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Firmly at the centre of our organisation and all our operations and a top priority for our staff.
Our principles are now laid down in two documents: our Ethics Charter and our Code of business Conduct. They are both a reference point and a clear set of rules for our employees. They apply to everyone throughout the entire Group, no matter where they work or whatever their job.
The Ethics Charter is our reference document and is to be applied in our business relations with our customers and providers.
As a major player in its markets, Akiem Group is committed to conducting its business responsibly.
The Group carries out its activities with due regard for the applicable laws and regulations in force, in particular respect for human rights.
Extreme vigilance is required on: Compliance with competition/anti-trust laws
Employees must:
At least once a year, the Group reports on its ethics framework and ensures the matter is on the agenda of the Group Executive Management Committee, which then provides an account of its discussions to the Security, Audit and Compliance Committee (and to the Supervisory Committee if required).
[1] The French version will be the reference for the French entities. The German version will be the reference for all German entities. The same principle of local language will apply equally to all significant Group entities. For the other entities, the English version will be the reference.
The Code of Business Conduct completes our Ethics Charter by defining concretely the rules of individual and collective behaviour that must motivate the choices we make, guide what we do and keep Akiem Group values at the forefront of our minds on a daily basis.
The Code of Business Conduct reflects the particular attention paid by Akiem Group to international principles and local laws governing:
As a consequence, every Akiem Group entity and employee must comply with the laws and regulations of the countries in which we operate. Where there is a difference between a legal requirement and our Code of Business Conduct or our policies, we must always apply the highest standard.
In addition, Akiem Group has signed the European Railway Safety Culture Declaration and is committed to promoting and applying its guidelines.
We are committed to providing a safe working environment where there is respect and equal opportunity for all, including in our recruitment, training and career development processes.
Specific rules and guidelines vary from country to country; however, as an organisation, Akiem Group is committed to promoting a positive and productive workplace environment and to providing a healthy work-life balance.
In particular we promote telework, take care of workspaces and tools to benefit employees’ comfort, and respect employees’ evenings, weekends and holidays.
We are committed to respecting and promoting human rights and are particularly vigilant about issues covered by the fundamental conventions of the International Labour Organisation (prohibition of child labour and forced labour, respect of freedom of association).
We do not tolerate violence, harassment and any form of discrimination against individuals based upon race, religion or belief, national origins, gender, sexual orientation, age, disability, or any other basis prohibited by law.
Akiem Group does not tolerate retaliation against anyone making a report in good faith or for participation in any aspect of an investigation, proceeding or hearing. Reports made in good faith must be honest and accurate; we do not tolerate the filing of any reports intended only to harm an employee’s career or reputation.
HSE is part of our strategy and culture and is an everyday priority.
The Group is committed to ensuring HSE training. Nevertheless, it is essential that each employee understands and applies the specific health, safety and security standards and practices associated with his or her position. For instance, wearing Individual Protection Equipment in workshops, or during a visit to or an intervention on site is compulsory.
Each of us must have a benevolent attitude towards our colleagues and partners and must not hesitate to advise, warn and alert those concerned if a situation that could affect the integrity and health of a person should occur.
To re-emphasise our commitment to safety, we must work free from the influence of alcohol or illegal drugs. These substances adversely affect job performance and can risk our health and safety and that of others. If you suspect that a colleague is intoxicated, under the influence of alcohol or illegal drugs, you should report the situation to your manager.
Akiem Group, our personnel, assets and services, contribute to the European Railway System Safety performance. Safety management culture is part of our DNA and our aim is that our contributions as rolling stock keeper, Entity in Charge of Maintenance or as a simple stakeholder in the railway environment do not lead to any railway accidents.
With this in mind, Akiem Group adheres to and is commited to implementing the European Railway Safety Culture Declaration:
A positive safety culture reinforces the effects of a Safety Management System, improving the capability and efficiency of safety management.
We are convinced that ethical business practices ensure our current and future success. This is why we strictly adhere to policies and laws that promote fair competition in the marketplace and that safeguard against anti-competitive practices, bribery and corruption. Violations in these areas could have severe consequences for Akiem Group and those individuals involved.
Corruption often occurs in secrecy. It is the reason why for all business matters that could significantly affect Akiem Group’s commitments, knowledge, reputation or assets, meetings with third parties should involve at least two Akiem Group employees. Another core element of transparent business conduct is proper documentation. Avoid entering into any agreement without proper written documentation.
In everything we do, we seek to add value for our customers. We are determined to fulfil our commitments and deliver promised traction solutions and maintenance services.
We respect our customers, suppliers and business partners, intellectual property and confidential information. We refuse unethical means of obtaining such information.
We believe in and promote the principle of unrestricted and fair competition. Being careful to comply with antitrust laws, we do not exchange sensitive business data or information with competitors.
For instance, do not engage in discussions or make agreements with any actual or potential competitor about pricing policies, discounts or other terms of sale, or splitting markets or customers.
For Akiem Group, business partners are our suppliers, service providers, consulting firms and labour providers.
As a rule, the use of intermediaries is not authorised. An intermediary is understood as a business facilitator, assisting the Group in approaching a market, an activity or a country, where the Group aims at developing its business. The intermediary’s remuneration typically integrates a success fee without demonstrating the materiality or effort to deliver the service or advice.
Any derogation to this rule is to be formally analysed, presented and pre-approved by the Group Legal Director.
We select business partners based on quality, need, performance and cost. We expect our business partners to be as committed as we are to human rights, fair sales and marketing practices, confidential and personal information protection, intellectual property, and anti-bribery.
It is the responsibility of each Akiem Group employee and manager to select business partners based on merit, without any favouritism or discrimination during the selection process.
Investing in a business partner or lending money to a business partner is not permitted. We may not directly or indirectly accept any kickback or bribe.
Within the Group, only nominated “Referents” are allowed to interact with public officials (such as officers or employees of the public administration, of a government agency, a state-owned company, etc.).
Any dealings with government representatives or administrative agencies must comply with the regulations in force in the country of the government representatives or administrative agencies.
We need to be careful when joining business or industry associations or working groups as these may cause us to interact with competitors. We must be very careful to respect the integrity of the marketplace and to not exchange sensitive data or information. Such participation is subject to Group pre-approval.
Our principle is very clear: corruption is prohibited. Employees must not initiate, proceed with or participate in any action, direct or indirect, with or without money involvement, aimed at influencing, in any way, people or organisations in the performance of their functions in order to gain undue advantage.
Corruption may take many forms, such as common social or business practices, including gifts, invitations, sponsorship, donations, etc.
Do not give or accept:
This list is not limitative.
When you are performing your work, you are responsible for acting professionally and making business decisions in the best interest of Akiem Group without any consideration of personal gain.
A conflict of interest can arise in situations where there is a risk that your personal interest will conflict or interfere with those of the company. You are required to disclose to your manager any personal interest, including outside employment, transactions or relationships that might jeopardise your objectiveness or professionalism in the performance of your work.
In particular:
Akiem Group and its legal entities regularly conduct business with private or publicly traded companies. In the course of this business, you may become aware of confidential information about a company, customer or business partner as part of your work. Buying or selling shares of a company while being aware of such information is considered as insider trading. As a general rule, inside information includes any information that is not public and that may have an effect (positive or negative) on the price of a company’s shares if it were to become public knowledge. For example, ongoing negotiations with a European locomotive supplier for the purchase of a significant number of locomotives may affect the market value of the supplier if listed. Disclosing information on the deal under consideration to external third parties may be considered as insider trading.
You may not provide inside information to anyone so that they can take benefit from it. Insider trading is prohibited.
Akiem Group’s reputation depends on the behaviour of each and every one of us. Particular attention is needed on social media if engaging your own reputation and Akiem Group’s reputation. Remember that whatever you write on the internet is, in practice, never deleted.
Company resources are intended to help employees achieve Akiem Group business goals. Misused or wasted company resources, including employee time, hurt us all and adversely affect the operational and financial performance of Akiem Group.
All information related to Akiem Group that is not in the public domain must be protected and treated confidentially, even if there is no formal obligation of confidentiality. Confidential information includes all non-public strategic, financial, technical or business information belonging to Akiem Group, as well as all business information belonging to our third parties (business partners, customers, etc.).
You are required to pay particular attention to IT confidentiality, such as data protection and data security. The information found on IT systems (hardware, software, networks) is critical to our business success and must be protected.
We take measures to protect our employees’ personal information. Personal information can include government-issued identification numbers, contact information and birth date, financial, medical and compensation information, performance evaluations, promotions and other employment-related information.
Access to this type of information is limited to authorised individuals. We use, manage and dispose of such information in compliance with applicable laws. We are committed to complying with all relevant data privacy requirements of the jurisdictions in which we operate.
We expect all employees and entities to work together in a respectful and open manner. Teamwork is encouraged and successes, as well as failures, should be shared.
We should all aim to give credit to other people’s ideas and recognise the contributions of others. We should listen with generosity and share information as needed with respect of confidentiality.
Being responsible means acting with transparency, being able to explain the rationale of decisions in connection with your area of responsibilities.
It is in the best interest of Akiem Group to speak up when we witness or suspect an activity in violation of our Code or policies.
The normal route for raising such issues is via your management. You can also contact your Human Resources Manager. There may also be additional resources available in your country, such as staff representatives and the whistle blowing platform.