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Gemalto strives to apply the highest ethical standards to the management of its business. Our principles are shaped by a series of codes and charters which form the ethical backbone of its management practices. The Company complies with the principles and best practice provisions of the Dutch corporate governance code, with the exception of the best practice provisions listed in "Compliance with the Dutch corporate governance code" (page 50).
Our code of ethics, updated in 2009, provides guidelines for the conduct of all employees with respect to internal controls, financial disclosures, accountability, business practices and legal principles. With regard to its employment practices, Gemalto does not tolerate any kind of harassment or discrimination against job applicants or employees. Our whistle-blower procedure guides the receipt, retention and treatment of complaints received by Gemalto regarding suspected financial irregularities. In addition, Gemalto has charters governing the functioning of the Board and its committees that are reviewed regularly with regard to their appropriateness and effectiveness. It also has a policy on the ownership of and transactions in Gemalto securities. For more information, please refer to "Corporate governance".
Gemalto’s anti-fraud commission comprises the Group Legal Counsel, the EVP Human Resources, the Chief Information Officer, the Security Director and the Internal Audit Director. It was created in 2008, and meets once a quarter to coordinate the various fraud prevention and detection programs. It initiated the anti-fraud policy which was published in 2009 and among its actions it promoted various training sessions on integrity and anti-fraud awareness (please refer to "Anti-fraud commission").
In 2007, Gemalto initiated an enterprise risk assessment and subsequently issued a risk map together with action plans to mitigate the key risks. An update of these action plans was presented to the Audit committee and twice to the Board in 2009. A detailed description is presented in "Internal risk management and control systems".
Gemalto’s management regards internal control as a responsibility that is shared by all managers and that is met by implementing a set of processes and procedures within Gemalto intended to provide reasonable assurance that risks are mitigated, financial reporting is reliable, applicable laws and regulations are complied with, and that the objectives of the Board can be attained (please refer to "Internal control environment").
As a business with operations and customers on every continent, we are also signatories to the United Nations Global Compact. This is a strategic policy initiative for those committed to aligning their operations and strategies with ten universal principles in the areas of human rights, labor, environment and anti-corruption. Please refer to www.unglobalcompact.org.
