CODE OF CONDUCT

BACK TO CONTENTS

BACK TO CONTENTS

The CACEIS Code of Conduct sets out the Group’s historic values, as contained in the Crédit Agricole S.A. Code of Ethics, in concrete rules and daily behaviour. It is a tool and a guide to help us better explain our professional obligations and adopt behaviour that is in line with CACEIS’s ethics and values. USING OUR CODE OF CONDUCT

lic interest, a violation or attempt to conceal a breach of an international commitment duly ratified or approved by France in par ticular, using the Group whistleblower tool, by clicking here. This tool, can be accessed 24/7 from a con nected personal or work computer via a unique link. It guarantees the confidential ity of the whistleblower, the incidents re ported and the people involved. The infor mation is encrypted and stored in a separate secure environment. WHAT ROLE AND EXPECTATIONS TOWARDS MANAGERS? As an executive or manager, you must em body the Group’s values as set out in the Crédit Agricole SA Code of Ethics and be exemplary in applying the principles of the Code of Conduct and Rules of Procedure. As an executive manager, you must ensure your teams know you are always there to listen to their needs and create a climate of trust so that they will not hesitate to seek your advice if they have a problem. You have to be able to explain the functions of the Code and how to apply them. If you have any questions, don’t hesitate to consult the department most qualified to deal with the issue at hand (Compliance, Human Re sources, etc.). You must be vigilant and conduct yourself in a transparent manner. Show that it is entirely possible to attain the objectives that have been set, while respecting the ethics and values of the Group.

WHO SUPERVISES THE IMPLEMENTATION OF THE CODE? WHO UPDATES IT? A multi-disciplinary team that is backed by the Compliance and Human Resources Heads is responsible for implementing, monitoring and updating the Code of Conduct. The con tents of the Code may change over time. The Code does not replace the internal regulations and procedures of CACEIS. It is your duty and responsibility to consult and apply them. HOW IS THE CODE OF CONDUCT MADE AVAILABLE? WHAT IS ITS VISIBILITY? The Code of Conduct is a document that is made public and shared with stakeholders. It is available on the website and Intranet of CACEIS. WHAT DOES IT MEAN ON A DAILY BASIS FOR EMPLOYEES ? We must all be aware of the principles set out in the Code of Conduct and respect them when performing our daily duties. In addition, we adopt and promote the values and prin ciples presented in the Code of Conduct, with vigilance and good intentions. Lastly, we must do the Code of Conduct training courses. The aim of the whistleblowing system is to strengthen risk prevention by giving all the employees, as well as any person subject to the laws in force (job applicant, former em ployee, shareholder and partner, external or occasional employee, supplier), the means to report or disclose information related to a crime, offence, threat or damage to the pub WHAT IS WHISTLEBLOWING?

WHO DOES IT APPLY TO?

Nevertheless, our Code of Conduct is not intended to be exhaustive. Neither does it claim to answer all questions or address all possible cases, particularly with regard to what you must do and must not do. For this reason, in all situations and when making decisions, everyone should ask themselves the following questions:

The Code of Conduct applies to us all: direc tors, managers and employees, regardless of our position and role within CACEIS.

OBJECTIVES AND HOW TO INTERPRET THE CODE?

Our Code of Conduct is a reference document and a tool to help us make decisions in ac cordance with our values, our ethical princi ples and, of course, the law. It explains, by topic, the professional behav iour to be followed and promoted in carrying out our duties and in our working relationships. Our rules of conduct are organised into four sections: • the «customer and supplier relations» sec tion ; • the «social, environmental and societal is sues» section ; • the «anti-corruption» section ; • the «protection and reputation of the Group» section. Note that conflicts of interests, which is a cross-functional topic, is included in the an ti-corruption section. To provide further information, some practi cal cases have been cited to illustrate, using specific examples, the principles presented in the Code.

Five questions to ask to ensure ethical behaviour

5 QUESTIONS

1. Is it legal? 2. Is it in line with the Crédit Agricole S.A.’s Code of Ethics and Code of Conduct? 3. Is it in the interest of our customers and stakeholders? 4. Have I taken into account the risks involved and what the consequences of my decision could be? 5. Would I be comfortable if my decision were to be made public internally and externally?

If the answer to any of these questions is «no», or if in doubt, you must discuss it with some one before taking action. You may consult your manager, or contact the Compliance, Human Resources, and Legal Affairs depart ments, or any other department qualified to deal with the issue at hand and keep a record of all problems encountered.

One key rule to remember

Whenever you notice or suspect an inappropriate act or form of behaviour, or when you feel under pressure, you must immediately talk about it with your manager.

ONE KEY RULE

6

7

CODE OF CONDUCT

CODE OF CONDUCT

Last update: june 2023

Last update: june 2023

Made with FlippingBook - Online magazine maker