LEGAL TERMS

Under Article 6 of Law No. 2004-575 of June 21, 2004 on confidence in the digital economy, users of the airtelis.com site are informed of the identity of the various parties involved in carrying it out. and its follow-up:

Airtelis is the property of :

Airtelis
A simplified joint-stock company with a capital of 10 000 000 € – RCS Avignon
SIRET n°532 602 265 00029

Head office address :
1470 Route de l’Aérodrome – CS 50146
84918 AVIGNON Cedex 9

Airtelis owns the intellectual property rights or holds the rights of use on all the elements accessible on the site, in particular the texts, images, graphics, logo, icons, sounds, software.

Any reproduction, representation, modification, publication, adaptation of all or part of the elements of the site, whatever the means or process used, is prohibited without the prior written consent of Airtelis.

Any unauthorized exploitation of the site or any of the elements it contains will be considered as constituting an infringement and prosecuted in accordance with the provisions of articles L.335-2 and following of the Intellectual Property Code.

Azuracom, agence Interactive
Creation site internet
84 avenue Victor Basch 84300 Cavaillon – France.

Julien BOTELLA

The present guidelines have been drafted and approved by Airtelis’ Personnel. The purpose of this code is to meet with a legal requirement and the desire of Airtelis to promote good professional conduct in its activities and to participate in the prevention of corruption and fraud.

This code of conduct is all the more important in view of the international nature and the scope of the company’s activities. The company must promote the same ethical values ​​in France as well as abroad and it is in this spirit that this code was written.

The main values ​​of Airtelis are openness, team spirit and excellence.
In the fight against corruption and fraud, and more generally in its good commercial conduct, the company is committed to promoting other values ​​such as transparency, independence, integrity, compliance with laws and regulations , respect and equal treatment.

The rules of this code apply to Airtelis staff members but also to its corporate officer, managers, temporary staff members from RTE, interns and agency workers. These categories are hereinafter called “staff members”.

In addition, this code of good conduct must be made available to Airtelis’ partners and suppliers, who sign a letter of commitment guaranteeing that they respect the same principles.

1. Compliance with legislation: Airtelis staff members agree to comply with applicable legislation, whether that applicable in France or that of the country in which they carry out assignments on behalf of the company. They thus comply with specific local safety instructions when carrying out their professional activities on French and foreign sites. Staff members certify that they have read the provisions of this code of good conduct and that they apply its rules and principles in all circumstances. They adhere to the values promulgated by it and, more generally, to the company. When they represent Airtelis in the context of their work or their mission, they undertake to transmit them.

2. Airtelis ethical commitments: The company undertakes to treat its suppliers, customers and partners in a neutral and equal manner in its commercial conduct and the delivery of services.

It also undertakes to conduct business with integrity, making itself clear, honest and available to its partners.

Airtelis staff members must ensure that they maintain professional behavior in all circumstances.

3. Good conduct in a French and international commercial context

3.1. Local customs: As part of their missions abroad, Airtelis’ staff members are aware that they represent the company and act accordingly, in accordance with the principles promulgated by the company. They must ensure that they maintain good professional behavior and dress in accordance with local safety standards and practices. Staff members also agree to behave respectfully towards local customs; to this end, they have the duty, before leaving, to inform themselves as much as possible about local customs, so as not to commit harmful prejudices by simple negligence. However, this commitment should not prevent them from showing adequate confidence in local measures against corruption habits. The same rules and prohibitions on fraudulent practices must be applied in France and abroad, which requires adaptability and reflection in the face of local customs.

3.2. Transport of data and equipment: Airtelis staff members have equipment and access to confidential information, documents and data which must not be loaned, rented, sold or even disclosed unless expressly stipulated in a contract. It is important that they do not transmit them outside of a specific contractual framework. Otherwise, such a transmission could be detrimental to Airtelis, and the person at fault would be required to compensate; such a transmission could also be considered as an act of embezzlement by the person at fault (if the transmission creates personal gain for the person at fault). Airtelis’ staff members must ensure that, when traveling abroad, they take for their mission only the strictly necessary internal documents (organizational notes, studies, procedures). These documents must not be left unattended in a public or private place not belonging to Airtelis. In case of doubt about the attitude to adopt, the member of staff is required to contact the Chief Executive Officer.

4. Implementation of a program to prevent and detect corruption

4.1. Corruption relates to a genuinely criminal conduct in which a person (the corrupt) solicits, approves or accepts a gift, an offer or a promise, gives gifts or any advantages in order to accomplish, delay or omit to perform an act which falls directly or indirectly within the framework of his functions. In France, corruption is punishable by 10 years’ imprisonment and a fine of € 1,000,000 (article 433-1 Criminal Code).

4.2. Fraud: Fraud refers to any dishonest act done with the intention of deceiving by breaking the law or regulations (internal as external to the company) in order to obtain an illegitimate advantage. The fraudulent acts included in this definition can consist of different practices: extortion, blackmail, embezzlement, money laundering, tax fraud, influence peddling […]. This list is not exhaustive. Under French law, these practices are punishable by 3 to 5 years’ imprisonment and fines up to € 375,000.

4.3. Prevention against fraud and corruption: Airtelis has a “zero tolerance” policy with regard to corruption and fraud. Airtelis staff members undertake to comply with the legislation in force on fraud and corruption in order not to commit an act liable to be personally condemned, to have the company condemned or to cause the Company damage by illegal acts. In addition, the company undertakes to prosecute anyone guilty of fraud or corruption. Consequently, any member of the personnel found guilty of such acts shall be liable to the corresponding criminal sanctions and prosecuted in civil matters for any damage caused to society. In order to ensure honest commercial conduct, Airtelis also undertakes not to conclude any agreement with a French or foreign company or a public organization found guilty of corruption or fraud.

4.4. Gifts and invitations: Airtelis’ staff members are particularly vigilant with regard to gifts which may be offered to them or offered as part of their professional activity by customers, suppliers, service providers and other partners, directly or indirectly (through a third party). Gifts can take various forms (offers of goods or services, promotional offers, discounts on the price of goods and services, including travel, hotel stays, meals, shows, receptions, plane tickets or tickets to cultural or sporting events). Gifts should not influence, or even appear to influence, staff members’ business decisions.
Otherwise, accepting a gift can be considered an act of corruption. Gifts are tolerated if they are of low value and if they are not recurring. Any gift offered in the form of a sum of money must be refused. Staff members must inform the Chief Executive Officer of the gifts they receive when they are worth more than € 80.

4.5. Conflict of interest: A conflict of interest is any situation of interference between a public interest and public or private interests which is likely to influence or appear to influence the independent, impartial and objective exercise of a function [law of 11 October 2013 on transparency in public life]. Airtelis’ staff members are committed to maintaining the most professional and neutral attitude possible in order to prevent situations of conflict of interest. In addition, they have the duty to alert the Chief Executive Officer of situations in which they detect a possible conflict of interest, in order to discuss an appropriate solution to avoid harmful consequences.

4.6. Alert system: All Airtelis staff members have the duty to alert their superiors or, if the superior is involved, a competent authority, when they witness an act of corruption, fraud or any other illegal act or non-compliance with the content of this code of conduct, or an act which they consider to be unethical. To do this, Airtelis is part of the alert system set up by its parent company RTE.

For all reports:

– A dedicated platform: https://www.bkms-system.com/rte-signalement, by phone: 01.41.02.17.67 or by letter (in a double envelope for RTE- Attention: O. Herz).

– The “Sapin 2” RTE-referent (O. Herz) receives the alert, acknowledges with a receipt, communicates the deadline for examining its admissibility (<15 days) and the procedures for information follow-up

– Respect of the anonymity of the whistleblower and persons implicated.

– Destruction of all of investigation data within 2 months (may be extended in the event of disciplinary proceedings, police or judicial investigation).

– No legal proceeding or discrimination of any kind may be brought against a person who alerts his superiors or the competent authorities on one of the points concerned by this code of good conduct, whether or not his alert resulted in an investigation or legal procedures. His anonymity is guaranteed by the company. This last provision does not apply in the event where this person abuses of his whistleblower status, for the sole purpose of harming a person or the company.