In an increasingly complex legislative and regulatory context and a changing professional environment, compliance plays an ever-important role in the business world.
We commit to conduct our activities and pursue our commercial objectives in accordance with the law and the highest ethical standards. To this end, the Proximus Group has adopted a Code of Conduct and established a compliance policy.
The Code of Conduct is dedicated to the values and identity of the Proximus Group. It aims to inspire the attitudes and behavior of Proximus Group employees in their daily activities. The general principles defined in the Code of Conduct – which are therefore not exhaustive – are set out in detail in several specific regulations which form a supplement to the Code of Conduct on specific issues and which must be observed by all Proximus Group employees.
Besides the Code of Conduct, the Proximus Group has a compliance policy which aims to promote, at all levels, ethical conduct, respect for values, and compliance with laws and internal and external regulations; to prevent illegal or unethical behavior; and to ensure an appropriate response in case such behavior should occur.
The Compliance Office is responsible for coordinating compliance activities within the Group (explaining the current rules, providing the necessary tools to encourage compliance, and ensuring a coherent approach to compliance).
Proximus Code of conduct
The new revised version of the Code of Conduct is available below. It replaces the Proximus Code of Conduct dated December 2009. It is applicable to all operations and employees of the Proximus Group.
The Proximus Code of Conduct reflects the fundamental principles and rules which form the basis of our commitment to being a socially responsible company. We believe that strong results have to be accompanied by integrity if we want to contribute to the economic, social and environmental development of our society. Ethical conduct does not limit itself to the compliance with the text of this Code of Conduct. It is a summary of the most important principles, and is thus non exhaustive. The principles and rules it contains are developed in greater detail in several internal policies and procedures.
Here are a few examples, chosen for their importance and general field of application.
The Dealing Code
This regulation aims to prevent insider dealing and market manipulation. It sets out the specific rules to be respected by Proximus Group directors and employees who wish to carry out stock-exchange transactions involving Proximus shares or shares of other telecom companies.
The regulation on Chinese Walls and competition law
This regulation aims to ensure compliance within the Proximus Group with the rules that seek to maintain healthy competition between telecom operators. Firstly, it insulates wholesale activities from retail activities. Indeed, given its historical position on the telecom market, Proximus is required to provide access to its network to other operators wanting to offer telecom products and services in Belgium. We have therefore concluded interconnection agreements with other operators and offer wholesale products and services. This inevitably gives us access to information on the traffic routed via our network and on the products and services offered by the other operators. This information, obtained in the framework of our wholesale activity, cannot of course be used to boost our retail activities in any way. This is why a Chinese wall exists between the wholesale information and the retail units. The regulation describes how this Chinese wall is organized. Secondly, the regulation aims to ensure compliance with the general rules of competition law, both at a Belgian and European level. This part of the regulation concerns all employees with decision-making powers who maintain relations with the competition, customers, or suppliers, or who come into contact with them.
The regulation on Proximus’ regulatory framework
As an autonomous public-sector company in the telecom sector, we are subject to many laws, notably the Law of 30 June 2005 transposing the European framework relating to electronic communication. The regulation dedicated to this regulatory framework sets out the rights and obligations of the Proximus Group in this area. It is of crucial importance that these rules be complied with by all Proximus Group employees.
The regulation on Anti-Bribery Policy and conflicts of interest
In the exercise of their jobs or in their private lives, Proximus Group employees may face situations in which their personal interests are in conflict with those of the Proximus Group. The regulation on conflicts of interest gives an overview of such situations, provides guidelines on how to recognize and avoid them, and defines the rules which should be followed in case such a conflict arises. The basic principle is that employees must always act in the interests of the Proximus Group. It is especially important that this principle be observed in the relationships with our suppliers. It is essential that suppliers who compete with each other to enter into a commercial relationship with the Proximus Group, can rely on the integrity of the selection process.
The anti-bribery policy implements the following principle set out in the Code of Conduct of the Proximus Group:
We are aware of the importance of fair business. We do not tolerate any conflict between personal and business interests. We do not tolerate practices such as corruption and bribery.
The regulation on the protection of privacy
The respect of the secrecy of telecommunications and the privacy of our customers is not just a legal obligation, it is also the determining factor for earning and keeping their trust. The regulation on the protection of privacy contains instructions intended to protect the secrecy of telecommunications and to ensure that personal data included in databases are processed in accordance with the legal requirements.
The regulation on the environment
We embed green sustainability in all our business decisions, and make sure we use technology and
innovation to the benefit of the environment. We have thus defined an environmental policy and translated it into a regulation.
Our Code of Conduct and values & behaviors are in fact inspired by fundamental principles such as those of the Universal Declaration of Human Rights adopted by the United Nations, the European Convention on Human Rights, and the United Nations Convention on the Rights of the Child.
As mentioned in our Code of Conduct, the Proximus Group bans any kind of corruption. Many internal regulations deal with these problems, in particular our regulations regarding the Proximus Group’s relations with public or political authorities, our regulations regarding conflicts of interest which, moreover, include compliance with certain rules concerning presents and hospitality, and finally our regulations on purchasing which cover our relations with suppliers. We also developed an ethical charter which has to be accepted by all our suppliers.
Compliance Office’s mission
The Compliance Office's mission is to give concrete shape to the Proximus Group's compliance policy. This aims to promote, at all levels, ethical conduct, respect of values and compliance with laws and internal and external regulations, prevent unlawful or unethical behavior and ensure an appropriate response in case such behavior does manifest itself.
To increase the visibility of the compliance strategy, the Compliance Office focuses its efforts on the following:
Clarity, accessibility and coherence of the rules
The Compliance Office aims to continuously improve the wording of the rules that apply within the Proximus Group in order to make them clearer, simpler and more understandable. It endeavors to make it easier to access the various regulations and to ensure that the different internal regulations form a coherent whole.
Knowledge of the rules
The Compliance Office organizes communication and training initiatives (manuals, e-learnings, posters, etc.) to ensure that the players in the field know the internal and external rules that apply to their activity and to help them translate these rules into appropriate procedures and behaviors. The Compliance Office updates these rules and procedures every year.
Management of the risk of non-compliance
On the basis of a periodical, systematic assessment of the risks of non-compliance in the whole Proximus Group, the Compliance Office works out prevention strategies in collaboration with the entities concerned.
Intervention in case of non-compliance
Finally, the Compliance Office intervenes if a situation of non-compliance arises (see below: alarm bell procedure).
Compliance Office’s governance
The Compliance Office is headed by the Director Audit Risk Management and Compliance, who reports directly to the Chief Corporate Affairs Officer and is directly accountable to the Chairman of the Audit and Compliance Committee. This committee assists and advises the Board of Directors within the framework of monitoring the company’s compliance with the legal and regulatory requirements and the Code of Conduct.
The Proximus Group has set up a “whistleblowing procedure” which enables its employees or external parties to report any breach of the Code of Conduct, the laws, regulations, the internal policies and procedures, confidentially, via one of the following channels:
whistleblowing mailbox: email@example.com
whistleblowing hotline (24h/24h – 7 days a week):
- From Belgium: 0800 45002
- From abroad: +32 (0) 800 45002
(ensure you indicate CONFIDENTIAL on the envelope)
- Proximus Group Compliance Officer:
Bruno de Hemptinne, Proximus - Group Compliance
27 Boulevard du Roi Albert II
B 1030 Bruxelles
- President of the Audit & Compliance Committee:
Catherine Vandenborre, Proximus – President of the Audit & Compliance Committee
27 Boulevard du Roi Albert II
B 1030 Bruxelles
by setting up a meeting with the Proximus Group Compliance Officer
- By phone by dialling: +32 485 74 32 63
- By email: firstname.lastname@example.org
Proximus does not allow retaliation of any kind against those who, in good faith, report an infringement or suspicion of an infringement of the rules or guidelines.
Scene 1: Whistle-blower in his car on his way to work. Whistle-blower parked his car in the car park. Proximus considers integrity as one of the corner stones of its DNA.
Scene 2: Whistle-blower notices an astonished work controller watching a worker on a ladder in a wheelbarrow. The boss of the worker is giving cash to the controller and tells him to keep quite about it. You notice wrongdoing or breaches of the Code of Conduct, internal policies and procedures, laws and regulations?
Scene 3: Whistle-blower notices a colleague at a restaurant with a partner. The colleague is being offered plenty of food and wine in front of him.
Scene 4: The same colleague (of the whistle-blower) is with another partner on a yacht and receives a big gift. The partner and the colleague agree on a contract. “Participating in” or “closing your eyes on” bribery may lead to disciplinary sanctions, dismissal and criminal prosecution.
Scene 5: The whistle-blower wants to escalate to N+1, but his N+1 is the colleague who happened to be the corrupt employee who went on the yacht and to the expensive restaurant during a bidding or proposal process in the previous scenes. Not appropriate to escalate to your manager? Use one of the whistleblowing channels!
Scene 6 : The 4 whistleblowing channels are showed:
send an email to email@example.com, make a phone call to the 0800 45 002, write a letter (physical paper with CONFIDENTIAL mentioned on the envelope), meet physically with the Compliance Officer
Scene 7: Compliance Officer and Investigations Manager discuss the case (confidential file on desk with CONFIDENTIAL in red) Your concern will be treated in the most confidential manner.
Scene 8: Animation where the whistle-blower receives an email (entitled “Acknowledgment of receipt”) If your identity is known, an acknowledgement of receipt will be sent to you within 7 days.
Scene 9: Compliance Officer, Investigations Manager, Head of Legal and HR gather in a meeting room. The screen shows “blacked name” of whistle-blower… entitled Whistleblowing Case Nr : WB#28 then with a few lines with Mr of who’s name has been made invisible reported concern …. The Whistleblowing Committee (Compliance, Investigations, Legal and HR) define the adequate measures to be taken regarding the case.
Scene 10: Animation where the whistle-blower receives an email entitled Acknowledgment of receipt. You will be informed within a timeframe of max 3 months following the acknowledgment of receipt about the action envisaged or taken as follow-up to the report.
Scene 11: Animation where co-workers run after the whistle-blower. Proximus does not allow retaliation of any kind against those who, in good faith, report an infringement or suspicion of an infringement of the rules or guidelines.
Final slide: Link to the procedure on the Compliance section of the Proximus.com website - Compliance | Proximus Group. Contact details for whistleblowing:
Email: firstname.lastname@example.org, Hotline: 0800 45 002, Hotline if you call from outside Belgium: (+32 800 45 002)
Speak up! Help us protect the Proximus Group!
Thanks to our certification in accordance with the standards ISO 9001, ISO 14001 and ISO 27001, we offer our professional customers ( Not for self-employed, liberal professions and small and medium-sized enterprises, +/- 200 employees) all the security and assurances they are looking for in terms of quality, information security and environmental requirements. From product development to complaints handling, quality is guaranteed in our processes. Proximus is also a reliable partner in the field of information security. Thanks to our environmental management system, our data centre operations (specifically for our Machelen datacenter) are fully compliant with the ISO 14001 requirements.
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For the Proximus Group, being a Belgian based company with affiliates operating in various countries around the globe, this includes the commitment to comply with U.S., U.N. and E.U. regulations on sanctions and embargoes.
Moreover, specific rules must be respected in terms of unauthorized reexport of goods, services, or technologies to countries or persons subject to export controls or economic sanctions, and not to take any action that assists targets of sanctions in evading or avoiding the lawful application of sanctions and export controls.
It is our policy to take all reasonable measures, including the procedures in this document, to detect and prevent violations of those export controls and sanctions that are applicable to our business operations.
The public affairs policy defines the responsibilities, principles and governance rules that apply to Proximus’ relations with public authorities.
Well-being is "feeling good at work" and is very important in our present-day society. It is obvious then that the Proximus Group should develop its activities with respect for all areas of well-being. We therefore regard the implementation of a well-being policy as an essential task that forms part of our general strategy and our company policy. After all, the well-being of every employee can contribute to the success of our activities and our company's performance.