Code of Ethics andBusiness ConductCEBCAmadeus Group June 2019 - PDF document

1 1 Code of Ethics andBusiness Conduct(CEB
1 Code of Ethics andBusiness Conduct(CEBC)Amadeus Group June 2019 Code of Ethics and Business Conduct (CEBC) 2 Money Laundering and Countering Terrorist Financing Safeguarding Information, Personal Data and CondentialityRelations with Third PartiesHandling of Company Property, Equipment, and InstallationsAppendix A: Amadeus Group Decision Tree 3 based on the following values: Customers First, Working Together, Taking Responsibility and Aiming for ExcellenceThe CEBC reects who we are and how we conduct our community and our professional integrity as a business professional behavior and how we treat one anotherguides our relations with stakeholders, our condu

2 ct in the communities in which we operat
ct in the communities in which we operate, and our eorts to contribute to a healthier, cleaner and more sustainable which we operate is therefore not enough Rather, we strive recognized for our practices and programs in corporate governance, social responsibility and environmental Following the spirit and the letter of this Code of Ethics and Business Conduct helps us sustain our market leadership It is, therefore, the responsibility of each and every one of us to know and live the values and provisions of this Code, and to make it the basis of what we do, every day, We strive to adhere to Therefore, protecting We believe in equal and all discrimination base

3 d on gender, race, ethnic origin, morals
d on gender, race, ethnic origin, morals, age, disability, state of health, sexual orientation, We are committed to helping all employees nd a healthy work-life balance We respect the privacy and integrity of all stakeholders, whether internal or externalrights and expects all its providers, third party contractors treatment of employees 5Beyond Compliance we must do our part to build a healthier, more sustainable We are committed to reducing the overall industries we serve take the important steps forward to reducing carbon emissions and other forms of pollutionIn addition, through innovative products and services, we safety, labor, discrimination, insider tra

4 ding, taxation, data privacy, competitio
ding, taxation, data privacy, competition and anti-trust, the environment, public Compliance alone, however, is not enoughthe values and principles set forth in this Code, we are guided by the highest ethical standards and are rmly committed to excellence in the elds of corporate governance, social Terrorist Financing We expect employees to honor the trust placed in them by acting at all times with personal and professional integrity Employees competing professional or personal interest put in question the impartial fullment of professional duties Employees resources of Amadeus, to obtain benets for themselves, To protect our reputation and in

5 tegrity, members of the Amadeus communit
tegrity, members of the Amadeus community should take all possible steps to avoid requests for proposals (RFPs) with the greatest possible openness and transparency, and, if necessary, recusing or connected third party has a stakeDecision Tree in provides further guidance on how Amadeus employees should not solicit, accept, promise, or oer gis, invitations, or entertainment from or to customers, employee receiving a gi, invitation, or entertainment that could be seen as not meeting the above criteria needs to promptly inform her or his supervisor Please refer to the Gis If in doubt, employees should always Ethics Committee for this Code We comp

6 ete on the basis of its employees will p
ete on the basis of its employees will pay or promise to pay government ocials, to win new business or to keep existing business Please refer As part of its global anti-corruption eorts, Amadeus is committed to conducting its business professionally, fairly and ethically, and in full compliance with anti-money laundering of the proceeds of criminal activity, for instance by setting Terrorists use techniques like those of money attitude towards money laundering and aiding terrorist nancing in all forms Employees can help protect the integrity and reputation of Amadeus by detecting and reporting If in doubt, employees member of the Ethics Committee for

7 any questions related to conducting it
any questions related to conducting its business professionally, fairly and ethically. depends critically on the safe, processing of sensitive information. Professional handling of information is our businesssafe, secure, reliable, and ecient processing of sensitive information, including passenger data and other information Such information specic guidance, please refer to the Amadeus Group Data Amadeus and its employees acquire information about our information is condential and may not be used outside the Amadeus employees will also from time to time be privy to internal information that is considered condential Employees should make all rea

8 sonable eort and take all reasonabl
sonable eort and take all reasonable precautions to protect such information and to ensure that it with policies issued by the Group from time to timerefer to the Information Classication and Handling PolicyCondential information includes, but is not limited to, the Group’s nancial information, including prots, budgets, targets, and forecasts; commercial agreements, project progress, investments or divestments; information information about the Group’s intellectual property; and personal information about employees, including health, performance assessment, and remunerationSafeguarding Information, Personal Data, Besides c

9 ustomers and suppliers, Amadeus and its
ustomers and suppliers, Amadeus and its employees Building and maintaining positive stakeholder Employees always represent Amadeus, directly and indirectly, The most important principle for relations with third parties is therefore the protection of Amadeus’ reputation, integrity, Accordingly, employees shall not engage in any conduct that could put any customers of competitors, Amadeus employees should use utmost discretion to ensure that no condential information is In particular, employees should never communicate formally, informally, or hypothetically – with a competitor regarding a competitive matter, including discussing pricing, functionalit

10 y, marketing programs, or service featur
y, marketing programs, or service features except approved in advance by, the Group Legal DepartmentEmployee participation in courses, classes, seminars and similar business events as lecturers, conference speakers, organizers or moderators, requires approval from an Amadeus Group Vice Presidentseminar, it will request approval from the employee’s of activity may be aectedthe employee must avoid making statements or Relations with Third Parties positive stakeholder relations accessible manner. Code of Ethics and Business Conduct (CEBC)11 condential information of the Group or its customersThe employee must avoid making statements or expressing con

11 dential information of the Group or its
dential information of the Group or its customers in chat sites, community forums and other websites and web pagesAs a processor of vast amounts of information, Amadeus occasionally receives requests for information provision or cooperation from public authorities or law enforcement bodiesTo ensure proper compliance with all applicable laws and provisions, such requests must be handled according to the centralized procedure put in place for the entire Group, under The same applies to public information requests regarding nancial, tax, or human resources data, in which case the Finance and Human Resource Departments will provide relevant guidance Code of Ethics

12 and Business Conduct (CEBC)12 The Group&
and Business Conduct (CEBC)12 The Group’s relations with the media is the responsibility of the Corporate Communications Department, except for will keep the Corporate Communications Department duly informed Only select, authorized employees are permitted Therefore, any call, request for information or other contact from the media must be passed Similarly, before contacting a member of the media in a professional capacity, employees must request prior authorization from The following senior executives may have direct relations Corporate Communications Department: the Group’s CEO, the designated by the CEO as well as the General Managers of only applies to

13 matters concerning the Company for whic
matters concerning the Company for which Handling of Company Property, Amadeus provides its employees with resources to carry out each employee to treat Amadeus property, equipment, and Handling of information technology equipment, such as Employees must ensure of the Amadeus IT infrastructure or information contained Please refer to the applicable Information Security policies for further informationAmadeus recognizes that employees occasionally employ company IT equipment for non-work- related purposes and To ensure that sensitive information and systems remain secure, employees must at all times apply the same safety and security procedures for their personal

14 and o-site use of company IT equip
and o-site use of company IT equipment as are mandated for work-related, of the Amadeus community, not just of the Information 14 This Code is binding on all employees of the Amadeus Group, Directors, and forms part of their employment relationship In addition to direct employees of the Amadeus Group, this of subcontracted people who render their services for an Amadeus Group Company through another company, It is the responsibility of each and every Amadeus employee to know this Code of Ethics and Business Conduct, strictly adhere to its provisions, and to promote this Code in their daily professional activities All employees will be oered Violations of

15 this Code may result in disciplinary I
this Code may result in disciplinary If any of the provisions of this Code infringe upon or conict with applicable local legal provisions, laws, or regulations, then such local provisions, laws or regulations, However, all employees should provisions of this Codeon an on-going basis and to refer any questions or doubts to their respective Amadeus Group VP or Director, or Group Amadeus provides dedicated, condential channels through which employees Please refer to the Speak-up Policyand every Amadeus employee to know this Code of Ethics Code of Ethics and Business Conduct (CEBC)15 or adverse consequences for any individual who, in good faith, Taking or

16 threatening to take An Ethics Committee
threatening to take An Ethics Committee has been formed to address concerns well as assist in issues brought forward by employees of corporate governance, social responsibility and for a brief description of the Ethics Committee Appendix A: Amadeus Group Decision Tree Do not proceed! If unsure seek guidance from a qualied member of the Legal DepartmentDo not proceed! If unsure seek guidance from a supervisor or a member of the Ethics CommitteeDo not proceed! If unsure seek guidance from a supervisor or a member of the Ethics CommitteeDo not proceed! If unsure seek guidance from a supervisor.Do not proceed!Go ahead! The Courtroom TestIs it legal in all a

17 ected jurisdictions?Would you be confort
ected jurisdictions?Would you be confortable telling a colleague, a Would Amadeus be confortable if it appeared do? Will it be seen as the right thing?The Values TestThe Family TestYesYesYesYesYesThe Headline TestThe Virtue Test Terms of Referencea key element of its corporate governanceand Business Conduct (CEBC) summarizes the professional conduct Amadeus expects from its employeesClearly, we anticipate that line management will bear primary responsibility for ensuring ethical business conduct by the Amadeus community, with support from HR, Legal, Risk & We encourage However, we also recognize that some matters eectively through an independent channelWith th

18 is approach in mind, Amadeus Executive M
is approach in mind, Amadeus Executive Management from various sites and regions, which is empowered to oversee compliance with the CEBC and other laws, policies, rules and regulations that set the framework for ethical This independent body provides support to all stakeholders, as we work toward our common goal of fostering ethical business behavior on a condential basis, and (ii) issues may be submitted by employees anonymously, if requested, provided local laws An employee may also request that an issue be dealt with without revealing that employee’s name and the Amadeus may be obliged by law to provide information Code of Ethics and Business Conduct (