Business conduct & ethics
It is only through ethical business leadership that we will be seen as a leader and truly ‘Unlocking Better Futures.’ We can only achieve this if we share the same ambition, culture, values, behavior and engagement, and recognize that ethics, safety, sustainability, innovation and profitability all go hand in hand.
Our Code of Business Conduct & Ethics
Our Code of Business Conduct & Ethics brings together the fundamental principles that illustrate our common commitment to integrity in our daily professional behavior. In line with our Purpose, Vision and Values, the Code sets out the standards of conduct that should motivate each of us, as employees of the Group, as well as our partners and suppliers.
It is based on respect for law, ethics and our Group values. The best practices and standards behind this Code serve all our internal and external stakeholders. The Code covers, amongst other topics, compliance with laws and regulations, protection of the environment and human rights, health and safety, and business conduct.
The Code is the product of a wide consultation process and is reviewed regularly under the supervision of the Ethics Committee. It is available in 21 languages.
Training is provided to help managers and employees understand and apply these standards. Employees taking the Code online training are required to expressly commit to respecting the Code’s principles and standards.
Read our Code of Business Conduct and Ethics:
Governance over Ethics matters
Imerys has a dedicated Ethics Committee to assist the Executive Committee in ensuring the Group’s operations are conducted ethically.
The Ethics Committee, composed of Executive Committee members and Senior Managers of the Group, is chaired by the Group General Counsel and Company Secretary. The Committee meets regularly and presents its annual report to the Board of Directors’ Audit Committee once a year. The Chair of the Ethics Committee and the Antitrust & Compliance General Counsel regularly inform the Executive Committee of the performance and effectiveness of the Group ethics and compliance programs.
Speak Up!, our alert mechanism
We believe in acting with transparency and integrity, and speaking up in case of wrongdoing.
Speak Up! is our global whistleblowing system for reporting suspected violations of our Code of Business Conduct and Ethics or applicable laws and regulations. This includes all topics covered by the Code, in particular breaches of environmental, societal and business conduct standards.
Speak Up! is open to all (employees and third parties), is completely confidential and ensures that issues raised will be investigated and handled carefully, with respect for the rights of all involved individuals.
Reports can be made either by telephone or via the Speak Up! web platform. Both channels are available in several languages, 24 hours a day and seven days a week.
Details on how alerts can be made and how they are treated within Imerys can be found in the Group Whistleblowing Policy.
Business conduct
We are committed to ensuring that our business practices comply with laws and regulations at all times and reflect the highest standards of integrity, responsibility and respect for our partners.
Our commitment to ethical business conduct is reflected in our Group compliance programs, supported by internal policies and procedures. We expect our employees to respect and embed these high standards in their daily work.
Imerys has a “zero tolerance” policy against bribery and influence peddling. All Imerys employees, directors, officers and third parties doing business with the Group must act ethically and are expected to actively take part in Imerys’ commitment to eradicate bribery.
Imerys has adopted a robust Antibribery Compliance Program to deter, detect, investigate and remediate bribery incidents or allegations in compliance with the requirements of the French Sapin II Law.
The program is defined in the Group Antibribery Policy. It provides definitions of bribery and influence peddling, a list of prohibited behaviors per business process, a description of the Imerys antibribery compliance program (governance, main antibribery controls, reporting and investigation of possible bribery).
Our Antibribery Policy is supported by internal procedures designed to enable employees to recognize, analyze and act upon situations entailing a risk of bribery. This includes procedures on gifts & hospitality, conflicts of interest, donations and intermediary due diligence.
Imerys is committed to full compliance with antitrust laws and regulations in all Group businesses and countries where it operates. Imerys firmly refuses to win business or maintain any customer relationships by competing unfairly.
To respect this commitment, Imerys implements a comprehensive antitrust compliance program to prevent, detect, report and sanction potential antitrust law violations. It is defined in the Group Antitrust Policy. This policy also details antitrust law rules applicable to Imerys’ business and provides practical guidelines to employees to help them act in compliance with antitrust regulations at all times.
As a leader of the mineral based specialties for industry, Imerys interacts with various stakeholders in countries where it operates. Imerys believes that its engagement with public authorities can play a constructive role in the public decision-making process.
Imerys is committed to ensure that its lobbying activities and the representation of its business interests, in particular through its memberships in selected professional associations, are carried out with integrity, transparency and compliance with laws and regulations.
Imerys is committed to ensuring that its operations effectively comply with applicable international sanctions when conducting business around the world. Its internal International Economic Sanctions Procedure requires sales and purchase teams to carry out careful reviews before accepting a customer order or placing a purchase order, making sure that commercial transactions with Imerys are not made with prohibited countries, in prohibited areas of business, involving prohibited products, or benefiting blacklisted individuals or companies.
Imerys’ Duty of Care Vigilance Plan details the measures in place within the Group to identify and prevent severe impacts on human rights, fundamental freedoms, human health and safety, and the environment resulting from the activities of the Group and those of its subcontractors and suppliers, in line with the French Law on Devoir de Vigilance.
The Vigilance Plan is published annually and available as part of the Group Universal Registration Document.
Imerys respects privacy and values the trust any employee or stakeholder places in the Group when they share their personal data with us. Protecting the confidentiality, availability and integrity of personal data is an essential responsibility that Imerys takes seriously at all times. Click here to learn more on the processing of personal data by Imerys.
If you have any questions relating to the processing of your personal data by Imerys or want to exercise one of your personal data protection rights, please contact us via the contact form or use the following contact details (by email: dpo@imerys.com ; by letter: Data Protection Officer, Imerys SA, 43, quai de Grenelle, 75015 Paris, France).
