Anti-corruption

Anti-corruption policy

Naval Group is committed to promoting a culture of integrity. Our anti-corruption policy reflects this commitment. Its creation and deployment is aimed at Naval Group SA employees, our controlled companies and all our stakeholders. It fully complies with the applicable laws and regulations (in particular the French “Sapin II” law dated 9 December 2016, relating to transparency, anti-corruption and economic modernisation).

Culture of integrity

The Naval Group culture of integrity we promote is based on the group’s Code of conduct, available to all employees. This code highlights the zero-tolerance principle with regard to the rules it lays out. This culture is driven by the Naval Group Chairmen and CEO himself and its foundation lies in the exemplary behaviour and engagement of our executive committees and governance bodies.

Vigilance and prevention 

Naval Group identifies, analyses and prioritises the risks of corruption that the company is exposed to by mapping these risks as well as those of influence peddling. This mapping is updated regularly with lessons learned as well as changes in the company’s business environment. An action plan has been drawn up for each of the risks identified, aimed at reducing their effects.

This mapping also helps identify the Naval Group employees (both in France and abroad) and stakeholders who are most exposed to these risks, and provide them training on the subject.

Concrete, comprehensive measures

On a daily basis, the group ensures that:  

• gifts, meals and hospitality are declared whenever they are given to or received from persons outside Naval Group in accordance with pre-defined thresholds;
• membership of non-profit organisations and sponsorship/patronage activities performed in the name of Naval Group are vetted in advance;
• its business practices outside France always comply with the applicable local anti-corruption regulations and with the accounting procedures in force within the group;
• due diligence compliance checks have been performed on contracts and agreements entered into with third parties (in particular business advisors, industrial and strategic partners, offset suppliers and lobbyists or representatives of interest groups);
• its decisions are free of any conflict of interest, particularly as regards the recruitment of new employees, the choice of new business partners, or the selection of new suppliers.
• its actions in terms of representing interests are declared with the HVTAP (High Authority for the Transparency of Public Life).

The Naval Group Code of Conduct sets out the following main rules for behaviour:

• every business relationship with a third party must be vetted in advance for compliance;
• any proposal or granting of request giving an inappropriate advantage, to any public officer or public official, whether directly or indirectly, in return for a decision favourable to Naval Group, or leading the said parties to make abusive use of their real or supposed influence in order to obtain a decision favourable to Naval Group, is strictly prohibited;
• any facilitation payment is prohibited, that is to say an illegal or unofficial payment of a sum in return for services that the paying party would have obtained legally and by right without such a payment;
• any request for patronage or sponsoring, partnership or joining an organisation (scientific bodies or schools) must go through the company approval procedure and be cleared by the group Compliance Department;
• all gifts and meals, whether received or offered, must be declared to and approved by the group Compliance Department, in accordance with the thresholds defined in the Code;
• the duty of loyalty to the company means that professional, financial, family, political or personal interests must not interfere with the judgment of individuals in the performance of their duties;
• each of us play a part at our own level, in maintaining good accounting practices.

For more information please consult our document repository, which can be downloaded from this site.