Ethics & Compliance

Compliance Officer Nomination

The compliance officer role and function within Gévelot is to make sure that the risks incurred by the Group through its activities are taken into account in the strategic and daily decisions, from the Management to Employees.

A Code of Conduct updated

To increase its Employees’ awareness, the Group updated its Code of Conduct in 2017 regarding all the topics related to ethics and compliance. This Code is signed by all the Employees who undertake to respect it and is available in 5 languages (French, English, Italian, Spanish and Chinese).

Insider Trading Prevention

As part of the Insider Trading Prevention, the Gévelot Group has issued an information notice to the persons identified as potentially holding insider information. This notice aims at reminding that everybody is, privately, concerned by the French Law regarding insider trading offences or defaults, and more particularly those relative to the use or the disclosure of insider information.
Such legislation potentially concerns all the shareholders (associates), leaders, employees and persons not employed by the Gévelot Group, whether or not they are shareholders, leaders, employees or not employed by the Gévelot Company, and no matter the subsidiary of the Group in which they work or perform their duties/mandates, the country they live in and their nationality.

Pursuant to the legislation applicable, the Gévelot Group is required to issue, update, and make it available for the Financial Markets Authority (FMA) a list of the people having access, on a regular or occasional basis, to information considered as « insider » concerning them either directly or indirectly. Third parties having access, on equal terms, to this information as part of their professional relations with the Gévelot Group should also appear in a list. It should be noted that the absence of an explicit mention of a person on a list does not prejudice its potential quality of insider. The persons mentioned on the insiders’ register are notified by post and receive the information notice relative to the Insider Trading Prevention.

This list, sent to the FMA on request, shall be kept by Gévelot for a period of 5 years from the day of its issuance or its update.

In this context, Gévelot is required to inform the people concerned about the applicable rules in terms of possession, communication and use of insider information, and about the penalties incurred in the event of breach of those rules. This information is automatically sent by post from the start of each calendar year to the people registered on the insiders register.

Other Tools to Prevent and Fight Corruption

The Gévelot Group must comply with the law n°2016-1691 of 9 December 2016 on transparency, prevention and fight against corruption, as known as the Sapin II law.
The entire Group therefore acts in compliance with this law and applies all its requirements. In particular, the Group has set up an internal whistleblowing system, trained all its staff at risk via a dedicated e-learning programm, established a code of conduct and set up a procedure for evaluating third parties.