Ethics & Compliance

Aubert & Duval has deployed a compliance program based on three main pillars to support its employees: ethics governance and its dedicated organization, regularly updated guidelines and tools, including an alert system.

 

The Legal, Ethics & Compliance Department is committed on a daily basis to placing ethics and compliance at the heart of our activities, by ensuring that laws, regulations and standards are respected within the company. In order to provide employees with the best possible support, an operational approach, as close as possible to those working in the field, is favored to raise awareness and train employees on often complex subjects.

 

The Legal, Ethics & Compliance Department relies on a dedicated network, consisting of:

• A Compliance Officer and several Ethics & Compliance ambassadors who, on each site, are responsible for raising awareness and supporting employees faced with ethical dilemmas.

 

Aubert & Duval and its subsidiaries make the ethics culture a central part of all employees’ activities through a training program and mandatory e-learning. A whistleblowing system also enables all stakeholders who are victims or witnesses of unethical behaviour to alert the company’s highest management bodies. All employees of Aubert & Duval, EcoTitanium, UKAD, Interforge and AD Irun must comply with all of the Compliance Program’s guidelines and mechanisms and carry out their daily activities with integrity. Any failure to comply with the legal and regulatory provisions, as well as the guidelines, may result in disciplinary action.

The whistleblowing system

This professional whistleblowing system is accessible to all employees as well as to external stakeholders, including our suppliers. It allows employees to report ethical problems such as discrimination, unfair treatment, harassment, fraud and corruption, as well as any violation of human rights as defined by law.

 

The service is outsourced to ensure transparency, confidentiality and protection of whistleblowers.

 

> Access to the platform

The guidelines

Aubert & Duval’s guidelines comply with international standards, including the Universal Declaration of Human Rights, the United Nations (UN) Convention against Corruption and the OECD Convention on Combating Bribery of Public Officials.

These guidelines include the company’s Ethics Charter.

This normative framework reflects the commitment of Aubert & Duval and its subsidiaries to preserve and strengthen business integrity in all its activities. The concrete examples and case studies included enable employees to identify unethical behavior and adopt good practices in their daily activities.

The Aubert & Duval Ethics Charter is available in English :Charte Ethique AD – GB – Mai 2023

Conflict minerals

Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires due diligence and disclosure requirements on companies that manufacture products containing certain minerals designated as “Conflict Minerals”

• Cassiterite, columbite, Tantalite, gold, wolframite, and their derivatives tin, tantalum, and tungsten
• Cobalt and Mica, By extension since October 2021

 

sourced from certain Central Africa countries – Democratic Republic of Congo or surrounding countries.

The obligations of disclosure apply to these materials along the entire supply chain and to all companies involved. A&D categorically rejects any use of conflict materials from any of these conflict regions and procures such materials exclusively from responsible sources.

As part of the supply chain and pursuant to the Dodd-Frank Act, A&D is committed to disclosure and compliance with the legal stipulations pertaining to conflict minerals. We require compliance with all obligations and an appropriate level of transparency along the supply chain.

The Company evaluates its relationships with its suppliers on an ongoing basis to ensure continued compliance with this policy. The Company reserves the right to request the Conflict Minerals Reporting Templates (CMRT, EMRT) from its suppliers regarding the source of any minerals included in its products. In addition, suppliers must maintain and provide to the Company, upon request, traceability data for a minimum of five years.

 

Conflict Minerals Reports

This transparency is important to us along the entire supply chain. We would be pleased to provide an up-to-date Conflict Minerals Reports:

The Conflict Minerals Reporting Template (CMRT ) to facilitate the transfer of information through the supply chain regarding mineral country of origin and the smelters and refiners being utilized.

The Extended Minerals Reporting Template (EMRT)  to identify pinch points and collect due diligence information in the cobalt and mica supply chains.

 

Compliance of A&D products to Conflict Minerals Act (PDF)