CODE OF ETHICS 20 20 - Lyreco
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20
20
CODE OF ETHICS
CONTENTS 20
20
OUR
OUR BUSINESS
PEOPLE INTEGRITY
13 25
Leadership • 14 Corruption and influence peddling • 26
Health, safety and well-being • 16 Fraud • 28
Inclusion and diversity • 18 Conflict of interest • 30
Intimidation and harassment • 20 Fair competition • 32
Listening to our colleagues • 22 Facilitation payment • 34
Gifts and invitations • 36
Customer and supplier relationships • 38
OUR OUR
CODE OF ETHICS
PRODUCTS SOCIETAL
AND ASSETS ENGAGEMENT
41 49
Product excellence • 42 Environment • 50
Protection of assets • 44 Human rights • 52
Communication • 47 Political activities and lobbying • 54
Citizenship and societal engagement • 56
OUR
VALUES
OUR
AGILITY EXCELLENCE
COMMITMENTS
—
Since it was established in 1926, Lyreco has been driven by its values of
Excellence, Respect, Passion and Agility. We are proud of them. They
are shared and promoted by all employees, form our key strength, and make
us a trusted partner. For us, respecting these values is a matter of course, an
obligation and a duty.
This new version of our Code of Ethics reaffirms our commitments. It once
more highlights the attitude we must adopt in our working environment, our
business activities and the relationships between our colleagues, customers
and business partners. This Code removes any doubt that may still linger when
an unusual situation presents itself and renews our commitment to combat any
breach of our ethical principles.
I urge you therefore to read it carefully and ensure that you abide by it, so that
every day is always “A Great Working Day” for everyone.
PASSION RESPECT
Grégory LIENARD • CEO
Code of Ethics • 5
WHAT IS
THE PURPOSE
OF THE CODE
OF ETHICS?
—
The Code of Ethics is intended to point out
the principles of integrity, neutrality, fair-play,
equity and compliance expected by Lyreco.
This Code of Ethics has been translated into all IT IS DESIGNED TO GUIDE OUR CONDUCT
languages used by Lyreco entities. In the case
of any doubt or difference in interpretation, AND OUR INDIVIDUAL AND COLLECTIVE DECISIONS
the English version shall prevail. IN ACCORDANCE WITH THESE PRINCIPLES:
TO WHOM DOES THE
CODE OF ETHICS APPLY?
The Code of Ethics applies to all employees For a full understanding of the rules
in all Lyreco entities worldwide. of conduct, each topic covered by this
Code of Ethics contains:
We also expect the same compliance and integrity With all our In all our Wherever At any time
requirements from our external business partners. — employees and business we operate
business partners activities
To this end, a Code of Ethics for our suppliers The key principles
is available on Lyreco’s corporate website. The behaviours to be adopted and those
to be avoided
A few examples in the form of questions-
WHAT HAPPENS IN CASE answers
OF NON-COMPLIANCE WITH The reference documentation
WHAT IF WHERE TO FIND IT
THE CODE OF ETHICS? The reference contacts
Each employee may, in the course of their A situation is not covered by the An interactive version of the Code of Ethics
professional duties, take a decision which entails Code of Ethics. is available for consultation and download via
Lyreco’s liability and compromises its reputation. Workplace, the Toolbox (library) and Lyreco’s
It is impossible to foresee all situations we
corporate website.
We are all expected to be familiar with the may face. We encourage you to use good
Code of Ethics and to act in accordance with judgment and, in case of doubt, to ask for All reference documentation is accessible
its principles. Dedicated training sessions are guidance before acting. in the Toolbox - QSS library.
provided in order to intensify understanding.
Failure to comply with the Code of ethics may result Local laws or regulations are more
in very serious consequences, both for the company or less restrictive than the Code of
and the persons involved. Depending on the nature of Ethics.
the employee’s breach, disciplinary sanctions may be
applied, in accordance with local legislation and Lyreco’s In all cases, the strictest and most repressive
internal policy. Under no circumstances shall ignorance requirements shall take precedence.
This is a living guidance whose purpose is
of the Code of Ethics be considered as an excuse.
to continuously evolve so as to better adjust
to our business activities. Consequently, the
latest updated version of the Code of Ethics Reference document
and reference documents will apply. P MNG 089 - Disciplinary sanctions
Code of Ethics • 7
YOUR
ALERT TOOL:
“RAISE YOUR
CONCERN”
—
Our common purpose is to prevent and
detect any breach of an ethical nature
so that Lyreco may take the appropriate
measures and remedy the situation.
We encourage you to discuss, ask for CONFIDENTIALITY
advice, raise questions, share your IDENTIFY SPEAK UP! AND ABSENCE
concerns and indicate any actual or OF RETALIATION
potential breach of the Code of Ethics.
— Contact: It takes courage to ask questions or voice your
concerns. Rest assured that Lyreco will treat
Your Manager
ASKING QUESTIONS AND any questions or alerts with confidentiality and
Your Operational Manager without any risk of reprisal.
VOICING YOUR CONCERNS
HELP LYRECO PROTECT • Marketing, Sales, QSS, Logistics, IT, Legal, Lyreco does not tolerate any form of reprisal
ITS CULTURE OF INTEGRITY Is this Is it a
Communication, etc. or retaliation against any person who reports
BREACH honestly and in good faith.
INCOMPATIBLE Your Ethics referent
WITH OUR OF THE CODE
At local level:
VALUES? OF ETHICS?
• Your Finance or HR Manager
At Group level:
• Your Group Compliance Officer
Does it appear to be Could it
UNETHICAL? HARM LYRECO’S Reference document
At any time
REPUTATION?
use the “raise your concern” tool accessible via P MNG 0 85 - Alert process and alert
the Toolbox and Lyreco’s corporate website. management
Code of Ethics • 9
COMPLIANCE WITH
LAWS, REGULATIONS
AND STANDARDS
OUR PRINCIPLES MUSTS WHAT IF
A customer has asked me to accept
a contractual clause which I find
contrary to our standards. What
should I do?
You are obliged to contact the legal referent
person of your entity in order to check the
INDIVIDUAL Remain informed on a regular basis of
applicable regulations concerning your
legal validity of such a clause before any
acceptance.
RESPONSIBILITY duties or your field of activity.
Employees must, under any circumstances, comply
Seek for advice before acting in case of I think that an action does not
with any applicable regulations, including the
doubt regarding the applicable regulations. comply with the applicable laws and
company’s policies and internal rules. Lyreco
regulations. How should I respond?
shall not tolerate any contrary practice. Ignorance Report any contravening conduct committed
shall never be considered as an excuse. by an employee or business partner. You should firstly verify and clarify the facts,
circumstances and reasons for such an action.
If you conclude that there is risk of a breach,
you may immediately inform one of the
COLLECTIVE RISK reference contacts.
In case of breach, the concerned employee
and the company are exposed to sanctions.
Some local laws and regulations
required in the country where
I work are different to some of the
requirements referred to in this Code
of Ethics. Which should I apply?
In the event of a conflict between your local
regulations and this Code of Ethics, you
MUST NOTS should always apply the strictest requirement.
In case of doubt, ask advice from one of the
reference contacts.
Become complicit in any illegal or
non-compliant act.
Conceal or ignore any illegal or Your reference contacts
non-compliant act.
Your manager
Take a decision whilst ignoring
the applicable regulations. Your Legal manager
Your Ethics referent
The “Raise your concern” tool
Code of Ethics • 11
OUR
PEOPLE
—
Code of Ethics • 13
LEADERSHIP OUR
PEOPLE
OUR PRINCIPLES MUSTS WHAT IF
I am a manager and a member of I don’t know whether the culture of
my team has reported an ethical integrity is correctly applied by my
problem. What should I do? team members. How can I be sure?
Above all, it is imperative to respect total We encourage you to identify and regularly
confidentiality regarding the alert raised and monitor potential risks of violating the Code
the identity of the whistleblower. Gather all of Ethics within your team. Encouraging
DEVELOP A Ensure the sharing and implementation of
the Code of Ethics.
the facts from the employee and share this
concern with one of the reference contacts.
discussions ensures that the Code of Ethics is
known and understood through its promotion
COLLECTIVE SPIRIT and assessments. Individual training should
Develop a trusting environment enabling be undertaken by all employees.
Motivating and helping colleagues grow I have difficulty in taking a decision
each employee to ask questions or voice
in the pursuit of collective objectives
their concerns. following a concern of an ethical
is a core mission of managers.
nature raised by one of my team
Manage any integrity or ethical issue raised.
members. How should I respond?
If you find a situation which raises either
PROMOTE AN potential or actual ethical issues, don’t make a
ETHICAL CULTURE decision alone or in a hurry. Gather the facts
and report any issue through the dedicated Your reference contacts
The mission of all our managers is to
create and uphold a culture of integrity alert tool. Your manager
and ethics within their team.
Your HR manager
Your Ethics referent
The “Raise your concern” tool
MUST NOTS
Ignore a concern raised by an employee.
Avoid or refuse to support an employee
seeking advice or help.
Put an individual’s interest first.
Code of Ethics • 15
HEALTH, SAFETY
AND WELL-BEING OUR
PEOPLE
OUR PRINCIPLES MUSTS WHAT IF
I have to wear personal protective
equipment to perform my work. Can
I be sure of working in complete
safety?
Lyreco, as an employer, determines whether
wearing personal protective equipment is
HEALTHY AND SECURE Comply with the health and safety rules
every day.
fit for a particular purpose by considering
the work environment and associated risks.
ENVIRONMENT Comply with all of Lyreco’s policies required
Know what to do in case of emergency
Preventing and fighting against work-related to this end. Before using, you are required
in your workplace and quickly comply with
accidents and occupational illnesses are to read any labels, warnings, information
all the evacuation instructions.
essential commitments for Lyreco. and instructions provided with the personal
Protect yourself and others. protective equipment made available to you.
In case of doubt, seek advice from reference
Quickly report any situation, even minor, contacts.
WELL-BEING AT WORK that may potentially damage health and safety
Lyreco aims at promoting quality of life in the at work.
I am faced with certain difficulties at
workplace, ensuring a balance between professional
work and consider that my working
and private life whilst encouraging a positive
environment has a negative impact on
and supportive attitude between colleagues.
my well-being. What should I do?
We encourage you to quickly discuss with
one of the reference contacts in order
to implement the appropriate corrective
measures. The longer you wait, the more this
MUST NOTS uncomfortable situation will have a negative
impact on your own feeling of well-being,
your professional performances and your
personal balance.
I am a logistics operator in a Lyreco
warehouse. I have noticed that an
equipment is not working properly.
What should I do?
Put yourself or other employees in danger.
Firstly, stop using this equipment immediately.
Remain passive and silent when facing any In order to avoid any potential risk for Your reference contacts
critical situation to the health and safety of the health and safety of others, share this Your manager
your colleagues or yourself. information around you and report this
situation immediately to the warehouse Your HR manager
Maintain a negative or damaging atmosphere
manager as well as to one of the reference
to the collective well-being. Your QSS manager
contacts so that the appropriate corrective
measures may be implemented as soon as Your Logistics manager
possible.
Your Ethics referent
The “Raise your concern” tool
Code of Ethics • 17
INCLUSION AND DIVERSITY OUR
PEOPLE
OUR PRINCIPLES MUSTS WHAT IF
My female colleague is very One of my colleagues often tells
committed and performs very well. offensive racist and homophobic
But, during the course of last year, jokes. Some of my colleagues feel
several male colleagues were offended and ill at ease, but no-one
promoted or received a pay rise dares tell him to stop. What should
despite weaker performances. I do?
I suspect that she is a victim of
RESPECT AS Act towards others, internally and externally,
with openness and respect for cultural discrimination because she is a
If you witness discrimination, have courage
and object to any inappropriate behaviour.
A CORE VALUE differences. woman. How should I respond? You may also report these behaviours to one
Social inclusion and diversity contribute to If you suspect discriminatory practices within of the reference contacts.
Object to any inappropriate behaviour.
the wealth of our corporate culture. your team, you are invited to report them to
one of the reference contacts.
NO DISCRIMINATION
Decisions by Lyreco regarding recruitment,
training and promotion are exclusively based on
qualifications, skills and professional experience.
—
What is it?
Discrimination refers to all unequal treatment
based on gender, age, disability, nationality,
colour, social class, family situation, sexual
MUST NOTS
orientation, religious beliefs, culture, political
opinions or any other characteristic.
Hold opinions or behave in a discriminatory Reference document
or non-respectful manner with respect to
P MNG 0 88 - Discrimination and
differences.
harassment
Favour certain employees.
Your reference contacts
Your manager
Your HR manager
Your Ethics referent
The “Raise your concern” tool
Code of Ethics • 19INTIMIDATION AND
HARASSMENT OUR
PEOPLE
OUR PRINCIPLES MUSTS WHAT IF
Reference document
P MNG 0 88 - Discrimination and
My manager regularly sends me harassment
sexually explicit messages. I feel very
ill at ease. How should I respond? Your reference contacts
We do not tolerate this kind of behaviour, Your manager
whether during or outside work hours,
irrespective of the context and situation. We Your HR manager
NO INTIMIDATION OR Listen carefully to any person voicing a
concern or problem regarding intimidation
encourage you to explicitly request your
manager to stop. In order to ensure rapid
Your Ethics referent
HARASSMENT or harassment. and effective action, you may also inform one The “Raise your concern” tool
Lyreco is focused on providing a working environment of the reference contacts to obtain help and
Object to any inappropriate behaviour. decide upon the action to be taken.
free from any form of intimidation or harassment.
My manager can be very intimidating.
DIGNITY AND I know that this is to incite us to
produce quality work, but sometimes
PROFESSIONALISM he can be very humiliating which
Any employee or business partner must be damages the morale of the whole
treated with dignity and professionalism. team. What should I do?
— Your manager’s role is to stimulate and
motivate his team to produce quality work.
Therefore, he is justified in assessing his team
What is it? members’ performance or making remarks
Intimidation and harassment refer to any to this end. However, a manager must also
unwelcome and repeated actions towards another treat his team with respect and act in an
person, whether verbal, visual or physical, MUST NOTS appropriate manner. If you think you were not
creating an intimidating, hostile, offensive treated professionally, you must try to speak
or threatening working environment. about it with your manager. You may also
consult your Human Resources manager.
Engage in any form of harassment using
words, gestures, remarks or inappropriate
physical contact.
Display offensive images or objects.
Code of Ethics • 21LISTENING TO
OUR COLLEAGUES OUR
PEOPLE
OUR PRINCIPLES MUSTS WHAT IF
I envisage a change which could have One of my team members wishes to
an impact on the team organisation. be elected as a trade union member.
Should I involve the employee What should I do?
representative bodies?
Lyreco respects the right of its employees to
Firstly, seek advice from one of the reference belong to a trade union. As a manager, you
contacts. According to the current local must not intervene in this process. If your
ENCOURAGE DIALOGUE Openly share your concerns. laws and regulations, it may be mandatory
to involve the trade unions or employee
employee is elected, you must ensure that
this employee is able to fulfill his or her trade
Allowing employees to express their Know who are the representatives and
representative bodies. union obligations and assess the impact on
opinions and guaranteeing constructive representative bodies of employees.
your team’s workload.
social dialogue is essential for Lyreco.
REPRESENT COLLEAGUES
All employees have the right to organise,
belong to and play an active part in trade
unions or employee representative bodies.
MUST NOTS
Treat trade union members or employee
representative bodies differently from other
employees.
Influence employees’ free choice to form or
belong to a trade union.
Your reference contacts
Your manager
Your HR manager
Your Ethics referent
The “Raise your concern” tool
Code of Ethics • 23OUR
BUSINESS
INTEGRITY
—
Code of Ethics • 25CORRUPTION AND
INFLUENCE PEDDLING OUR
BUSINESS
INTEGRITY
OUR PRINCIPLES MUSTS WHAT IF
I am working on a building permit of them. May I accept his offer?
application for the extension of our You should explicitly refuse to receive samples at
distribution centre. I know that such your personal address. This might be considered
a request is complicated as many as an attempt to inappropriately influence your
authorisations are necessary and decision. As a reminder, the quantity of samples
the result is uncertain. I have been sent by our suppliers must be limited to the
contacted by a consultant who is
A STRICT PROHIBITION Refuse any form of corruption or influence
peddling committed by an employee or offering to help me, arguing that he is
strict minimum. Samples must not, under any
circumstances, be used for private purposes or
Any form of corruption or influence peddling, business partner. very familiar with the public official who sold to your profit. You could maybe suggest to
either direct or indirect, active or passive, will take the decision. Should I accept the supplier that, in the event of surplus samples,
public or private, is strictly forbidden. Follow the training dedicated to fighting his proposal? he sends them for your attention to Lyreco for the
against corruption and influence peddling purposes of “Lyreco for Education”.
organised by Lyreco. You must be very careful and check the
consultant’s reputation and references. It may
ZERO TOLERANCE definitely be wise to call on external assistance One of my colleagues told me that he
As the company and the employees involved for a complicated case. However, you must be had received a gift voucher for a luxury
incur liability, any contravening conduct, certain that we only pay fees for his technical weekend of his choice from a supplier.
including any intention or attempt of corruption expertise and that his service does not constitute, Is this normal?
or influence peddling, shall be subject to directly or indirectly, a form of corruption or
influence peddling. In such a situation, the fact First of all, you should inform your colleague
sanctions by Lyreco with zero tolerance. that this violates the Code of Ethics and, more
that the consultant has invoked his personal
relationship with the decision-maker is an specifically, the “Gifts and invitations” procedure,
— and that he should explicitly refuse the voucher
indication that you must be vigilant.
and return it to the supplier. This might be
What is it? considered as an attempt to inappropriately
Corruption is the fact of promising, giving, Whilst working on the reply to a tender influence his decision. If he disagrees, you
soliciting or receiving, directly or indirectly, money MUST NOTS organised by a potential customer, the should inform one of the reference contacts of
or anything of value for the purpose of obtaining purchaser of this customer company such a situation.
an unjustified advantage or influencing a decision. is demanding a kickback payment for
It does not always involve a material act. selecting Lyreco as supplier, or asking
me for a favourable price agreement
Influence peddling refers to the fact that
in return for a luxury weekend. May
a person is remunerated for influencing a
decision to be taken by a third party. I accept in order to win the contract?
This is a case of pure corruption! You should Reference documents
Corruption or influence peddling
may be active or passive. never, directly or indirectly, nor at any time, P MNG 0 81 - Corruption
Become complicit in any act of corruption or accept or receive any kind of kickback, bribe or
P MNG 0 82 - Conflict of interest
influence peddling. other compensation, regardless of the amount
and source, whether from the private or public PMNG 0 83 - Facilitation payment
Conceal or ignore any situation involving
sector, whatever the context and particularly as P MNG 0 86 - Gifts and invitations
corruption or influence peddling.
part of a call for tenders. In such a situation, you
are required to refuse and immediately report it
to one of the reference contacts. Your reference contacts
Your manager
One of our suppliers informs me that he Your Finance manager
can send extra samples of products to
Your Ethics referent
my personal address as he has too many
The “Raise your concern” tool
Code of Ethics • 27FRAUD OUR
BUSINESS
INTEGRITY
OUR PRINCIPLES MUSTS WHAT IF
I am an accountant and someone, I am a project manager and the
presenting himself as the president of external service provider is
the company with which I do not have invoicing, for providing services
regular professional contact, called linked to this project, an amount
me for an urgent and unusual request exceeding the budgeted amount. May
to transfer funds. What should I do? I spread the cost over several months
to conceal this over-expenditure?
MAINTAIN React immediately to any unusual request
which may conceal a fraudulent approach.
This is a typical sign of fraud. Do not panic
or transfer any funds on your own initiative. Absolutely not. Inaccurate reporting of costs is
CONSTANT VIGILANCE You are obliged to check the source and manipulation of the company’s accounts and
Comply with Lyreco’s internal accounting
Any employee must prevent, detect and combat immediately report this request to one of the is strictly prohibited.
procedures.
all types of fraud, whether internal or external. reference contacts and the Finance director.
Make sure that any information and data
My monthly sales are lower than the
used are reliable and obtain supporting
I work in the Finance Department and individual performance objective.
documentation.
ACCURACY OF received an email which apparently I therefore asked a customer to
emanated from a public authority,
FINANCIAL DATA requesting connection to a website in
make an order totalling a significant
amount of products which he will
Each employee has a duty to ensure that any order to download certain financial return next month for a full credit. Is
financial information provided is accurate. information for statistical purposes. this acceptable?
How should I respond?
— This kind of manipulation intended to obtain a
If this is an unusual request, you should monthly bonus is strictly prohibited and may
What is it? report it to your manager and check whether lead to serious penalties for the concerned
this request was really issued by a public employee.
Fraud refers to an illegal act characterised by authority. It might be a phishing attempt.
deception, concealment or a breach of trust
(e.g., false or misleading financial declarations, MUST NOTS
misappropriation of funds, theft of company’s
assets, false declarations to a third party,
identity theft and document falsification, false or
fraudulent bank transfers, cyber-attacks, money
laundering, malpractice, overcharging, etc.).
Distort or manipulate data.
Disclose any information which may be used
for fraudulent purposes.
Your reference contacts
Your manager
Your Finance manager
Your Ethics referent
The “Raise your concern” tool
Code of Ethics • 29CONFLICT OF INTEREST OUR
BUSINESS
INTEGRITY
OUR PRINCIPLES MUSTS WHAT IF
I have financially invested in
a company which is a supplier
participating to a call for tenders
organised by Lyreco. What should
I do?
You should immediately inform your manager
MAINTAIN OBJECTIVITY Question yourself about any risk of conflict of
interest before any action or decision.
and refrain from taking part in this supplier
selection process. You should also ensure that
Lyreco does not allow personal interests
you do not influence the final decision.
to conflict with Lyreco’s interests. As a manager, manage any situation
involving a conflict of interest and take a
decision depending on the circumstances. I am a purchaser. My best friend has
been appointed as sales manager
DECLARE ANY RISK within one of our suppliers. I have
Any risk entailing a conflict of interest must to initiate the annual commercial
be declared by the employee in question. supplier negotiation with this friend.
May I accept to negotiate with him?
—
You should immediately share the situation
with your manager. Your manager will
What is it? carefully and confidentially analyse this
A conflict of interest refers to any situation in situation and decide whether you are allowed
which an employee has a private or personal or not to carry out this negotiation.
interest which is likely to influence the objectivity
of an internal or external decision, particularly
in the context of a contractual negotiation, a A friend is asking whether there
business partner selection or a recruitment. MUST NOTS are employment possibilities within
Lyreco. May I inform him of possible
jobs?
Lyreco encourages recommendations
proposed by its employees for any candidate
fulfilling the required skills. Once the CV is
received, you cannot participate, in any form
whatsoever, in the recruitment process and
must inform your friend of this.
Conceal or ignore any situation involving a
conflict of interest. Reference document
P MNG 0 82 - Conflict of interest
Enter into a negotiation or decision
implicating a friend or a close relation
without prior information and approval. Your reference contacts
Your manager
Your HR manager
Your Ethics referent
The “Raise your concern” tool
Code of Ethics • 31FAIR COMPETITION OUR
BUSINESS
INTEGRITY
OUR PRINCIPLES MUSTS WHAT IF
During professional trade fairs, I have friendly relationships with
I sometimes discuss general market some people working for one of
trends, in an informal way, with Lyreco’s competitors. What should
some competitors. What should I be I do when having informal discussions
BANISH ALL careful? with them?
UNFAIR PRACTICE Discussions on general market trends are Any discussions with competitors, even
Avoid contacts with a competitor. acceptable. But it is strictly prohibited to informal and occasional, present a risk. Be
Any unfair or anti-competitive practices
are not tolerated by Lyreco in any way. It is disclose or gather sensitive information that very careful and avoid any conversation or
Only share public information concerning a
prohibited to restrict, distort or prevent free could affect the commercial interests of activity which could lead to disclosing or
business partner, a market or a competitor.
competition, including by using threat. Lyreco or its competitors. If you think that receiving sensitive information.
Protect confidential or sensitive information of the conversation could lead to disclosing
Lyreco or its business partners. sensitive information unintentionally, leave
the conversation or change the topic of
A SHARED discussion.
RESPONSIBILITY
Lyreco requires that its business partners and During a call for tenders organised
employees perform commercial practices by a potential customer, a competitor
in compliance with the regulations. proposed that I inflate his offer
so that Lyreco could win it. As a
counterpart, the competitor asked me
to do the same for the next customer
MUST NOTS tender process. Is this acceptable? Your reference contacts
Absolutely not. Such a practice contravenes Your manager
the competition law and could expose Lyreco
and yourself to judicial proceedings and Your Legal manager
severe penalties. You should reject such a
Your Ethics referent
proposal and immediately inform one of the
reference contacts. The “Raise your concern” tool
Exchange or conclude any unlawful
agreement with a competitor regarding
prices, margins, costs, market allocation, etc.
Conceal or ignore any unfair or anti-
competitive practices committed by a
colleague or a business partner.
Code of Ethics • 33FACILITATION PAYMENT OUR
BUSINESS
INTEGRITY
OUR PRINCIPLES MUSTS WHAT IF
I am waiting for a business trip visa
and the consulate employee tells
me that he can accelerate the visa
procedure in exchange for €50. If
I refuse, I risk receiving my visa too
late for my business trip already
scheduled. May I accept his offer?
PROHIBITED Refuse to make any facilitation payment or
allow a third party to do so on your behalf. You should refuse to pay even if you risk
These payments, even small, are acts of
being forced to cancel your business trip. You
corruption and are prohibited.
should also report this practice to one of the
The only exception concerns threats to the reference contacts.
health, safety or freedom of our employees.
One of my strategic customers is
—
waiting for products that are blocked
at the border for customs control.
What is it? The customs agent tells me that
Facilitation payments refer to paying a small he can accelerate the process by
sum, directly or indirectly, to a public official for paying €500 to customs control. May
administrative formalities in order to facilitate or I accept so as to keep good business
speed up the granting of services or permits.
relationships with this customer?
This facilitation payment is strictly forbidden,
MUST NOTS even if it is made by a third party. This should
also be reported to one of the reference
contacts.
During a trip abroad, I am stopped
for border control. Even though
I have all the required authorisations
and visas, the controller has a
different point of view about the
Put yourself in danger by refusing to make a situation and threatens to hold me
facilitation payment. back for breaching immigration
laws, unless I pay him €100. Can you
accept to do this? Reference document
As your freedom appears to be threatened, P MNG 0 83 - Facilitation payment
you are exceptionally authorised to make a
payment. You must also report this incident to
Your reference contacts
one of the reference contacts.
Your manager
Your Finance manager
Your Ethics referent
The “Raise your concern” tool
Code of Ethics • 35GIFTS AND INVITATIONS OUR
BUSINESS
INTEGRITY
OUR PRINCIPLES MUSTS WHAT IF
I would like to invite a potential I am organising a call for tenders with
customer from the public sector to our suppliers. One of the applicants has
visit our distribution centre in order to invited me to a professional trade fair
demonstrate our technical and logistical which he is attending and has offered
expertise. He accepts, provided to bear all my costs, including those
that Lyreco bears the travel and of travel and accommodation. May
accommodation expenses. May I accept? I accept?
STRICT REGULATIONS Politely refuse any unauthorised gift or
invitation. Any relationship with public officials is sensitive No, you should refuse as you are responsible
Any gift or invitation, whether received or offered
for anti-corruption matters as the regulation may for managing the call for tenders. This could be
by an employee, is strictly regulated by Lyreco. Consider the context as well as the internal
forbid them to accept any gifts or invitations. The considered as affecting your independence and
policy of Lyreco and that of the business influencing your decision.
partner, before offering a gift or invitation. costs involved must therefore be reasonable,
approved beforehand and strictly associated with
A PRACTICAL GUIDE Read the practical guideline in case of any the visit. Luxury hotels, expensive meals and trips A supplier has invited me to attend
doubt. exceeding the duration of the visit, are strictly a sport event in a VIP suite with one
All employees are invited to read the “Gifts, meals
and invitations” guideline to be familiar with the scope forbidden. of my customers in order to promote
of application and the prior validation process. his products to this customer. Should
I received a gift from a supplier. As I am I accept the invitation?
familiar with the supplier, I consider that No, you cannot accept such an invitation from a
refusing such a gift would be considered supplier, even in the presence of a customer.
as offensive and could hurt our business
relationship. May I accept the gift?
MUST NOTS Gifts from suppliers are not acceptable. However,
if a refusal may affect the business relationship in
question, and solely in this rare case, it may be
accepted, subject to exceptional approval from
the manager. However, you must donate this gift
to “Lyreco for Education”.
My team and I are invited to a whole
day’s meeting by a supplier to present
Conceal gifts or invitations received. his new products. This meeting will take
place in a luxury hotel, followed by a
Be held liable for corruption, subject to dinner. The supplier will bear all costs. Reference document
severe sanctions, by accepting gifts or May I accept? P MNG 0 86 - Gifts and invitations
invitations likely to influence your decision.
In all cases, you must request prior validation “Gifts, meals and invitations” guideline
in accordance with Lyreco’s internal policy.
Approval will depend on the context and factual
circumstances, including the time spent at the Your reference contacts
business meeting during this business trip. It will Your manager
not be accepted if the invitation is considered as
aiming to influence commercial decisions. Your Finance manager
Your Ethics referent
The “Raise your concern” tool
Code of Ethics • 37CUSTOMER AND
SUPPLIER RELATIONSHIPS OUR
BUSINESS
INTEGRITY
OUR PRINCIPLES MUSTS WHAT IF
One of my potential customers from the
public sector has contacted me to inform
me of his intention to delist his existing
supplier for office products in order to
choose Lyreco. However, he does not
wish to launch a public call for tenders
and asked me if I was ready to split our
FOCUS ON CUSTOMER Listen carefully to our business partners.
commercial offering into several lots
EXCELLENCE Resolve or voice our business partners’ so as to remain under the thresholds of
concerns. public tenders. What should I do?
Customer excellence is at the heart
of Lyreco’s performance. Select suppliers on the basis of objective and Any public procurement procedure, including
Our mission equitable criteria. public tenders, are regulated and subject to
Pioneer in delivering sustainably what any workplace Refer to applicable contractual conditions in conditions defined by law. Any manipulation
needs, so its people can focus on what matters most. case of claims from our business partners. or attempt to bypass the public procurement
procedures could lead to heavy penalties for both
Lyreco and the public official in question. Before
accepting your customer’s proposal, you must
A PARTNERSHIP report it to your legal contact referent so as to
WITH OUR SUPPLIERS check the legal feasibility of such a proposal.
Our ability to offer customer excellence One of our suppliers is currently out of
is based, above all, on a long-term stock, which could affect our capacity
partnership with our suppliers. to serve our customers. I have found
MUST NOTS
an alternative supplier who I know
professionally, but who is not listed by
A GUARANTEE OF Lyreco. May I place the order directly
with him?
INTEGRITY AND TRUST
Any supplier selection must follow the mandatory
Acting with integrity and respect is
tender process, even in this case. Moreover, the
essential to a sustainable and trusting
supplier must be subject to prior assessments.
relationship with our business partners.
A new supplier may not, therefore, be selected
Promise products or services that Lyreco is without following Lyreco’s internal policy on this
unable to supply. matter.
Enter into a business relationship without During a supplier assessment, I noted
prior information regarding the business that a subsidiary of one of our suppliers
partner in question. was suspected of corruption. How
should I respond? Your reference contacts
Disclose any confidential information without
prior approval. You should immediately inform one of the Your manager
reference contacts. A decision to continue or not Your Sales manager
Ignore or minimise any complaint from our business relationships with this supplier, based
business partners. on substantiated facts, shall be taken by Lyreco Your Legal manager
and communicated to the supplier in question.
Your Ethics referent
Vigilance is required considering the potential
impact on Lyreco’s reputation. The “Raise your concern” tool
Code of Ethics • 39OUR
PRODUCTS
AND ASSETS
—
Code of Ethics • 41PRODUCT EXCELLENCE OUR
PRODUCTS
AND ASSETS
OUR PRINCIPLES MUSTS WHAT IF Reference document
MNG 010 - Suppliers Code of Ethics
A customer is faced with a quality
issue concerning a product supplied
by Lyreco. I was informed of
this problem. May I reply to this
customer? Your reference contacts
Any question raised by a customer Your manager
A QUEST Require the suppliers to provide all the
documentation regarding the products.
concerning the quality of our products and Your Marketing manager
services must be handled with the utmost
FOR EXCELLENCE care. Inform immediately one of the reference Your QSS manager
Store, transport and deliver the products,
Lyreco shall ensure that all the products offered contacts so that Lyreco can quickly assess the
considering the nature and instructions from Your Ethics referent
to our customers meet the highest standards in quality issue and the risk level both for the
the suppliers.
terms of quality, safety and environment. customer and ourselves. You are only allowed The “Raise your concern” tool
to inform your customer that the issue raised
has been taken into account. Do not take any
initiative or action on your own. Based on
THE KEY ROLE quality investigation, corrective measures and
OF OUR SUPPLIERS dedicated communication (if any) could be
Lyreco works exclusively with business partners implemented by the relevant departments in
sharing the same ambitions for product excellence. charge.
MUST NOTS
Conceal or ignore any issue related to
product quality or product conformity.
Attempt to resolve a quality issue without
referring to the relevant persons.
Code of Ethics • 43PROTECTION OF ASSETS OUR
PRODUCTS
AND ASSETS
OUR PRINCIPLES MUSTS WHAT IF
A colleague does not have access
to an IT tool for which I am the
administrator. May I send them my
login details?
You must never disclose your login details.
Instead, create a new access for your
AVOID ANY Lock your computer when leaving the office
and change your password when requested.
colleague after having received prior
approval justifying the access request for this
INAPROPRIATE USAGE colleague.
Process the personal data in accordance
Each employee must use the company’s assets
with the applicable regulations and Lyreco’s
exclusively for professional purposes
internal policy. My computer and mobile phone
and protect them against any loss, theft,
have been stolen. What should
destruction, illicit use or premature wear. Ensure that all external persons invited
I do to ensure that company data is
on Lyreco’s premises are registered and
protected?
accompanied.
Please immediately inform one of the
SECURITY MEASURES reference contacts so that they may secure
Lyreco has implemented adequate security data stored on your devices. Also, quickly
measures to guard against cyber-attacks report the loss or theft to the competent
and risks of loss or breach of data. authorities.
—
MUST NOTS
What is it?
Assets refers to all Lyreco’s tangible and intangible
assets (e.g., its facilities, tools, vehicles, office
equipment, mobile phones, computers, laptops,
financial data, personal data, sensitive information,
intellectual property rights, software, etc.).
Share your logins and passwords.
Disclose data to a non-authorised person. Reference document
Leave confidential or sensitive data on a Data privacy policy
printer or on a shared server.
Keep or transfer professional documents onto Your reference contacts
personal devices (telephones or laptops). Your manager
Your IT manager
Your data protection officer
Your Ethics referent
The “Raise your concern” tool
Code of Ethics • 45COMMUNICATION OUR
PRODUCTS
AND ASSETS
OUR PRINCIPLES MUSTS WHAT IF
I would like to use my own social approval from your your Managing director
media account to promote Lyreco, and your Communication manager.
its solutions and products, but I fear
to speak the wrong way or disclose A service provider has asked me for
confidential information. What can a customer testimony during an event
A NECESSARY I do? or on his website to promote his
Comply with the communication guides and
VALIDATION graphic charts.
You may ask your Communication manager offer. Is this authorised?
for advice and ready-to-use contents. You Use of the Lyreco brand by an external
Any employee brought to voice in the media
Take any necessary measures to avoid are free to re-post any official content posted business partner is subject to authorisation
or during external events, as a representative
disclosing confidential information. by the Communication teams or managing defined by contract. Ask your legal reference
of Lyreco, must obtain prior approval.
directors on the company or subsidiary contact if such an authorisation is mentioned
Share with the Communication manager company account. in the contract between the company
any sensitive or negative comment or news
and the service provider. The testimony
VIGILANCE AND article that could harm Lyreco’s reputation,
particularly those intended for social A magazine or blog has asked me for must be submitted for prior approval by
CONFIDENTIALITY networks. an interview. Is this authorised? the Communication manager before any
publication.
Irrespective of the channel, especially on social Only accredited spokespersons are authorised
networks, any employee communications must comply to give interviews. If the media or interview
with our values and with the reality of our business is related to your specific expertise, ask for
activity and not contain any confidential information.
Reference document
MUST NOTS P MNG 087 - Communication
Your reference contacts
Your manager
Your Communication manager
Your Ethics referent
The “Raise your concern” tool
Give an interview or publish information that
has not been previously approved by the
Communication manager.
Publicly denigrate the company or its
business partners.
Disseminate false or misleading information
or contents.
Code of Ethics • 47OUR
SOCIETAL
ENGAGEMENT
—
Code of Ethics • 49ENVIRONMENT OUR
SOCIETAL
ENGAGEMENT
OUR PRINCIPLES MUSTS WHAT IF
I am a purchaser. How can I ensure A customer has requested more
that suppliers I have selected information concerning our
comply with our environmental environmental commitment. What
requirements? information may I supply?
Lyreco has implemented strict policies and You can send the information published in the
procedures to ensure the full respect of the CSR report. Each year, Lyreco provides and
A HISTORIC Consider the respect of the environment when
making decisions.
environment in all our business activities
and decisions, wherever we operate. Any
publishes a CSR report at Group level. Each
subsidiary may also provide a local version of
COMMITMENT supplier must comply with these policies and this report highlighting local facts and figures.
Follow local instructions regarding
The respect of the environment, the preservation of procedures.
environmental impact (e.g., reducing and
natural resources and the fight against climate change,
sorting waste, prohibiting single-use drinking A customer has asked me for
are longstanding policies within Lyreco’s values.
cups, making energy savings, etc.). I am a new Lyreco employee. sustainable products. May I respond
What can I do to contribute to the to his request?
company’s environmental objectives?
Yes. Lyreco provides a very wide range of
CONCRETE EVIDENCE Being ISO 14001 certified, environmental sustainable products, also called “green
We contribute to this commitment by adopting objectives have been specifically defined for products”, which are selected and assessed
a CSR approach, by raising our colleagues and our business activities. Please consult these to comply with the relevant ISO standards.
business partners awareness on more responsible objectives in order to contribute to them.
practices, offering our customers products and
solutions which are always more sustainable and by
continuously improving our operational processes.
MUST NOTS
Reference documents
Conceal or ignore any inappropriate
environmental practices from employees or MNG 010 - Suppliers Code of Ethics
business partners. CSR report
Overpromise when communicating our
corporate responsibility about environment.. Your reference contacts
Your manager
Your QSS manager
Your Ethics referent
The “Raise your concern” tool
Code of Ethics • 51HUMAN RIGHTS OUR
SOCIETAL
ENGAGEMENT
OUR PRINCIPLES MUSTS
FUNDAMENTAL RIGHTS Treat everyone, internally or externally, with
dignity and respect.
Lyreco prohibits any form of breach of human
rights such as child labour or modern slavery. Be vigilant against any form of infringement
of human rights.
AN INTEGRATED WHAT IF
ASSESSMENT
The CSR assessment of our suppliers is part
of our auditing and selection processes. I read in the papers that one of A customer wants to know the Lyreco
our suppliers is suspected of being process implemented for reducing
directly or indirectly involved in the CSR risks in our supply chain.
a case of modern slavery or child What information can I share with
labour. How should I respond? him?
Share the information immediately with one of The CSR report is provided and published
the reference contacts so that an investigation every year and is the reference document
MUST NOTS may be conducted and the information may which can be sent to him. You will find a
be clarified. Our suppliers are required to detailed description of our CSR policies
apply standards equivalent to ours. In such a therein. Furthermore, you may also share
situation, vigilance is required considering our vigilance plans which set out the latest
the potential impact on Lyreco’s reputation. relevant facts and figures.
I am a purchaser and I would like
to select a new supplier for Lyreco
branded products. I know that
Conceal or ignore any breach of human rights prerequisite criteria for selection Reference documents
internally or externally. are required. May they be requested
after selecting the supplier? MNG 010 - Suppliers Code of Ethics
Try to resolve, by yourself, any issue relating
to human rights. CSR report
No. A CSR assessment for all suppliers
providing Lyreco branded products is a Your reference contacts
prerequisite before any supplier selection.
Only suppliers that have been duly assessed Your manager
and approved may be selected.
Your QSS manager
Your Ethics referent
The “Raise your concern” tool
Code of Ethics • 53POLITICAL ACTIVITIES
AND LOBBYING
OUR
SOCIETAL
ENGAGEMENT
OUR PRINCIPLES MUSTS WHAT IF
I find climate change very worrying.
I am an active member of a reputable
association which undertakes
lobbying actions towards local
governments to encourage them
to act against climate change. I am
proud of Lyreco’s commitments
POLITICAL NEUTRALITY Respect the political choices and opinions
of colleagues. regarding the climate. May I use
Lyreco does not support or finance any Lyreco’s name and actions as
political party or organisation. Avoid any political communication on behalf leverage?
of Lyreco.
Any employee may, as an individual, contribute You are free to be part of any association or
to political activities on a personal basis but organisation and conduct active campaigns to
must not, under any circumstances, give the support a cause in which you believe. These
impression of representing Lyreco. types of activities must strictly remain in the
private sphere.
Under no circumstances should the brand,
NO LOBBYING facilities and actions of Lyreco be associated
On principle, any lobbying activities on with your personal engagement or used to
behalf of Lyreco are prohibited. influence the public authorities.
— I would like to get involved in politics
and I foresee presenting myself in a
What is it? local or national election. Do I have
Lobbying refers to any action or communication the right to do this?
towards public or political authorities for
MUST NOTS
You are free to be part of any political
the purpose of influencing a decision. activities, whether as a member of a political
party or by presenting yourself for election,
as long as you do not use the brand, facilities
or premises of Lyreco to improve your profile
or support your campaign. Political activities
must remain strictly in the private sphere. Your
name must not, under any circumstances, be
associated with Lyreco in this context. Reference document
Carry out political activities within Lyreco.
P MNG 0 84 - Lobbying and
sponsoring
Your reference contacts
Your manager
Your HR manager
Your Ethics referent
Code of Ethics • 55CITIZENSHIP AND SOCIETAL
ENGAGEMENT OUR
SOCIETAL
ENGAGEMENT
OUR PRINCIPLES MUSTS WHAT IF
I would like my subsidiary to support Supporting a charitable cause for commercial
a charitable organisation in addition purposes is strictly unethical and contrary
to “Lyreco For Education”. Is this to Lyreco’s values. All our resources are
possible? dedicated to “Lyreco For Education”. We
recommend that you present the efforts
Any support or funding aimed at a local accomplished by Lyreco for “Lyreco For
charitable organisation must be approved. Education” to your customer. Please feel
A CONCRETE COMMITMENT Act transparently when supporting local
communities.
Before you commit yourself to such local free to invite your customer to join us in this
As a responsible corporate citizen, Lyreco is committed actions, ensure that the organisation you project. Additionally, considering the number
to international or local social and citizen activities. Record all donations offered for accounting would like to support has good references. of customers and suppliers working with
purposes. Funds must be clearly allocated to specific Lyreco, we are unable to permit ourselves to
In 2008, Lyreco created “Lyreco For Education”, support all of their charitable projects.
actions carried out by the organisation and
a programme to support the education of
the impacts on the community must be
children in the poorest countries.
measured by means of key indicators.
I have been contacted for the
NO SPONSORSHIP purposes of Lyreco sponsoring a
On principle, any form of sponsorship is Reference document
sport event. How should I respond?
forbidden. Instead, material or financial support P MNG 0 84 - Lobbying and
to local communities on behalf of Lyreco may Sponsorship is not, in principle, authorised in sponsoring
be authorised, under certain conditions. accordance with Lyreco’s internal policy. You
should refuse such a request.
— Your reference contacts
A potential customer supports a Your manager
What is it? MUST NOTS
charitable organisation. If Lyreco Your Communication manager
Sponsorship refers to financial or material support supports the same organisation,
granted to an event or programme (generally in the I think that this would help us to win Your Ethics referent
field of sports, arts, entertainment or charitable actions) this customer’s account. Am I right? The “Raise your concern” tool
for the purposes of promoting its brand or image.
Use the engagement towards “Lyreco For
Education” or any other local charitable
organisation as commercial leverage.
Support any organisation that could harm
Lyreco’s reputation.
© Nicolas Axelrod
Code of Ethics • 57Revised version : October 2020
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