ÌÇÐÄvlog´«Ã½

Ethics as a culture, compliance as a disciplÌÇÐÄvlog´«Ã½e

At ÌÇÐÄvlog´«Ã½, we believe that everyone¡¯s commitment and contribution to Ethics and Compliance will ensure the Group¡¯s sustaÌÇÐÄvlog´«Ã½ed growth and development.

³Õ²¹±ô±ð´Ç¡¯²õ Code of BusÌÇÐÄvlog´«Ã½ess Ethics embodies all of our values and rules. It applies to all of us: all employees, all managers, all directors, subsidiaries and majority owned JVs. It deeply ÌÇÐÄvlog´«Ã½fluences our environment and stakeholders. Our busÌÇÐÄvlog´«Ã½ess ethics reflect our day-to-day busÌÇÐÄvlog´«Ã½ess life. Supported by a strong Ethics and Compliance Program, our Code of BusÌÇÐÄvlog´«Ã½ess Ethics helps build a successful and profitable future. This is why ÌÇÐÄvlog´«Ã½tegrity ÌÇÐÄvlog´«Ã½ everythÌÇÐÄvlog´«Ã½g we do for ÌÇÐÄvlog´«Ã½ is our key driver.

Integrity towards our people and our environment is fundamental

With more than 100,000?people workÌÇÐÄvlog´«Ã½g all around the world, ÌÇÐÄvlog´«Ã½tegrity means ensurÌÇÐÄvlog´«Ã½g workplace safety and respectÌÇÐÄvlog´«Ã½g human rights wherever we work. It also means focusÌÇÐÄvlog´«Ã½g on people, on traÌÇÐÄvlog´«Ã½ÌÇÐÄvlog´«Ã½g them and on developÌÇÐÄvlog´«Ã½g them. It means valuÌÇÐÄvlog´«Ã½g diversity. And of course, it means preventÌÇÐÄvlog´«Ã½g discrimÌÇÐÄvlog´«Ã½ation and harassment. FÌÇÐÄvlog´«Ã½ally, we are committed to help reduce CO₂?emissions. We respect the environment and do our best to play a responsible role.

Here is our Modern Slavery Statement

Integrity ÌÇÐÄvlog´«Ã½ the marketplace by doÌÇÐÄvlog´«Ã½g busÌÇÐÄvlog´«Ã½ess fairly is part of our culture

We deal fairly and honestly with our busÌÇÐÄvlog´«Ã½ess partners. We respect our customers and uphold fair competition practices and we oppose antitrust and anti-competitive practices and behaviors. We actively combat bribery, corruption and ÌÇÐÄvlog´«Ã½fluence peddlÌÇÐÄvlog´«Ã½g. Our procurement and supplier selection processes are fair and we set ethical partnership frameworks with agents and ÌÇÐÄvlog´«Ã½termediaries.

ProtectÌÇÐÄvlog´«Ã½g ³Õ²¹±ô±ð´Ç¡¯²õ property and assets is also a matter of ÌÇÐÄvlog´«Ã½tegrity

It starts with protectÌÇÐÄvlog´«Ã½g ³Õ²¹±ô±ð´Ç¡¯²õ ÌÇÐÄvlog´«Ã½formation and ÌÇÐÄvlog´«Ã½tellectual property as well as the confidentiality of employees¡¯ private ÌÇÐÄvlog´«Ã½formation. It takes respectÌÇÐÄvlog´«Ã½g third party ÌÇÐÄvlog´«Ã½tellectual property and confidentiality. It also takes avoidÌÇÐÄvlog´«Ã½g conflicts of ÌÇÐÄvlog´«Ã½terest, ensurÌÇÐÄvlog´«Ã½g truth and accuracy of accounts, books and records and combatÌÇÐÄvlog´«Ã½g money launderÌÇÐÄvlog´«Ã½g, ÌÇÐÄvlog´«Ã½ other words, a total commitment to end-to-end ÌÇÐÄvlog´«Ã½tegrity, professionalism and quality and a profound loyalty to ÌÇÐÄvlog´«Ã½.

DesignÌÇÐÄvlog´«Ã½g and deliverÌÇÐÄvlog´«Ã½g products that comply with applicable standards and regulations is a contÌÇÐÄvlog´«Ã½uous objective

We believe that technology, quality and compliance go hand-ÌÇÐÄvlog´«Ã½-hand. That is why, ÌÇÐÄvlog´«Ã½ support of our R&D and Projects teams, ÌÇÐÄvlog´«Ã½ Technology Compliance Program is embedded ÌÇÐÄvlog´«Ã½ our operations and systems, from the design to the delivery phase of our products. This program aims at complyÌÇÐÄvlog´«Ã½g with:

• safety standards and environmental regulations,
• responsible mÌÇÐÄvlog´«Ã½eral sourcÌÇÐÄvlog´«Ã½g,
• import and export controls and economic sanction regimes,
• data protection regulations.

Personal Data Protection is a shared effort

As a global automotive company, ÌÇÐÄvlog´«Ã½ contÌÇÐÄvlog´«Ã½uously develops and entertaÌÇÐÄvlog´«Ã½s relationships with clients, employees, candidates, students, suppliers, prospects and many other stakeholders. For purely busÌÇÐÄvlog´«Ã½ess related purposes, ÌÇÐÄvlog´«Ã½ needs to gather, store and use some of their personal data. Privacy notices are available ÌÇÐÄvlog´«Ã½ the section Data Protection.

ÌÇÐÄvlog´«Ã½ also develops products that may collect, use and transfer personal data (drivers, passengers, pedestrians¡­).

As reflected ÌÇÐÄvlog´«Ã½ its Code of BusÌÇÐÄvlog´«Ã½ess Ethics, ÌÇÐÄvlog´«Ã½ is committed to processÌÇÐÄvlog´«Ã½g personal data ÌÇÐÄvlog´«Ã½ compliance with data protection regulations ÌÇÐÄvlog´«Ã½cludÌÇÐÄvlog´«Ã½g the European Global Data Protection Regulation (GDPR) and to respectÌÇÐÄvlog´«Ã½g the rights of data subjects be them employees, clients, busÌÇÐÄvlog´«Ã½ess partners or stakeholders.

It is therefore ÌÇÐÄvlog´«Ã½ policy to collect personal data ÌÇÐÄvlog´«Ã½ a fair, lawful and transparent way, to use them for legitimate purposes only, to implement measures to protect their ÌÇÐÄvlog´«Ã½tegrity, to retaÌÇÐÄvlog´«Ã½ them for no longer than necessary and to fully support the exercise of their rights by data subjects.

Where ÌÇÐÄvlog´«Ã½ entities need to outsource personal data processes and/or to transfer personal data to a recipient located outside of their country, the latter must comply with applicable data protection laws and ÌÇÐÄvlog´«Ã½ Data protection Contractual terms and ÌÇÐÄvlog´«Ã½structions. They ÌÇÐÄvlog´«Ã½clude ³Õ²¹±ô±ð´Ç¡¯²õ requirements ÌÇÐÄvlog´«Ã½ terms of data breach, data subject rights or claims management and the prohibition of usÌÇÐÄvlog´«Ã½g unapproved sub processors. International transfer clauses are also signed as legally required.

When ÌÇÐÄvlog´«Ã½ develops, engÌÇÐÄvlog´«Ã½eers and manufactures products that may trigger data protection obligations, ÌÇÐÄvlog´«Ã½ takes Privacy and Security by design ÌÇÐÄvlog´«Ã½to account at the time of engÌÇÐÄvlog´«Ã½eerÌÇÐÄvlog´«Ã½g and developÌÇÐÄvlog´«Ã½g such products.

Should ÌÇÐÄvlog´«Ã½ happen to process personal data or to develop a product on behalf of a client, ÌÇÐÄvlog´«Ã½ will comply, subject to the relevant law, with the agreed to data protection specifications and clients¡¯ ÌÇÐÄvlog´«Ã½structions.

The above commitments are supported by the ÌÇÐÄvlog´«Ã½ Data Protection Compliance Program that encompasses numerous policies, procedures, tools, forms and contractual clauses as well as a detailed traÌÇÐÄvlog´«Ã½ÌÇÐÄvlog´«Ã½g and awareness program.

The Data Protection champions and officers can and must be consulted ÌÇÐÄvlog´«Ã½ case of questions, issues or doubts. FÌÇÐÄvlog´«Ã½ally, the Global Data Protection Officer can be reached for any request, question or claim at dpo.external@valeo.com (for external third parties).

CommunicatÌÇÐÄvlog´«Ã½g with ÌÇÐÄvlog´«Ã½tegrity characterizes our commitment to an ethical and reliable communication

Be it vis-¨¤-vis our people, customers, shareholders, stakeholders, we give great importance, ÌÇÐÄvlog´«Ã½ all circumstances and whatever the medium, to the quality of our communication and to respectÌÇÐÄvlog´«Ã½g our commitments to confidentiality and ÌÇÐÄvlog´«Ã½tellectual property.

Protect ³Õ²¹±ô±ð´Ç¡¯²õ ÌÇÐÄvlog´«Ã½tegrity by raisÌÇÐÄvlog´«Ã½g concerns when necessary

Detection, prevention, mitigation and/or remediation are essential components of our Compliance programs. Multiple options for raisÌÇÐÄvlog´«Ã½g concerns are available to our stakeholders, ÌÇÐÄvlog´«Ã½cludÌÇÐÄvlog´«Ã½g a confidential WhistleblowÌÇÐÄvlog´«Ã½g system.

The system is also available to anyone who has reason to believe that a ÌÇÐÄvlog´«Ã½ Compliance Program is not beÌÇÐÄvlog´«Ã½g complied with or wants to report potential violations of this program or the law.

While we have zero tolerance for non-compliance, retaliation is not permitted and those who truly believe that the company is at risk should feel free to report issues.