire and excellence). These values, which now permeate the whole group, were largely inspired by Mr Robert LOHR, its founder. Our values inspire and guide the way we conduct business, both in our interactions within the company and with our ecosystem and our partners. They are reflected accordingly in several fundamental principles: Integrity, the respect of individuals and the law, and an unquestionable code of ethics. Integrity and respect of the law are opposed, in particular, to any form of corruption, both active and passive. They also seek to reject unfair business practices, avoid conflicts of interest and respect the confidentiality of sensitive information. Ethics set respect and dignity as guiding principles and do not tolerate any form of discrimination. These principles are at the core of our Code of Conduct. 2 – OBJECTIVES AND CONDITIONS OF THE CODE OF CONDUCT The practical objective of the Code of Conduct is to help LOHR Group’s managers and employees, whatever their position, to know the rules in force, comply with them and be aware of the procedure to follow to ask for assistance or report a breach. The Code of Conduct commits LOHR’s employees to running the group’s activities in compliance with the laws and regulations in all countries where it is present. In particular, corruption cannot be tolerated and is prohibited in any form. All the necessary support will be systematically given to employees who place respect of our values above other interests. The behaviour proscribed in this Code, and more generally any behaviour which does not comply with the commitments and the principles of the company in terms of prevention and detection of corruption, will result in disciplinary sanctions. An internal whistleblowing process enables every employee to report any behaviour deviating from the rules set out in this Code. LOHR Group undertakes to ensure that the confidentiality of the process is respected and therefore guarantees the protection of any whistle-blower. No employee will suffer reprisals after reporting any breach of the Code. LOHR Group undertakes to monitor the effectiveness of these internal procedures and to improve them where necessary and possible. 3 – SCOPE OF THE CODE OF CONDUCT This Code is applicable, in all circumstances and without exception, to LOHR Group’s management and employees, regardless of their hierarchical position, their function, their status (permanent, external or temporary), or the country where they work. It therefore applies to all its subsidiaries and the companies it controls without prejudice to the application of more demanding laws or local regulations if applicable. The Code also covers relations between LOHR Group and its customers, suppliers, and more generally, all of its partners. 4 – THE APPLICABLE RULES 4.1- FIGHT AGAINST CORRUPTION AND INFLUENCE PEDDLING: “ZERO TOLERANCE” In a globalised world, we are witnessing the appearance of an increasing number of measures to prevent corruption and control business ethics and transparency .(1) It is particularly important that LOHR Group employees are familiar with and respect all the national and international laws and regulations relative to the fight against corruption and influence peddling. Corruption and influence peddling are not only illegal and contrary to the fundamental values of LOHR Group, but they also restrict competition and have an impact on economic development. It is the responsibility of LOHR Group employees wherever they are, both in France and abroad, to:
Any act of corruption committed in the context of relationships with private or public partners, as well as any breach of our “Zero Tolerance” policy in the fight against corruption and influence peddling will result in disciplinary sanctions, in accordance with the law and the Internal Rules and Regulations. (1) France: The so-called “Sapin 2” law of 2016 relative to transparency, the fight against corruption and the modernisation of economic life / European Union: Council of Europe Conventions of 1999 / OECD: Anti-corruption convention of 1997 and recommendations of 2009 /United States: Foreign Corrupt Practices Act (FCPA) of 1977, amended by the International Anti-Bribery Act of 1998 / United Kingdom: United Kingdom Bribery Act (UKBA) of 2010 4.A- HOW DO YOU RECOGNISE CORRUPTION? Corruption is a behaviour by which a person working in the public or private sector seeks or accepts any advantage, goods or services (money, travel, gifts, etc.) in return for performing or refraining from carrying out an act falling within their duties (granting of an administrative authorisation, obtaining a contract, etc.). E.g. one of your suppliers promises you a holiday with your family if a contract is signed. 4.B – HOW DO YOU RECOGNISE INFLUENCE PEDDLING? Influence peddling is the act by which a person abuses the real or assumed influence that they exercise with a public authority to obtain a decision favourable to a third party. E.g. you agree to pay an elected member of the town where your plant is located so that they use their influence to obtain the issuance of a building permit. 4.C – HOW CAN YOU PREVENT ACTS OF CORRUPTION OR INFLUENCE PEDDLING? It is prohibited for the companies and all the employees in LOHR Group to:
4.D – IN WHAT SITUATIONS SHOULD YOU BE PARTICULARLY VIGILANT? Be particularly vigilant if:
4.E – WHAT SHOULD YOU DO IF YOU ARE CONFRONTED WITH ATTEMPTED CORRUPTION OR INFLUENCE PEDDLING? Corruption and influence peddling may take very varied forms. All employees are requested to comply with the instructions and procedures implemented within LOHR Group. Any LOHR Group employee who is confronted with corruption or influence peddling in France or abroad is asked to contact the Legal Department or use the “Internal Whistleblower Procedure” (see page 24). Case study : As an employee of LOHR Group, you meet the representative of a business with a view to potentially referencing them as a supplier. You decide to meet them to find out more about their company and its range of products. During this discussion, the representative lets you know that if you assist them in becoming referenced by our business, “they will show gratitude”.</p LOHR Group has adopted a zero-tolerance policy towards any behaviour contrary to integrity in general and any risk of corruption in particular. Therefore, you must:
4.F – GIFTS AND INVITATIONS Although the exchange of business gifts or invitations is a relatively widespread practice in business relations, you should bear in mind that offering and accepting such advantages, depending on the circumstances, may be considered as acts of corruption or influence peddling. These gifts and invitations should under no circumstances have the effect of influencing a decision or obtaining an undue advantage of any kind whatsoever. That is why LOHR group’s employees are required to comply with the following rules of conduct:
In an international context (beneficiary or donor outside France), any business gift or any invitation may only be given or received after having checked their legality in accordance with the local legislation. Case Study : One of our main suppliers contacts you. They wish to invite you in the very near future to lunch in a luxury restaurant. As their contract with a company in LOHR Group is nearing its end, they say that they “want to catch up with you regarding the prospects of its renewal”. Such an invitation in terms of the selected location (a luxury restaurant) and current context (their contract renewal period) could potentially undermine the independence of your decision in the selection process for this business partner. Accepting such an invitation is contrary to the values and rules of conduct set by LOHR Group. Therefore, you must:
Gifts and invitations: ask yourself the right questions 4.G – RELATIONSHIPS WITH OUR BUSINESS PARTNERS In certain situations, LOHR Group could be held responsible for acts of corruption committed by one of its business partners acting on its behalf (consultant, sales representative, distributor, dealer, joint-venture partner, etc.). More generally, it is the responsibility of LOHR Group to ensure the integrity of third parties (customers, suppliers, service providers, etc.) with which it may be in relations or may wish to enter into relations. For this reason, LOHR Group has set up a Partners Charter (), in which our values, ethical rules and the terms of this Code of Conduct are included. To ensure our values and ethical rules are respected and to ensure the efficiency of the third-party evaluation procedure, all employees, executives and managers of companies in LOHR Group who become aware of a non-ethical practice on the part of a LOHR Group partner, either in France or abroad, are asked to contact their line manager, the Legal Department or the Human Resources Department, or to use the “Internal Whistleblower Procedure” (see page 24). Case Study 1 : You go to visit the representative of a company with a view to possibly referencing it as a supplier. During the visit of the premises, you notice that the basic rules for employee safety are not respected, or you suspect that forced labour, illegal employment or child labour are being used. LOHR You are required to inform your line manager of your observations so that they can be taken into account in the evaluation process for this potential partner. Case Study 2 : After months of negotiations, you come to a financial agreement for the renewal of a service contract with one of our major customers. While your team is currently busy finalising the drafting of this contract, the customer lets you know that he would like to come and sign the contract at our headquarters. He specifies that he expects his travel and accommodation expenses to be fully covered and that he will come accompanied by his wife and two children. Accepting such a request could be perceived as granting a benefit to this customer in return for the award of the contract to a LOHR Group company, and therefore could constitute an act of corruption. LOHR group cannot justify unlawful behaviour to obtain a commercial advantage. Therefore, you must:
4.H – FACILITATION PAYMENTS Facilitation payments are low amount, unofficial payments made to ensure or to facilitate the execution of regular and non-discretionary administrative formalities (obtaining a license, a visa, a permit, etc.). French law considers facilitation payments to be an offence and strictly prohibits this. Facilitation payments, whatever their frequency and amount, whether in France or abroad, are liable to criminal prosecution for corruption. Tolerance to facilitation payments in certain countries exposes LOHR Group to prosecution. The group could be held liable. For this reason, LOHR Group’s employees are asked to refuse facilitation payments except in the case of payments demanded under duress or putting the employee’s physical integrity or safety at risk. In the latter case, the employee subject to duress must report this to their line manager as soon as the risk to their safety is no longer imminent. Case Study : As an employee of LOHR group, you are responsible for the completion of the administrative formalities with the customs authorities of a foreign State. A local customs official offers “to take care of the processing of your application” against the payment of the equivalent of 150 euros. Such payment may be considered as a facilitation payment. Therefore, you must:
4.I – CASH TRANSACTIONS Cash transactions are prohibited on principle. In exceptional cases, a cash payment may be accepted, provided that the amount is compliant with the applicable legislation and provided that the third-party payer has been evaluated with the support of your line manager, the Legal Department and the Finance Department. 4.J – PATRONAGE AND SPONSORSHIP Patronage activities (support with no direct return from the beneficiary of a project or a person for the performance of activities of general interest) and sponsorship (material support given to an event, a person, a product or an organisation resulting in direct benefits) are subject to legislation and a specific regulatory framework. LOHR Group is aware that patronage or sponsorship activities carried out in its name or using its financial means could be diverted from their original purpose to conceal an unfair advantage. Employees must therefore comply with the following rules of conduct:
4.K – FINANCING OF POLITICAL ACTIVITIES While LOHR Group respects the right of its employees to individually invest themselves in the political and civic life of their countries, any financial or contributions in kind to organisations, parties or political figures cannot be paid by one of its entities or on its behalf. Financing activities means any direct or indirect contribution to provide support to a political organisation, a candidate or an elected official. This contribution may consist of a payment of money or any other advantage (sponsorship of a campaign meeting or a fund-raising dinner, gifts, the provision of facilities or services free of charge or at a reduced price – offices, photocopying, etc.). That is why LOHR group’s employees are required to comply with the following rules of conduct:
Case Study : You are an employee of LOHR Group and you campaign a few hours per week within a political party. One day, your supervisor informs you that the local federation is experiencing some financial difficulties because of the loss of several members. To save money, he asks you to use the photocopiers available to you at your place of work to print all the documents composing the welcome booklet which will be given to all participants at the next symposium organised by your local federation. Accepting such a request can be considered to be a political contribution. You must then explain to your contact that LOHR Group’s policy on the financing of political activities does not allow you to use the equipment at your disposal to exercise your professional activities to this effect. 4.L – REPRESENTATION OF INTERESTS/LOBBYING For an organisation, the representation of interests or lobbying is the transfer of any information to public officials, policy-makers or elected officials for the purposes of informing their decision-making. Within LOHR Group, these activities are supervised by the Executive Board. To prevent the risk of corruption or influence peddling, LOHR Group’s lobbying activities may only be conducted in compliance with the following rules of conduct:
Case Study : You are an employee of LOHR group. You are in a call for tender phase with a principal in the public sector and you are contacted by a consultant working within a public affairs consulting firm. This consultant informs you that she can influence the decision of the principal by providing them with confidential information disqualifying the offer of one of LOHR Group’s competitors. She offers to “put her expertise at the service of your interests”. LOHR Group cannot accept such actions. Therefore, you must:
4.2 – CONFLICTS OF INTEREST In a professional setting, a conflict of interests may arise if an employee’s personal interests conflict with, or may be interpreted by third parties as conflicting with, the interests of LOHR Group. The concept of personal interest must be understood very broadly. In effect, this conflict may be:
For example, the following circumstances may generate a conflict of interest:
Such situations could lead to LOHR Group obtaining an unfair advantage and therefore expose it to heavy penalties. It is therefore the responsibility of each employee to:
Case Study : You are a buyer within LOHR Group. You mention in a discussion with the sales manager of one of your key suppliers that, as part of her studies, your daughter is looking for an internship. He offers to “do you a favour” by taking her in his company. Accepting such a proposal could be considered as corruption and, in all events, create a conflict of interest for you. Therefore, you must:
4.3 – FIGHT AGAINST MONEY LAUNDERING AND THE FINANCING OF TERRORISM Money laundering is the process used to disguise the origin of assets derived from illicit activities by giving them a legitimate appearance. LOHR Group undertakes to conduct its activities in compliance with the laws and regulations applicable in the field of the fight against money laundering and the financing of terrorism. Every employee in LOHR Group is required to be vigilant in the exercise of their activities in order to:
Case Study : An intermediary requests the payment of their commission to an offshore bank account that does not correspond to the information provided by them when they entered into a
contractual relationship and unrelated to the place of performance of the service. 4.4 – COMPLIANCE WITH COMPETITION LAW Competition law ensures effective competition between companies, and promotes and encourages productivity, innovation and excellence. In fact, to stay competitive in a context of free and undistorted competition, a company must innovate and constantly improve the quality of the products and services it offers to its clients. LOHR group is committed to acting in strict compliance with the competition laws applicable in all the countries in which it operates. To this end, LOHR Group’s employees are required in particular:
Did you know? : Discussions with competitors concerning sensitive information such as product characteristics, R&D activities, margins, and the sales or pricing policy are prohibited insofar as they may undermine competition. Be particularly vigilant during meetings in the context of a professional association and during breaks or meals. If you witness this type of discussion, inform the people that this type of conversation is prohibited and leave the meeting after asking the secretary for the session to record the fact that you have left the meeting and to specify the reason. Even if you do not say anything, the simple fact of being present during these discussions can mean that you and also LOHR Group can be held liable. 4.5 – COMPLIANCE WITH DATA PROTECTION AND PRIVACY RULES LOHR Group makes sure to protect the personal data of its employees, the employees of its customers, suppliers and partners, and any other people whose personal data may be processed by LOHR Group. Personal data means all data allowing a physical person to be identified directly (e.g. last name, first name), or indirectly (e.g. telephone number, car registration plate). A person may be identified by a single piece of data (e.g. a name) or by a combination of several pieces of data (e.g. date of birth + profession + company name). Therefore, all employees are required to limit the collection of personal data to the strict minimum (the data minimisation principle) and in general, to comply with all the security rules introduced by LOHR Group for processing personal data (limited retention time, access and rectification rights, transfer to third parties under strictly controlled conditions, etc.). For any questions, LOHR Group employees are invited to consult the Legal Department. 4.6 – ENVIRONMENTAL PROTECTION LOHR Group is mindful of its impact on the environment. It is committed to conducting its business in a way which best preserves and safeguards the environment for life to flourish on earth now and in the future, particularly by developing offers and products which can provide solutions, notably in terms of sustainable mobility. Therefore, every employee must reflect this value in their personal behaviour and contribute to the protection of the environment, the fight against climate change and the preservation of natural resources while respecting the environmental standards applicable to their activities and their behaviour in the workplace. 4.7 – RESPECT FOR AND PROTECTION OF PERSONS LOHR Group is particularly committed to respect for human rights. The same applies to the health and safety of its employees. Thus, any form of discrimination, harassment or any behaviour of a nature likely to affect the physical or moral integrity of any person cannot be tolerated. To this effect, in accordance with the national and international laws and regulations in force, LOHR Group’s employees are required to implement appropriate measures to:
It is everyone’s responsibility to contribute to making their place of work a safe environment where individuals are respected. Any behaviour contrary to the applicable rules and principles will lay the perpetrator open to disciplinary measures or even penal sanctions. In addition, LOHR Group subscribes to the principle of neutrality, as specified in its Internal Rules and Regulations. While respecting the political, philosophical and religious beliefs of individuals, LOHR Group is above all a place of work, and each employee must abide by its rules of operation. No exceptions will be granted for political, philosophical and religious practices. 4.8 – RESPECT FOR AND PROTECTION OF MATERIAL AND IMMATERIAL ASSETS LOHR Group employees have an individual and collective responsibility for the preservation of the assets and goods placed at their disposal. It is therefore the responsibility of each LOHR Group employee to:
IT security: did you know? : Human error is behind 75% of all IT security incidents. It just takes a single episode compromising the information system and the entire functioning of the company can be brought to a halt.
4.9 – INTEGRITY OF FINANCIAL INFORMATION LOHR Group ensures that its books and records are kept in accordance with and respect of the accounting rules and principles in force. Its employees are therefore required to ensure the management, retention, archiving and destruction of data in accordance with the legal deadlines and the applicable procedures implemented within LOHR Group. Any action undertaken by an employee aiming to falsify, omit, conceal or misrepresent the financial information contained in LOHR Group’s books and records will be sanctioned. 5 – INTERNAL WHISTLEBLOWER PROCEDURE All permanent and temporary employees or external partners who, during their activities with LOHR Group, observe behaviour or situations which appear contrary to the provisions of this Code of Conduct are invited to use the Whistleblower Procedure implemented by LOHR Group. This system also provides guidance to staff wondering what behaviour to adopt in a specific situation. Your access to the Whistleblower Procedure: Intranet : Lotus Portal / Our company / CSR – Email : – Postal service: Lohr Industrie Code of conduct alert (CONFIDENTIAL) Aurélie Denonnin, Group Legal Manager 29 Rue du 14 juillet, 67980 HANGENBIETEN and/or Nicolas Marson, Human Resources Manager Avenue de la Concorde – ZA Bruche, 67120 DUPPIGHEIM Permanent or temporary employees of LOHR Group can also contact their line manager who will guide them and advise them appropriately. The managers of LOHR Group can also be contacted directly on these subjects if the employees concerned are unable to use the reporting lines or whistleblower procedure. To ensure the protection of individuals using the whistleblower system or who are the subject of a report, LOHR Group makes every effort to ensure:
Any person who takes (or attempts to take) retaliatory action against an employee of LOHR Group for having exercised their whistle-blowing rights is liable to disciplinary sanctions. 6 – DISCIPLINARY SANCTIONS Failure to comply with the ethical principles set out in the Code of Conduct will incur the application of disciplinary measures in accordance with the applicable local rules, i.e. the Internal Rules and Regulations if it concerns LOHR Group employees linked to French companies. Which of the following relationships is not fraternization?The following relationships are permitted in the military and not considered fraternization: Dating between enlisted members of the same rank. Dating between enlisted members and civilian employees or government contractors.
Which of the following persons is normally authorized to assign extra military instruction EMI?The authority to assign EMI rests with the commanding officer, but delegation of the authority to assign EMI may be part of a normal supervisory task.
Which of the following situations qualifies a sailor to wear one Navy service stripe?All personnel wear one stripe for each four years of active duty service or reserve service in an active status in any of the armed services.
What are the two basic types of marching commands?(1) The preparatory command states the movement to be carried out and mentally prepares the cadet for its execution. In the command Forward, MARCH, the preparatory command is Forward. (2) The command of execution tells when the movement is to be carried out.
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