157
Annual Report -
2013
-
Vivendi
Information About The Company |
Corporate Governance
| Reports
3
Compliance Program
3.6.
Compliance Program
The purpose of the Compliance Program is to inform, train and raise
the awareness of Group employees in their activities, with a view to
reducing any liability risks incurred.
The Compliance Program sets rules of conduct based on general
principles of international law (including those established by the OECD,
ILO and EU law) as well as prevailing legislation in various countries
(principally France and common law countries).
The Compliance Program sets forth the general ethical rules applicable
to all Group entities. These rules are applied downstream, in each
operational business unit in all the countries in which Vivendi is present,
adapted to address the specific features of a subsidiary’s business as
well as those of national legislation. At its meeting held on March 16,
2004, the Board of Directors of Vivendi, upon recommendation of its
Audit Committee, approved a Financial Code of Ethics. This Code has
been maintained following the change in the Company’s organizational
structure. The Code applies to the senior executives of Vivendi SA,
particularly those responsible for communications and financial and
accounting reporting, which represents approximately 60 people.
The company’s legal department, based at its headquarters, and
the Compliance Officers of each business unit work to ensure
overall consistency, coordinated by the General Counsel’s office. An
annual progress report is prepared and presented by Vivendi SA’s
legal department to the Audit Committee, which then reports to the
Supervisory Board and transmits the report to the Management Board.
3.6.1.
Reasons for the Program
The Compliance Program addresses the following main issues:
the new national and international standards requiring companies to
report on how they comply with their societal responsibilities; and
the introduction of new non-financial rating criteria aimed at
assessing the policies that companies have set up to manage these
responsibilities.
3.6.2.
Objectives
The Compliance Program has two major purposes:
to raise the awareness of Group employees and provide them with
a clear and precise reference tool that guides them in determining
appropriate courses of action; and
to reduce the risks of civil and criminal liability by both the Group’s
employees and its companies.
