DORIS is a major player in both engineering and energy sectors, where public authorities regularly play a role and where the amounts invested may be very high. In addition, DORIS is present in a number of countries, some of which have a high perceived level of corruption according to the index drawn up by Transparency International, others where anticorruption legislations are very stringent. Aware that it is highly exposed to the risk of corruption, DORIS applies a principle of zero tolerance.
DORIS’ culture for integrity and the prevention of corruption are key objectives for the Group. DORIS is committed to continuously strengthening its internal integrity policies and procedures, as well as ensuring the commitment of all its employees. Employees must be aware of and strictly apply the principles set out in the Code of Conduct and the rules set out in the other internal policies that form part of DORIS’ anti-corruption framework.
DORIS complies with the laws, regulations and international standards that apply to the conduct of business in all countries where the Group operates and does business. In particular, and given its presence in France, the United States and the United Kingdom, DORIS complies with French criminal law (the Sapin II law), the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, US legislation, including the Foreign Corrupt Practices Act (FCPA), the UK Bribery Act 2010, and follows the Recommendations of the French Anti-Bribery Agency (AFA).
Commitment of the governing bodies
Compliance with anti-corruption laws is a top priority for DORIS and this commitment is regularly confirmed by the CEO with the full support of the Board of Directors.
The Board of Directors regularly reviews and monitors DORIS’ ethics and compliance policies. Each year, it receives the « Annual Ethics Report to the Board of Directors », which is presented to the Board by the Chief Compliance Officer in coordination with the Chairman and CEO.
The mission of the Compliance function is to prepare the content of the DORIS anti-corruption programme and to promote its implementation in all subsidiaries and controlled companies of the Group worldwide. The Group’s culture embraces the best international ethical standards and is based on the DORIS values. The tone is set not only by the Board of Directors, but also by the entire management team, i.e. the Chairman and CEO as well as the management of the subsidiaries, and is passed on to all employees.
For all of the Group’s activities, the Management of the Group is involved in making operational activities compatible with ethical principles, which is reflected in the governance based on the policy of zero tolerance for breaches of probity. The fundamental principles of this governance are:
Growth and Good Governance
The DORIS code of conduct
The Code of Conduct applies to every employee within the DORIS Group. Violations of the Code of Conduct are not tolerated and may be subject to disciplinary action.
The version of the Code of Conduct currently applicable within the Group dates from March 2022. It is the result of an update that takes into account the outcome of the latest risk mapping.
The Code of Conduct is now available in English, French and Portuguese.
It provides formal and binding guidance on the key principles and commitments that must be respected by managers, employees and the Group as a whole on a daily basis. Every employee of the Group is expected to comply with the principles and rules of the Code of Conduct and is responsible for his or her actions.
The Code of Conduct also prescribes the essential rules of conduct with regard to the Group’s relations with its business partners; its commitments as a socially responsible company; human resources policies, and commitment to the protection of the Group’s assets.
It provides guidance to employees and managers on their role and responsibilities, how to take ethics into account in decision-making, how to obtain information and answers to questions, and how to report a concern, in particular through the whistleblowing system.
In terms of communication, the Code of Conduct is given to each new employee of the Group. Its content is also systematically recalled during training sessions and meetings organised by the subsidiaries’ Senior Management.
A simple and accessible
global whistleblowing system
This system allows any employee to report the existence of conduct or situations contrary to the Group’s code of conduct, and in general, any report concerning a crime or offence.
The Group’s whistleblowing system provides for the possibility of reporting via a dedicated email address managed at Group level.
In addition, reports can be made using an « Incident Form », available in English and French.
A written Whistleblowing procedure exists, updated in May 2022. It describes the scope of the system and how to handle reports. It is supplemented by a User’s Guide and a poster that can be put up on the notice boards intended for staff. The package was sent to managers and compliance officers and cascaded to the organisations.
Assessment and engagement
of business partners
The DORIS Group is committed to providing its customers with technical solutions that focus on performance and cost, while maintaining the highest standards of ethics and integrity in its business practices and relationships.
These commitments are shared by all Group entities and their employees, but also shared by the business partners with whom the entities work or wish to work. DORIS particularly expects these partners, whether they are suppliers and service providers, joint venture or consortium partners, any intermediaries DORIS may use, or its customers, to work with integrity and in accordance with applicable laws and regulations.
The risks identified in the risk mapping appear in situations where one or more third party partners are involved, whether they are customers, suppliers or intermediaries, and the risk is all the higher when the third party is itself less honest, carries out a more sensitive activity, or operates in a country more exposed to corruption.
The main purpose of the Business Partner Assessment and Engagement Procedure is to establish rules for the implementation by all DORIS Group entities of a harmonised, reliable and consistent system for assessing the integrity of Business Partners.
DORIS employees who engage their entity through business relationships with partners must therefore apply the procedure.
Awareness raising and training
As part of our continual improvement we ensure we raise awareness of associated risks and actions to all employees. Each subsidiary’s intranet contains a section about the fight against corruption which provides employees with various materials, e.g. the internal standards, guides and procedures.
Face-to-face anti-corruption training courses have been rolled out periodically. These training courses are accessible to all employees and mandatory for the targeted personal and new hires, in the various regions where DORIS operates its activities.