Compliance Ethics and Commitment
"We know Business"
Our commitment to ethics and compliance checks is communicated widely and regularly in many sectors — and is an essential aspect and core value of how we conduct our business.
· A comprehensive compliance governance structure
· The First Edge Code of Conduct
· Policies, procedures and controls
· Monitoring and auditing practices
· An annual compliance risk assessment (with related mitigation plans and
· processes for continuous improvement)
· Ethics and compliance communications focusing on maintaining logistics
· Keeping clients Updated on any new banking resolution process
We continued to implement our zero-tolerance policy last year, requiring 100% integrity in all business practices. Management expects all employees to comply with applicable legal and company requirements. Any identified violations are addressed swiftly, consistently and fairly. We also furthered our phase-out of sales agents and consultants — a mandated process initiated in 2008. Alcatel-Lucent has not engaged a new sales agent or consultant since 2009.
The status of the zero-tolerance policy is reviewed regularly at the highest
levels of the company, including review by the Ethics & Compliance Council and
the Board of Directors.
Our anti-trust law policy and guidelines for most companies are readily available through most company regulations. When in doubt, they are urged to consult the Law Division to ensure their activities comply with competition/anti-trust laws.
Suppliers and contractors from whom we consult on goods and services are also
required to comply with our compliance ruling. To enforce this obligation, we
have the right to conduct an audit confirming compliance. Any knowledge or
reasonable suspicion that an anti-trust violation has occurred will be reported
to relevant authorities. In case of a violation of such laws, we may terminate
our service immediately in case of any further violation.