Ethics & Compliance
CMA CGM Ethics & Compliance Program
CMA CGM Group, a leading worldwide shipping group, is determined to conduct its business activities in a responsible, transparent and ethical way, maintaining its values and rules emphasized in its Code of Ethics and its Third Party Code of Conduct.
CMA CGM Group has implemented an Ethics & Compliance Program to provide to all employees the necessary awareness to respect the values and principles that the Group is committed to defend and to ensure the compliance of its activities with all applicable laws and regulations.
The Ethics & Compliance Department
CMA CGM Ethics & Compliance department is responsible for implementing and monitoring the proper implementation of Ethics & Compliance Program within the Group.
A set of Compliance documents
The new Code of Ethics was established in November 2014 and is the cornerstone of the Group’s Ethics & Compliance Program.
It is built around the core values of the CMA CGM Group:
- Boldness which pushes us to new heights;
- Initiative that drives continuous improvement;
- Creative imagination to strive to be the best in everything we do;
- Integrity to strive sustainable business.
It expresses, in practical terms, principles and guidelines that every employee must comply in performing its daily job.
The Third Party Code of Conduct: As stated in the Group's new Code of Ethics, CMA CGM selects its partners based on objective criteria, being assured of their compliance with the rules and principles enshrined in the Third Party Code of Conduct. This Code sets out the minimum standards required of its partners as part of a contract with CMA CGM.
The Code of Ethics and Third Party Code of Conduct are supplemented by Compliance Guides and Procedures designed to provide concrete answers to the Group’s employees:
- The Focus on ... Compliance with applicable regulations establishes general guidelines of the Ethics & Compliance Program. This guide provides concrete examples to employees and allows them to adopt the appropriate behaviors. This Guide is supplemented by four detailed Compliance Guides designed specifically to provide concrete answers to the employees of the Group on the following topics:
- The Compliance Guide - Competition
The CMA CGM Group is committed to strictly comply with competition rules within the European Union as well as in all states in which it operates. These rules can vary from country to country, but they have the common goal of ensuring that the behavior of economic operators is such that competition works effectively in the public interest.
- The Compliance Guide - Anti-Corruption
The Group strongly condemns corruption, unacceptable and incompatible with its values and very detrimental to its reputation and its image.
CMA CGM is member of the Maritime Anti-Corruption Network since March 2014. The Maritime Anti-Corruption Network is a global business network working towards its vision of a maritime industry free of corruption that enables fair trade to the benefit of society at large. MACN Members promote good corporate practice in the maritime industry for tackling bribes, facilitation payments, and other forms of corruption by adopting the MACN Anti-Corruption Principles, communicating progress on implementation, sharing best practices, and creating awareness of industry challenges. MACN also collaborates with key stakeholders, including governments, authorities, and international organizations, in markets where corruption is prevalent to its membership, to identify and mitigate the root causes of corruption in the maritime industry.
- The Compliance Guide - Economic Sanctions
CMA CGM has developed a strict compliance policy regarding the applicable regulations related to economic sanctions and embargoes, in close cooperation with national and international authorities.
- The Compliance Guide - Data Protection
CMA CGM Group has been committed for years in a personal data protection policy. This policy is fully applied in each of its subsidiaries through its Binding Corporate Rules (BCR) to ensure the proper use of personal data worldwide.
• Notice of individuals at data collection;
• Affirmative consent of individuals ;
• Security and access control.
A training program:
The Ethics & Compliance Department makes it a point of honor to the accompaniment of Group employees. To this end, an e-learning session was set up in 2009 in order to give the necessary awareness to CMA CGM employees on competition law to prevent anti-competitive practice within our Group. This training is mandatory for all employees Group and was updated in 2012. Similarly, a mandatory training program was designed to train, adequately Group’s employees to the U.S. OFAC (US Office of Foreign Assets Control) rules.
To complement the existing training program, an e-learning module on the "Fight against corruption" is in progress and should be launched soon.
Finally, an e-learning mandatory for all employees was developed and launched in November 2014 to give to all employees CMA CGM the necessary knowledge on the principles, requirements and values introduced by the new Code of Ethics.
An ad hoc communication :
The Ethics & Compliance Department diffuse an "Ethics & Compliance" culture within the Group by several means. All the Compliance documents are available to the Group employees on the Ethics & Compliance intranet site. Employees are also informed via our weekly internal newsletter, the "Flash news" of changes in the Group's policy in this area and the new applicable rules.
A culture of openness and employees’ accountability is essential to prevent any illegal conducts or practices that could be in contradiction with CMA CGM Code of Ethics or to address them whenever they do occur.
All Group’s employees are encouraged to report, by any way, to the Top Management, their hierarchy, the Ethics & Compliance Desk and/or other existing channel, any violation of CMLA CGM’s Ethics & Compliance Program, in respect of the following items:
- Fraud and / or corruption;
- Anti-competitive practices