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 does not meet the thresholds of the anti-corruption measures set out in the Sapin II Law (500 people and 100 million euros of turnover). Despite all the analysis and some actions required by this law (Risk mapping related to corruption, internal warning system, staff training, code of conduct) are already in place, and the others will follow quickly, to make sure the Group is ready if the thresholds are met.

GDPR

The General Data Protection Regulation (GDPR) is the new text from the European Union defining the rules and obligations that apply to the processing of personal data. It came into effect in May 25, 2018.
It aims at strengthening the rights of individuals, making the people processing data accountable and facilitating the cooperation between the regulatory authorities in charge of data protection.

The Gévelot Group undertakes to process with compliance all the personal data in its possession as part of its responsibilities associated with GDPR. Some procedures have been implemented, as well as the nomination of a data protection officer to put it all together.