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SNCF GROUP ETHICAL CHARTER

SNCF GROUP

ETHICAL CHARTER

CONTENTS

SUMMARY 4

SCOpE Of ThE EThiCAl ChARTER 8

OUR EThiCAl vAlUES 10

ThE ThREE kEYS TO EThiCAl CONdUCT 22

AN ESSENTiAl pREREqUiSiTE 26

ElEvEN pRiNCiplES Of EThiCAl CONdUCT 28

EThiCS STAkEhOldERS 78

USEfUl liNkS 86

3

— to reaffirm and reinforce our ethical commitments, a key factor in the success

SUMMARY The creation of the Public Railway Group gives us the opportunity

to reaffirm and reinforce our ethical commitments, a key factor in the success of our operations and to achieve our ambitions, which are for SNCf Mobilités [transport of passengers and goods] to be the model for multimodal transport in france and abroad, and for SNCf Réseau [network] to combine industrial excellence and economic performance, under the umbrella of the SNCf EpiC1.

Within this new legal framework, and in view of the major challenges facing SNCf and its subsidiaries – speeding up the modernization of the rail network, constantly improving safety, devising mobility solutions for the future, supporting digital changes and international development, it is essential, in terms of motivating the whole workforce, that the management and the employees of the group share common ethical values, and that they abide by the same rules of conduct.

1 Translator’s note: EpiC stands for Établissement public industriel et Commercial and refers to a public-service enterprise with a commercial and/or industrial remit which is owned by the french state. The term “public enterprise” is used hereafter.

This need is all the more imperative since the SNCf group, like other large groups, is facing increasing risks and ever more stringent legislation, with very severe penalties for any breaches. All our employees must know and understand this, and make a conscious decision to integrate the ethical dimension into their duties at work.

These are the reasons why this SNCf Group Ethical Charter was presented to the Boards of directors of SNCf Mobilités and SNCf Réseau, and approved by the Supervisory Board of SNCf EpiC.

4 5

— concerning all the group’s employees.

This Code of Ethics, which replaces the 2011 SNCF Group

Ethics Guide, is designed to: �highlight�the�five�ethical�values�chosen�by�the�group’s�employees�following a survey carried out among a broad cross-section of them, namely Integrity, Responsibility, Respect for the individual, Trust and Courage. outline a series of eleven principles of professional conduct, the first�ten�concerning�all�the�group’s�employees�and�the�eleventh�specifically�for��employees�of�the�Public�Rail�Group�and�its�subsidiaries with a direct public service remit.

SUMMARY

These principles explain what we must do (obligations) and what we must not do (prohibitions) and they deal with: protecting the group’s human capital, preventing�and�fighting�corruption, combating fraud, complying with competition law, conflicts�of�interest, protecting�confidential�information�and�personal�data, managing SNCf funds and assets with integrity, reducing our environmental footprint, our obligations as a socially responsible and accountable group, the ethical standards of our suppliers, service providers and partners, the�specific�duties�associated�with�carrying�out�a�public�service�

(secularism, equal treatment, fair dealing and discretion).

Most of these principles are illustrated by practical examples.

The role of the Ethics department is to explain the contents of the Charter and support managers and employees in putting its values and principles into practice.

Monique SASSIER

Chair of the Group Ethics Committee

Jean-Luc DUFOURNAUD

head of the Ethics department

6 7

— some of the principles it sets out will be covered in specific guides.

SCOpE Of ThE EThiCAl ChARTER

ThE EThiCAl ChARTER, signed by the Chairman and deputy Chairman of the Board of directors of SNCf, concerns the entire workforce of SNCf Group, that is the managers and staff of the three public institutions making up the public Rail Group and those employed by its subsidiaries, whatever their level of responsibility and their status. This�field�of�application�is�referred�to in the Charter as " SNCF Group ". The Charter, which is also the core ethical reference source for relations with our stakeholders, does not claim to be exhaustive. for this reason, some of the�principles�it�sets�out�will�be�covered�in�specific�guides.

furthermore, subsidiary companies may complement the Charter with their own ethical codes or guidelines, particularly with regard�to�specific�activities�that�they�perform�internationally, provided that they ensure these documents are consistent with the Charter.

The Ethical Charter is available on the SNCf Group corporate website.

it has been translated into English. The french version will constitute the reference document for employees working in france and in french-speaking countries, while the English translation will be the reference version in other countries.

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iNTEGRiTY

RESpONSiBiliTY

RESpECT fOR ThE iNdividUAl

TRUST

COURAGE

OUR EThiCAl vAlUES

OUR fivE EThiCAl vAlUES express the way we want to work within the company and with all our stakeholders: customers, suppliers, partners, non-governmental organisations and community associations.

They are designed to be shared by all SNCf Group employees, who must all be conversant with them. They must be publicly promoted at every available opportunity and must instinctively dictate the way we behave when the response to any given situation is not provided in the Charter.

10 11

OUR EThiCAl vAlUES

iNTEGRiTY means being honest with ourselves and with others, being impartial and not acting in our own interest to the detriment of the common interest.

Acting with integrity also means the total exclusion from our behaviour of any kind of fraud, corruption,�favouritism�or�peddling�of�influence.

— being honest with ourselves and with others

iNTEGRiTY

12 13

— Acting in a responsible way means accepting the consequences of one’s actions: anticipating and controlling them, and answering for them.

SNCF�Group�fully�assumes�its�high-profile�corporate�social and environmental RESpONSABiliTY in particular for the safety of its customers and employees, for job satisfaction and well-being in the workplace, and for regional planning and development.

Acting in a responsible way means accepting the consequences of one’s actions: anticipating and controlling them, and answering for them.

To this end it is essential to foster a culture of dialogue, education and awareness with those whom our decisions may affect, notably our colleagues, customers, suppliers and corporate partners.

RESpONSABiliTY

OUR EThiCAl vAlUES

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— making sure their working conditions are good, and ensuring their safety and dignity.

OUR EThiCAl vAlUES

RESpECTiNG pEOplE means making sure their working conditions are good, and ensuring their safety and dignity. it also includes having a caring and considerate attitude, being attentive to fellow workers, suppliers, partners and customers. The climate must be one of mutual respect, in which every individual feels accepted and does not encounter discrimination. The Group will be all the richer for its diversity.

RESpECT fOR ThE iNdividUAl

16 17

— is built through genuine, honest professional relations.

TRUST is built through genuine, honest professional relations. Acting in good faith and honouring our commitments helps to establish and maintain the trust of our colleagues and stakeholders (customers, service providers, suppliers, local and regional authorities, public institutions, etc.).

TRUST

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OUR EThiCAl vAlUES

— we need courage to face up to difficulties

COURAGE in management and in our work, the courage to deal with dysfunction, to put forward proposals and make the correct decisions: we need courage to face up to�difficulties�and�take�the�right�action,�not�over-hastily�but with determination, strength of character and a sense of fairness, even if this is not the easiest way.

COURAGE

20 21

OUR EThiCAl vAlUES

— The Ethics department provides an advice and support service

ThE ThREE kEYSTO EThiCAl CONdUCT : ThINk ANy pRObLEM ThROUGh, SEEk ADvICE, RAISE ThE ALARM Thinking problems through :

Any employees who have doubts or are faced with ethical dilemmas concerning any action or decision they have to take,�and�who�do�not�find�answers�in�the�Ethical�Charter�should�first�of�all�apply�the�“Golden�Rule”�which�is�to�ask�themselves, and then answer, the following four questions: does my action or decision comply with the law? does my action or decision comply with the SNCf Group

Ethical Charter and my professional Code of Conduct, if there is one applicable to my job or in my company?

Could my action or decision have a negative impact on my company, my close professional circle or on other stakeholders?

Am i willing to be held accountable for my action or decision with total transparency?

Seeking advice: if the doubt or problem persists, advice should be sought

from the appropriate people: line managers, the human Resources department, the legal department, or the Ethics department. The Ethics department provides an advice and support service (see “Useful Links” at the end of the Charter), which will respond to enquiries from employees of the Group and provide assistance regarding the action and decisions that they are required to take.

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— Whistle-blowers acting in good faithare protected against the risk of reprisals.

Raising the alarm: finally, if an employee observes or is affected by behaviour that seems to them to be unethical or inappropriate, they can trigger the whistleblowing system by notifying the Ethics department (see “Useful links” at the end of the Charter).

This scheme enables all employees of the public Rail Group and its subsidiaries (except those with their own whistle-blowing systems) in france to inform the Ethics department of any facts or actions that are unlawful, contrary to the Ethical Charter, or likely to damage the business or the reputation of an SNCf Group entity. The alert may concern, but is not restricted to, breaches in standards of honesty (fraud,�corruption,�financial�wrongdoing, embezzlement, theft, breach of trust, etc.), damage to the environment, safety and human rights violations (dangerous situations, forced labour, harassment and bullying, discrimination, etc.), or the misuse or diversion of the Group’s assets or means of communication.

The whistle-blower’s identity remains�strictly�confidential,�unless�the�right�to�confidentiality�is waived by the whistle-blower him- or herself for the purposes of the investigation.

The Ethics department does not respond to anonymous tip-offs, unless they reveal a serious safety or security risk for SNCf customers, its employees or facilities, or they report acts that could�be�classified�as�corruption,�in-house fraud, misappropriation of�assets,�conflicts�of�interest,�peddling�of�influence,�or�favouritism.

Whistle-blowers acting in good faith are protected against the risk of reprisals. Conversely, alerts raised with deliberate intent to harm, notably the reputation of a natural person or legal entity, may give rise to disciplinary action and may incur the civil and criminal liability of the perpetrator.

ThE MAIN FEATURES OF ThE whISTLE-bLOwING SySTEM:

FOR FURTHERDETAILS: Guide to Whistle-blowing (June 2016)

24 25

ThE ThREE kEYS TO EThiCAl CONdUCT

AN ESSENTiAl pREREqUiSiTE:RESpECT FOR ThE LAw AND hUMAN RIGhTS

in france as in all the countries in which it operates, SNCf Group carries out its activities in accordance with the laws and regulations that apply there. Therefore employees must refrain from acting or behaving in any way that could constitute a breach of this legislation and give rise to disciplinary or legal proceedings. The abuse of human rights, failure to comply with the rules governing the employment of children and corruption will not be tolerated.

These laws and rules constitute the legal framework for the Group and should not be seen in any way as hampering its activities, but on the contrary, as a means of leveraging its development.

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11 pRiNCiplES Of EThiCAl CONdUCT

28 29

pROTECTING ThE

GROUp’S hUMAN CApITAL1260 000


A group employing thousands of people has a particular responsibility towards all the members of its staff. it must protect this human capital, which is the key to the development of its activities, and ensure that the working environment of every employee is safe, healthy and harmonious.

It is also one of the Group’s responsibilities to which we must all contribute on a daily basis.

people

FOR FURTHER DETAILS:

Reference document on the principles of good conduct, requirements applicable to staff (RH 0006).

factsheet “Ethics in practice” on psychological and sexual harassment and personal data.Guides to dealing with harassment and discrimination.Ethics and diversity in the workplace.Guides “Making diversity a day-to-day reality” (versions for managers and employees). Awareness-raising kit “Making social, racial and gender diversity

a day-to-day reality“.

WE MUST

WE MUST NOT

Ensure that working conditions comply with regulations and respect the human rights and dignity of all.

Require of ourselves and others standards of behaviour which guarantee respect for individuals, their private lives and their diversity.

Treat all our colleagues fairly.

Support the Group’s commitment to diversity and equal opportunities, and be particularly vigilant in preventing and ending discrimination, in particular on grounds of sex, age, health, disability, actual or supposed ethnic, racial or national origin, religion, sexual orientation, physical appearance, trade-union activity, etc.

Engage in or tolerate behaviour or�remarks�that�could�be�qualified�as psychological or sexual harassment, or any discriminatory or sexist actions, whether at the time of taking on new staff or when making any decisions related to training, promotion and, more generally, to working conditions.

Engage in or tolerate insulting or demeaning behaviour or remarks (of a racist, sexist, homophobic nature, etc.).

�Affix�or�allow�to�be�affixed�in�any�business premises any posters, pictures, drawings or writings of an abusive, offensive or degrading nature.

Welcome and successfully integrate new colleagues, introducing them to the values and principles of conduct formulated in the Ethical Charter.

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SOME pRACTiCAlEXAMplES

i am asked in my role as manager to include in my team a person with a disability. i am aware of the issue of avoiding discrimination but i am nevertheless afraid that this person’s performance will not be of the same standard as the other members of my team and so i will tend to be more lenient with him or her, risking making the others jealous or arousing hostile reactions from them. i am therefore tempted to rule this person out on the pretext that they so not have the necessary�profile�and�skills�for�the�position.

1-1.DISCRIMINATION

Am I right to do this?

No. Such reasoning is based on preconceived ideas. Experience shows that the presence of employees with a disability does not change working relationships. The only criteria to be taken into account when recruiting are the professional skills of the candidate, once it has been established that the workstation is compatible with the particular disability concerned, bearing in mind that if necessary, it can be adapted.

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1-2.SExUAL hARASSMENT

A tutor is abusing his position as manager to request favours from someone on a work-study contract. Every day for the last month, especially in the evenings after work, he has sent her thirty or so text messages, the content of which is inappropriate and which she has shown me as the head of the establishment: - he is constantly complimenting her or making inappropriate comments on her dress; - he invites her for the weekend; - he sends her photos of his house. She says she is uncomfortable but does not dare put him in his place as he has promised her a job at the end of her work-study contract and he is the person who will mark her work for her diploma.

What should I do?

if proven, the allegations are serious since they constitute sexual harassment, which is a criminal offence in france. The manager of the establishment must immediately either initiate the procedure laid down in the "Guide to dealing with allegations of sexual harassment for hR managers", or ask for a written explanation if the facts are not contested and then start disciplinary proceedings. At the same time, the tutor and the person on the work-study contract must immediately be placed in separate working environments.

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pREvENTING AND COMbATING CORRUpTION AND pEDDLING OF INTEREST

Corruption consists of offering, promising, giving, consenting to give or authorising payment, directly or indirectly, of money or any other thing�of�value,�to�a�third�party�with�the�aim�of�influencing�a�commercial�transaction�or�decision,�or�of�consenting�to�or�accepting�any�benefit�contrary�to�one’s�official�duties�and�incompatible�with�the�respect�for�the rights of others. Corruption�and�trading�of�influence�create�inequality�and�destroy�the�trust of stakeholders, whether they are investors, customers or the general public. They may give rise, among other things, to disciplinary and criminal sanctions. As a signatory to the UN Global Compact, the 10th principle of which is that businesses should act to combat corruption, SNCf Group therefore rejects corruption in all its forms and applies a zero-tolerance policy in this regard. The Group prohibits any form of corruption in its commercial transactions and complies with international anti-corruption conventions and anti-corruption laws in the countries in which it operates.

FORFUTHERDETAILS

Recommendations of the SNCf Group Ethics Committee on the prevention of corruption and factsheet “Gifts, invitations and technical study trips”.Group Ethical Charter for procurement.internet : Transparency international france : http://www.transparency-france.org/

UN Global Compact: http://www.un.org/fr/globalcompact/corruption.html

2

Comply strictly with international conventions, in particular the Organisation for Economic Cooperation and development (OECd) Convention on combating bribery, and national provisions such as french law, the US foreign Corrupt practices Act, the Uk Bribery Act 2010 etc., which prohibit all forms of bribery and corruption.

implement the SNCf Group programme on the prevention of corruption and refuse absolutely all forms of bribery, in particular the giving or receiving of gifts or�other�benefits�in�order�to�obtain or grant undue favours, such as making a payment so an intermediary will intercede in our favour with decision-making authorities, or attempting to avoid, simplify or shorten administrative,�customs�or�fiscal�formalities.

Make sure, by means of internal or external audits, that all our operations as regards accounts, treasury, corporate philanthropy, sponsoring, partnerships with associations, communications or advertising conceal no transactions that could be classified�as�corrupt.

Carry out the necessary assessment procedures to check that our partners and commercial intermediaries act in a lawful and honest manner. When there are serious doubts, we accept to lose the business, to not enter into the contract with the supplier or agent, or to terminate the contract.

Request or accept payments, gifts�or�benefits�from�suppliers,�service-providers or candidates in exchange for a decision or action unfairly made in their favour, including preferential treatment in awarding contracts, authorisations, jobs or privileges, etc.

Give to or accept from a public official�or�a�partner�any�payment,�gift�or�benefit�in�exchange�for�a�decision or action unduly in our favour, including preferential treatment in awarding contracts, authorisations, jobs or privileges, etc.

WE MUST

WE MUST NOT

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A pRACTiCAlEXAMplE

A supplier with a major contract with my establishment, and who is also interested in other contracts in the future, has invited me to go with him to Madrid to see the next football match between the french and Spanish national teams, flights,�hotel�and�meals�included.� As i am a keen supporter of the french team, and have never had the opportunity to go to one of their matches abroad, i am quite tempted to accept the invitation.

What should I do?

i apply the principle of transparency. i speak about it with my managers, a purchasing manager�or�compliance�officer�from the Ethics department. in order to avoid any suspicion of bribery and corruption, i am obliged to turn down the invitation, explaining to the supplier our corporate rules on gifts and invitations.

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COMbATINGFRAUD

fraud is an intentional act designed to deceive another person deliberately�to�obtain�a�benefit�one�is�not�entitled�to�or�to�circumvent�legal obligations or professional rules.

It is predominantly carried out either by straightforward theft of company funds, values or assets or by concealing or falsifying documents in order to obtain the said funds, values or assets improperly.

3

WE MUST NOT

WE MUST


factsheet “internal fraud”.

Ensure operations are fully traceable and accounts true and fair.

Be conversant with and make known the relevant procedures within the Group designed to prevent any risk of fraud.

Adhere strictly to the rules regarding the separation of functions (the person making the decision and the person verifying it cannot be the same), delegations of power, signatures and double checking.

deliberately create discrepancies in�records�between�the�inflow�and�outflow�dates�of�funds�in�order to conceal shortfalls in the accounts or to grant oneself undue payment facilities.

Misappropriate money, products or equipment belonging to the Group.

lie about the quantity of services, supplies or work required in order to obtain financial�or�other�considerations�from suppliers or service providers.

destroy supporting documents, tamper with accounts entries or documents, omit compulsory formalities to conceal unlawful acts or personal gain.

Monitor the authenticity of business expenses reimbursed by the Group.

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A pRACTiCAlEXAMplE

My immediate superior, who has the delegated authority to purchase services up to €500k, has sub-delegated his power to me for purchases up to €150k. Someone insists that i sign urgently for a purchase of €300k as my boss is away for several days. i consider signing, telling myself that it is only a question of in-house rules on delegation�of�powers�and�I�am�sufficiently�competent to sign this undertaking.

Should I do it?

No. if i do, i am ignoring the Group’s rules on the delegation of powers and am possibly being party to a fraudulent transaction. in any event, i am creating considerable legal uncertainty for the Group as, if problems should arise with the service thus purchased, the service provider could attempt to discharge himself from his obligations by claiming the signature of the SNCf representative was invalid owing to my lack of the relevant powers, thus making the contract void.

42 43


4 RESpECTING

COMpETITION LAw

WE MUST

WE MUST NOT

The aim of competition law is to allow economic stakeholders and customers to have access to a variety of products and services at competitive prices.

It therefore requires companies to compete fairly on the market and not to act in any way that will distort competition.

Act fairly with regard to our competitors, partners, service providers and suppliers.

Enter into agreements with competitors concerning the price of products or services, divide up markets, restrict market access, pervert any tendering processes.

Take advantage of a dominant market position to hamper the development of competitors on this market or solicit undue benefits�from�economically�dependent suppliers or service providers.

Unduly favour a supplier or service provider by, for example, giving him or her inside information on our prices, methods and practices.

Comply with the relevant rules of free competition in france and in all the countries in which we operate.

Adhere strictly to the current SNCf Group procurement rules and principles, and where applicable, follow the requirements permitting mutual agreement contracts to be negotiated or imposing a tender procedure.

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A pRACTiCAlEXAMplE

At a trade fair, i realise that some documents clearly showing a�list�of�prices�and�financial�projections�have�been�left�lying�on the stand of one of our competitors. i am keen to take advantage of this opportunity to look at them, as this is very valuable information in this sector of business for SNCf Group, who could use it to improve their market position.

Should I do so?

No. Such behaviour would be contrary to our ethical code and could seriously damage the reputation of SNCf Group as this would constitute a theft of documents and so would be completely illegal. it would give the Group an unfair advantage on the market concerned, distorting the rules of open competition and thus infringing competition law.

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5 AvOIDING CONFLICTS

OF INTERESTWhatever�our�position�or�seniority,�we�can�all�find�ourselves�faced�with�a�conflict�of�interest�if�our�own�self-interest�clashes�with�the�objective and impartial performance of our professional duties.

This interest may be, for example, a personal relationship, the prospect of some benefit or gain for ourselves or someone close

to us, or the acceptance of a gift which makes us feel beholden.

WE MUST

WE MUST NOT

FOR FURTHERDETAILS:

Awareness-raising�guide�on�conflicts�of�interest�(June�2015)�and�factsheet "Conflicts of Interest".

identify high-risk situations before they arise, for instance regarding our participation on behalf of SNCf Group in a decision in an area in which we have a potentially conflicting�outside�activity,�a�financial�interest,�or�a�personal�relationship with someone such as a supplier, service provider, job applicant, or with a public authority or association.

Report such situations in a transparent way to our line manager or to a specialist in the Ethics department.

Ask for someone to take our place in such cases during the negotiations and signing of the contract, or avoid attending any meetings where decisions will be made and generally not take part in the process leading up to the conclusion of the contract.

Engage in outside activities that compete with the business of the Group or assist its competitors.

participate in any process involving the selection of a supplier or service provider in the case of a personal connection (family relationship, friendship, or other) with the person in the supplier or service provider company in charge of this process.

��Use�our�authority�to�influence�the Group’s decisions in order to�obtain�unfair�benefit,�whether�financial�or�other,�for�ourselves,�a member of our family or any natural or legal person with which we have links.

Maintain a special relationship with one of the Group’s suppliers, service providers or subcontractors that makes us dependent on them and is likely to lead to unfair treatment compared with others.

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— a self-interest which clashes with...our professional duties.

A pRACTiCAlEXAMplE

My position leads me to participate in the selection of companies submitting bids on our calls for tender for the provision of iT services. My cousin is the operations manager for�one�of�the�firms�tendering.�Even�so,�I�do�not�consider�withdrawing from the assessment of his company’s bid as i am honest and i think that i will not favour his company to the detriment of any other.

Am I right?

No. Even if you think you would act honestly, it is important that if the bidding process is to be thorough and not open to dispute, there should be no hint of favouring one company over another. If�your�cousin’s�firm�is�awarded�the�contract,�this�could be challenged by a competitor if he knew of the family relationship. in addition, your credibility and legitimacy risk being called into question within the company by your colleagues, who may wonder how objective the choice of your cousin’s firm�really�was.��In�such�situations,�you�should�inform your superiors and avoid participating in the invitation to tender.

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Reference document on SNCf Group’s information assets.

Reference document on security policy regarding group information systems.

Guide on the use of social media.

pROTECTING CONFIDENTIAL INFORMATION AND

pERSONAL DATAThe information we possess at work does not belong to us but is the property of SNCf Group or of third parties, and may be very valuable.

before passing on or revealing the substance of this information to colleagues or third parties, we must consider the status of this information, whether or not it is of a strategic nature, how sensitive it is and whether it is legitimate for the colleague or third party

to receive it.

6

WE MUST

WE MUST NOT

��Protect�confidential�information�belonging to our customers, service providers and suppliers.

protect SNCf Group’s know-how, economic, commercial and strategic information and technical data, by complying with the rules on the use and dissemination of this information.

follow the rules laid down by law concerning the use of data from which it is possible to identify individual persons (employees, suppliers, service providers, partners or customers), the security of this data, its transmission and the length of time it is stored. failure to comply with these rules may render the person liable to criminal proceedings.

know and apply the reference document on the protection of information assets: ensure the�classification�level�appears�on all documents and apply the rules on protecting and marking�documents�(Specific�recommendations for the EpiCs making up the public Rail Group).

Broadcast or distribute on social media or by any other means accessible to third parties, company repositories or internal documents such as reports, notes and�financial�statements.

Reveal our professional digital and iT tool user names and passwords to unauthorised colleagues or to third parties.

divulge in any form whatsoever details of a patent or trademark, or more generally, any intellectual property belonging to SNCf Group and as such, strictly protected.

pass on personal data belonging to employees, suppliers, service providers and partners to colleagues or third parties not authorised to have knowledge of it, or put it to unauthorised use.

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A pRACTiCAlEXAMplE

i am taking part in a trade show on railway equipment and i am to make a presentation on the changes in maintenance rules for high-speed trains to participants at the show. This will include people not necessarily employed by SNCf Group, even though i will be basing my presentation on an internal�document�classified�as�“Confidential – for limited distribution”.

Can I do this ?

��No.�Given�its�classification,�this�document is likely to contain high-stake business information or data potentially of economic or predictive value. i may only divulge it to legally recognised third parties and only after approval by the general management. i must therefore submit my draft presentation to the general management before the trade fair to obtain their explicit agreement.

54 55



Reference document on security policy regarding group information systems.

MANAGING AND USING SNCF GROUp FUNDS AND ASSETS wITh hONESTy AND INTEGRITy

SNCf Group provides us with the necessary resources, means and tools to carry out our professional activities.

Such items are the property of the Group, meaning we must manage and employ them honestly and with integrity.

7

WE MUST

WE MUST NOT

Manage, operate and maintain equipment properly in order to guarantee the safety of personnel, customers and third parties.

Use the Group’s assets and resources honestly and as intended. When private use is allowed, for example in the case of computers, tablets and smartphones, this use must remain within reasonable limits and be marginal compared to its original professional assignment.

Ensure the funds, assets, resources and tools placed at our disposal by SNCf Group are used legitimately, for the execution of our professional tasks and activities.

Ensure information systems are properly used by checking, among other things, that authorisations for these systems are regularly reviewed.

Use SNCf Group information systems or digital tools for improper or illegal purposes, in particular to :

download material or access sites whose content is in breach of public order, individual privacy or dignity, public decency (pornography, paedophilia, incitement to ethnic or racial hatred, terrorism, revisionism, etc.).

Slander, libel or verbally abuse anyone, circulate images of colleagues without their permission, reproduce logos and trademarks without the necessary legal authorisation.nécessaires.

Misappropriate or use for private purposes SNCf Group assets placed at our disposal (tools, vehicles, bank cards, tablets, smartphones, etc.).

Use the Group’s information systems in such a way as to jeopardise the proper operation of these systems.

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A pRACTiCAlEXAMplE

An executive in one of our establishments is in charge of having a certain length of disused track removed by a specialised�firm,�which�has�been�awarded�the�contract�for�this�work.�The�manager�of�this�firm�offers�to�remove�more�of�the disused track than planned and split 50/50 the proceeds of the sale of the material, including track, sleepers, scrap metal etc. salvaged from this site but not provided for in the contract. SNCf would not pay any more than agreed for the work and would pay for the materials removed following the prescribed internal procedures, but only for the track included in the contract and not for all the track actually removed.

7-1.RESALE OF MATERIALS

Can he accept this proposal?

No, as the track removed over and above that mentioned in the contract is the public property of SNCf Réseau [the division in charge of the tracks]. Neither the SNCf executive nor the sub-contracting company has the right to appropriate the product of the sale of this salvaged material for their own benefit.�This�would�constitute�a theft of SNCf property by both the executive and the sub-contractor.

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��I�am�the�chair�of�a�not-for-profit�environmental�protection�association. in my position in the SNCf Group, i have been delegated the authority to make donations of modest amounts�of�money�to�non-profit�organisations.�I�therefore�intend to make a donation to the association i head, telling myself there is nothing illegal about this as i have been delegated the necessary powers and i am not seeking any personal gain since the contribution is for the legitimate purposes of the association.

7-2.SpONSORShIp

Am I right?

No, the strict management of any sums you may grant in the form of donations to associations implies that your choices are not dictated by any personal interest, even if this interest is not directly pecuniary. By choosing the association you preside, you are immediately ruling out any other organisations that could claim to be legitimately entitled to this donation on the grounds of their commitment to environmental protection. This is therefore conduct contrary to the sound and rigorous management of SNCf Group funds,�irrespective�of�a�possible�conflict of interest.

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FOR FURTHER DETAILS: SNCf Group CSR Report

REDUCING OUR

ENvIRONMENTAL FOOTpRINTSNCf Group is fully aware of its responsibilities towards current and future generations and has set itself ambitious targets as far as sustainable mobility and reducing its environmental impact are concerned.

All employees of the Group at their respective levels must take their share of this responsibility.

8

WE MUST

WE MUST NOT

Adopt methods and behaviour likely to minimise this impact.

Assess and control the environmental impact of our professional activities: our facilities, equipment, materials and products, how we carry out our work, our workplace environment, business travel, waste management.

Avoid making the necessary investment or carrying out the procedures or checks needed to protect the environment.

deliberately conceal or suppress information on pollution caused by the Group.

Adhere strictly to SNCf Group rules and regulations on environmental protection.

help to protect biodiversity and contribute to the sustainable management of resources by our own individual actions.

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i am a site manager and i am informed at the last minute that my superior is going to visit the site. i want everything to be immaculate and so i want to clear away some old computers that are lying around the premises. There is no time to call the facilities management department to come to fetch them so i ask the team to get rid of them, even if they just dump them in the station yard.

A pRACTiCAlEXAMplE

Is this all right?

No. Waste management is regulated and electrical and electronic equipment often contains components that are harmful to the environment (batteries and accumulators, greenhouse gases, cathode-ray tubes, components containing mercury, capacitors that may contain pCBs, etc.). in addition, the materials they are made of (ferrous and non-ferrous metals, rare metals, glass, plastics, etc.) are potentially highly recyclable. in france, the system for the disposal of electrical and electronic equipment is regulated by the Environment Code and SNCf Group must comply with this. No emergency can justify contravening the Code and so i must apply the regulations set by the company regarding waste management.

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perform actions in the workplace categorised as political activities unrelated to our professional duties.

�Use�our�influence�unduly�by�having�recourse�to�corruption,�influence�peddling or other dishonest or improper practices.

Ensure our accounts are transparent and settle all the taxes, charges and contributions incumbent on us.

��Use�our�influence�in�a�socially�responsible, accountable and transparent way:

Comply with the codes of conduct and rules of the political and professional bodies with which we have dealings.

Base our stance and attitudes towards political and institutional bodies on information that has been analysed, appraised and assessed in-house by the relevant departments of the Group.

Respect local cultures, integrate into our policies and actions the opening up of the regions, the diversity of our fellow citizens, and take vulnerable groups into account.

bEING A GOOD CORpORATE CITIzEN AND ACTING wITh SOCIAL RESpONSIbILITy

The civic actions undertaken by SNCf Group are in line with its overall commitment to continuing to improve and promote the Group’s efforts in terms of corporate and social responsibility.

9

WE MUST

WE MUST NOT

FOR FURTHERDETAILS:

SNCf public Affairs Charter: https://www/medias.sncf.com/sncf com/pdf/transparence/charte

Affaires Publiques.

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A pRACTiCAlEXAMplE

i am an employee of SNCf Group but also a town councillor dealing with town planning issues. A plan to develop a freight depot requiring the sale to SNCf Group of a plot of land belonging to the municipality is presented at a council meeting at the same time as a rival offer from a car dealership to purchase this land. having given the matter some thought, i decide that my duties as a councillor should not interfere with my professional ones and so i choose not to participate in the part of the council meeting dealing with this plan.

Was I right to do so?

Yes, it is clear that in this case there�is�a�potential�conflict�of�interest�between�my�office�as�a�councillor and my status as an employee of SNCf Group. This conflict�of�interest�could�raise�suspicions that i have taken an illegal advantage that is subject to sanctions and could lead, in the event of a dispute, to the calling into question of the council’s decision if the choice is made to sell the land to SNCf Group. This would be prejudicial for the Group.

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ENSURING OUR SERvICE pROvIDERS, SUppLIERS AND pARTNERS AppLy ThE SAME EThICAL STANDARDS

AS wE DOSNCf Group is in constant contact with numerous different stakeholders: service providers, suppliers, partners and intermediaries.

As a responsible and accountable Group, we must make sure these firms and organisations apply standards equivalent to our own.

10 Enter into contracts with persons or companies who employ illegal immigrants or children who are underage according to international conventions on child labour and to the legislation of the country in which they are employed.

Enter into contracts with suppliers or service providers who do not comply with labour law or with our ethical principles, notably in the fields�of�human�rights,�combating�corruption, free competition and environmental protection.

Enter into contracts with persons or companies who employ practices such as the deprivation of liberty, forced or compulsory labour or working conditions likely to seriously harm the physical or mental health of the people they employ.

if one of the above-mentioned breaches is perpetrated by an entity with which the Group already has a contractual relationship, this entity must present a plan of action detailing how it will end this malpractice and SNCf Group will then assess whether or not it should terminate the contract.

familiarise our service providers, suppliers, partners and in general all our stakeholders with our Ethical Charter, and require that they make a contractual commitment to comply with this Charter and ensure that their own suppliers and subcontractors also respect it.

Require our suppliers, service providers and partners to outlaw all acts of corruption or peddling of influence,�by�demanding�specific�contractual commitments on these points, and in particular on that of carrying out audits.

Require our suppliers, service providers and partners to make a commitment to respect the fundamental principles of the prohibition of harassment, discrimination, child labour and forced labour, in accordance in particular with the conventions of the international labour Organisation.

WE MUST

WE MUST NOT

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��I�have�received�unconfirmed�information�that�one�of�my�suppliers is using a foreign subcontractor, of which i was previously unaware. The company apparently employs children under the age of 15, contrary to the rules on child labour of the international labour Organisation. Even though�I�am�very�satisfied�with�the�quality�of�the�products�from this supplier, i believe i cannot ignore this information and i should investigate this matter.

Am I right?

Yes indeed, you cannot ignore such information. You should ask your supplier to explain and if you are not convinced, you should undertake an audit by referring to the clause in the contract with this supplier which allows for just such audits. if the audit shows up such practices, this will constitute a serious breach of contract by the supplier, on the basis of which all relations with the supplier company would be brought to an end.

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A pRACTiCAlEXAMplE

ASSUMING ThE SpECIFIC DUTIES OF pUbLIC SERvICE

IMpORTANT: this eleventh principle applies more specifically to the public enterprises making up the public rail group and the public-service activities of its subsidiaries.

The activities of the public enterprises that constitute the public Rail Group and those of its subsidiaries with a public-service mission require our extreme vigilance to ensure we observe our duties towards the State and the principles of public service: its secular and neutral nature,�equal�access�to�public�services�and�specific�duties�of�trust�and�confidentiality.

11

The principle of equal treatment and the duty to observe trust and�confidentiality�apply�to�all�SNCF�Group�employees�without�exception, and those who work for the public Rail Group or who, in the subsidiary companies, have a public-service mission, have more stringent obligations in these areas.

The principles of religious and other neutrality which the State must abide by, are also applicable to the employees of public enterprises and those of SNCf Group subsidiaries, whether or not they are in direct contact with the general public.

SECULARISM AND NEUTRALITy

practise or tolerate within the company any proselytising activity or conspicuous behaviour based on political or religious convictions.

Allow any confusion to exist between our private convictions and commitments, whether religious or political, or our involvement with associations, and the views of SNCf Group.

Respect the principles of secularism and neutrality and make sure they are respected, in the public Rail Group and its subsidiaries when they are carrying out public service missions.

Always put the requirements regarding the proper functioning of the public service, in particular those of continuity and equality, above the demands of users or employees related to their religious customs and practices.

Uphold the strictest standards of discretion when manifesting our political or religious convictions.

WE MUST

WE MUST NOT


Guide: “The principles of Secularism and Neutrality within the public Rail Group”.

factsheet: “The principles of Secularism and Neutrality within the public Rail Group”.

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Equal treatment is a fundamental principle of public service.

EqUAL TREATMENT

Ensure equal treatment in all circumstances, when situations are comparable, as regards access to:

our services for our customers, our contracts for our suppliers and service providers, the national rail network and its service infrastructure for all users.

Behave in such a way as to discriminate against certain customers or unduly deprive them of access to our services on grounds of any actual or presumed difference.

WE MUST

WE MUST NOT

The performance of a public service implies strict standards of behaviour, as far as relations with the customers and the general public is concerned.

SpECIFIC DUTIES OF TRUST

AND CONFIDENTIALITy

Make offensive public statements that fail to respect the dignity of customers, especially passengers.

discuss professional records, mention the names of customers or suppliers or speak of in-house professional practices in public, particularly in stations and on trains, without due regard to confidentiality�and�discretion.

Behave in an exemplary manner when listening to and serving our customers.

provide assistance to our customers spontaneously, whenever it is required.

Behave in stations and in trains in such a way as to avoid offending other travellers and fuelling disputes with colleagues, in particular with inspectors.

provide them with any information they may need.

WE MUST

WE MUST NOT

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ThE AGENTS Of EThiCAl pRACTiCE

All employees of SNCf Group must integrate the values and principles of the SNCf Group Ethical Charter in the day-to-day practice of their duties. however, there is one particularly important player, the manager, and there are dedicated personnel whose role is to give guidance and advice on ethical issues.

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— The manager must communicate a specific vision and act as a guide to everyone working with him or her.

TO MANAGE, is to be responsible for leading a team of whatever size, for setting targets, and for motivating and giving a sense of purpose. The�manager�must�communicate�a�specific�vision�and act as a guide to everyone working with him or her. from executive level to local supervisors, managers are the primary ambassadors of our values. They must ensure that the principles arising from them are properly put into action.

ThE MANAGER: A kEY plAYER

Managers therefore have a duty to : know thoroughly the Ethical Charter and to behave and act in such

a way as to provide a good example of responsible conduct, in-house and externally,

ensure those working with them also have a thorough knowledge of the Ethical Charter, be capable of explaining its contents when necessary, and do so systematically to all new arrivals in their unit or team,

be available for and attentive to any fellow workers who have concerns of an ethical nature, and pass these worries on to the dedicated member of staff if they are not themselves able to provide solutions,

ensure that any person to whom they consider entrusting a position of responsibility knows the Ethical Charter thoroughly and has the necessary skills, authority and means to make sure in turn that it is properly applied.

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— it provides support and reasoned advice to all managers or other employees confronted with an ethical problem.


Reference document on the organisation and remit of the Ethics department.

The task of the Group Ethics Committee is to make recommendations regarding ethical policies to SNCf Group’s management board. it endorses the Ethical Charter through spin-offs such as guides and action plans on�specific�ethical�topics.

dEdiCATEd EThiCS pROfESSiONAlSThE GROUp EThICS COMMITTEE

The Ethics department is an operational unit within SNCf Group, dedicated to emphasizing the importance of ethics and carrying out all training, educational and awareness programmes to promote the principles of the Ethical Charter and make sure they are properly implemented. Through the Ethics Helpline, it provides support and reasoned advice to all managers or other employees confronted with an ethical problem. Through the professional whistle-blower

scheme, it handles ethical problems brought to their attention, by carrying out or having carried out, the necessary investigations.

ThE EThICS

DEpARTMENT

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— The ethical advisors are responsible for making sure the Ethical Charter is implemented.

The Ethics department coordinates a network of people that employees may refer to on ethical matters in every major sector of SNCf Group and its main subsidiaries.

The ethical advisors are responsible for making sure the Ethical Charter is implemented within their particular unit. As both facilitators and organisers, they contribute to the prevention of ethical risks by encouraging professional conduct that conforms to the principles and values of action of the Ethical Charter, and, when necessary, by having specific�codes�and�guides�implemented�concerning�the�activities�and�trades of their unit.

DEDICATED EThICAL ADvISORS

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USEfUl liNkSAll the documents mentioned in the Charter under the heading “For further details” are available on the SNCf intranet, mostly on the pages�specifically�concerning�ethics. These documents can also be requested directly from the department of Ethics.

The Ethics helpline for support and advice can be contacted by:

The whistle-blower scheme can be alerted by:

This Ethical Charter has been signed by the Chairman and deputy Chairman of the SNCf EpiC Executive Board.

Guillaume pEpy

Chairman of the Executive Board

patrick JEANTET

deputy Chairman of the Executive Board

TElEphONE : +33 (0)1 85 07 89 06 (internal 38 09 06)

EMAil : [email protected]

REGUlAR MAil : SNCf

direction de l’Éthique et de la déontologie 2 place aux Étoiles CS 70001 93633 la plaine Saint-denis Cedex. france

TElEphONE : +33 (0)1 85 07 89 05 (internal 38 09 05)

EMAil : [email protected]

REGUlAR MAil : SNCf

direction de l’Éthique et de la déontologie 2 place aux Étoiles CS 70001 93633 la plaine Saint-denis Cedex. france

86 87

SNCf direction de l’Éthique et de la déontologie 2, place aux Étoiles – CS 70001 93633 la plaine Saint-denis Cedex

Editing: direction de l’Éthique et de la déontologie

design and production : Agence 4uatre

illustrations: SNCf Media Center

photographs: SNCf Media Center : Yann Audic, Brigitte Baudesson, Alfred Cromback, Raphaël dautigny, fred de Gasquet, Seb Godefroy, Ronan Guillou, Claire-lise havet, Maxime huriez, letizia le fur, patrick Messina, Géronimo potier, Matthieu Raffard, Adrien Toubiana.

israel Railways

Geodis Media Center: Bruno Clergue

keolis Media Center: Angie, Raphaël dautigny, Michel djaoui

printing: dejalink