code of ethics us
TRANSCRIPT
-
7/29/2019 Code of Ethics Us
1/40
CODE OF BUSINESS ETHICS
2007
THE WAY WE WORK
-
7/29/2019 Code of Ethics Us
2/40
CONTENTS
1
2
3
4
5
6
78
9
10
11
12
13
15
1617
18
20
21
22
23
25
2627
28
2930
31
32
33
35
36
THE LORAL SPIRIT
FOREWORDby Sir Lindsay Owen-Jones and Jean-Paul Agon
FOREWORDby the Management Committee
HOW TO USE THIS CODE
RESPECT FOR INDIvIDUALS, RESPECT FOR THE LAWAND RESPECT FOR LOCAL CUSTOmS
OPEN TALK
AS A BUSINESSProduct Saety and Quality
Accuracy in Financial and Business Records
Use o Company Resources
Condential Inormation
Representing the Company
Gits and Entertainment
Bribery and Facilitation Payments
AS AN EmPLOYERHealth, Saety and Security
Diversity
Harassment and Bullying
Sexual Harassment
Privacy
Conficts o Interest
AS A RESPONSIBLE CORPORATE CITIzEN
Political ActivitiesContribution to the Community
Environmental Stewardship
ADDITIONAL GUIDANCE FOR mANAGERSThe Managers Role
Advertising and Marketing
Insider Trading
Supplier Selection and Fair Treatment o Suppliers
Fair Competition
Tax
-
7/29/2019 Code of Ethics Us
3/40
1
At LORAL, w bliv tat vro aspirs to bat. Or missio is to lp m a wom
aro t worl ralis tat aspiratio, a xprss tir iivial prsoalit is to t fll. Tis
is wat ivs mai a val to or bsiss, a to t worki livs of or mplos. W
ar pro of or work.
AS A BUSINESS
Our strategy or leadership is based on continuous investment in rigorous scientic research and development. This enables our
brands to deliver products which are innovative, highly eective, practical and pleasant to use, and which are manuactured to the
most demanding standards o quality and saety. We aim or excellence, and constantly challenge ourselves and our methods.
We place great value on honesty and clarity; our consumer advertising is based on proven perormance and scientic data. We
are committed to building strong and lasting relationships with our customers and our suppliers, ounded on trust and mutual
benet. We do business with integrity; we respect the laws o the countries in which we operate and adhere to good corporate
governance practices. We maintain high standards in accounting and reporting, and support the ght against corruption. We
deliver long-term, sustained shareholder value by protecting and making the most eective use o company assets.
AS AN EmPLOYER
We aim to make LORAL a great place in which to work. We know that our employees are our greatest assets. They areentitled to a sae and healthy working environment; one in which personal talent and merit are recognised, diversity is valued,
privacy is respected, and the balance between proessional and personal lie is taken into account. We believe in oering our
employees a stimulating environment, exciting personal opportunities and a chance to make a dierence. We encourage an
atmosphere o openness, courage, generosity and respect, so that all our employees eel ree to come orward with their
questions, ideas and concerns.
AS A RESPONSIBLE CORPORATE CITIzEN
We play our part in creating a world o beauty and airness. We are mindul o our impact on the natural environment, including
biodiversity, and constantly seek to reduce it; we are determined to avoid compromising tomorrow or the sake o today. We makea positive contribution to the countries and communities in which we are present, and respect local cultures and sensitivities.
We are committed to the respect o human rights. We want to help end the exploitation o children in the workplace and the
use o orced labour. We want an end to animal testing in our industry, and we contribute to the development and acceptance o
alternative methods. We actively seek out and avour business partners who share our values and our ethical commitments.
Tis is t spirit i wic w oprat: t LORAL SPIRIT.
THE SPIRIT
-
7/29/2019 Code of Ethics Us
4/40
2
FOREWORDBY SIR LINDSAY OWEN-JONESAND JEAN-PAUL AGON
LORAL has been built around undamental values which have guided
us throughout the lie o our company, and continue to do so today. Our
values have shaped our culture, and they underpin our reputation.
For many years, we have passed them on through word-o-mouth.
But now that we are so many, present in an ever-growing number o
countries, we believe the time is right to bring our values together in
a single document: one which can both inspire us and bring us closer
together.
We live in rapidly changing times. It is no longer enough simply to share
common convictions. We need in addition to be able to express clearly,
through a new document, how we are living up to our responsibilities
in practice.
It brings our values to lie and it shows how they inspire and inorm the
decisions we make in our day-to-day work.
We all have a responsibility to ollow these rules o conduct which driveLORALs integrity and ethical standards. We are counting on each and
every one o you to respect them and to pass them on.
We believe that our commitment to live up to these powerul values,
and to demonstrate our high ethical standards in all that we do, will more
than ever ensure that LORAL is seen as an exemplary organization:
one which inspires trust and respect.
SIR LIndSAy OWen-JOneS JeAn-PAuL AgOn
Chairan Chief Executive Ofcer
-
7/29/2019 Code of Ethics Us
5/40
3
We are committed to bringing the LORAL SPIRIT to lie in our
day-to-day work. This is crucially important to the Companys
continued success.
That is why we have produced this code. Its aim is to help
everyone understand what is expected o us as LORAL
employees. It applies to us all, wherever we operate and
whatever our role whether we are junior sta or Company
directors.
Each o us and everyone in the Company, as ambassadors
o LORAL and as members o our community, makes a
personal commitment to ollow this code both in letter and
in spirit.
You should always remember that:
The values and guiding principles set out in this document
are not optional: you must respect them
You set the example: LORALs reputation is what you make it
You will be judged not only on what you do, but the way you
do it
Ethical questions are rarely easy, but must be addressed
We advise you not to keep such questions to yoursel: disclose
them and seek advice.
Integrity and respect are paramount to the way we work.
FOREWORDBY THE mANAGEmENT COmmITTEE
11 MARC MeneSguenPresidentLOral Luxury Products
6 PATRICK RABAInPresidentLOral Consumer Products
1 JeAn-JACqueS LeBeLPresidentLOral Proessional Products
8 JOChen ZAuMSeILManaging Director othe Asia Zone
9 JOSePh BITTOnManaging Director o theLatin America Zone
10 JeAn-PhILIPPe BLAnPAInExecutive Vice-PresidentProduction & Technology
12 ChRISTIAn MuLLIeZExecutive Vice-President
Administration & Finance
5 BATRICe dAuTReSMeExecutive Vice-PresidentCorporate Communications,External Aairs & Prospective
2 BRIgITTe LIBeRMAnManaging DirectorActive Cosmetics International
13 JeAn-FRAnOISgROLLIeRExecutive Vice-PresidentResearch & Development
4 geOFF SKIngSLeyExecutive Vice-PresidentHuman Resources
7 LAuRenT ATTALPresident and Chie
Executive OcerLORAL USA
3 JeAn-PAuL AgOnChie Executive Ocer
7
1
8
2
9
3
10
4
11
5
12
6
13
-
7/29/2019 Code of Ethics Us
6/40
4 THE WAY WE WORK
HOW TO USE THIS CODE
THE WAY WE WORK does not replace any existing policies,
and you should continue to reer to whatever rules andstandards have been set in your workplace. Instead, this code
aims to provide a ramework or these policies, so that it is
easier or you to understand the rationale behind them.
But, just as importantly, it is also a tool to help you deal with
any questions or dilemmas you may have concerning the way
we work.
O course, no document can anticipate and address every
situation that may arise, particularly since many ethical
dilemmas take place in grey areas, where the solution isnot readily apparent. So whenever you are aced with what
you eel is an awkward ethical decision, always ask yoursel
the ollowing questions:
1. Is it in line with the LORAL SPIRIT and THE WAY
WE WORK?
2. Is it legal?
3. How do y actions affect our arious stakeholders
and how would they react if they learnt about y
actions?
4. If I a not sure, hae I asked for help?
We recognise that some situations are not easy. When in
doubt, the ol rl is to isclos t mattr a to
iscss it opl.
Technical subjects are best directed to internal experts such
as Finance, Human Resources, Health and Saety, Legal and
Tax, Purchasing, and other departments.
q: dos tis ocmt appl to m?
A: All o us at LORAL can be aced with an ethical dilemmaduring our daily work; how we behave towards colleagues
and respond to their behaviour; how we deal with dicult
or awkward requests rom customers or suppliers; how
we resolve questions about the use o Company property.
Each o these has an ethical dimension. This code provides
useul, practical guidance on these and many other common
dilemmas which we all ace rom time to time.
The LORAL SPIRIT and THE WAY WE WORK are addressed
to all employees o the LORAL Group and its subsidiaries
worldwide. They also concern all Ocers and Directors o the
LORAL Group and its subsidiaries.
The Code o Business Ethics is currently available in 41
languages. The UK English version o this code is the reerence
document.
THE WAY WE WORK cannot in any way be understood as a
contract o employment or continued employment between
the Company and any employee. It is a code to acquaint all
employees with the Companys expectations.
The Company recognises that THE WAY WE WORK is not
exhaustive and that it may change rom time to time. The
Company reserves the right to change, modiy or correct
THE WAY WE WORK at any time, with or without notice, and
the right to take whatever action it deems appropriate in any
employment situation.
-
7/29/2019 Code of Ethics Us
7/40
THE WAY WE WORK 5
RESPECT FORINDIvIDUALSWe expect all employees and entities to work together in a
respectul and open manner. In this way, we will maintain a
culture o loyalty, trust and solidarity throughout our business.
We should all aim to give credit to other peoples ideas, and
recognise the contributions o others.
Teamwork is to be encouraged and successes, as well as
ailures, should be shared. We should listen with generosity
and share inormation as needed, subject to the Groups rules
on condentiality. Finally, disparagement o colleagues is
contrary to LORALs values.
RESPECT FORTHE LAWLORAL operates in many countries home to a wide variety
o cultures, laws and political systems.
As a basic rule, we as a business and as individuals in the
perormance o our duties, must always respect the laws o
the countries in which LORAL operates.
LORAL is particularly attached to the spirit and the letter o
laws governing:
Human rights; prohibition o child labour and orced
labour; discrimination; working time and remuneration;
employees collective representation
Quality, health and saety standards
The environment
Corruption and bribery
Taxation and the accurate communication o nancial inor-
mation
Fair competition
LORAL seeks to share these principles with its business
partners and to ensure, as ar as possible, that such partners
also respect these laws and regulations.
RESPECT FOR
LOCAL CUSTOmSTHE WAY WE WORK has been drated with the help o
LORAL employees across the world. We believe that its
core messages will be applicable throughout our operations.
We should ensure that, wherever possible, we conduct our
activities in a manner sensitive to the cultural and social
traditions o communities with which we come into contact.
There may be instances when the guidance in this code is at
variance with the local law or customs o a particular country.
I that is the case, then where local law requires a higher
standard than that set out in the code, local law should always
apply. I, by contrast, the code provides or a higher standard,
then it should supersede local law unless this results in
illegal activity.
-
7/29/2019 Code of Ethics Us
8/40
6 THE WAY WE WORK
OPEN TALK
LORAL coras a cltr of opss
wr mplos ca rais tir icocrs.
All employees are expected to take personal responsibility or
ensuring that our conduct complies with the LORAL SPIRIT
and THE WAY WE WORK.
We encourage all employees to air their views, deend their
opinions and signal unacceptable behaviours or demands.
We recognise that employees may have concerns about
certain practices and need advice and guidance to help resolve
them.
It is our policy that any concerns raised in good aith about
misconduct on the part o the Company or any o its employees
or business partners are thoroughly investigated, and that
appropriate actions are taken to deal with the outcome o that
investigation. Good aith means that you have provided
inormation that you believe to be honest and accurate at the
time, even i you are later proven to be mistaken.
We will provide eedback to the individual who has raised
the concern, to the extent that it is appropriate and can be
given without inringing legal requirements or other duties o
condentiality.
We will ensure a air process in case o an investigation and,
in particular, respect the principles o due process and the
presumption o innocence.
All inormation given in the course o an investigation will
be communicated on a need-to-know basis, and anyemployee raising such concerns in good aith will be protected
against retaliation. Full cooperation is expected during such
investigations.
The normal route or raising such issues is via your line
management. I or any reason you eel uncomortable
with this route, you should raise the issue with your Human
Resources Manager. There may also be additional resources
available in your country, such as sta representatives,
grievance procedures or a helpline.
I or cotr, it is t Cotr Maar
wo is ltimatl rsposibl for sri trspct of t LORAL SPIRIT a The WAy We
WORK.
I you have raised the issue locally and you are still not satised
with the answer you were given by local management, or
in the exceptional case that it is inappropriate to raise the
issue locally, you may contact the Group Director o Ethics o
LORAL as ollows:
wbsit: www.lorealethics.com
lttr: grop dirctor of etics, LORAL,
41, rue Martre, 92117 CLICHY, FRANCE
Plas ot tat wil w o ot proibit aomos
rports, w o ot cora tm. W bliv w offr
sufcient guarantees to make it unnecessary for an
mplo rporti a cocr i oo fait to cocal is
or her identity. It is also difcult to investigate a matter
torol if it is rport aomosl.
-
7/29/2019 Code of Ethics Us
9/40
LORAL 7
THE WAY WE WORK
AS A BUSINESS
We aim or excellence, and constantlychallenge ourselves and our methodsThe LORAL SPIRIT
-
7/29/2019 Code of Ethics Us
10/40
8 THE WAY WE WORK
Q: I work on the production line, and Ie noticed soe
defective nished goods, showing that one machineay be generating soe quality probles. I know were
supposed to stop production when that happens, but
y superisor has not taken any action. I know that the
production schedule is ery tight. Should I trust that she
knows what shes doing in ignoring it?
A: LORAL has put in place quality controls at each stage
o the manuacturing process to ensure that our customers
obtain the highest quality products. Quality comes rst,
regardless o production schedules. You should put that line
on hold without any hesitation, openly share the problem with
your manager, and work with her and the rest o the team to
x the issue, beore carrying on with production.
Q: We hae receied a report fro a supplier stating that
containation ay hae occurred in a recent shipent
of ingredients. The products containing the ingredients
hae already been shipped to our custoer and there is
no concrete eidence of containation in our products.
Do we hae an obligation to recall the entire production
run?
A: At LORAL, we respond promptly to any concern about
possible product saety. You should discuss the issue with
your manager or your Quality Control Manager immediately.
Remember:If youre facing an issue around product safety,
dont keep it to yourself. Youll get help and support from
discussing it with your management, your Quality Control
Manager or your Human Resources Manager (see also the
chapter on Open Talk).
PRODUCT SAFETY AND QUALITY
Proct saft a alit is paramot at
all tims.
It is t sprior prformac, alit a
saft of or procts wic mostrats or
icatio a rspct for or cosmrs, wic
ars s tir trst, rpis t rptatio of
or bras a srs tat LORAL rmais
the leader in our eld.
W ar committ to markti procts tat
have proven efcacy and safety, guaranteed by
rioros tsti.
evr LORAL mplo troot t
worl mst b committ to t acivmt
of total proct alit from cocptio to
istribtio, a v aftr t proct as
b pt o t markt.
All of s ivolv i t vlopmt,mafactri, markti, istribtio a
sals of or procts ar xpct to:
Coply with all legislatie and regulatoryrequireents on product deelopent andlabelling
Encourage a free and open exchange of iewson product safety so that no safety issue is
ignoredEnsure that the highest standards of hygieneand strict quality controls are applied at eachstage of the production process
Ensure all aderse reactions by consuersare reported to the Departent of Postmarketing Sureillance
Respond proptly to any concerns aboutpossible product safety, tolerance and quality
control issues
-
7/29/2019 Code of Ethics Us
11/40
THE WAY WE WORK 9
ACCURACY IN FINANCIAL ANDBUSINESS RECORDSAccrac is paramot for a sccssfl
bsiss. Tis is a sstial part of riour business legally, honestly and efciently.
W all av a t to mak sr tat all or
records, nancial or otherwise, are accurate. In
particlar, it is crcial to bi abl to provi
traspart, rlar a rliabl iformatio to
or sarolrs.
W ar all xpct to:
Play our part in ensuring that accuratenancial and business records are maintainedat all ties
maintain records securely and follow anyguidelines on record retention
Cooperate with our internal and externalauditors
Refuse all cash transactions. If there is no
other possibility, cash transactions ust beexpressly authorised, properly recorded anddocuented
make sure we do not sell, transfer or disposeof any LORAL assets without properauthorisation and docuentation
Q: Ie been asked to check the sales report prepared by
y anager for the year end. In doing so, Ie spottedwhat I think is an error, which nobody else sees to hae
picked up on. I rather nerous about entioning it,
because I dont want to jeopardise y relationship with
y anager. What should I do?
A: The reason you were asked to check the sales report is
precisely to make sure there were no mistakes. I you do not
disclose this, you are not doing your job properly and you are
not serving the interests o the Company. You should talk to
your manager about what you have ound. He or she has no
reason to be angry with you; on the contrary, youve done well
to avoid inaccurate inormation being passed up the line.
Q: Life gets very hectic sometimes, and I cant always nd
all the receipts I need to clai y expenses. Is it all right ifI add a few ctitious expense items that are less than the
aount requiring a receipt, just to ake it up to the right
total? It wouldnt be dishonest in any way, as I wouldnt
be coing out ahead. Id only be aking sure I receied
y due.
A: No, this is not OK. It means the expense reports are
inaccurate, and that translates into inaccurate accounting
records. You need to take responsibility or looking ater all
receipts; thats the only guarantee that youll receive the
settlement youre due.
Q: One of our custoers has asked if they can pay through
a ix of different accounts, using a cobination of cash
and cheques. Is this acceptable? What should I do?
A: You should be especially careul with these sorts o
transactions. It could be money laundering, a process in which
unds obtained through illegal means (e.g. drugs, bribery and
prostitution) are concealed, or made to look legitimate. So you
should always inorm your line management beore accepting
payment, and take all possible steps to satisy yoursel that
this is a bona de transaction. Among the danger signs to
look out or are: payments made rom currencies other than
that specied in the invoice; attempts to make payments in
cash; payments made by someone who is not a party to the
contract; payments to and rom an account other than the
one used in the normal business relationship; and requests to
make an overpayment.
Remember:If youre facing an issue around nancial accuracy,
dont keep it to yourself. Youll get help and support from
discussing it with your management, your Financial Directoror your Human Resources Manager (see also the chapter on
Open Talk).
-
7/29/2019 Code of Ethics Us
12/40
10 THE WAY WE WORK
USE OF COmPANY RESOURCES
Compa rsorcs ar it to lp
mplos aciv LORALs bsiss oals.Miss or wast Compa rsorcs,
icli mplo tim, rt s all a ama
the operational and nancial performance of
LORAL.
W ar all xpct to:
As a general rule, aoid personal use ofcopany assets. Liited use of counication
tools such as e-ail, telephone and the internetay be acceptable so long as it does not incurany unreasonable costs and does not interferewith our job responsibilities
Respect and protect Copany assets to ensurethat they are not lost, daaged, isused orwasted, nor loaned to others, transferred, soldor donated without authorisation
Aoid inappropriate use of coputer systes,
corporate e-ail accounts and the internet
Recognise that all copany assets anddocuents belong to LORAL
Q: I suspect that one of y tea ebers has been
running an outside consulting business on Copany
tie, using his Copany laptop and e-ail to do so. I
entioned it to a friend in Inforation Serices. He canaccess the guys e-ail, and has offered to help e do a
bit of sleuthing to nd out whats going on. Is this OK?
A: No. I you have suspicions o this kind, you should raise
them directly with your manager. The Company has specic
procedures or accessing employee e-mail accounts in
connection with an investigation o misconduct or or other
legitimate reasons. Even though your riend in Inormation
Services has access to these accounts, he should not use it
or this purpose without proper authorisation through ocial
Company channels.
Q: Our printer at hoe is broken, and y wife needs to
send her Cv out for a possible job as a atter of urgency.Is it OK if I type it up and print it at work?
A: In general, you may be able to use the computer during
non-working hours to type personal documents, so long as
this is occasional, reasonable and does not interere with your
job responsibilities.
Q: I keep receiing joke of the day e-ails fro a friend in
another departent, soe of which are ery funny. Id like
to send the on to y colleagues and gie the a sile
on a monday orning, but I not sure if y anager will
approe. What should I do? Leae her off the list ?
A: Use your common sense with regard to this. Remember that
not everyone has the same sense o humour, and you should
think twice beore orwarding such jokes. In particular, you
should bear in mind that the Companys e-mail and internet
access systems must not be used to access, store, send or
publish any material which is inconsistent with the LORAL
SPIRIT notably including respect or individuals. This
includes, o course, pornographic or sexually explicit images,
political or religious content, or anything which promotes
violence, hatred or intolerance.
Q: At work, we can buy products fro the Copany shop
at discount prices. I also soeties get free products fro
y friends in marketing. I hae soe of these products to
y aunt and she suggested that we could sell the on the
internet. Is this OK?
A: No, you cannot sell the products. Employees have
access to ree or discounted products because we eel that
it is important or all LORAL employees, whatever their
unctions, to be able to know and enjoy our products. It is part
o being proud o our work. This means that the products are
or your personal use. You can also oer them as a git to your
amily and riends, but this should be exceptional.
Remember: If youre facing an issue around the use of
company assets, dont keep it to yourself. Youll get help and
support from discussing it with your management or your
Human Resources Manager (see also the chapter on Open
Talk).
-
7/29/2019 Code of Ethics Us
13/40
THE WAY WE WORK 11
CONFIDENTIAL INFORmATION
Unauthorised disclosure of condential
iformatio ma b trimtal to LORAL. Wmst all sr tat all iformatio ot kow
to the general public is kept strictly condential.
Those of us who have access to condential
iformatio bloi to bsiss partrs
ar r a similar obliatio to protct it from
isclosr.
W ar all xpct to:
Limit disclosure of condential informationto people with a legitiate need to knowthat seres LORALs interests
Secure all condential customer and supplierrecords, both paper and electronic
Prevent disclosure of condential informationto third parties outside LORAL (includingfaily ebers of eployees)
Avoid discussing or working with condentialinforation in a public area whereconersations can be oerheard or datacoproised
make sure that we are not disclosing aprevious employers condential information
Return all condential information (includingall copies of original aterial) upon leaingLORAL
Q: my friends often ask e about y work at LORAL.
Theyre curious as to just what it is we put in our products,and what new launches wee got up our sleee. Obiously,
I know quite a lot of the answers through y work so
how uch can I tell the?
A: Any inormation (written, electronic or any other orm) which
is not publicly available and to which you have had access
as a LORAL employee, should be considered condential.
Revealing such inormation, even to trusted riends, is not
appropriate. It may harm LORALs interests.
Q: The other day, I was taking a potential custoer to a
eeting. On the way to the eeting roo, we walked
past a colleagues ofce. His door was open, and he was
talking to another custoer about our pricing conditions
on his speakerphone. Just as we passed, we could hear
hi offering soe special deals all within y custoers
hearing! Surely he should be ore careful?
A: We all need to take the necessary measures to protect
the condentiality o inormation, even within the workplace:
or example, by ollowing the clean desk policy, locking
les away, changing passwords regularly and exercising
caution when using speakerphones. You never know who
may be passing, and even amongst LORAL employees,
commercially sensitive inormation should only be shared on
a need-to-know basis.
Remember:If youre facing an issue around condentiality,
take the appropriate steps to resolve it. Youll get help and
support from discussing it with your management, the Legal
Department or your Human Resources Manager (see also the
chapter on Open Talk).
-
7/29/2019 Code of Ethics Us
14/40
12 THE WAY WE WORK
Q: I isited a colleagues blog and saw hed expressed
soe personal iews on LORALs anageent. He had
not said that he was a LORAL eployee, but it was pretty
easy to guess fro other inforation he had gien such
as I work for the n1 cosetic copany! Should I hae
a word with hi about this?
A: Weblogs (blogs) are becoming a popular mode o expression.
When participating in blogs, employees must make it clear
that they are expressing their own personal views, and take all
necessary precautions to ensure that these are not in any way
mistaken or those o LORAL. In most cases, it would notbe appropriate to identiy themselves as LORAL employees
on such a blog. You should raise this issue with your colleague
rst, as he may not have realised how his actions could be
against LORALs interests. I necessary, you may decide to
discuss it with your manager.
REPRESENTING THE COmPANY
LORALs rptatio ps o t bavior
of ac a vr o of s.
W ar all xpct to:
Act with LORALs best interests at heart
Deonstrate LORALs alues in ourprofessional behaiour
Aoid speaking or writing on behalf ofLORAL unless duly authorised
Aoid speaking or writing on subjects fallingoutside our personal expertise
Ensure there is no confusion between ourpersonal iews and those of the Copany.(So, for exaple, we should aoid the useof LORAL letterhead or e-ails to expresspersonal iews or for personal business.)
Q: Our tea took part in a conference which inoled
staying oernight and haing dinner at the conferencehotel. One of y tea ebers drank ore than he
should hae during the dinner and started behaing badly,
telling stupid jokes and being aggressie with the hotel
staff. What should I say to hi about his behaiour?
A: Although the incident took place during the evening, your
team member was still on Company business. For others
around him, he was representing LORAL. It is clear that his
behaviour was not acceptable.
Q: Soeties the internet sees to be full of
isinforation about LORAL. Isnt it y responsibility
to correct it?
A: No. I theres erroneous inormation circulating in public,
you should let your manager or someone in Public Relations
know about it and they will take action i required. But no
unauthorised employee may post Company inormation or a
Company position on the internet or elsewhere.
Remember: If youre facing an issue around representing
the company, dont keep it to yourself. Youll get help and
support from discussing it with your management, your Public
Relations Manager or your Human Resources Manager (see
also the chapter on Open Talk).
-
7/29/2019 Code of Ethics Us
15/40
THE WAY WE WORK 13
GIFTS AND ENTERTAINmENT
excai ifts a trtaimt ca lp
bil rstai a improv workirelationships, but they can also cause a conictof itrst btw prsoal itrsts aprofssioal t.
W rcivi ifts or trtaimt, tol rl is fll isclosr.
W ivi ifts or trtaimt, t olrl is rasoablss a ow tis wol b
prciv b t wir pblic.
W ar all xpct to:
Neer accept gifts or entertainent fro anysupplier unless they are clearly sybolic inalue
Neer gie or accept cash gifts
Ensure that all gifts and entertainent offered
are appropriate and in line with LORALsalues
make sure that when establishing a newbusiness relationship, all parties are awarefro the outset of LORALs guidelines ongifts and entertainment. In turn, nd out whatour business partners policy is on theseissues. That can go a long way to aoidingany isunderstandings
Iediately disclose to our anageentany gift or initation we hae receied
Q: may I offer a LORAL custoer tickets to a concert that
I cannot attend?A: Someone rom LORAL must be present and be able
to conduct business with the customer as part o any such
outing. The same rule applies when accepting entertainment
rom a supplier. It is only permissible i the entertainment is
reasonable, usual and customary or your business relationship,
and the provider is in attendance.
Q: We hae just closed an iportant deal with a new
custoer. my Sales manager has suggested that we take
hi to a club to celebrate. I thought that was a good idea
until I discoered it was a lapdancing club! I feel really
uncofortable about offering this type of entertainent.
A I being oer-sensitie?
A: Entertainment oered to customers should not only be
reasonable but also acceptable. This type o club is not only
likely to clash with the LORAL SPIRIT, but could also make
the customer very uncomortable, not to mention any member
o your sales team who nds this sort o entertainment
distasteul. You should encourage your Sales Manager to nd
a more appropriate option. In the long term, that will refect
well on the Company.
Q: In order to sell off obsolete products, a supplier just
offered e a 15% personal discount. Can I accept it?
A: No, you cannot accept the discount unless it is on oer to
all LORAL employees.
-
7/29/2019 Code of Ethics Us
16/40
14 THE WAY WE WORK
Q: As part of y job, I organise nuerous business
eetings, trips and conentions. Now a hotel where Ioften book roos for LORAL eployees has offered e
a free weekend for y parents wedding anniersary. Its
a sweet gesture. Can I accept it?
A: No. Even i you are not personally going to benet rom
the git, accepting the oer makes it dicult to remain
impartial when you arrange uture hotel accommodations or
LORAL. Even the appearance o such a confict o interest is
inappropriate and should be avoided by politely declining the
oer, making clear why youre doing so.
Q: A supplier has just offered e a large haper of his
products. I know it wont hae cost hi uch, so can
and should I accept it?
A: You can only accept gits and invitations which are symbolic
in value. For example, products with the suppliers company
logo or a box o chocolates is usually ne. In this case, you
should thank the supplier or his generosity, but politely
decline the git. I you think it would harm the relationship
were you to reuse, seek advice rom your management to
nd an appropriate way o dealing with the git.
Remember: If youre facing an issue around gifts and
entertainment, nd out your countrys policy and dont keep
it to yourself. Youll get help and support by discussing it with
your management, your Purchasing Manager, or your Human
Resources Manager (see also the chapter on Open Talk).
-
7/29/2019 Code of Ethics Us
17/40
THE WAY WE WORK 15
BRIBERY AND FACIL ITATIONPAYmENTSW bliv tat corrptio is accptabl.
Sc bavior is ot i li wit t LORALSPIRIT, does not benet the communities inwic w oprat, a rprsts a cost fort Compa. Bribr is a form of corrptio,a is illal i most cotris, particlarlwhere public ofcials are involved. Somecotris v ba facilitatio pamts.These are dened as payments used to secureor sp p roti lal ovrmt actios,sc as issi prmits or rlasi oos
l i cstoms. Most ar, i ffct, a formof bribr.
W ar all xpct to:
Neer ake, offer or proise cash orserices (including gifts and entertainent)to government personnel, other ofcials andthose who inuence them
Neer knowingly ake such payentsthrough third parties which eans carefullyselecting and onitoring contractors, agentsand business partners
Ensure that, if we nd ourselves in asituation where such payent wouldbe unaoidable, we infor our Countrymanager iediately, and fully docuentthe request
Q: Ie been told I should hire a local consultant to
help get all the necessary perits which we need froa foreign goernent. The consultant requested a large
retainer and said that he would use the oney to help
oe the process along. Since we dont really know
where the oney is going, do we hae to worry about it?
A: Yes. I you suspect that any agent is acting improperly, you
should not pay any such retainer until you have determined
that no improper payments have been or are being made.
Investigating such matters may be culturally dicult in some
countries, but any agents doing business with multinational
companies should understand the necessity o these
measures.
Q: I am setting up a new ofce and the local authorities
requested a sall gratuity before they will install our
phone lines. may I ake this payent?
A: The Company does not provide gratuities to ocials to
ensure execution o ocial duties. I the payment is not a
legitimate installation ee, you should not pay it.
Remember: If youre facing an issue around bribery and
facilitation payments, dont keep it to yourself. Youll get help
and support from discussing it with your management, your
Purchasing Manager or your Human Resources Manager (see
also the chapter on Open Talk).
-
7/29/2019 Code of Ethics Us
18/40
16 LORAL
THE WAY WE WORK
AS AN EmPLOYER
We aim to make LORAL a great place inwhich to work. We know that ouremployees are our greatest assetsThe LORAL SPIRIT
-
7/29/2019 Code of Ethics Us
19/40
THE WAY WE WORK 17
HEALTH, SAFETY AND SECURITY
All of s wo work wit a for LORAL av
a rit to a alt, saf a scr workiviromt.
W ar all xpct to:
Coply with the Copanys rules on healthand safety at work
Take eery reasonable precaution to aintaina safe and healthy working enironent
Ensure we are not putting ourseles orothers at risk by our actions
Ensure that we know what to do if aneergency occurs at our workplace
Report to anageent any behaiour,installations or ites likely to coproisethe safety of our working enironent, aswell as all accidents, howeer inor
Q: my anager says shes worried I not getting enough
sleep, and has suggested I shouldnt go out so uch inthe eenings after work. She says shes concerned I ight
doe off and hae an accident. OK, so once or twice Ie
been a bit sleepy but I can still do y job. Surely its
none of her business what I do out of hours? Dont I hae
the right to a priate life? I think shes being petty. What
should I do?
A: How you spend your evenings is up to you. But i your
tiredness is putting yoursel or others at risk, then your
manager is right to raise the matter with you although she
should do so with sensitivity and respect or your privacy.
Although we respect employees private lives, behaviourwhich might create a saety hazard or you or your colleagues
cannot be accepted. There can be no compromise on saety.
Q: my production superisor has instructed e to disable
a safety deice that slows down the production line. What
should I do?
A: You should never bypass, disconnect or disable any saety
device or monitoring equipment without the proper prior
approval o a saety representative. Saety is an absolute
commitment that should not be compromised by productionschedules or or any other reason.
Q: As a sales representatie, I often drie after dark with
product saples in large cities and rural areas. Soeties,
I dont feel safe. I hae raised the security issue with y
anager but he has not acted on y concerns. Should I
take this up with soeone else in the Copany?
A: You should try to avoid putting yoursel in this situation, but
on occasion it may be unavoidable. I you eel your security is
at risk, you should contact your Human Resources Manager
to discuss possible solutions.
Q: I hae just learnt that one of our sub-contractors has
been drinking on our preises. Since he is not technically
a LORAL eployee, do we need to be concerned?
A: Report to management any behaviour which could
compromise the saety o our working environment or put
anyone at risk.
Remember: If youre facing an issue around health and
safety, dont keep it to yourself. Youll get help and supportfrom discussing it with your Health and Safety Manager, your
Human Resources Manager or your Site Manager (see also
the chapter on Open Talk).
-
7/29/2019 Code of Ethics Us
20/40
18 THE WAY WE WORK
Q: What exactly does LORAL ean by discriination?
Is it the same as the denition given by the law in mycountry, or is it different?
A: The rst rule is that LORAL respects local laws and
thereore any employee violating the discrimination laws in
their country may be sanctioned. But there may be countries
where LORAL considers that the law on discrimination does
not prohibit certain behaviours which the Company nds
unacceptable. For example, LORAL is opposed not only to
direct discrimination, but also to indirect discrimination.
Direct discrimination means any action taken with regard
to jobs, training, promotions, continued employment or anyother aspect o working lie which means those aected do
not enjoy equal treatment or opportunities.
Indirect discrimination is any action which, while apparently
neutral, puts anyone with a particular gender, age, disability or
other characteristic at a disadvantage compared to others.
Q: A colleague in y departent often akes jokes about
peoples ethnic background and religion. He says hes just
having a laugh but I nd his comments insulting and
deeaning. I dont want to be seen as a killjoy, though, oras soeone who is oersensitie and huourless, and I
a afraid to confront hi. What should I do?
A: Jokes or slurs against people because o the colour o their
skin, their country o birth, their religion or even their accent
are not acceptable or us at LORAL. They deny the respect
that each o us deserves. Tell your colleague that you nd
his jokes oensive. I they do not stop, you should raise
the matter with your line management or Human Resources
Manager.
DIvERSITY
At LORAL, w bliv i t val of iffrc,
a s it as a rat asst i or work. Tivrs backro of or workforc fostrscrativit, a ivs s a bttr rstaiof or cstomrs.
LORAL is also committ to facilitati tprofssioal itratio of tos wo rirspcial atttio: o alts, prsos fromisavata backros a tos witspcial psical s.
W ar all xpct to:
Ensure we do not discriinate on the basis of:
- Gender
- Disability
- Faily situation
- Sexual orientation
- Age
- Political and philosophical opinions- Religious beliefs
- Union actiity
- Racial, social, cultural or national origins
This applies not only to recruitent, butalso to all decisions relating to training,prootion, continued eployentand working conditions in general
Support and proote LORALs coitentto a dierse workforce
Ensure that our suppliers, custoers andbusiness partners are aware of LORALsdiersity policy
-
7/29/2019 Code of Ethics Us
21/40
THE WAY WE WORK 19
Q: I like to wrap up the working week with a Friday eening
tea eeting so that we can discuss any issues that caeup during the week. I know that this creates difculties
for two ebers of y tea who, for religious reasons,
prefer to leae early on Fridays unless, of course, there
is work still to be nished. Is this indirect discrimination?
A: It could be indirect discrimination i you do not have a
legitimate need to hold the meeting on Friday evenings, or
i there are more appropriate ways to meet your needs. You
appear to have a legitimate need or the meeting (monitoring
your teams progress and being available or their questions)
but do you really have to hold it on a Friday evening? Could
you obtain the same result by holding the meeting earlier in
the day or rst thing Monday morning?
Q: I keep hearing that diersity is iportant for the Group.
Does that ean I should only hire or proote woen or
people fro ethnic inorities?
A: No, this is not what is expected. At LORAL, we hire
on the basis o merit, and thereore you should select the
best candidate or the job. But remember that diversity is
not just limited to ethnic minorities and women. It includes
other groups who are oten discriminated against, such as the
disabled, older people, and so on.
Remember:If youre facing an issue around diversity, dont
keep it to yourself. Youll get help and support from discussing
it with your management or your Human Resources Manager
(see also the chapter on Open Talk).
-
7/29/2019 Code of Ethics Us
22/40
20 THE WAY WE WORK
Q: What exactly does LORAL ean by harassent
and bullying? I dont think we hae a law on this in ycountry.
A: The rst rule is that LORAL respects local law and
thereore any employee violating the harassment laws in
their country may be sanctioned. But there may be countries
where LORAL considers that the law on harassment does
not prohibit certain behaviours which the Company nds
unacceptable. Depending on the circumstances, certain
behaviour may be considered inappropriate, such as:
- Actions intended to cause hurt or upset
- Deliberately setting a person up to make a mistake
- Humiliation or intimidation
- Physical or social isolation (the so-called silent treat-
ment)
There may be no law on this particular subject in your country.
You will, however, probably nd that these types o behaviour
are legally prohibited, even i it is not reerred to as harassment
or bullying.
Q: my anager can be highly intiidating. I know shes
pushing us hard to delier quality work, but at ties she
can really huiliate people, and its affecting the orale
of the whole tea. Is there anything I can do about it?
A: Your manager is expected to challenge and drive her team
to deliver the quality o work we expect at LORAL. This may
mean that she will criticise or comment on team members
perormance. However, a manager is also expected to treat
team members with respect and act with due sensitivity.
I you eel that you are not being treated in a proessional
manner, you should try and speak to your manager. You can
also consult your HR Manager. A good working environment
can only occur with the support and involvement o us all
managers and sta alike.
Remember:If youre facing an issue around harassment or
bullying, dont keep it to yourself. Youll get help and support
from discussing it with your management or your Human
Resources Manager (see also the chapter on Open Talk).
HARASSmENT AND BULLYING
eac of s as t rit to rspct a ma
iit. At LORAL, tat pricipl is famtalto t wa w work. A bavior or actiolikl to ifri o tis rit, a, i particlar,a form of arassmt or blli, is otaccptabl. At LORAL, w call facts aias, ot iivials.
W ar all xpct to:
Abstain fro any harassent or bullying
Support and proote LORALs coitentto a workplace free fro all bullying andharassent
Be courteous treat our fellow workers theway we would like the to treat us
-
7/29/2019 Code of Ethics Us
23/40
THE WAY WE WORK 21
Q: What exactly does LORAL ean by sexual
harassment? Is it the same as the denition given by thelaw in y country, or is it different?
A: The rst rule is that LORAL respects local law and
thereore any employee violating the sexual harassment laws
in their country may be sanctioned. But there may be countries
where LORAL considers that the law on sexual harassment
does not prohibit certain behaviours which the Company
nds unacceptable. Depending on the circumstances, certain
behaviours may, because o their gravity or requency, be
considered inappropriate, such as:
- Unwelcome physical contact, looks and other gestures,comments, invitations or requests
- Distributing or displaying oensive material, including
inappropriate pictures or cartoons
Q: A colleague of ine works with seeral en who
regularly ake sexually charged rearks about woen.
The coents are often coarse, rude and belittling. She
doesnt think they realise what they are doing, but she
nds their behaviour upsetting and demeaning. Shes
afraid to speak out, though, as she doesnt want to coeoer as a prude or attract siilar rearks directed at her
personally. What should I do about it ?
A: You should encourage your colleague to speak with the men
directly i she eels comortable about doing so. She can also
raise the matter with her line management or HR Manager. I
your colleague does not take action, then you should report
what she has told you even i you dont have all the acts or
havent observed the harassment yoursel. It is critical to stop
oensive behaviour beore it becomes severe.
Remember: If youre facing an issue around sexual
harassment, dont keep it to yourself. Youll get help and
support from discussing it with your management or your
Human Resources Manager (see also the chapter on Open
Talk).
SEXUAL HARASSmENT
eac of s as t rit to rspct a
ma iit. At LORAL, tat pricipl isfamtal to t wa w work. A bavioror actio likl to ifri o tis rit, a iparticlar a form of sxal arassmt, isot accptabl.
W ar all xpct to:
Abstain fro any sexual harassent
Iediately stop any behaiour which we
hae been told is unwanted
Support and proote LORALscoitent to a workplace free fro allsexual harassent
-
7/29/2019 Code of Ethics Us
24/40
22 THE WAY WE WORK
Q: I would like to send one of y colleagues a surprise
birthday gift to her hoe. I asked Huan Resources togie e her personal address but they say they cant
tell e, because that would be infringing her right to
priacy! Isnt this going a bit oer the top?
A: No. The Human Resources departments response is totally
appropriate all employee personal data has to remain strictly
condential. They cant start making exceptions.
Q: I recently oerheard y anager talking with Huan
Resources about one of y colleagues and the fact that she
is seriously ill. In y spare tie, I olunteer for a charity
which helps people with serious illness and I would like to
know if there is anything I can do to help. Can I approach
my colleague directly or speak to my manager rst?
A: You should not approach your colleague. Instead, you
should inorm your manager and/or the Human Resources
Department that you overhead this conversation. In order to
respect your colleagues privacy, you should not, o course,
share the inormation you have with anyone.
Remember:If youre facing an issue around privacy, take the
appropriate steps to resolve it. Youll get help and support from
discussing it with your management, your Data Protection
Manager or your Human Resources Manager (see also the
chapter on Open Talk).
PRIvACY
W all av a rit to privac.
LORAL is committed to respecting the con-tialit of mplos prsoal iformatio(sc as tir prsoal rcors, potos aom arss). Ol sc ata as is cs-sar for t ffctiv opratio of LORAL isacir a rtai b t Compa.
If w ar atoris to av accss to prsoalmplo ata, w ar xpct to:
Ensure we proide such inforation toauthorised persons only, on a need-to-know basis
Ensure we neer proide such inforationto anyone outside LORAL, unless legallyrequired to do so or with the eployeesspecic authorisation
make sure such inforation is stored
securelyRefrain fro holding this inforation longerthan is necessary to eet the legal orbusiness reason for which it was acquired
Seek adice before transferring such personaldata outside its country of origin
W ar all xpct to:
Refrain fro accessing and storingpersonal eployee data, unless we haethe appropriate authorisation and a clearbusiness need for that inforation
Respect the right to priacy of ourcolleagues
-
7/29/2019 Code of Ethics Us
25/40
THE WAY WE WORK 23
CONFLICTS OF INTEREST
W sol all avoi sitatios wr or
personal interests might come into conictwit t itrsts of LORAL.
Even the appearance of a conict can tarnishLORALs rptatio as wll as or ow.
The key to dealing with any potential conictis fll isclosr. Tat allows vrti tob proprl ivstiat. As a rslt, it mawll b tat somti wic appar at
rst sight to be a problem is, in fact, not thelast bit armfl to t Compa. Bt it isol tro fll isclosr of all t factstat vro cocr ca kow tis forsure and be able to state it with condenceto otrs.
W ar all xpct to:
Disclose to line anageent if there is a
potential conict of interest which mightinuence or appear to inuence our judgmentand actions (for exaple, where a failyeber is eployed by a supplier)
Refrain fro holding any position,involvement or nancial stake in anyorganisation that is a copetitor, custoer,supplier or any other business partner ofLORAL, if our position at LORAL allowsus to inuence the business relationship
Q: One of y colleagues has a cousin whos joined us,
and an old school friend of ine has just started workingwith e. I slightly concerned that people ight think
there could be a conict of interest here. Do these policies
only apply to iediate faily or would they coer this,
too?
A: The answer is simple: i the relationship is such that it could
infuence your objectivity, then you should apply this policy
and ask or guidance. The act that a member o someones
amily or a riend already works or LORAL has no bearing
on their own worthiness as a candidate or a job with the
Company. But every eort is made to ensure that salary
and perormance evaluation are handled by an independent
person, and that these situations are monitored on an ongoing
basis to ensure objectivity and airness to all.
Q: Ie been really ipressed with the quality of work
fro a particular LORAL supplier, and as a result Id like
to invest in the company. Is there any conict of interest
here?
A: Even though your involvement could only be nancial, there
may be a confict o interest depending on your position in
LORAL, your infuence on purchasing decisions, the amount
o your investment and the importance o LORAL as a
customer to the company concerned. The only way to nd
out i it is acceptable is to disclose it to your management or
Human Resources Manager and discuss the matter openly.
Q: my son owns a really good local hotel, and lots of
copanies in the area use it for lunches and functions.
It would be an obious choice for our eent. Gien that it
copares well on price and quality with other options, is
there any obstacle to e aking a booking?
A: Given the competitive price and popularity o the venue, it
may well be acceptable or the Company to arrange unctions
there. However, it would not be right or you to have a say
in the matter, as there is an obvious confict o interest here.
As with all such cases where a close amily member works
or a current or potential supplier or other business partner,
you should disclose this act to your line manager. Then he or
she can take the necessary steps to avoid placing you in an
awkward situation.
-
7/29/2019 Code of Ethics Us
26/40
24 THE WAY WE WORK
Q: During y spare tie, I a vice-President of the
National Consuer Association. Ie held the post forany years. Now Ie learnt the Association is planning to
lobby for a change in the law which ight cause probles
for LORAL. What should I do?
A: LORAL respects employees privacy and takes a
positive view on employees contributing to society through
associations or charities. However, you should disclose your
membership o or involvement with any such organisations
to your line management when you eel that there is a clash,
or potential clash, with LORALs interests. Your manager or
Human Resources Manager will be able to guide you on the
appropriate action. In this case, it would be wise also to make
ull disclosure to your colleagues in the Association, to explain
the confict o interest or them as well and to withdraw rom
any involvement with that particular lobbying campaign.
Q: my wife works for one of LORALs copetitors. We dont
talk about work at hoe, and I cant see its any business
of the Copany what y wife does in her professional
life. Yet soe of y colleagues hae suggested I in a
coproising situation. So what should I do?
A: This could create the appearance o a confict o interest. To
protect both yoursel and the Company, you should disclose
the acts to your management or Human Resources Manager.
Additionally, you and your wie should continue to avoid
discussing business and take steps to ensure that condential
or proprietary inormation o both companies is protected.
Q: A eber of y tea has been dating his secretary
for a couple of onths. They were pretty discreet aboutit at work, but people still found out. I not supposed
to know about it ofcially. It has started off all sorts of
ruours, and its fair to say soe of the other secretaries
arent at all happy about it. Of course, I a keeping an
eye on things to ake sure there can be no eidence of
faouritis but what if they split up and it all gets nasty?
Should I do soething about it and if so, what?
A: This is a very sensitive situation. At LORAL, we respect
employees private lives, and thereore we do not need or
want to know about their romantic relationships. However,
we do have an interest in their proessional relationships. The
situation you describe is not appropriate because there is a
confict o interest. A manager cannot be expected to judge
his subordinate objectively i he is romantically involved. You
should consult your Human Resources Manager in order to
discuss how to handle this. Ideally, one o the employees
should change jobs, and we would endeavour to make sure
that this could be achieved eectively but with sensitivity.
Depending on the acts and circumstances, there may also be
a sexual harassment issue.
Remember: If youre facing an issue around conicts of
interest, dont keep it to yourself. Youll get help and support
from discussing it with your management or your Human
Resources Manager (see also the chapter on Open Talk).
-
7/29/2019 Code of Ethics Us
27/40
LORAL 25
THE WAY WE WORK
AS A RESPONSIBLE
CORPORATE CITIzEN
We play our part in creating aworld o beauty and airnessThe LORAL SPIRIT
-
7/29/2019 Code of Ethics Us
28/40
26 THE WAY WE WORK
POLITICAL ACTIvITIES
LORAL rspcts its mplos rit to
participat as iivials i t politicalprocss so lo as t mak sr tat, ioi so, t o ot rprst t Compa.
A of s wo tak part i political activitisar xpct to:
make it clear that we are not representingLORAL in any way
Aoid all use of Copany resources (including
Copany tie, phones, paper, e-ail andother assets) to carry out or support ourpersonal political actiities
Q: I do soe olunteer work for a local candidate whose
policies are ery uch in line with LORAL alues. may Iuse the copy machine to run off a few yers?
A: No. Do not use company time or resources o any kind to
support political activities.
Q: my line anager has asked e if Id like to ake a
donation to his daughters ayoral capaign. Is this
appropriate?
A: No. Even i your supervisor isnt pressuring you, any such
request, however innocent, is inappropriate and could be
coercive.
Remember:If youre facing an issue around political activit ies,
dont keep it to yourself. Youll get help and support from
discussing it with your management, your Public Relations
Manager or your Human Resources Manager (see also the
chapter on Open Talk).
-
7/29/2019 Code of Ethics Us
29/40
THE WAY WE WORK 27
LORAL is a rsposibl actor i socit, a oo
ibor a a cocr citiz committto t commitis i wic w o bsiss.W cora mplos to pla a activ roli t commit.
W ar all xpct to:
Support the philanthropic projects prootedby the LORAL Group, participating in thosewhich are of interest to us and to which our
individual prole brings an added valueEnsure that we only engage LORALin actions which reect our corporatephilanthropy strategy, and reect ourcorporate alues
Understand that philanthropy is a long-tercoitent, and that all actions, regardlessof sie, ust be engaged in with a clear planof how to deelop the partnership oer tie
CONTRIBUTION TO THECOmmUNITY
Q: A philanthropy prograe that I a inoled with in
y local counity has asked if LORAL can proidefree products to support their cause. I aware that there
is a large quantity of shapoo and bath gel that is going
to be destroyed because it is in the old packaging. I could
arrange to hae the picked up without anyone knowing.
Can I gie it to the?
A: LORAL wants to support you in your philanthropic eorts,
i they are in line with the Companys strategy. You should
notiy your manager, who can see i this particular charitable
cause is in line with LORALs strategy, and propose it to the
person responsible or philanthropy in your country.
Q: The hospital at which I olunteer each week is asking
eeryone to help recruit new olunteers, and would like
e to get LORAL ore inoled. I know that seeral of
y colleagues ight be interested. Should I speak with
the directly?
A: I this hospital represents an opportunity in line with
LORALs overall philanthropy strategy, you should speak to
your manager to see i it would be possible to engage the
Company in a partnership with the hospital. LORAL strives
to go beyond the cheque, and to develop partnerships
which combine cash and in-kind donations, employee
contributions, and especially sharing the expertise we have in
so many domains to help others. You could be the corporate
sponsor or this project, and develop a meaningul long-term
programme together.
Remember:If youre facing an issue around contribution to
the community, dont keep it to yourself. Youll get help and
support from discussing it with your management or your
Human Resources Manager (see also the chapter on OpenTalk).
-
7/29/2019 Code of Ethics Us
30/40
28 THE WAY WE WORK
Q: The pollution control deice on a critical piece of
anufacturing equipent is faulty. Ie just learnt it willtake three days to obtain parts and ake a repair. Can
we really afford to halt production when we hae a huge
backlog of orders to full?
A: We have no choice. Our commitment to environmental
good practice takes precedence over short-term prots or
production schedules. The machine must not be run without
the required pollution controls. You should notiy your line
management to help you work out a solution.
Q: As long as we coply with local law, why do we hae
to follow LORALs enironental standards if it puts us at
a copetitie disadantage?
A: LORALs commitment to the environment goes beyond
simple legal compliance. I you eel that there are competitive
business issues at stake, you should discuss these with your
manager.
Remember:If youre facing an issue around the environment,
dont keep it to yourself. Youll get help and support from
discussing it with your management, your Health and Safety
Manager or your Human Resources Manager (see also the
chapter on Open Talk).
ENvIRONmENTAL STEWARDSHIP
LORAL rspcts t viromt, a sks to
miimis its viromtal impact. W aim tocommicat opl abot or acivmtsi tis ara, as wll as or calls.
Ma of t activitis ivolv i brii orprocts to markt av a irct impact o tviromt. It is vros rsposibilit tosk to rc tat impact wrvr possibl.evr small stp cots.
W ar all xpct to:
Ipleent LORALs coitent toenironentally-friendly processes
Faour the use of renewable raw aterialsand the deelopent of enironentally-friendly packaging
Consider how our behaiour in all aspectsof our work ipacts on the enironent,
so that we can reduce that ipact whereerpossible: for exaple, by cutting outunnecessary trael, saing water and energyand aoiding generating waste. Where wasteis unaoidable, we ust ensure aterialsare recycled or disposed of in a responsiblefashion. Een sall gestures, such asseparating food waste in copany eatingareas, can ake a difference
Take all necessary actions to preent andstop iolations of LORALs enironentalpolicy
Report iediately all spills or unusualeissions to the air or water to anageentor our Health and Safety manager
-
7/29/2019 Code of Ethics Us
31/40
LORAL 29
THE WAY WE WORK
ADDITIONAL RESOURCES
FOR mANAGERS
We do business with integrityThe LORAL SPIRIT
-
7/29/2019 Code of Ethics Us
32/40
30 THE WAY WE WORK
As a Maar, o av a a rsposibilit
bcas:
You set the exaple and proote ethicalconduct
You are a decision-aker faced with orecomplex and difcult issues
Your tea will coe to you for adiceand help
A as a Maar, o will also al witsbjcts wic ar rall ol cotrat a maarial lvl, aml:
Adertising and arketing
Insider trading
Supplier selection and fair treatentof suppliers
Fair copetitionTax
Q: Which is ore iportant for e as a manager: eeting
my obligations on nancial or business goals, or those ofthe LORAL SPIRIT and THE WAY WE WORK?
A: The two are completely compatible and directly connected.
Doing the right things or the right reasons is always good
business. The Companys interests are never served by
unlawul or unethical business practices.
THE mANAGERS ROLE
-
7/29/2019 Code of Ethics Us
33/40
THE WAY WE WORK 31
Q: my colleague has shown e a arketing proposal for
a body lotion which uses an extreely thin young odel.I think its distasteful in the least, and could lead us to
accusations of encouraging girls to stare theseles in
pursuit of an unhealthily thin physique. She said I was
being oer-sensitie and that the artwork had already
been sent for approal. What can I do about it?
A: Our advertising and promotion is designed to have the
maximum impact possible on our desired audience, so we must
own our responsibility or all the messages it communicates
or is seen to communicate. There is growing concern about
eating disorders among young women, and the health risks
associated with this. This has to be taken into account when
deciding on our advertising campaigns. This does not mean
that you cannot be creative, but you need to make sure
that the advertising message will not be misinterpreted as
encouraging unhealthy or damaging behaviour.
Q: I just deising a arketing prograe for a new
product. The R&D departent responsible has said that it
only reduces wrinkles, but y anager has told e to
say it eliinates wrinkles. I concerned that this isnt
entirely truthful. What is the right thing to do?
A: Overselling our products by making infated or exaggerated
claims or them is dishonest, and creates distrust among our
customer base. I the product does not eliminate wrinkles,
then you should not claim that it does.
Remember:If youre facing an issue around advertising and
marketing, dont keep it to yourself. Youll get help and support
from discussing it with your management, your Scientic
Manager, your Technico-Regulatory Manager or your Human
Resources Manager (see also the chapter on Open Talk).
ADvERTISING AND mARKETING
LORALs avrtisi a markti is bas
o or procts itrisic caractristicsa prformac. Tis pricipl is sstialto wii a kpi t loalt of orcosmrs.
All of s ivolv i t markti apromotio of or procts ar xpct to:
Ensure that all adertising and prootionalaterial is based on proen perforance
and scientic dataGie a fair and truthful description and isualrepresentation of our products and theireffects
Endeaour to ensure that the purpose andcorrect usage of our products is readilyunderstandable by consuers
Be sensitie to the possible reaction ofreligious, ethnic, cultural or social groups toour adertising
Ensure that we do not undertake productplaceent with any outlets (Tv or radioprograes, againes or digital edia)whose strategy for attracting an audiencerelies on exploiting extree iolence,pornography or encouraging offensiebehaiour or hatred toward others.Such strategies are contrary to LORALs
principles
Take great care to ensure our actions areconsistent with the LORAL SPIRIT if we areenisaging adertising to children and youngpeople
-
7/29/2019 Code of Ethics Us
34/40
32 THE WAY WE WORK
Q: I not a legal expert. What exactly is inside
inforation?A: Inside inormation is a concept dened by law. In broad
terms, it relates to non-publicly available inormation which
a reasonable investor could consider important in making an
investment decision. Such inormation can relate to LORAL
but also to one o its customers or suppliers, or another
company with which LORAL is in contact. You will nd
additional inormation in our Stock Market Ethics document.
Q: Ie just heard that LORAL is about to acquire another
copany. This sounds like an excellent tie to buy stock
in one or the other or both, since the alues are bound
to rise when the deal is announced. Is it OK for e to go
ahead and do so?
A: No. As a LORAL employee, you are most likely to be
considered an insider and thereore cannot buy or sell stock
in either LORAL or the other company until the deal has
been announced to the public.
Q: I realise that I cant buy LORAL stock based on inside
inforation yself. But what if I just happened to
ention to y girlfriend that now ight possibly be a
good tie to buy would that be OK?
A: No. It would be as i you were buying it yoursel. Even i
all you heard was a rumour, you would still be encouraging its
spread, and that too is unethical.
Remember:If youre facing an issue around insider trading,
take the appropriate steps to resolve it. Youll get help and
support from discussing it with your management, your Legal
Department or your Human Resources Manager (see also the
chapter on Open Talk).
INSIDER TRADING
Wil LORAL os ot wis to rstrict t
from of mplos to mak appropriatprsoal ivstmts, ac of s mst alwasbar i mi t risk of bi s as aii isir trai w maki ivstmtcisios.
W ar all xpct to:
Be aware that using condential informationto ake inestents could fall within the
scope of insider trading lawsRefrain fro buying or selling shares inLORAL or any other copany if we haeinside inforation at that tie
Aoid disclosing such inside inforationto anyone outside the Copany, includingfaily ebers
Aoid disclosing such inside inforationto anyone within the copany, except on a
need-to-know basis
Protect inside inforation fro accidentaldisclosure
-
7/29/2019 Code of Ethics Us
35/40
THE WAY WE WORK 33
LORALs rlatiosip wit its spplirs
xts bo t prcas a livr ofoos a srvics. It is itral to t lo-trm sccss of or bsiss. W will bj b t alit of t rlatiosips wav wit or spplirs. I particlar, w willb scrtiis o ow w slct or spplirs,a ow t mostrat tir commitmtto oi bsiss rsposibl.
All of s ali wit spplirs ar
xpct to:
Select suppliers on the basis of opencopetitie bidding based on objectiecriteria for ealuating perforance andquality of serice; ensure that all supplieroffers are copared and considered fairlyand without faouritis
Be transparent about the bidding processand gie honest, sensitie feedback tofailed bids
Ensure that the Copanys General Tersof Purchase and Payent, which includesLORAL ethical expectations, are understoodand accepted by all suppliers whereer theyoperate
Proide feedback to suppliers based onobjectie, transparent and consistentindicators
Support suppliers in eeting LORALsexpectations but hae the courage to endthe relationship with those suppliers whopersistently fail to eet the
Pay suppliers on tie and according tothe agreed ters (proiding that thesupplier perfors according to the tersof the contract)
make sure that the supplier is not oerlydependent on LORAL business
SUPPLIER SELECTION AND FAIRTREATmENT OF SUPPLIERS
Refrain fro asking suppliers to ake
unreasonable concessions in order to win orretain business with LORAL. In particular,aoid reciprocal dealing. (This inolesstating or iplying that a decision to buygoods or serices is based on a reciprocalagreeent for the supplier to purchase ourown products or serices.)
Protect the suppliers condential infor-ation as if it were our own, in particularaking sure that we respect their copyrightand intellectual property
W ar pro of or rptatio for aliwit spplirs i a mtall spportiv aop wa. Ts rlatiosips ar bas o tpricipls of impartialit, fairss a loalta w rspct tir ipc a itit.LORAL will ot abs its markt positio toai favor.
Q: I am trying to nd a new supplier for ofce materials.
The rst one I contacted offers a good service, but at a
high price. The second isnt quite as good, but hes cheaper
(mainly because hes made a signicant discount in an
effort to win LORAL business). Can I tell the rst supplier
what price the second guy quoted, in order to try to get
his price down?
A: You can tell the rst supplier that you have a better price
oer elsewhere, but you should protect the identity o the
second supplier. Otherwise, you would be giving the rst
supplier price-sensitive inormation about his competitor, and
thats unethical.
-
7/29/2019 Code of Ethics Us
36/40
34 THE WAY WE WORK
Q: I hae found a really good supplier but he is just starting
up his business and LORAL is, for the oent, his onlyclient. Can I use hi?
A: Yes. There is no reason not to help this supplier start his
business. However, you should provide in the contract that he
is expected to nd other customers beore a certain period
o time and that, should he not do so, LORAL may consider
changing suppliers. I he is really good, this should not be a
problem.
Q: Someone told me condentially that one of our overseas
suppliers is under inestigation following allegations of
forced labour. The supplier hasnt told e any of this, and
on preious site isits theres been no reason for concern.
Should I ignore these ruours?
A: No. You should investigate, starting by asking the supplier
or inormation. I you are in any doubt, consider including them
in LORALs Social Audit programme, which involves sending
an external auditor to veriy the acts around employment
practices, working conditions and other issues.
Remember: If youre facing an issue around supplier
selection or treatment, dont keep it to yourself. Youll get help
and support from discussing it with your management, your
Purchasing Manager or your Human Resources Manager (see
also the chapter on Open Talk).
-
7/29/2019 Code of Ethics Us
37/40
THE WAY WE WORK 35
FAIR COmPETITION
W rspct all actors i or profssioal spr,
icli comptitors. W trat tm t waw wol lik tm to trat s. Or positio aslar i t cosmtics istr riforcs ort to st a oo xampl i tis ara.
It is i or itrst to work i a istr wrbsiss practics ar rptabl. It maks orwork asir a riforcs t trst of orcstomrs. Sari a tp of iformatiosc as prici, costs or markti plas cala to t apparac, ral or prciv, ofprice xing, territorial division or other types ofmaiplatio or istortio of t fr markt.
W ar all xpct to:
Aoid any contact with copetitors wherecondential information is discussed
Aoid inducing custoers or suppliers to breachcontracts with copetitors
Refrain fro knowingly taking action to cut off a
copetitors sources of supply
Ensure that we do not establish exclusie dealingarrangeents (i.e. contracts that require acopany to buy or sell only to LORAL) withoutprior legal adice if LORAL could be consideredto hold a doinant position in the arket
Ensure that we do not ipose contracts which tieor bundle together different products or serices(e.g. those which require a buyer who wants one
product to buy a second tied product as well) orallow delity rebates without prior legal advice ifLORAL could be considered to hold a doinantposition in the arket
Refrain fro all disparaging rearks concerningcopetitors (including any false stateentsconcerning their products or serices)
Proptly disclose to our line anageent if wehae inadertently receied or used proprietaryor condential information which relates to
copetitors and legitiately belongs only tothe or to third parties
Collect copetitie inforation through
legitiate eans only and always identify
ourseles as a LORAL eployee whencollecting such inforation
Neer allow new recruits to LORAL to sharecondential information about competitors forwho they used to work
Q: I ran into one of our copetitors representaties at a
trade show recently. Oer a drink in the bar, he entioned
that his copany would soon ipleent a price increase
on seeral key products. This is really useful intelligence!
Who should I tell about it so we can take full adantage?
A: We do not share or exchange price or bid inormation
with competitors. This includes pricing policies, discounts,
promotions, royalties, warranties and terms and conditions o
sale. I a competitor volunteers such inormation, you should
bring the conversation to a close sensitively but immediately,
and alert your line management. While the exchange may
be intended innocently, it also could create the appearance
o price-xing or bid-rigging which is unethical and, in mostcountries, illegal.
Q: LORAL is a eber of the National Professional
Cosetics Association and I a LORALs representatie
for the Coercial Coittee. After one of the
Coittees onthly eetings, one of y colleagues, a
representatie of a ery well-known copetitor, suggested
that the ebers of the Coittee eet in a restaurant
to reinforce personal links and to speak off the record.
What should I do?
A: Do not accept the invitation, and immediately inorm
your Legal Department. We have an obligation to warn the
Association o such o-the-record meetings. Remember
that contact with competitors must remain exceptional and
limited to non-specic, non-sensitive, non-strategic topics.
Strictly avoid inormal contact and even social events with
competitors. I during authorised ocial contact with
competitors, you realise that sensitive issues are about to be
discussed, just leave the meeting and get the act that you
let registered in the minutes.
-
7/29/2019 Code of Ethics Us
38/40
36 THE WAY WE WORK
TAX
LORAL aims to b a oo corporat citiz
wrvr it oprats. A k lmt of tis isrspcti all rlvat tax laws, sri tatlocal tax obligations are correctly fullled (bothocmtatio a alis), a pai ifll all local a atioal taxs as rir btos laws.
W ar all xpct to:
Ensure that LORAL does not knowingly
eade its tax obligationsPlay our part in keeping accurate andcoprehensie books and records
Q: I hae been approached by a supplier who says he has
a cast-iron way to sae us oney. Hes offering to re-route
the paperwork for purchasing the Christas order of their
goods ia a third country to aoid paying sales tax (vAT)
that they would otherwise charge us. It sounds like acleer schee can I gie it the go-ahead?
A: No. Any attempt to evade meeting our tax obligations in
ull which is in eect what this would be is illegal and
unethical. LORALs budgeting includes provisions to pay all
legitimate taxes.
Remember:If youre facing an issue around tax, dont keep it
to yourself. Youll get help and support from discussing it with
your line management, your Finance Manager, your Legal
Department or your Human Resources Manager (see also the
chapter on Open Talk).
Q: Ie found out that one of our ain copetitors will be
launching a new product shortly that could hae seriousiplications for our sales and arketing strategies. We
desperately need to nd out more about it, whatever it
takes. Gien how crucial this is, can we hire soeone
to sort through their trash in search of clues as to their
launch strategy?
A: No. This is wholly unethical behaviour, which could be
severely damaging to our reputation or integrity. LORAL
can never be party to such activities. Apart rom the act
that such espionage is inappropriate, just ask yoursel how
it would look i it came out in the newspaper! We can only
collect competitive inormation through legitimate means.
Such means include examining our competitors products and
using publicly available sources, such as promotional leafets,
annual reports, competitors displays at trade shows, and
aggregated industry data that does not disclose company-
specic inormation.
Q: Six onths ago, I hired soeone who used to work
for a copetitor. While there, she gained soe hugely
aluable research expertise in a key area for us. Indeed,
that experience was one of the ain reasons I hired her.Obiously, Ie taken great care to ensure she doesnt pass
on any condential information to us, but surely theres a
tie liit, after which she can share her knowledge freely?
Otherwise, it would just be taking all this condentiality
stuff to extrees, wouldnt it?
A: No. There is no time limit on protecting condential
inormation. Your recruit should have been hired on the basis
o the research she would be able to do or us, not that
conducted in the past or our competitor. It may even be
appropriate to transer her to a dierent department, whereshe wont eel under any pressure to pass on condential
knowledge.
Remember:If youre facing an issue around fair competition,
dont keep it to yourself. Youll get help and support from
discussing it with your management, your Legal Department
or your Human Resources Manager (see also the chapter on
Open Talk).
-
7/29/2019 Code of Ethics Us
39/40
LORAL is osetting all the carbon emissions resulting rom the
creation, production and distribution o the Code o Business Ethics.
This is our rst climate neutral document.
We are doing so via Climate Care, one o the most reputable
companies providing osets.
Published by:Group Director o Ethics
LORAL
41, rue Martre
92117 CLICHY
FRANCE
http://ethics.loreal.wans
Photographs:
Jean-Jacques Ceccarini, Carole Bellache, Micheline Pelletier/
Gamma, Kitty Sirichaiwat, David Arraez, LORAL Recherche, all
rights reserved
Design:
Futerra Sustainability Communications Ltd
www.uterra.co.uk
This document was printed using biodegradable vegetable inks
and low-alcohol print technology. It is made rom paper certied by
the Forest Stewardship Council and containing 50% recycled post-
consumer waste. We chose a printer with an independently certied
ISO 14001 environmental management system.
-
7/29/2019 Code of Ethics Us
40/40