Compliance

At EuroTeleSites, we make a conscious choice to commit ourselves to the high standards of integrity towards all our stakeholders. Only by following an honest, fair and transparent way to conduct our business we are able to fulfill trustworthy our vision to provide the sustainable foundation for the digital transformation.

Integrity has a central place in our values. We consider that the right results can only be obtained by going the right way and that integrity is more important than short term business success. In this matter, it is everybody’s responsibility to always act ethically and legally. Acting with integrity in our daily business life is essential for a sustainable business success and our reputation.

Code of Conduct

Guided by our corporate strategy and culture and integrated in our ESG Policy, our compliance goals are oriented towards best in class principles. Our code of conduct summarizes our approach and is the basis of actions.

Compliance Management System

The Compliance Management System (CMS) works then effectively by using the 3 pillars processes: prevent, detect and react.
 
Prevent: we implement relevant compliance guidelines that are fixing clear rules for all stakeholders, also in our purchasing process regarding right business conduct from our suppliers and other business partner. We conduct a yearly compliance risk assessment to identify risks and potential for improvement, define measures to manage effectively those risks and proceed to regular reviews on it. Training and learning for all employees are also part of the prevention’s pillar. Furthermore, EuroTeleSites maintains a strong ICS (incl. related with SOX requirements) that play a useful role in the CMS.
 
Detect: we implement permanent and periodic controls and audits to be able to detect compliance cases or problems. The whistleblowing platform https://eurotelesites.whistleblowing-software.com/ is also a central part of the detection process. Each stakeholder can help us to strengthens our compliance by signaling violations of laws and rules.
 
React: Each detected case is then duly investigated by internal audit. If a violation is confirmed, we discipline such deliberate, unlawful misconduct   consistently, regardless of the rank or position of the person involved. Also, business partners have to expect appropriate consequences in case of breach of contractual compliance obligations or violations of anti-corruption laws.

We evaluate yearly the appropriateness of our Guidelines, the completeness of our compliance risk assessment as also the effectiveness of our processes and measures  and report periodically to our governing bodies about our activities and implemented improvement.

Contact

You have questions or concerns as to whether a certain incident is in line with our values in terms of integrity or our rules? Then please contact us.

Compliance Office: Compliance@eurotelesites.com
Compliance Officer – Guillaume.dubois@eurotelesites.com
Whistleblowing Channel: https://eurotelesites.whistleblowing-software.com/