Responsible Business Practices

Our Code of Ethics is more than a collection of abstract ideas; it is a formalization of Capgemini’s longstanding commitment to ethical behaviour, and our ethics shape our business practices at every level of the company.

Bribery and Corruption

We have zero tolerance for any form of bribery and corruption in Capgemini. In the event of any bribery or corruption instance brought to the Capgemini Group’s attention, we would take immediate steps to take all necessary corrective actions and report it to the relevant authorities if need be.

Conflict of Interest

Each employee has the duty to the Group to act with integrity and good faith. It is essential that the Group employees do nothing which conflicts with the Group’s interests or which could potentially be construed as being in conflict with such interests.

Sales Activities

No Capgemini employee may accept commission from or pay commission to third parties unless expressly authorized to do so by top Group Management in strictly limited cases. Any breach of this rule may result in immediate disciplinary sanctions in full compliance with applicable local laws. Facilitation payments are not allowed.

Funding of Activities & Organizations

All funding of activities and organizations, outside Capgemini must be authorized by top Group Management to ensure that we support only activities and organizations whose ethical rules are aligned with our own. Capgemini does not finance political parties.

Business Gifts & Entertainment

Group employees may give and receive appropriate, lawful business gifts in connection with their work with the Group’s clients, suppliers or business partners provided that all such gifts are nominal in value and are not given or received with the intent or prospect of influencing the recipient’s business decision.

Insider Trading

The Group has set strict rules relating to the trading of Cap Gemini SA or any other Capgemini-related securities and especially the rule of not buying or selling company shares during “closed” periods before our results are published (twice a year prior to the release of half-year and year-end results). The aim of these rules is to protect our employees and the Group against any potential risks (mainly insider trading). All employees are notified of the closed periods applicable to Capgemini. In addition, there are certain restrictions that apply to trading in publicly-listed securities of the Group’s actual or potential clients, suppliers or business partners.

Confidential Information

The Group has defined standards on the protection of confidential or non-public information belonging to the Group, the Group employees or third parties such as Group clients, suppliers or business partners. Nonpublic information includes but is not limited to any personal information or confidential information provided by employees or third parties as well as information about the Group clients, finances, product development, marketing strategy, sales prices, non-published financial results and changes to shareholders.

Public Position

The Capgemini Group does not lobby with governments or regulators on behalf of Capgemini or its clients. We are members of relevant trade bodies in our industry and undertake an advisory role regarding the impact and opportunities of technology. We are also members of relevant non-governmental and non-profit organizations. Capgemini regularly publishes “thought leadership” on various topics of public interest.

Country Risk

Capgemini has permanent operations in some 30 countries. An increasing proportion of the services we deliver are based in emerging countries. In the absence of minimum legislative standards, the Capgemini Group’s Blue Book contains the policies that are applicable to all of our operating units. Strict approval criteria must be met before employees are sent to work in countries where there are no existing Group operations. In addition, even stricter criteria apply in the event that employees are sent to countries considered to be at risk.

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