Anti-corruption laws exist throughout the world: as Michel Sapin, former Minister of the Economy and Finance, put it: “trade flourishes where corruption is in retreat”.
Corrupt acts are totally contrary to the values of the TF1 group, and to the ethical principles we wish to promote. We do business with integrity and transparency, and remain alert to any risk of corruption. This means deploying anti-corruption measures to sensitise our people and warn them of the risks, including our Anti-Corruption Compliance Program (and associated procedures) and our Corporate Affairs Charter.
Consequently, any executive officer or employee must refrain from any practice, nationally or internationally, that allows them to be corrupted or that corrupts a private individual or public official, whether directly or through an intermediary. They must also prohibit their subcontractors or co-contractors and any other partner from engaging in corruption or committing offences bordering on corruption (influence-peddling, favouritism, misappropriation of resources, money-laundering, etc).
All the choices and decisions made by our executive officers and employees must serve and uphold the higher interests of the TF1 group over and above their own personal interests, or the interests of their close associates (family, friends, relations, networks, etc). So our Conflicts of Interest Compliance Program (and the associated procedures) require each of them to declare, with full transparency and without delay, any personal circumstances that could bring them into conflict with the interests of the Group, so that any appropriate measures can be taken.
The countries where we do business have adopted laws to protect consumers by imposing fair competition in terms of pricing, product choice and innovation in each market.
It is important for us that in every market where we operate, the way we do business complies with fair competition rules. That’s why we set our prices and our terms and conditions of sale independently in light of our costs, market conditions, and the competitive environment.
Because doing business fairly is essential, we run a Competition Compliance Program, calling on all our executive officers and employees to refrain from anti-competitive practices (mainly collusion and abuse of market dominance, but also any other practice that breaches competition law), and to ensure that all the people we do business with make a contractual commitment to do likewise.
The main thrust of Corporate Affairs is to help regulators better understand what we do and the challenges we face, so as to create the best possible conditions for our long-term business development. This also feeds into dialogue with other players in our ecosystem (such as trade bodies and international organisations), raising their awareness of the risks and challenges facing the media industry as a whole.
That’s why we’re committed to contributing transparently, constructively and with integrity to debates and thinking around the drafting of legislation, regulations and public policy which affect what we do, by giving our opinion and bringing our technical expertise to bear.
In addition, our employees are free to participate in civic and political life outside of their contract of employment, but strictly in a personal capacity and at their own expense. The TF1 group is committed to strict impartiality and to respecting pluralism of political, religious and other beliefs.
For a listed company, compliance with stock market legislation and financial transparency are important factors in building trust among investors in the financial markets, and in cementing our financial reputation – essential for maintaining confidence in TF1 shares, supporting our share price, and giving us the ability to raise capital when we need to.
So, as a company listed on the stock market (on NSY Euronext), we have developed our Stock Market Legislation Compliance Program, which requires each of our executive officers and employees to comply strictly with current stock market regulations – especially those issued by the AMF (the French financial markets authority).
Compliance with international sanctions and embargos is an essential part of our business ethics at the TF1 group, in line with the principles set out in our Code of Ethics relating to respect for the law, and to integrity and honesty in how we do business.
Generally speaking, we take account of embargo and export risks when doing business, especially in terms of international strategy and expansion. This is supported by our Embargos and Export Restrictions Compliance Program, designed to help our executive officers and employees avoid any breach of economic sanctions, embargos or export restrictions.