The MANE Goup’s Code of Ethics

1. Preamble

For whom is the code intended?
MANE's Code of Ethics has been designed to serve as a guide for all Group employees and anybody working on behalf of the Group.
MANE is deeply committed to the principle of ethical conduct, regardless of the country in which the Group is doing business.
The Group's Code of Ethics provides the general framework for the professional conduct of all employees.
It describes the basic principles of conduct and ethics that govern the Group's activities and that every employee is obliged to apply on a daily basis in decision-making and in his/her interactions with others, both within and outside the Group.
The principles described in this document do not under any circumstances replace the laws and regulations in effect in the different countries where the Group does business.

2. Disseminating and understanding the Code of Ethics

In order to ensure that every employee can understand the Code of Ethics, this document has been translated into several languages, including Arabic, Chinese, English, French, German, Gujrati, Hindi, Indonesian, Italian, Japanese, Kannada, Kazakh, Korean, Malayalam, Marathi, Polish, Portuguese, Romanian, Russian, Spanish, Tamil, Telugu, Thai, Turkish, Ukrainian and Vietnamese.

The Group encourages employees to adopt the ethical principles outlined in the present document and to refer to them regularly in order to become thoroughly familiar with the specific requirements that concern them directly, in the way they do their jobs and conduct business. When in doubt, ask your immediate supervisor.

As part of their responsibilities, managers must actively disseminate and promote the Code of Ethics in the workplace and set an example by adhering to the outlined principles.

Managers must not only inform employees in a pragmatic and concrete manner of the principles they should put into practice, but also make sure they are understood and applied.

3. Our Principles

Transparency
The Group is committed to ensuring transparency in any decision-making that has an impact on society and the environment.
Moreover, the Group is committed to providing appropriate and relevant responses to requests for information.

Upholding laws and regulations
The Group is committed to upholding laws, regulations and other legal obligations in effect in all countries where it conducts business, particularly with regards to human rights and environmental and labour laws.
Every employee must, in the framework of his/her professional activity, demonstrate integrity and uphold applicable laws and regulations.

Respecting Human Rights
The Group respects and uses its sphere of influence to promote the rights laid out in the Universal Declaration of Human Rights. Moreover, the Group recognizes the principle of universal human rights in all countries, cultures and circumstances.

In this way, the Group ensures that none of its subsidiaries participates in human rights violations. The Group expects all employees to adopt, support and enforce human rights in their scope of action.

Upholding labour laws
a. Freedom of assembly and the right to collective bargaining
The Group respects the right of all employees to form and organize unions, belong to the union of their choice and bargain collectively with the Group on their behalf.
The Group is committed to ensuring that all employee representatives and staff members forming worker unions will not be subjected to discrimination, harassment, intimidation or retaliation due to union membership or participation in union activities, and that the representatives in question may contact members in the workplace. 

b. The eradication of all forms of forced or compulsory labour
The Group promises not to engage in or encourage forced or compulsory labour. Forced or compulsory labour refers to work or services carried out by someone who is unwilling, either under threat of sanction or reprisal or demanded as repayment of a debt.

c. Child labour
The Group promises to not engage in or encourage child labour, in compliance with the provisions of the International Labour Organization's Recommendation no. 146 on minimum age.
Child labour refers to work carried out by a child less than 15 years of age, except when local laws stipulate a higher minimum age for work or compulsory education, in which case it is the higher age that prevails.
The Group voluntarily refrains from hiring children less than 18 years of age for working at night or dangerous work.

d. Discrimination
The Group ensures that no employees, suppliers, customers or any other contacts are subjected to discrimination.
Discrimination implies a distinction, exclusion or preference for which the underlying reasoning is based on prejudice rather than a legitimate reason, resulting in the suppression of equal opportunity or treatment. Unfounded reasons for discrimination include gender, age, origin, religion, sexual orientation, physical appearance, pregnancy, invalidity and union membership.
The Group has also signed a company Diversity Charter. The Group is committed to combating all forms of discrimination in recruitment, training and career management. 

e. Health and safety
Within the framework of its work-related health and safety policy, the Group undertakes to provide a healthy and safe work environment for all employees and external company personnel working on one of its sites.
To do this, the Group is committed to providing all necessary resources to avoid the risk of accidents and injuries possibly occurring during, as a result of, or in relation to work by minimizing as much as possible the causes of danger inherent to the work environment.
The Group expects employees to scrupulously respect the rules and standards regarding occupational safety and hygiene.

Working together with mutual respect
All our employees are expected to treat each other professionally, based on mutual respect, trust and individual dignity. The Group condemns all forms of harassment - psychological, physical or sexual. All our employees are expected to use the same standards when interacting with customers, suppliers, as well as others affected by our activities.
Harassment is unwanted verbal or physical behaviour against another person or against a group or community, which may be disturbing, upsetting, threatening, or causing significant emotional distress in ways that are linked to the gender, ethnic origin, nationality, colour, religion, sexual orientation, physical appearance, or disability.

Respecting the Environment
Protecting the Environment is an integral part of the Group's management strategy.
On the basis of commitments shaping its Sustainable Development Policy, the Group is committed to:

  • Designing eco-friendly products and manufacturing processes;
  • Preserving biodiversity and using it sustainably and fairly;
  • Reducing greenhouse gas emissions and improving energy-efficient processes.

All employees contribute to upholding these commitments in their daily activities.

Ensuring respect for property rights

Property rights cover both physical and intellectual property including land rights and other physical property, patents, know-how, manufacturing secrets and other industrial property. They can also include property claims in a wider sense such as traditional knowledge by specific groups (native populations, for example) or the intellectual property of employees or other persons.
The Group is committed to respecting the property rights of others and ensures that its employees do not engage in activities violating these rights.
Employees are also obliged to respect and safeguard MANE's property rights by protecting the Group's interests and tangible and intangible assets in all circumstances.

Confidentiality
Within the scope of his/her duties, any employee may become privy to sensitive and confidential information constituting the Group's intangible assets, which have economic or strategic value.
Any information acquired within the framework of his/her professional responsibilities and which has not officially been made public is considered to be confidential. This information can be scientific, technical or business-related in nature. It includes, but is not limited to, financial results, business strategies, sensitive business information concerning customers or suppliers, human resources information or personal data, information related to new products, product formulas, manufacturing secrets, or know-how developed by the Group, etc.

Under all circumstances, employees entrusted with or having access to confidential information must ensure that it is not divulged to or shared with third parties or used in an unauthorized manner both inside and outside the Group.
In order to protect confidential information, employees must ensure that confidential documents are kept in a safe place and not left in the open in a waste-paper basket, on a desk, on a printer or in a meeting room.

Anti-corruption
The Group condemns corruption in all its forms in its business transactions. As a company that abides by the laws and regulations, either those applying at the national level or international level, MANE also requires its business partners including the joint venture partners, agents, distributors, representative offices, contractors and suppliers to comply with the applying regulation and policies on corruption.

Corruption is an abuse of power by people who use their influence to personal advantage.
No employee should accept or directly or indirectly propose payment in money, gifts or other advantages that may influence the fairness with which he/she does his/her job.
It is obvious, however, that depending on local customs and traditions which vary from one country to the next, or out of courtesy, employees may sometimes accept inexpensive token gifts or lunch invitations on the Group's behalf. Local managers should give employees clear instructions regarding this matter.

Conflict of interest
In performing their tasks, all employees must act in the best interests of MANE and shall avoid any situation and activity, which may give rise to potential conflicts of interests, particularly in regards to personal and/or family interests that might influence their independent judgements and decisions and come into conflict with their work carried out within the company.

Employees shall immediately inform their direct manager/supervisor of any situation concerning them that could create a conflict of interest. Employees in this situation are requested to document and file a specific Conflict of Interest declaration (see FO-RSE-022 available in the Global Documentary System of the Q.S.E.É. space of the Intranet France - Le Bar-sur-Loup).
Furthermore, self-dealing must be avoided. Self-dealing is a conduct of a person that consists of taking advantage of his/her position in a transaction and acting for his/her own interests.

Abiding by competition law
The Group and its employees undertake to respect local laws and regulations that aim to prohibit anti-competitive practices, including pricing agreements and bid rigging, and to promote open and fair competition.

4.  Professional ethics alert system

Framework of the procedure
The present procedure is a complementary device which is not intended to replace traditional channels of internal communication, according to the rules applicable in each country, such as the hierarchical chain, the employee representative bodies or the Human Resources Department.
Its usage is optional and must remain exceptional with regards to its scope of application.
In case of doubt or concern regarding the application of the law or ethical standards, employees may use this professional ethics alert system open to all employees that the MANE Group has established, described in the Code of Ethics.
Since June 2017, an Ethics Committee, reporting directly to the President of MANE Group, has been set up to examine any question relating to ethics via an email address dedicated to ethical alerts: ethics@mane.com. The setting up of this internal warning system allows Group employees to report any violation of the Company's Code of Ethics, including any practices or behaviour that could constitute a breach of applicable laws and regulations, or threats or serious harm to the public interest.

For example, a professional ethics alert could include:

  • The violation:
    • Anti-corruption laws
    • Competition law
    • Banking and accounting law
  • Facts likely to constitute:
    • Internal or external fraud
    • A situation of moral or sexual harassment
    • A safety risk.

The Group is committed to ensuring the confidentiality of the whistle-blower's identity and will ensure that anyone who reports, in good faith, a known or suspected breach of the Code of Ethics is not subject to retaliation, harassment or discrimination in the workplace because of his notice of violation.
However, anyone who abuses the procedure (for example, maliciously reporting a violation of false allegations or making slanderous denunciations for the purpose of harming a person) will be subject to disciplinary action.
Conversely, an employee acting in good faith will not be disciplined or prosecuted if the alleged facts prove to be inaccurate or result in no action.
In order to ensure that no concerns regarding the prevention of corruption remain unanswered, our employees can directly contact the Ethics Committee via the ethics@mane.com e-mail address.

Treatment of personal data collected as part of the professional ethics alert system
Only data strictly limited to the areas covered by the alert may be processed (ie: the identity, functions and contact details of the alert issuer, the alerted persons and those involved in the collection or processing of the alert, the facts reported, the elements collected, the report of the verification operations and the follow-up given to the alert).
The data relating to an alert considered as soon as it is collected by the Ethics Committee as not falling within the scope of the device, will either be destroyed or archived (after anonymization) without delay.
When the alert is not followed by a disciplinary or judicial procedure, the data relating to this alert are destroyed or archived, after anonymization, within two months of the closure of the verification operations.
When disciplinary proceedings or legal proceedings are instituted against the person implicated or the author of an abusive alert, the data relating to this alert are kept until the end of the procedure.

Methods of handling the alert and disciplinary measures
Any receiver notified with a case of violation or suspected violation shall promptly and carefully conduct investigations to ascertain the reported information and, if it is found accurate, shall submit the violation case to the appropriate Manager/Function responsible or to the Ethics Committee who shall take immediate actions against the alleged perpetrator(s), through appropriate and proportionate disciplinary measures in accordance with applicable laws and regulations. Violation of any of the principles of this Code, in consideration of the severity, may also constitute good cause for the closure of working contract.