Ethics & Compliance: being an ethical partner of choice

From combating corruption to managing conflicts of interest, fraud, and protecting Human Rights, our businesses and the regions in which we operate require an extreme vigilance. By applying our Ethics Charter, whose principles meet the most exacting ethics regulations and standards, we support our values and protect our business.

Portrait of Nicole Sourgens, Eramet Group's Ethics & Compliance Director

Nicole Sourgens

Ethics & Compliance Director

Our number-one goal is to make Ethics and Compliance a cornerstone of our business, in order to transform it into a lever of performance. The Ethics & Compliance Department works every day to help all of the Group’s employees coalesce with our partners and customers.

Our priority is to act with integrity, in full accordance with the legal and regulatory environment. The Group has a zero-tolerance policy toward any behavior that runs counter to the highest national and international standards. We’ve put together a number of reference materials on the subject, including an Ethics Charter, an Anti-Corruption Policy signed by every member of the Executive Committee, an Anti-Corruption Guide, as well as a range of specific procedures. 
To assist our employees, we’ve set up a Compliance Program that rests on three main pillars: an organization dedicated to Ethical Governance, regularly updated reference materials, and an array of tools, including a whistleblower system.

An organization dedicated to Ethical Governance: the Ethics & Compliance Department

Every day, Eramet’s Ethics & Compliance Department ensures that laws, regulations and standards are followed within the Group. This dedicated organization operates in close collaboration with several key departments: the Audit and Internal Control Department, the Legal Department, and the Communication and Sustainable Development Department.
To provide the most effective support to employees, we engage as closely as possible with frontline stakeholders, in order to train and educate employees on frequently complex subjects.
The Ethics & Compliance Department depends on a network, including:  

  • 17 Ethics & Compliance Managers, appointed by the Executive Committee. They are responsible for ensuring that our Ethics Charter and procedures are implemented and followed in their respective areas. They receive reports from employees and ensure they are escalated internally.
  • 55 Ethics & Compliance Ambassadors appointed by the Ethics & Compliance Director, after consultation with the relevant Ethics & Compliance Manager. Every site, whether it’s a mining center, a plant, or a railway station, will have an ambassador on hand to educate and assist employees who are facing ethical dilemmas. 

Eramet uses mandatory e-learning modules and in-person training programs on every site to instill an ethical culture among all of its employees. A whistleblower system has been set up so that any stakeholders who are victims of or witnesses to non-ethical behavior can alert the Group’s top-level senior management. 
All Eramet employees are required to follow Compliance Program procedures and reference materials, and are expected to perform their daily duties with the utmost integrity. Anyone who violates legal and regulatory requirements or fails to comply with these materials may face disciplinary sanction.

Targeted reference materials

The Group’s reference materials comply with international standards, including the Universal Declaration of Human Rights, the United Nations Convention against Corruption, and the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.
These materials include the Group’s Ethics Charter—a foundational document—the Anti-Corruption Policy, the Anti-Corruption Guide of conduct, along with an array of specific procedures (the Gifts and Hospitality Policy, the Conflicts of Interest Policy, etc.). This normative framework reflects Eramet’s commitment to maintaining and strengthening its business integrity in everything that it does, wherever it operates. A number of practical examples and case studies are included to help employees identify non-ethical behaviors and adopt good practices on a daily basis in their activities.  

The standards are accessible to all employees and stakeholders worldwide via the Group's website and intranet.  They are available in the Group's twelve main languages HERE and are regularly updated.

A whistleblower system

A Professional alert system, accessible to all employees, but also to external stakeholders, has been deployed.. It allows them to report ethical problems, including instances of discrimination, unfair treatment, harassment, fraud, bribery, as well as any violations of human rights, as defined under the law. Available worldwide in the thirteen main languages spoken in the Group, the service is outsourced to ensure full transparency, confidentiality and protection for whistleblowers.
Reports may be made through various channels:

  • The Ethics & Compliance Department and its Ethics & Compliance Network, available anywhere in the world.
    • Ethics & Compliance Department
      • Nicole SOURGENS - Ethics & Compliance Director
      • Lionel LACUES - Ethics & Compliance Officer & DPO
      • Ranim KAMEL - Apprentice Ethics & Compliance Officer
    • Compliance Network
      • Nicholas FELL (USA)
      • Christian WINTERTHUN (Norway- TTI)
      • Eva DANNBERG (Sweden) 
      • Christine NZE (Gabon - Setrag)
      • Pascale JEANJEAN (New Caledonia - SLN)
      • Makhtar SY (Senegal- GCO)
      • Jose Manuel SANCHEZ (Norway- Eramet Norway)
      • Christine Deram (Eramet International)
      • Marie-Sophie BOUTRON (Mines & Metals Division)
      • Clotilde HUET (France - High-Performance Alloys Division)
      • Axel DE MONT-MARIN (France - High-Performance Alloys Division)
      • Landry ONTOUA (Gabon - DFIP)
      • Nadia NGALANI (Gabon - Comilog)
      • Philippe GUNDERMANN (Argentina Global Lithium)
      • Sophie BERGEROT (Argentina) 
      • Jean-Michel TAJAN (Financing)
      • Samia VILLA (Bureaux commerciaux)
  • The websiteeramet.integrityline.org

This whistleblower system is available in all 24 countries where the Group operates, in thirteen languages. It guarantees protection, anonymity and full confidentiality to all whistleblowers, as defined under the law.

If you are a victim of or witness to non-ethical behavior, such as discrimination, unfair treatment, harassment, fraud, bribery, or human rights violations, let us know by clicking HERE

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