Valeo compliance program: zero tolerance
The Group’s Compliance Organization
The Compliance organization is based on several committees and the total commitment of Valeo’s management as well as the personnel’s mobilization.
Audit & Risks Committee
The Audit and Risks Committee of the Board of Directors is responsible for ensuring the effectiveness of the risk management and internal control systems. As such, it regularly ensures that Valeo maintains a comprehensive program to comply with all laws and regulations governing its business activities, and conducts its business in an ethical and responsible manner.
The Executive Committee
The Executive Committee, chaired by Valeo’s Chief Executive Officer, defines the directions and priorities of the Compliance Program, allocates the necessary means and resources, and oversees and manages its implementation.
Executive Committee members are then responsible for conveying Valeo impeccable business ethics and end-to-end integrity culture throughout the organization either directly or via their own leadership teams.
The Ethics and Compliance Office
The Chief Ethics, Compliance and Data Protection Officer, together with a team of Compliance professionals, initiates, manages and coordinates the implementation of the Compliance programs as defined by the Executive Committee.
Reporting to the CEO, Valeo’s Chief Ethics, Compliance and Data Protection Officer provides regular program updates to the Audit & Risks Committee and to the Board of Directors of Valeo. She also sits on the Executive and Liaison Committees and collaborates extensively and closely with their members. She also sits on the risk committee and chairs the Alert committee. All contribute actively, both individually and via their teams, to the effectiveness and efficiency of the Compliance programs of Valeo.
The Compliance Champions
In support of and in coordination with the Ethics and Compliance Office, a team of Compliance and Data Protection Champions and officers, are responsible for promoting the Compliance programs within their area of responsibility, at Business Group, local and functional levels (Sales, R&D, Projects, Finance, HR, Legal, Purchasing, etc.).
Acting as spokespersons of both their leadership and the Chief Ethics, Compliance and Data Protection Officer, Compliance and data protection Champions are also responsible for helping their peers and colleagues understand the policies and tools applicable to their activities in consultation with the Ethics and Compliance Office as needed.
The management team
E&C and Data protection roles and responsibilities are clearly allocated among the various managers. As a matter of fact, managers, from all countries and businesses, have a key role to play in advocating and enforcing Compliance among their teams throughout Valeo’s day-to-day operations.
Ultimately, managers are all expected to act as role models and convey a zero tolerance approach to non compliance.
Employees at large
All employees are expected to behave ethically. They are specifically responsible for knowing and understanding the Code of Business Ethics, the Compliance programs and the policies, for complying with approval procedures, for taking all training in due course, asking for help as needed and alerting in case of doubts.
Education awareness, training:
the cornerstones of Ethics and Compliance
Education awareness
Education is provided and awareness is developed in a variety of ways, including orientation and induction programs, team meetings, annual elearning campaigns and dedicated in person and virtual training sessions. The Executive Management conveys an Ethics and Compliance culture and reminds staff our zero tolerance for Ethics and Compliance violations.
Training
As stated in Valeo Compliance Training policy, training is an essential component of Valeo’s Ethics and Compliance Program.
It is available in the form of both live training sessions and e-learning programs, developed in multiple languages. It is mandatory for all executives and engineers and those who either are exposed in their day to day activity or take part in particular projects or operations, in line with Valeo’s policies. It is strongly recommended for all other staff, who are regularly encouraged to follow the Program; and new joiners are to take the Ethics and compliance program within a month from on boarding.
In addition, special modules have been integrated into Valeo’s Leadership Development programs as well as training geared to specific functions such as sales, supply chain and purchasing.
Failure to participate in mandatory Compliance training may result in disciplinary action.
Business partners’ Commitment
Valeo expects from its Business partners that they share the same business ethics and apply the same level of care, diligence and compliance to their operations.
Suppliers, service providers, third party intermediaries must comply with both the laws and regulations of the countries in which they operate. They also need to agree to the Valeo Business Partner Code of Conduct and to make sure that their team members assigned to a mission for Valeo, understand and agree to it.
Business partners’ awareness development
In order to develop their understanding and awareness of the Compliance programs and Valeo’s policies and expectations in that respect, Valeo Ethics & Compliance Office has:
- Created a Business Partners Ethics and Compliance Library containing a handbook on each program (Anti-corruption, Antitrust, Export Control & Economic Sanctions, Data Protection and Human Rights),
- Made free compliance awareness development e-learning available to Valeo’s Business partners; those modules are highly recommended for all business partners and they are mandatory for some of them, among whom agents and intermediaries and their teams assigned to a Valeo project or mission. Modules are available in English, French, German, Chinese, Japanese and Spanish.
