Compliance Program

 

Anti-corruption Code

At Vivendi, all employees are required to comply with the laws and regulations in the countries in which they operate. The Group’s commitment in this regard is reflected in the implementation of a Compliance Program that covers personal data protection and anti-corruption measures, as well as obligations for monitoring the Group’s business activities.

An Anti-corruption policy has been drawn up to prevent and identify any potential risks situation. These rules apply to all Vivendi employees and all Group business partners (suppliers, subcontractors, intermediaries, etc.).

The anti-corruption program will be rolled-out at Group level by the Compliance Officers appointed in each entity. Working alongside the Group’s CSR and Compliance Department, they are responsible for implementing the program in place.

 

Vigilance Program

Since 2002, Vivendi has committed to implementing a Compliance Program which sets out general ethics rules which are applicable to each and every group employee.

These guidelines cover the rights of employees, the quality of information and its protection, the prevention of conflicts of interest, commercial ethics and the respect of competition rules, the use of group property and resources, financial ethics and respect for the environment. The objective of the Compliance Program is to make employees aware of their professional responsibilities, to provide them with a reference tool that helps them determine appropriate conduct.

These general rules are applied in each operational business unit and are adapted to both local legislation and business activities as required. As a result, certain entities have implemented an additional code of conduct.

The implementation of the Compliance Program is followed by the legal teams and the compliance officers of the main operational entities and headquarters.

At the beginning of each year, subsidiaries submit a report to Vivendi on the actions taken in the prior year. The General Counsel presents this report to the Audit Committee for validation. Then the report is sent to the compliance officers of the business units.