Our compliance program
The Quadient Ethics and Compliance Program is an integral part of our daily business operations and practices. To ensure this commitment to compliance and enabling a strong culture of excellence and integrity, we have developed our program around our Code of Ethics, our compliance policies and practices, measures and mechanisms to conduct due diligence on third party companies, our ethics line to report any violation or misconduct, and a worldwide compliance team responsible for their implementation.
As a signatory of the UN Global Compact, Quadient strives each day to conduct its business with the highest standards of professionalism and integrity. Quadient’s senior management is committed to:
- Complying with all applicable laws;
- Applying the ethical standards set forth in the Company’s Code of Ethics and corporate policies;
- Enabling a culture of Excellence and Integrity by raising the awareness of our employees, providing relevant training and communication;
- Enforcing the ethics & compliance program across the organization.
An Ethics & Compliance committee chaired by the VP of CSR and Compliance manages the investigations and remediations of the alerts received. This committee is composed of:
- the Chief People Officer;
- the General Counsel;
- and the VP of Internal audit.
A Risk Committee brings together:
- the Chief Executive Officer;
- the Chief People Officer;
- the Chief Financial Officer;
- the Chief Transformation Officer;
- the VP of Internal Control and Internal Audit;
- and the VP of CSR and Compliance.
The Risk Committee is responsible for validating and monitoring the effectiveness of the action plans covering the major risks identified in the risk mapping. It ensures and supports the proper functioning of the risk management systems and may also decide on which risks are unacceptable within the context of the business. The Quadient risk assessment and risk mapping is reviewed every year by the Board's Audit committee as well as the performance of the compliance program.
The Compliance team is led by the VP of CSR and Compliance who reports directly to the Chief Transformation Officer who is a member of the Company's Executive Committee.
The Compliance team is organized around:
- A center of excellence which establishes the company-wide policies and standards and dedicated to the supervision of the various risks and controls as well as key cross-functional activities such as training;
- Teams dedicated to each business line, regions and other support functions.
The Compliance team works daily to execute our unified ethics and compliance program across Quadient, which includes the following activities:
- Monitoring regulatory changes;
- Identifying compliance risks and areas of opportunity;
- Monitoring and supporting the update of our compliance-related policies;
- Managing our Integrated Management Systems (IMS);
- Implementing processes and controls to improve our business;
- Investigating any compliance issues, and supporting the implementation of any related remedial action plans;
- And as needed, auditing our teams' compliance with non-financial policies.
As soon as they arrive at Quadient, new employees are made aware of the Company's Compliance Program. All employees, whether they are permanent or fixed term or temporary workers, are requested to follow the mandatory compliance training and awareness courses. All of them must complete the e-learning modules related to the Code of Ethics, Data Privacy, Information Security and Corruption and Bribery. Enhanced training courses are provided to employees exposed to greater potential risks.
Acting with integrity also includes speaking up when we believe someone has engaged in conduct that violates the law or our Code of Ethics or simply to ask questions about our program and our policies. We encourage all employees to contact the compliance team, ask a question or report their concern through our Quadient Ethics Line.
Our Code of Ethics
Our Code of Ethics
We believe that conducting our business in an ethical and responsible manner is essential to the sustainable growth and success of our Company. Our Code of Ethics sets out principles of ethics and business conduct that help each of us to act with integrity and ethically. This instrumental booklet describes best practices and policies that will elevate our Company's reputation and set us on a path of continued growth. In short, our Code of Ethics stands as a testament for doing what we know is right. It covers the following topics: Human Rights, employees, business Ethics, business relationships, Quadient assets and third parties, citizenship and responsible engagement.
Our Compliance Policies and Practices
Based upon the assessment of Quadient compliance risks, policies and procedures have been implemented to control these risks and thus avoid misconducts or compliance violations. These policies are revised on a regular basis and communicated to all our employees and third party companies when relevant.
Corruption and Bribery
Quadient has zero tolerance for any kind of corruption, whether public or private, active or passive. We expect any of our employees, whatever their level of responsibility, and any third party conducting business with Quadient or acting on our behalf to refrain from offering, promising, giving, soliciting or receiving (directly or indirectly) money or anything of value in order to obtain or provide an improper advantage to or from a public official or a private actor. Our anti-corruption policy summarizes our commitment, principles and measures to preventing our employees from the key risk situations such as improper and facilitation payments, gifts & hospitality, conflict of interest, charitable contributions and engaging with third parties.
Antitrust and Fair Competition
Quadient rejects all kind of anti-competitive practices, including price fixing, the rigging of tenders and responses to tenders, or sharing customers, markets or territories. Accordingly, Quadient forbids its employees from entering into any agreement with competitors intended to restrict the nature or quantity of products and services offered, as well as any agreement with suppliers or other partners to obstruct fair competition or the exchange of information with competitors regarding corporate strategy on products or pricing.
Sanctions and Money Laundering
Quadient conducts business with zero tolerance for commercial, financial, or other dealings involving sanctioned countries, territories, and third parties. To prevent the Company from any risks related to economic sanctions or money laundering (AML), we have implemented appropriate risk-based mechanisms for screening business partners, third parties, and transactions for potential economic sanctions and AML exposure.
Information Security
Quadient handles a lot of sensitive information every day and their protection has always been of very high concern for us whether it is concerning the protection of postal transactions, customers’ data or our own data. Aware of the consequences of a security failure in its operations, Quadient has implemented a general information security policy to prevent data loss, misuse or corruption, or theft of Quadient’s assets and data, by limiting access to data and information, protecting information processing facilities from cyber-attacks and physical intrusion and ensuring business continuity.
Data Privacy
Quadient is committed to respecting the privacy rights of its customers, suppliers, business contacts, employees, job applicants, and other third parties Quadient has a relationship with or may need to contact. Quadient has implemented a data privacy policy to ensure that personal information entrusted to us are processed lawfully, fairly and in a transparent manner in relations to individuals as well as ensuring appropriate security level.
Relationships with Third Party
At Quadient, we do business with partners who share our vision and values. We encourage all third-party companies desired doing business with Quadient to become familiar with all the principles and respect the requirements set out within our Code of Conduct for business partners to help align their actions in ways that benefit us all.
Due Diligence
Ensuring high standards in all dealings with our business partners is not an option. Quadient has implemented a policy to perform risk-based due diligence to ensure the integrity of the third party companies to engage with. This process includes reputational screening based on sanctions/watch lists, politically exposed persons lists, checks for exposure to global adverse media and questionnaires related to information security, data privacy and corporate social responsibility. The process also incorporates an enhanced level of due diligence to be performed where a prospective third party resides in a designated high-risk jurisdiction, or where other red flags are identified. The due diligence is updated periodically on a risk basis and in case of significant changes in our relationship with a third party.
Quadient Ethics Line
How to report an Ethical Concern?
Acting with integrity includes speaking up when we believe someone has engaged in conduct that violates the law or our Code of Ethics. Any Quadient employee or any person or third party is encouraged to speak up, in compliance with the law and the rules applicable in the country where he resides or exercises his activities. If you know or suspect a violation of our Code of Ethics or Quadient rules and policies, report it to the compliance team or contact the Quadient Ethics Line.
- The ethics line is available 24hours a day.
- You can make a report online or in most countries, by calling a toll-free number.
- Reports are treated confidentially and, where allowed by law, can be made anonymously.
- We prohibit retaliation for reporting concerns in good faith.
- Antitrust, fair competition and business compliance;
- Asset / information misuse and access;
- Corruption and influence peddling;
- Discrimination or harassment or unfair treatment;
- Financial issues;
- Fraud;
- Health, Safety & Environment;
- Human Rights.
Quadient takes seriously its responsibility to investigate potential violations or instances of misconduct. Quadient has developed an investigation policy and a disciplinary actions policy to ensure that these investigations are conducted in a consistent and professional manner, and that disciplinary actions are considered in full objectivity, fairly and independence.
