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Compliance Program
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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
maximizing reduction of 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) and European legislation.
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 every country in which Vivendi is present,
adapted to address the specific features of each 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 totals approximately 60 people.
The Company’s General Counsel, based at its headquarters, and the
Compliance Officers of each business unit work to ensure overall
consistency. An annual progress report is prepared and presented
by Vivendi SA’s Legal department, in conjunction with the various
operational divisions, 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:
p
p
the new national and international standards requiring companies to
report on how they comply with their societal responsibilities; and
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the introduction of new non-financial rating criteria aimed at
assessing the policies that companies have set up to manage this
responsibility.
3.6.2.
Objectives
The Compliance Program has two major purposes:
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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
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to reduce the risks of civil and criminal liability by both the group’s
employees and its companies.
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