Legrand's Compliance Business Ethics Program

Legrand’s compliance program focuses on four key pillars that support the fundamental principles and form the framework for Legrand’s social responsibility. Legrand’s employees and sales/supplier partners are expected to be familiar with the principles of this program and to be vigilant and active in adhering to it.

Corruption

Corruption is a form of dishonesty committed by a person in a position of power, often to gain personal advantage.

  • Avoid offering, giving, receiving, or soliciting, directly or indirectly, anything of value to influence the actions of another party.
  • Accepting gifts, entertainment, and other business favors can create the appearance of a conflict of interest. Report all gifts, meals, travel, and entertainment received from customers or competitors valued at more than $100 to your controller so it can be recorded in the compliance register.
  • Side jobs and certain activities outside of work may potentially conflict with your responsibilities to Legrand. Report any possible personal conflict of interest on the disclosure form available from your HR administrator.
  • To avoid misunderstandings, ensure that business meals are reasonable and proportionate to the size of the business account.
  • Document all discounts and rebates offered. Never make payments that could be interpreted as bribes, even if they are customary in the country where business is being conducted.

Fraud

A deliberate act using deception to obtain an unlawful or illegal advantage

  • Avoid any act, omission, or misrepresentation that knowingly misleads to gain financial or other advantage.
  • Fraud and money laundering are strictly prohibited.
  • Ensure all travel expenses are pre-approved. Make sure expenses are reasonable, directly related to business activities, and supported by proper documentation.
  • Never cooperate with external third parties attempting to illegally obtain Legrand’s properties, whether financial resources or intellectual property.

Embargoes

The United Nations Security Council, the U.S. government, and the European Union impose financial and economic sanctions on certain individuals, companies, and countries.

  • Avoid doing business with entities in countries subject to financial and economic sanctions.
  • Before doing business with a customer in a new country, check if the country is on the Legrand Group’s embargo list.
  • Ensure all customers and suppliers are screened through the World-Check One database.

Competition

Any violation of competition law (antitrust), whether voluntary or involuntary, has the effect of disrupting or reducing competition in a particular market and is prohibited.

  • Avoid agreements with competitors on pricing or markets.
  • Avoid exchanging information with competitors.
  • Where possible, avoid exclusive distribution agreements.
  • Avoid agreements with competitors to exclude other competitors from opportunities or to boycott suppliers or other third parties.

ETHICS MAILBOX

Employees, suppliers, and customers are encouraged to report illegal or unethical behavior through Legrand’s reporting portal.