Your questions and answers about Ethics and Compliance

Corruption can take many forms that vary in degree from the minor use of influence to institutionalised bribery. Transparency International's definition of corruption is "the abuse of entrusted power for private gain."

http://www.transparency.org/cpi2011/in_detail#myAnchor3

http://www.unglobalcompact.org/aboutthegc/thetenprinciples/principle10.html

Two elements can be isolated:

• A diversion of the power entrusted
• The search of private gain

Therefore, corruption encompasses a variety of practices such as illegal transactions, embezzlement of public funds or theft of public assets, bribery - either monetary or not - favours, services, gifts, etc

For quite a long time, corruption has been pervasive in a great number of countries. But, in the late seventies, the US government was the first to introduce laws designed to prevent corruption of public officials outside the US. In 1997, as part of a campaign led by the OECD, the rest of the world gradually decided to tackle the problem head-on. The year was a turning point in the battle against corruption: the 34 OECD members signed a convention that they subsequently incorporated into national legislation, each bolstering their ability to stamp out corruption. These measures gave countries real power to bring offenders to justice, with investigators and judges in different countries working together to fight against corruption and bribery.

Alstom's commitment rests on three key building blocks.

The first is the Code of Ethics. Alstom released its initial Code of Ethics in 2001 as a direct extension of the first anti-corruption laws. It provides a summary of all Alstom's commitments and rules with regard to ethical conduct.

Second, Alstom has a dedicated team: the Ethics & Compliance Department, which defines ethical rules and monitors their application throughout Alstom. The Ethics & Compliance department has full authority and independence. It reports to the General Counsel and has direct access to the Chairman & CEO and to the Ethics Compliance & Sustainability Committee of the Board.

Lastly, an ambitious Integrity Programme defined and supervised by the Ethics & Compliance Department embodies Alstom's commitments through rules that complement the Code of Ethics. For example, it clarifies proper conduct in potentially risky situations such as dealing with gifts, invitations, contributions and sponsorship. In the field, the Alstom Integrity Programme is promoted and implemented by E&C Ambassadors, all volunteers mainly from the Legal, Finance and HR functions.

The Alstom Integrity Programme also comprises very strict Instructions that govern Alstom's relationship with sales partners, consulting companies, suppliers and contractors, and joint ventures and consortiums. Other Instructions, with regards to conflicts of interest management, gifts & hospitality, facilitation payments, political and charitable contributions and sponsorship, must be also applied by every employee. And face-to-face training sessions and e-learning programmes are deployed within Alstom to explain the Ethics & Compliance policy.

As explained in the Code of Ethics, any Alstom employee may use the Alstom's Alert Procedure, in accordance with the laws and rules applicable in the country where they live or work, if he/she has reason to suspect a violation of the Code of Ethics or Alstom rules and policies.

The Alstom employee wishing to report can use various channels according to his/her preference. Informing his/her direct manager is the most obvious way. But, in case the employee has reason to believe that informing his or her direct manager could cause difficulties or has reason to believe that the reported alleged irregularity will not receive the proper follow-up, he/she can opt for alternative channels such as the website devoted to alert reporting.

Every measure is taken to respect employee's wishes for confidentiality. Alstom does its utmost to honour its commitment that no employee will suffer from retaliation, such as a change of status, harassment or any other form of discrimination as a result of using the Alert Procedure or disclosing information in good faith.

In 2011, Alstom became the first listed French company to be certified by the ETHIC Intelligence Agency, after an audit conducted by the Swiss company SGS, for the Alstom Integrity Programme. It represents real recognition of the Alstom's efforts in this area, proving that the Programme conforms to the most advanced international practices.

In May 2014, Alstom was awarded a renewed certificate for 3 years.

In June 2017, Alstom has obtained the first AFAQ ISO 37001 certification awarded by AFNOR Certification following an audit carried out between March and May 2017 at seven sites in France and Europe, confirming its commitment to fight corruption.

The international standard ISO 37001, introduced in October 2016, advocates a series of measures to help organisations of all sizes, both private and public, to prevent, detect and tackle bribery through the implementation of an anti-bribery management system.

The audit focused on the adequacy of Alstom's anti-bribery system on a European scale according to the standard ISO 37001, in particular its Ethics & Compliance policy, the Group's Code of Ethics issued to all its employees since 2001, and the various instructions relating to existing anti-corruption procedures and numerous associated training tools.

In 2018, an initial audit took place in Asia-Pacific Region and this new region obtained the certification. An audit campaign was also launched for the remaining regions between September-December 2018 and Alstom is now certified ISO 37 001 for all of the 6 operational regions.

The Alstom Integrity Programme aims at promoting a culture of integrity, at preventing and detecting misconduct, infringement of laws, illegal payments and at protecting the company and its employees. Based on a risk assessment, it is continuously enhanced through meetings with peers, anti-corruption experts and specialised law firms to exchange views, good practices and benchmarking and legal opinions.

All Alstom employees are personally responsible for ensuring that their conduct and that of those reporting to them fully complies with this Code of Ethics and all applicable Alstom instructions. Violations of certain instructions may have a severe and/or lasting impact on Alstom’s image, business relations and financial situation. Where circumstances warrant, Alstom may seek civil or criminal prosecution and apply relevant internal measures.