Ethics at the heart of Eau de Paris’s commitments

The responsibility, which is one of the five values ​​of our company, implies for all of our employees a duty of exemplarity in all acts carried out within the framework of their missions, with regard to the conduct of procurement procedures, relations with partners, service providers and users /subscribers.

This is why Eau de Paris is implementing a zero tolerance policy towards all unethical behavior, in general, and any risk of corruption.

Thus, as part of its internal operation and vis-à-vis third parties and in compliance with the obligations imposed by the Sapin 2*, Eau de Paris law:

• places the prevention and detection of acts of corruption, influence peddling and illegal taking of interests at a priority level for the company and has set up, for this purpose, an ethics college, a training system for its agents most likely to be exposed to it as well asa professional alert procedure ;
• adopts a firm attitude towards any situation contrary to the requirements of integrity and probity, relying on the Code of conduct and professional ethics in force within the public company;
• materializes its commitment and transparency, through the internal and external dissemination of this policy.

*Law No. 2016-1691 of December 9, 2016 relating to transparency, the fight against corruption and the modernization of economic life 

A college of ethics, an independent body

This college fulfills the functions of ethics referent responsible for providing any Eau de Paris employee (as an employee or staff representative), any external person contributing to the activity of Eau de Paris (namely, any legal representative or any employee of a company holding or bidding for a public market, a contract or an agreement with Eau de Paris, any subscriber) as well as to any user of a public water service, useful advice for complying with ethical obligations, under conditions which guarantee their independence and confidentiality.

Attributes

• Provide advice to Eau de Paris employees, any person contributing to the authority's activity as well as any user on compliance with ethical obligations and principles and the prevention of risks of conflict of interest;
• Answer questions relating to situations brought before it in order to recommend any measures aimed at ensuring compliance with ethical obligations and preventing or putting an end to a conflict of interest situation;
• Contribute to any reflection concerning the application of ethical obligations and principles concerning the services of the public establishment and propose awareness-raising and training actions necessary for understanding ethical issues and developing a proactive approach to prevention.

Composition

Three qualified members from outside Eau de Paris:

• Ms. Marie-Françoise LEBON-BLANCHARD, Referent to the ethics commission of the City of Paris
• Madame Marie PITTET, magistrate of the Court of Auditors
• Mr. David MOREAU, Master of Requests at the Council of State

Three members appointed from among Eau de Paris employees:

• Mrs Claire CARPENTIER - de PONTICH, Director of Administration and Finance
• Mr. Gwenaël de CONTI, Director of Human Resources
• Mr. Gérald-James BENCHETRIT, Head of the Risk Management and Performance Mission

The presence of external members at Eau de Paris is intended to be a guarantee of perfect impartiality in the processing of alerts and the assurance of a contribution of expertise on these complex and sensitive subjects.

Role, referral and instruction procedures

The main body, made up of three external members, is the sole recipient of reports and requests on individual situations.

How to contact the ethics college?

The main ethics committee can only be contacted by email at the following address:

college_deontologie@eaudeparis.fr

 The referrals must include all the information and documents necessary for their understanding. The applicant must in particular specify his/her last name, first name, electronic contact details, functions, department of assignment. 

The main college acknowledges receipt of requests as soon as possible.

If the referral does not fall within the jurisdiction of the college, it informs the applicant electronically.

The enlarged college, bringing together the three external members and the three internal members, has the role of carrying out advisory work and supporting the application of ethical obligations and the implementation of the recommendations made by the main college, including the three internal members can be responsible, within Eau de Paris.

A reinforced alert system

Eau de Paris has set up an anonymous system for collecting reports based on an outsourced solution – ethicorp – which fully ensures the conditions of independence, impartiality and confidentiality.

Eau de Paris has chosen a very wide opening of this system which is accessible:

• to Eau de Paris staff members;
• to external collaborators (consultants, temporary workers) or occasional employees (interns);
• to incumbent companies and subcontractors (management and staff members);
• to any subscriber;
• to any user of the public water service.

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Integrity and probity, a shared commitment

Eau de Paris has acquired a Code of conduct and professional ethics to ensure compliance with the principles of integrity and probity.

This code is an appendix to the internal regulations of Eau de Paris and constitutes a tool to protect us from risky behaviors and postures that could lead to criminal and disciplinary sanctions.

In particular, it sets out the principles to be adopted regarding gifts, benefits and invitations, while respecting the principles of integrity and probity. 

Generally speaking, within the framework of its relations with partners and suppliers, the principle is that Eau de Paris employees cannot accept or request gifts, invitations or any other advantage.

This Gifts and Invitations policy applies internally and to all partners within the framework of relations with Eau de Paris.

Are likely to be admitted:

•  low-value gifts that can be considered collective (note, the donation of bottles of alcohol is prohibited);
• invitations of a reasonable value, less than 30 euros, as part of a work meeting or a collective event, subject to informing the hierarchy.

Compliance with these rules constitutes the basis of a quality relationship between Eau de Paris and its stakeholders.

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