Code of Ethics Us

7/29/2019 Code of Ethics Us

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CODE OF BUSINESS ETHICS

2007

THE WAY WE WORK


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CONTENTS

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THE LORAL SPIRIT

FOREWORDby Sir Lindsay Owen-Jones and Jean-Paul Agon

FOREWORDby the Management Committee

HOW TO USE THIS CODE

RESPECT FOR INDIvIDUALS, RESPECT FOR THE LAWAND RESPECT FOR LOCAL CUSTOmS

OPEN TALK

AS A BUSINESSProduct Saety and Quality

Accuracy in Financial and Business Records

Use o Company Resources

Condential Inormation

Representing the Company

Gits and Entertainment

Bribery and Facilitation Payments

AS AN EmPLOYERHealth, Saety and Security

Diversity

Harassment and Bullying

Sexual Harassment

Privacy

Conficts o Interest

AS A RESPONSIBLE CORPORATE CITIzEN

Political ActivitiesContribution to the Community

Environmental Stewardship

ADDITIONAL GUIDANCE FOR mANAGERSThe Managers Role

Advertising and Marketing

Insider Trading

Supplier Selection and Fair Treatment o Suppliers

Fair Competition

Tax


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1

At LORAL, w bliv tat vro aspirs to bat. Or missio is to lp m a wom

aro t worl ralis tat aspiratio, a xprss tir iivial prsoalit is to t fll. Tis

is wat ivs mai a val to or bsiss, a to t worki livs of or mplos. W

ar pro of or work.

AS A BUSINESS

Our strategy or leadership is based on continuous investment in rigorous scientic research and development. This enables our

brands to deliver products which are innovative, highly eective, practical and pleasant to use, and which are manuactured to the

most demanding standards o quality and saety. We aim or excellence, and constantly challenge ourselves and our methods.

We place great value on honesty and clarity; our consumer advertising is based on proven perormance and scientic data. We

are committed to building strong and lasting relationships with our customers and our suppliers, ounded on trust and mutual

benet. We do business with integrity; we respect the laws o the countries in which we operate and adhere to good corporate

governance practices. We maintain high standards in accounting and reporting, and support the ght against corruption. We

deliver long-term, sustained shareholder value by protecting and making the most eective use o company assets.

AS AN EmPLOYER

We aim to make LORAL a great place in which to work. We know that our employees are our greatest assets. They areentitled to a sae and healthy working environment; one in which personal talent and merit are recognised, diversity is valued,

privacy is respected, and the balance between proessional and personal lie is taken into account. We believe in oering our

employees a stimulating environment, exciting personal opportunities and a chance to make a dierence. We encourage an

atmosphere o openness, courage, generosity and respect, so that all our employees eel ree to come orward with their

questions, ideas and concerns.

AS A RESPONSIBLE CORPORATE CITIzEN

We play our part in creating a world o beauty and airness. We are mindul o our impact on the natural environment, including

biodiversity, and constantly seek to reduce it; we are determined to avoid compromising tomorrow or the sake o today. We makea positive contribution to the countries and communities in which we are present, and respect local cultures and sensitivities.

We are committed to the respect o human rights. We want to help end the exploitation o children in the workplace and the

use o orced labour. We want an end to animal testing in our industry, and we contribute to the development and acceptance o

alternative methods. We actively seek out and avour business partners who share our values and our ethical commitments.

Tis is t spirit i wic w oprat: t LORAL SPIRIT.

THE SPIRIT


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2

FOREWORDBY SIR LINDSAY OWEN-JONESAND JEAN-PAUL AGON

LORAL has been built around undamental values which have guided

us throughout the lie o our company, and continue to do so today. Our

values have shaped our culture, and they underpin our reputation.

For many years, we have passed them on through word-o-mouth.

But now that we are so many, present in an ever-growing number o

countries, we believe the time is right to bring our values together in

a single document: one which can both inspire us and bring us closer

together.

We live in rapidly changing times. It is no longer enough simply to share

common convictions. We need in addition to be able to express clearly,

through a new document, how we are living up to our responsibilities

in practice.

It brings our values to lie and it shows how they inspire and inorm the

decisions we make in our day-to-day work.

We all have a responsibility to ollow these rules o conduct which driveLORALs integrity and ethical standards. We are counting on each and

every one o you to respect them and to pass them on.

We believe that our commitment to live up to these powerul values,

and to demonstrate our high ethical standards in all that we do, will more

than ever ensure that LORAL is seen as an exemplary organization:

one which inspires trust and respect.

SIR LIndSAy OWen-JOneS JeAn-PAuL AgOn

Chairan Chief Executive Ofcer


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3

We are committed to bringing the LORAL SPIRIT to lie in our

day-to-day work. This is crucially important to the Companys

continued success.

That is why we have produced this code. Its aim is to help

everyone understand what is expected o us as LORAL

employees. It applies to us all, wherever we operate and

whatever our role whether we are junior sta or Company

directors.

Each o us and everyone in the Company, as ambassadors

o LORAL and as members o our community, makes a

personal commitment to ollow this code both in letter and

in spirit.

You should always remember that:

The values and guiding principles set out in this document

are not optional: you must respect them

You set the example: LORALs reputation is what you make it

You will be judged not only on what you do, but the way you

do it

Ethical questions are rarely easy, but must be addressed

We advise you not to keep such questions to yoursel: disclose

them and seek advice.

Integrity and respect are paramount to the way we work.

FOREWORDBY THE mANAGEmENT COmmITTEE

11 MARC MeneSguenPresidentLOral Luxury Products

6 PATRICK RABAInPresidentLOral Consumer Products

1 JeAn-JACqueS LeBeLPresidentLOral Proessional Products

8 JOChen ZAuMSeILManaging Director othe Asia Zone

9 JOSePh BITTOnManaging Director o theLatin America Zone

10 JeAn-PhILIPPe BLAnPAInExecutive Vice-PresidentProduction & Technology

12 ChRISTIAn MuLLIeZExecutive Vice-President

Administration & Finance

5 BATRICe dAuTReSMeExecutive Vice-PresidentCorporate Communications,External Aairs & Prospective

2 BRIgITTe LIBeRMAnManaging DirectorActive Cosmetics International

13 JeAn-FRAnOISgROLLIeRExecutive Vice-PresidentResearch & Development

4 geOFF SKIngSLeyExecutive Vice-PresidentHuman Resources

7 LAuRenT ATTALPresident and Chie

Executive OcerLORAL USA

3 JeAn-PAuL AgOnChie Executive Ocer

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4 THE WAY WE WORK

HOW TO USE THIS CODE

THE WAY WE WORK does not replace any existing policies,

and you should continue to reer to whatever rules andstandards have been set in your workplace. Instead, this code

aims to provide a ramework or these policies, so that it is

easier or you to understand the rationale behind them.

But, just as importantly, it is also a tool to help you deal with

any questions or dilemmas you may have concerning the way

we work.

O course, no document can anticipate and address every

situation that may arise, particularly since many ethical

dilemmas take place in grey areas, where the solution isnot readily apparent. So whenever you are aced with what

you eel is an awkward ethical decision, always ask yoursel

the ollowing questions:

1. Is it in line with the LORAL SPIRIT and THE WAY

WE WORK?

2. Is it legal?

3. How do y actions affect our arious stakeholders

and how would they react if they learnt about y

actions?

4. If I a not sure, hae I asked for help?

We recognise that some situations are not easy. When in

doubt, the ol rl is to isclos t mattr a to

iscss it opl.

Technical subjects are best directed to internal experts such

as Finance, Human Resources, Health and Saety, Legal and

Tax, Purchasing, and other departments.

q: dos tis ocmt appl to m?

A: All o us at LORAL can be aced with an ethical dilemmaduring our daily work; how we behave towards colleagues

and respond to their behaviour; how we deal with dicult

or awkward requests rom customers or suppliers; how

we resolve questions about the use o Company property.

Each o these has an ethical dimension. This code provides

useul, practical guidance on these and many other common

dilemmas which we all ace rom time to time.

The LORAL SPIRIT and THE WAY WE WORK are addressed

to all employees o the LORAL Group and its subsidiaries

worldwide. They also concern all Ocers and Directors o the

LORAL Group and its subsidiaries.

The Code o Business Ethics is currently available in 41

languages. The UK English version o this code is the reerence

document.

THE WAY WE WORK cannot in any way be understood as a

contract o employment or continued employment between

the Company and any employee. It is a code to acquaint all

employees with the Companys expectations.

The Company recognises that THE WAY WE WORK is not

exhaustive and that it may change rom time to time. The

Company reserves the right to change, modiy or correct

THE WAY WE WORK at any time, with or without notice, and

the right to take whatever action it deems appropriate in any

employment situation.


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THE WAY WE WORK 5

RESPECT FORINDIvIDUALSWe expect all employees and entities to work together in a

respectul and open manner. In this way, we will maintain a

culture o loyalty, trust and solidarity throughout our business.

We should all aim to give credit to other peoples ideas, and

recognise the contributions o others.

Teamwork is to be encouraged and successes, as well as

ailures, should be shared. We should listen with generosity

and share inormation as needed, subject to the Groups rules

on condentiality. Finally, disparagement o colleagues is

contrary to LORALs values.

RESPECT FORTHE LAWLORAL operates in many countries home to a wide variety

o cultures, laws and political systems.

As a basic rule, we as a business and as individuals in the

perormance o our duties, must always respect the laws o

the countries in which LORAL operates.

LORAL is particularly attached to the spirit and the letter o

laws governing:

Human rights; prohibition o child labour and orced

labour; discrimination; working time and remuneration;

employees collective representation

Quality, health and saety standards

The environment

Corruption and bribery

Taxation and the accurate communication o nancial inor-

mation

Fair competition

LORAL seeks to share these principles with its business

partners and to ensure, as ar as possible, that such partners

also respect these laws and regulations.

RESPECT FOR

LOCAL CUSTOmSTHE WAY WE WORK has been drated with the help o

LORAL employees across the world. We believe that its

core messages will be applicable throughout our operations.

We should ensure that, wherever possible, we conduct our

activities in a manner sensitive to the cultural and social

traditions o communities with which we come into contact.

There may be instances when the guidance in this code is at

variance with the local law or customs o a particular country.

I that is the case, then where local law requires a higher

standard than that set out in the code, local law should always

apply. I, by contrast, the code provides or a higher standard,

then it should supersede local law unless this results in

illegal activity.


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6 THE WAY WE WORK

OPEN TALK

LORAL coras a cltr of opss

wr mplos ca rais tir icocrs.

All employees are expected to take personal responsibility or

ensuring that our conduct complies with the LORAL SPIRIT

and THE WAY WE WORK.

We encourage all employees to air their views, deend their

opinions and signal unacceptable behaviours or demands.

We recognise that employees may have concerns about

certain practices and need advice and guidance to help resolve

them.

It is our policy that any concerns raised in good aith about

misconduct on the part o the Company or any o its employees

or business partners are thoroughly investigated, and that

appropriate actions are taken to deal with the outcome o that

investigation. Good aith means that you have provided

inormation that you believe to be honest and accurate at the

time, even i you are later proven to be mistaken.

We will provide eedback to the individual who has raised

the concern, to the extent that it is appropriate and can be

given without inringing legal requirements or other duties o

condentiality.

We will ensure a air process in case o an investigation and,

in particular, respect the principles o due process and the

presumption o innocence.

All inormation given in the course o an investigation will

be communicated on a need-to-know basis, and anyemployee raising such concerns in good aith will be protected

against retaliation. Full cooperation is expected during such

investigations.

The normal route or raising such issues is via your line

management. I or any reason you eel uncomortable

with this route, you should raise the issue with your Human

Resources Manager. There may also be additional resources

available in your country, such as sta representatives,

grievance procedures or a helpline.

I or cotr, it is t Cotr Maar

wo is ltimatl rsposibl for sri trspct of t LORAL SPIRIT a The WAy We

WORK.

I you have raised the issue locally and you are still not satised

with the answer you were given by local management, or

in the exceptional case that it is inappropriate to raise the

issue locally, you may contact the Group Director o Ethics o

LORAL as ollows:

wbsit: www.lorealethics.com

lttr: grop dirctor of etics, LORAL,

41, rue Martre, 92117 CLICHY, FRANCE

Plas ot tat wil w o ot proibit aomos

rports, w o ot cora tm. W bliv w offr

sufcient guarantees to make it unnecessary for an

mplo rporti a cocr i oo fait to cocal is

or her identity. It is also difcult to investigate a matter

torol if it is rport aomosl.


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LORAL 7

THE WAY WE WORK

AS A BUSINESS

We aim or excellence, and constantlychallenge ourselves and our methodsThe LORAL SPIRIT


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8 THE WAY WE WORK

Q: I work on the production line, and Ie noticed soe

defective nished goods, showing that one machineay be generating soe quality probles. I know were

supposed to stop production when that happens, but

y superisor has not taken any action. I know that the

production schedule is ery tight. Should I trust that she

knows what shes doing in ignoring it?

A: LORAL has put in place quality controls at each stage

o the manuacturing process to ensure that our customers

obtain the highest quality products. Quality comes rst,

regardless o production schedules. You should put that line

on hold without any hesitation, openly share the problem with

your manager, and work with her and the rest o the team to

x the issue, beore carrying on with production.

Q: We hae receied a report fro a supplier stating that

containation ay hae occurred in a recent shipent

of ingredients. The products containing the ingredients

hae already been shipped to our custoer and there is

no concrete eidence of containation in our products.

Do we hae an obligation to recall the entire production

run?

A: At LORAL, we respond promptly to any concern about

possible product saety. You should discuss the issue with

your manager or your Quality Control Manager immediately.

Remember:If youre facing an issue around product safety,

dont keep it to yourself. Youll get help and support from

discussing it with your management, your Quality Control

Manager or your Human Resources Manager (see also the

chapter on Open Talk).

PRODUCT SAFETY AND QUALITY

Proct saft a alit is paramot at

all tims.

It is t sprior prformac, alit a

saft of or procts wic mostrats or

icatio a rspct for or cosmrs, wic

ars s tir trst, rpis t rptatio of

or bras a srs tat LORAL rmais

the leader in our eld.

W ar committ to markti procts tat

have proven efcacy and safety, guaranteed by

rioros tsti.

evr LORAL mplo troot t

worl mst b committ to t acivmt

of total proct alit from cocptio to

istribtio, a v aftr t proct as

b pt o t markt.

All of s ivolv i t vlopmt,mafactri, markti, istribtio a

sals of or procts ar xpct to:

Coply with all legislatie and regulatoryrequireents on product deelopent andlabelling

Encourage a free and open exchange of iewson product safety so that no safety issue is

ignoredEnsure that the highest standards of hygieneand strict quality controls are applied at eachstage of the production process

Ensure all aderse reactions by consuersare reported to the Departent of Postmarketing Sureillance

Respond proptly to any concerns aboutpossible product safety, tolerance and quality

control issues


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THE WAY WE WORK 9

ACCURACY IN FINANCIAL ANDBUSINESS RECORDSAccrac is paramot for a sccssfl

bsiss. Tis is a sstial part of riour business legally, honestly and efciently.

W all av a t to mak sr tat all or

records, nancial or otherwise, are accurate. In

particlar, it is crcial to bi abl to provi

traspart, rlar a rliabl iformatio to

or sarolrs.

W ar all xpct to:

Play our part in ensuring that accuratenancial and business records are maintainedat all ties

maintain records securely and follow anyguidelines on record retention

Cooperate with our internal and externalauditors

Refuse all cash transactions. If there is no

other possibility, cash transactions ust beexpressly authorised, properly recorded anddocuented

make sure we do not sell, transfer or disposeof any LORAL assets without properauthorisation and docuentation

Q: Ie been asked to check the sales report prepared by

y anager for the year end. In doing so, Ie spottedwhat I think is an error, which nobody else sees to hae

picked up on. I rather nerous about entioning it,

because I dont want to jeopardise y relationship with

y anager. What should I do?

A: The reason you were asked to check the sales report is

precisely to make sure there were no mistakes. I you do not

disclose this, you are not doing your job properly and you are

not serving the interests o the Company. You should talk to

your manager about what you have ound. He or she has no

reason to be angry with you; on the contrary, youve done well

to avoid inaccurate inormation being passed up the line.

Q: Life gets very hectic sometimes, and I cant always nd

all the receipts I need to clai y expenses. Is it all right ifI add a few ctitious expense items that are less than the

aount requiring a receipt, just to ake it up to the right

total? It wouldnt be dishonest in any way, as I wouldnt

be coing out ahead. Id only be aking sure I receied

y due.

A: No, this is not OK. It means the expense reports are

inaccurate, and that translates into inaccurate accounting

records. You need to take responsibility or looking ater all

receipts; thats the only guarantee that youll receive the

settlement youre due.

Q: One of our custoers has asked if they can pay through

a ix of different accounts, using a cobination of cash

and cheques. Is this acceptable? What should I do?

A: You should be especially careul with these sorts o

transactions. It could be money laundering, a process in which

unds obtained through illegal means (e.g. drugs, bribery and

prostitution) are concealed, or made to look legitimate. So you

should always inorm your line management beore accepting

payment, and take all possible steps to satisy yoursel that

this is a bona de transaction. Among the danger signs to

look out or are: payments made rom currencies other than

that specied in the invoice; attempts to make payments in

cash; payments made by someone who is not a party to the

contract; payments to and rom an account other than the

one used in the normal business relationship; and requests to

make an overpayment.

Remember:If youre facing an issue around nancial accuracy,


discussing it with your management, your Financial Directoror your Human Resources Manager (see also the chapter on

Open Talk).


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10 THE WAY WE WORK

USE OF COmPANY RESOURCES

Compa rsorcs ar it to lp

mplos aciv LORALs bsiss oals.Miss or wast Compa rsorcs,

icli mplo tim, rt s all a ama

the operational and nancial performance of

LORAL.

W ar all xpct to:

As a general rule, aoid personal use ofcopany assets. Liited use of counication

tools such as e-ail, telephone and the internetay be acceptable so long as it does not incurany unreasonable costs and does not interferewith our job responsibilities

Respect and protect Copany assets to ensurethat they are not lost, daaged, isused orwasted, nor loaned to others, transferred, soldor donated without authorisation

Aoid inappropriate use of coputer systes,

corporate e-ail accounts and the internet

Recognise that all copany assets anddocuents belong to LORAL

Q: I suspect that one of y tea ebers has been

running an outside consulting business on Copany

tie, using his Copany laptop and e-ail to do so. I

entioned it to a friend in Inforation Serices. He canaccess the guys e-ail, and has offered to help e do a

bit of sleuthing to nd out whats going on. Is this OK?

A: No. I you have suspicions o this kind, you should raise

them directly with your manager. The Company has specic

procedures or accessing employee e-mail accounts in

connection with an investigation o misconduct or or other

legitimate reasons. Even though your riend in Inormation

Services has access to these accounts, he should not use it

or this purpose without proper authorisation through ocial

Company channels.

Q: Our printer at hoe is broken, and y wife needs to

send her Cv out for a possible job as a atter of urgency.Is it OK if I type it up and print it at work?

A: In general, you may be able to use the computer during

non-working hours to type personal documents, so long as

this is occasional, reasonable and does not interere with your

job responsibilities.

Q: I keep receiing joke of the day e-ails fro a friend in

another departent, soe of which are ery funny. Id like

to send the on to y colleagues and gie the a sile

on a monday orning, but I not sure if y anager will

approe. What should I do? Leae her off the list ?

A: Use your common sense with regard to this. Remember that

not everyone has the same sense o humour, and you should

think twice beore orwarding such jokes. In particular, you

should bear in mind that the Companys e-mail and internet

access systems must not be used to access, store, send or

publish any material which is inconsistent with the LORAL

SPIRIT notably including respect or individuals. This

includes, o course, pornographic or sexually explicit images,

political or religious content, or anything which promotes

violence, hatred or intolerance.

Q: At work, we can buy products fro the Copany shop

at discount prices. I also soeties get free products fro

y friends in marketing. I hae soe of these products to

y aunt and she suggested that we could sell the on the

internet. Is this OK?

A: No, you cannot sell the products. Employees have

access to ree or discounted products because we eel that

it is important or all LORAL employees, whatever their

unctions, to be able to know and enjoy our products. It is part

o being proud o our work. This means that the products are

or your personal use. You can also oer them as a git to your

amily and riends, but this should be exceptional.

Remember: If youre facing an issue around the use of

company assets, dont keep it to yourself. Youll get help and

support from discussing it with your management or your

Human Resources Manager (see also the chapter on Open

Talk).


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THE WAY WE WORK 11

CONFIDENTIAL INFORmATION

Unauthorised disclosure of condential

iformatio ma b trimtal to LORAL. Wmst all sr tat all iformatio ot kow

to the general public is kept strictly condential.

Those of us who have access to condential

iformatio bloi to bsiss partrs

ar r a similar obliatio to protct it from

isclosr.

W ar all xpct to:

Limit disclosure of condential informationto people with a legitiate need to knowthat seres LORALs interests

Secure all condential customer and supplierrecords, both paper and electronic

Prevent disclosure of condential informationto third parties outside LORAL (includingfaily ebers of eployees)

Avoid discussing or working with condentialinforation in a public area whereconersations can be oerheard or datacoproised

make sure that we are not disclosing aprevious employers condential information

Return all condential information (includingall copies of original aterial) upon leaingLORAL

Q: my friends often ask e about y work at LORAL.

Theyre curious as to just what it is we put in our products,and what new launches wee got up our sleee. Obiously,

I know quite a lot of the answers through y work so

how uch can I tell the?

A: Any inormation (written, electronic or any other orm) which

is not publicly available and to which you have had access

as a LORAL employee, should be considered condential.

Revealing such inormation, even to trusted riends, is not

appropriate. It may harm LORALs interests.

Q: The other day, I was taking a potential custoer to a

eeting. On the way to the eeting roo, we walked

past a colleagues ofce. His door was open, and he was

talking to another custoer about our pricing conditions

on his speakerphone. Just as we passed, we could hear

hi offering soe special deals all within y custoers

hearing! Surely he should be ore careful?

A: We all need to take the necessary measures to protect

the condentiality o inormation, even within the workplace:

or example, by ollowing the clean desk policy, locking

les away, changing passwords regularly and exercising

caution when using speakerphones. You never know who

may be passing, and even amongst LORAL employees,

commercially sensitive inormation should only be shared on

a need-to-know basis.

Remember:If youre facing an issue around condentiality,

take the appropriate steps to resolve it. Youll get help and

support from discussing it with your management, the Legal

Department or your Human Resources Manager (see also the



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12 THE WAY WE WORK

Q: I isited a colleagues blog and saw hed expressed

soe personal iews on LORALs anageent. He had

not said that he was a LORAL eployee, but it was pretty

easy to guess fro other inforation he had gien such

as I work for the n1 cosetic copany! Should I hae

a word with hi about this?

A: Weblogs (blogs) are becoming a popular mode o expression.

When participating in blogs, employees must make it clear

that they are expressing their own personal views, and take all

necessary precautions to ensure that these are not in any way

mistaken or those o LORAL. In most cases, it would notbe appropriate to identiy themselves as LORAL employees

on such a blog. You should raise this issue with your colleague

rst, as he may not have realised how his actions could be

against LORALs interests. I necessary, you may decide to

discuss it with your manager.

REPRESENTING THE COmPANY

LORALs rptatio ps o t bavior

of ac a vr o of s.

W ar all xpct to:

Act with LORALs best interests at heart

Deonstrate LORALs alues in ourprofessional behaiour

Aoid speaking or writing on behalf ofLORAL unless duly authorised

Aoid speaking or writing on subjects fallingoutside our personal expertise

Ensure there is no confusion between ourpersonal iews and those of the Copany.(So, for exaple, we should aoid the useof LORAL letterhead or e-ails to expresspersonal iews or for personal business.)

Q: Our tea took part in a conference which inoled

staying oernight and haing dinner at the conferencehotel. One of y tea ebers drank ore than he

should hae during the dinner and started behaing badly,

telling stupid jokes and being aggressie with the hotel

staff. What should I say to hi about his behaiour?

A: Although the incident took place during the evening, your

team member was still on Company business. For others

around him, he was representing LORAL. It is clear that his

behaviour was not acceptable.

Q: Soeties the internet sees to be full of

isinforation about LORAL. Isnt it y responsibility

to correct it?

A: No. I theres erroneous inormation circulating in public,

you should let your manager or someone in Public Relations

know about it and they will take action i required. But no

unauthorised employee may post Company inormation or a

Company position on the internet or elsewhere.

Remember: If youre facing an issue around representing

the company, dont keep it to yourself. Youll get help and

support from discussing it with your management, your Public

Relations Manager or your Human Resources Manager (see

also the chapter on Open Talk).


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THE WAY WE WORK 13

GIFTS AND ENTERTAINmENT

excai ifts a trtaimt ca lp

bil rstai a improv workirelationships, but they can also cause a conictof itrst btw prsoal itrsts aprofssioal t.

W rcivi ifts or trtaimt, tol rl is fll isclosr.

W ivi ifts or trtaimt, t olrl is rasoablss a ow tis wol b

prciv b t wir pblic.

W ar all xpct to:

Neer accept gifts or entertainent fro anysupplier unless they are clearly sybolic inalue

Neer gie or accept cash gifts

Ensure that all gifts and entertainent offered

are appropriate and in line with LORALsalues

make sure that when establishing a newbusiness relationship, all parties are awarefro the outset of LORALs guidelines ongifts and entertainment. In turn, nd out whatour business partners policy is on theseissues. That can go a long way to aoidingany isunderstandings

Iediately disclose to our anageentany gift or initation we hae receied

Q: may I offer a LORAL custoer tickets to a concert that

I cannot attend?A: Someone rom LORAL must be present and be able

to conduct business with the customer as part o any such

outing. The same rule applies when accepting entertainment

rom a supplier. It is only permissible i the entertainment is

reasonable, usual and customary or your business relationship,

and the provider is in attendance.

Q: We hae just closed an iportant deal with a new

custoer. my Sales manager has suggested that we take

hi to a club to celebrate. I thought that was a good idea

until I discoered it was a lapdancing club! I feel really

uncofortable about offering this type of entertainent.

A I being oer-sensitie?

A: Entertainment oered to customers should not only be

reasonable but also acceptable. This type o club is not only

likely to clash with the LORAL SPIRIT, but could also make

the customer very uncomortable, not to mention any member

o your sales team who nds this sort o entertainment

distasteul. You should encourage your Sales Manager to nd

a more appropriate option. In the long term, that will refect

well on the Company.

Q: In order to sell off obsolete products, a supplier just

offered e a 15% personal discount. Can I accept it?

A: No, you cannot accept the discount unless it is on oer to

all LORAL employees.


16/40

14 THE WAY WE WORK

Q: As part of y job, I organise nuerous business

eetings, trips and conentions. Now a hotel where Ioften book roos for LORAL eployees has offered e

a free weekend for y parents wedding anniersary. Its

a sweet gesture. Can I accept it?

A: No. Even i you are not personally going to benet rom

the git, accepting the oer makes it dicult to remain

impartial when you arrange uture hotel accommodations or

LORAL. Even the appearance o such a confict o interest is

inappropriate and should be avoided by politely declining the

oer, making clear why youre doing so.

Q: A supplier has just offered e a large haper of his

products. I know it wont hae cost hi uch, so can

and should I accept it?

A: You can only accept gits and invitations which are symbolic

in value. For example, products with the suppliers company

logo or a box o chocolates is usually ne. In this case, you

should thank the supplier or his generosity, but politely

decline the git. I you think it would harm the relationship

were you to reuse, seek advice rom your management to

nd an appropriate way o dealing with the git.

Remember: If youre facing an issue around gifts and

entertainment, nd out your countrys policy and dont keep

it to yourself. Youll get help and support by discussing it with

your management, your Purchasing Manager, or your Human

Resources Manager (see also the chapter on Open Talk).


17/40

THE WAY WE WORK 15

BRIBERY AND FACIL ITATIONPAYmENTSW bliv tat corrptio is accptabl.

Sc bavior is ot i li wit t LORALSPIRIT, does not benet the communities inwic w oprat, a rprsts a cost fort Compa. Bribr is a form of corrptio,a is illal i most cotris, particlarlwhere public ofcials are involved. Somecotris v ba facilitatio pamts.These are dened as payments used to secureor sp p roti lal ovrmt actios,sc as issi prmits or rlasi oos

l i cstoms. Most ar, i ffct, a formof bribr.

W ar all xpct to:

Neer ake, offer or proise cash orserices (including gifts and entertainent)to government personnel, other ofcials andthose who inuence them

Neer knowingly ake such payentsthrough third parties which eans carefullyselecting and onitoring contractors, agentsand business partners

Ensure that, if we nd ourselves in asituation where such payent wouldbe unaoidable, we infor our Countrymanager iediately, and fully docuentthe request

Q: Ie been told I should hire a local consultant to

help get all the necessary perits which we need froa foreign goernent. The consultant requested a large

retainer and said that he would use the oney to help

oe the process along. Since we dont really know

where the oney is going, do we hae to worry about it?

A: Yes. I you suspect that any agent is acting improperly, you

should not pay any such retainer until you have determined

that no improper payments have been or are being made.

Investigating such matters may be culturally dicult in some

countries, but any agents doing business with multinational

companies should understand the necessity o these

measures.

Q: I am setting up a new ofce and the local authorities

requested a sall gratuity before they will install our

phone lines. may I ake this payent?

A: The Company does not provide gratuities to ocials to

ensure execution o ocial duties. I the payment is not a

legitimate installation ee, you should not pay it.

Remember: If youre facing an issue around bribery and

facilitation payments, dont keep it to yourself. Youll get help

and support from discussing it with your management, your

Purchasing Manager or your Human Resources Manager (see



18/40

16 LORAL

THE WAY WE WORK

AS AN EmPLOYER

We aim to make LORAL a great place inwhich to work. We know that ouremployees are our greatest assetsThe LORAL SPIRIT


19/40

THE WAY WE WORK 17

HEALTH, SAFETY AND SECURITY

All of s wo work wit a for LORAL av

a rit to a alt, saf a scr workiviromt.

W ar all xpct to:

Coply with the Copanys rules on healthand safety at work

Take eery reasonable precaution to aintaina safe and healthy working enironent

Ensure we are not putting ourseles orothers at risk by our actions

Ensure that we know what to do if aneergency occurs at our workplace

Report to anageent any behaiour,installations or ites likely to coproisethe safety of our working enironent, aswell as all accidents, howeer inor

Q: my anager says shes worried I not getting enough

sleep, and has suggested I shouldnt go out so uch inthe eenings after work. She says shes concerned I ight

doe off and hae an accident. OK, so once or twice Ie

been a bit sleepy but I can still do y job. Surely its

none of her business what I do out of hours? Dont I hae

the right to a priate life? I think shes being petty. What

should I do?

A: How you spend your evenings is up to you. But i your

tiredness is putting yoursel or others at risk, then your

manager is right to raise the matter with you although she

should do so with sensitivity and respect or your privacy.

Although we respect employees private lives, behaviourwhich might create a saety hazard or you or your colleagues

cannot be accepted. There can be no compromise on saety.

Q: my production superisor has instructed e to disable

a safety deice that slows down the production line. What

should I do?

A: You should never bypass, disconnect or disable any saety

device or monitoring equipment without the proper prior

approval o a saety representative. Saety is an absolute

commitment that should not be compromised by productionschedules or or any other reason.

Q: As a sales representatie, I often drie after dark with

product saples in large cities and rural areas. Soeties,

I dont feel safe. I hae raised the security issue with y

anager but he has not acted on y concerns. Should I

take this up with soeone else in the Copany?

A: You should try to avoid putting yoursel in this situation, but

on occasion it may be unavoidable. I you eel your security is

at risk, you should contact your Human Resources Manager

to discuss possible solutions.

Q: I hae just learnt that one of our sub-contractors has

been drinking on our preises. Since he is not technically

a LORAL eployee, do we need to be concerned?

A: Report to management any behaviour which could

compromise the saety o our working environment or put

anyone at risk.

Remember: If youre facing an issue around health and

safety, dont keep it to yourself. Youll get help and supportfrom discussing it with your Health and Safety Manager, your

Human Resources Manager or your Site Manager (see also

the chapter on Open Talk).


20/40

18 THE WAY WE WORK

Q: What exactly does LORAL ean by discriination?

Is it the same as the denition given by the law in mycountry, or is it different?

A: The rst rule is that LORAL respects local laws and

thereore any employee violating the discrimination laws in

their country may be sanctioned. But there may be countries

where LORAL considers that the law on discrimination does

not prohibit certain behaviours which the Company nds

unacceptable. For example, LORAL is opposed not only to

direct discrimination, but also to indirect discrimination.

Direct discrimination means any action taken with regard

to jobs, training, promotions, continued employment or anyother aspect o working lie which means those aected do

not enjoy equal treatment or opportunities.

Indirect discrimination is any action which, while apparently

neutral, puts anyone with a particular gender, age, disability or

other characteristic at a disadvantage compared to others.

Q: A colleague in y departent often akes jokes about

peoples ethnic background and religion. He says hes just

having a laugh but I nd his comments insulting and

deeaning. I dont want to be seen as a killjoy, though, oras soeone who is oersensitie and huourless, and I

a afraid to confront hi. What should I do?

A: Jokes or slurs against people because o the colour o their

skin, their country o birth, their religion or even their accent

are not acceptable or us at LORAL. They deny the respect

that each o us deserves. Tell your colleague that you nd

his jokes oensive. I they do not stop, you should raise

the matter with your line management or Human Resources

Manager.

DIvERSITY

At LORAL, w bliv i t val of iffrc,

a s it as a rat asst i or work. Tivrs backro of or workforc fostrscrativit, a ivs s a bttr rstaiof or cstomrs.

LORAL is also committ to facilitati tprofssioal itratio of tos wo rirspcial atttio: o alts, prsos fromisavata backros a tos witspcial psical s.

W ar all xpct to:

Ensure we do not discriinate on the basis of:

- Gender

- Disability

- Faily situation

- Sexual orientation

- Age

- Political and philosophical opinions- Religious beliefs

- Union actiity

- Racial, social, cultural or national origins

This applies not only to recruitent, butalso to all decisions relating to training,prootion, continued eployentand working conditions in general

Support and proote LORALs coitentto a dierse workforce

Ensure that our suppliers, custoers andbusiness partners are aware of LORALsdiersity policy


21/40

THE WAY WE WORK 19

Q: I like to wrap up the working week with a Friday eening

tea eeting so that we can discuss any issues that caeup during the week. I know that this creates difculties

for two ebers of y tea who, for religious reasons,

prefer to leae early on Fridays unless, of course, there

is work still to be nished. Is this indirect discrimination?

A: It could be indirect discrimination i you do not have a

legitimate need to hold the meeting on Friday evenings, or

i there are more appropriate ways to meet your needs. You

appear to have a legitimate need or the meeting (monitoring

your teams progress and being available or their questions)

but do you really have to hold it on a Friday evening? Could

you obtain the same result by holding the meeting earlier in

the day or rst thing Monday morning?

Q: I keep hearing that diersity is iportant for the Group.

Does that ean I should only hire or proote woen or

people fro ethnic inorities?

A: No, this is not what is expected. At LORAL, we hire

on the basis o merit, and thereore you should select the

best candidate or the job. But remember that diversity is

not just limited to ethnic minorities and women. It includes

other groups who are oten discriminated against, such as the

disabled, older people, and so on.

Remember:If youre facing an issue around diversity, dont

keep it to yourself. Youll get help and support from discussing

it with your management or your Human Resources Manager

(see also the chapter on Open Talk).


22/40

20 THE WAY WE WORK

Q: What exactly does LORAL ean by harassent

and bullying? I dont think we hae a law on this in ycountry.

A: The rst rule is that LORAL respects local law and

thereore any employee violating the harassment laws in

their country may be sanctioned. But there may be countries

where LORAL considers that the law on harassment does

not prohibit certain behaviours which the Company nds

unacceptable. Depending on the circumstances, certain

behaviour may be considered inappropriate, such as:

- Actions intended to cause hurt or upset

- Deliberately setting a person up to make a mistake

- Humiliation or intimidation

- Physical or social isolation (the so-called silent treat-

ment)

There may be no law on this particular subject in your country.

You will, however, probably nd that these types o behaviour

are legally prohibited, even i it is not reerred to as harassment

or bullying.

Q: my anager can be highly intiidating. I know shes

pushing us hard to delier quality work, but at ties she

can really huiliate people, and its affecting the orale

of the whole tea. Is there anything I can do about it?

A: Your manager is expected to challenge and drive her team

to deliver the quality o work we expect at LORAL. This may

mean that she will criticise or comment on team members

perormance. However, a manager is also expected to treat

team members with respect and act with due sensitivity.

I you eel that you are not being treated in a proessional

manner, you should try and speak to your manager. You can

also consult your HR Manager. A good working environment

can only occur with the support and involvement o us all

managers and sta alike.

Remember:If youre facing an issue around harassment or

bullying, dont keep it to yourself. Youll get help and support

from discussing it with your management or your Human


HARASSmENT AND BULLYING

eac of s as t rit to rspct a ma

iit. At LORAL, tat pricipl is famtalto t wa w work. A bavior or actiolikl to ifri o tis rit, a, i particlar,a form of arassmt or blli, is otaccptabl. At LORAL, w call facts aias, ot iivials.

W ar all xpct to:

Abstain fro any harassent or bullying

Support and proote LORALs coitentto a workplace free fro all bullying andharassent

Be courteous treat our fellow workers theway we would like the to treat us


23/40

THE WAY WE WORK 21

Q: What exactly does LORAL ean by sexual

harassment? Is it the same as the denition given by thelaw in y country, or is it different?

A: The rst rule is that LORAL respects local law and

thereore any employee violating the sexual harassment laws

in their country may be sanctioned. But there may be countries

where LORAL considers that the law on sexual harassment

does not prohibit certain behaviours which the Company

nds unacceptable. Depending on the circumstances, certain

behaviours may, because o their gravity or requency, be

considered inappropriate, such as:

- Unwelcome physical contact, looks and other gestures,comments, invitations or requests

- Distributing or displaying oensive material, including

inappropriate pictures or cartoons

Q: A colleague of ine works with seeral en who

regularly ake sexually charged rearks about woen.

The coents are often coarse, rude and belittling. She

doesnt think they realise what they are doing, but she

nds their behaviour upsetting and demeaning. Shes

afraid to speak out, though, as she doesnt want to coeoer as a prude or attract siilar rearks directed at her

personally. What should I do about it ?

A: You should encourage your colleague to speak with the men

directly i she eels comortable about doing so. She can also

raise the matter with her line management or HR Manager. I

your colleague does not take action, then you should report

what she has told you even i you dont have all the acts or

havent observed the harassment yoursel. It is critical to stop

oensive behaviour beore it becomes severe.

Remember: If youre facing an issue around sexual

harassment, dont keep it to yourself. Youll get help and


Human Resources Manager (see also the chapter on Open

Talk).

SEXUAL HARASSmENT

eac of s as t rit to rspct a

ma iit. At LORAL, tat pricipl isfamtal to t wa w work. A bavioror actio likl to ifri o tis rit, a iparticlar a form of sxal arassmt, isot accptabl.

W ar all xpct to:

Abstain fro any sexual harassent

Iediately stop any behaiour which we

hae been told is unwanted

Support and proote LORALscoitent to a workplace free fro allsexual harassent


24/40

22 THE WAY WE WORK

Q: I would like to send one of y colleagues a surprise

birthday gift to her hoe. I asked Huan Resources togie e her personal address but they say they cant

tell e, because that would be infringing her right to

priacy! Isnt this going a bit oer the top?

A: No. The Human Resources departments response is totally

appropriate all employee personal data has to remain strictly

condential. They cant start making exceptions.

Q: I recently oerheard y anager talking with Huan

Resources about one of y colleagues and the fact that she

is seriously ill. In y spare tie, I olunteer for a charity

which helps people with serious illness and I would like to

know if there is anything I can do to help. Can I approach

my colleague directly or speak to my manager rst?

A: You should not approach your colleague. Instead, you

should inorm your manager and/or the Human Resources

Department that you overhead this conversation. In order to

respect your colleagues privacy, you should not, o course,

share the inormation you have with anyone.

Remember:If youre facing an issue around privacy, take the

appropriate steps to resolve it. Youll get help and support from

discussing it with your management, your Data Protection



PRIvACY

W all av a rit to privac.

LORAL is committed to respecting the con-tialit of mplos prsoal iformatio(sc as tir prsoal rcors, potos aom arss). Ol sc ata as is cs-sar for t ffctiv opratio of LORAL isacir a rtai b t Compa.

If w ar atoris to av accss to prsoalmplo ata, w ar xpct to:

Ensure we proide such inforation toauthorised persons only, on a need-to-know basis

Ensure we neer proide such inforationto anyone outside LORAL, unless legallyrequired to do so or with the eployeesspecic authorisation

make sure such inforation is stored

securelyRefrain fro holding this inforation longerthan is necessary to eet the legal orbusiness reason for which it was acquired

Seek adice before transferring such personaldata outside its country of origin

W ar all xpct to:

Refrain fro accessing and storingpersonal eployee data, unless we haethe appropriate authorisation and a clearbusiness need for that inforation

Respect the right to priacy of ourcolleagues


25/40

THE WAY WE WORK 23

CONFLICTS OF INTEREST

W sol all avoi sitatios wr or

personal interests might come into conictwit t itrsts of LORAL.

Even the appearance of a conict can tarnishLORALs rptatio as wll as or ow.

The key to dealing with any potential conictis fll isclosr. Tat allows vrti tob proprl ivstiat. As a rslt, it mawll b tat somti wic appar at

rst sight to be a problem is, in fact, not thelast bit armfl to t Compa. Bt it isol tro fll isclosr of all t factstat vro cocr ca kow tis forsure and be able to state it with condenceto otrs.

W ar all xpct to:

Disclose to line anageent if there is a

potential conict of interest which mightinuence or appear to inuence our judgmentand actions (for exaple, where a failyeber is eployed by a supplier)

Refrain fro holding any position,involvement or nancial stake in anyorganisation that is a copetitor, custoer,supplier or any other business partner ofLORAL, if our position at LORAL allowsus to inuence the business relationship

Q: One of y colleagues has a cousin whos joined us,

and an old school friend of ine has just started workingwith e. I slightly concerned that people ight think

there could be a conict of interest here. Do these policies

only apply to iediate faily or would they coer this,

too?

A: The answer is simple: i the relationship is such that it could

infuence your objectivity, then you should apply this policy

and ask or guidance. The act that a member o someones

amily or a riend already works or LORAL has no bearing

on their own worthiness as a candidate or a job with the

Company. But every eort is made to ensure that salary

and perormance evaluation are handled by an independent

person, and that these situations are monitored on an ongoing

basis to ensure objectivity and airness to all.

Q: Ie been really ipressed with the quality of work

fro a particular LORAL supplier, and as a result Id like

to invest in the company. Is there any conict of interest

here?

A: Even though your involvement could only be nancial, there

may be a confict o interest depending on your position in

LORAL, your infuence on purchasing decisions, the amount

o your investment and the importance o LORAL as a

customer to the company concerned. The only way to nd

out i it is acceptable is to disclose it to your management or

Human Resources Manager and discuss the matter openly.

Q: my son owns a really good local hotel, and lots of

copanies in the area use it for lunches and functions.

It would be an obious choice for our eent. Gien that it

copares well on price and quality with other options, is

there any obstacle to e aking a booking?

A: Given the competitive price and popularity o the venue, it

may well be acceptable or the Company to arrange unctions

there. However, it would not be right or you to have a say

in the matter, as there is an obvious confict o interest here.

As with all such cases where a close amily member works

or a current or potential supplier or other business partner,

you should disclose this act to your line manager. Then he or

she can take the necessary steps to avoid placing you in an

awkward situation.


26/40

24 THE WAY WE WORK

Q: During y spare tie, I a vice-President of the

National Consuer Association. Ie held the post forany years. Now Ie learnt the Association is planning to

lobby for a change in the law which ight cause probles

for LORAL. What should I do?

A: LORAL respects employees privacy and takes a

positive view on employees contributing to society through

associations or charities. However, you should disclose your

membership o or involvement with any such organisations

to your line management when you eel that there is a clash,

or potential clash, with LORALs interests. Your manager or

Human Resources Manager will be able to guide you on the

appropriate action. In this case, it would be wise also to make

ull disclosure to your colleagues in the Association, to explain

the confict o interest or them as well and to withdraw rom

any involvement with that particular lobbying campaign.

Q: my wife works for one of LORALs copetitors. We dont

talk about work at hoe, and I cant see its any business

of the Copany what y wife does in her professional

life. Yet soe of y colleagues hae suggested I in a

coproising situation. So what should I do?

A: This could create the appearance o a confict o interest. To

protect both yoursel and the Company, you should disclose

the acts to your management or Human Resources Manager.

Additionally, you and your wie should continue to avoid

discussing business and take steps to ensure that condential

or proprietary inormation o both companies is protected.

Q: A eber of y tea has been dating his secretary

for a couple of onths. They were pretty discreet aboutit at work, but people still found out. I not supposed

to know about it ofcially. It has started off all sorts of

ruours, and its fair to say soe of the other secretaries

arent at all happy about it. Of course, I a keeping an

eye on things to ake sure there can be no eidence of

faouritis but what if they split up and it all gets nasty?

Should I do soething about it and if so, what?

A: This is a very sensitive situation. At LORAL, we respect

employees private lives, and thereore we do not need or

want to know about their romantic relationships. However,

we do have an interest in their proessional relationships. The

situation you describe is not appropriate because there is a

confict o interest. A manager cannot be expected to judge

his subordinate objectively i he is romantically involved. You

should consult your Human Resources Manager in order to

discuss how to handle this. Ideally, one o the employees

should change jobs, and we would endeavour to make sure

that this could be achieved eectively but with sensitivity.

Depending on the acts and circumstances, there may also be

a sexual harassment issue.

Remember: If youre facing an issue around conicts of

interest, dont keep it to yourself. Youll get help and support

from discussing it with your management or your Human



27/40

LORAL 25

THE WAY WE WORK

AS A RESPONSIBLE

CORPORATE CITIzEN

We play our part in creating aworld o beauty and airnessThe LORAL SPIRIT


28/40

26 THE WAY WE WORK

POLITICAL ACTIvITIES

LORAL rspcts its mplos rit to

participat as iivials i t politicalprocss so lo as t mak sr tat, ioi so, t o ot rprst t Compa.

A of s wo tak part i political activitisar xpct to:

make it clear that we are not representingLORAL in any way

Aoid all use of Copany resources (including

Copany tie, phones, paper, e-ail andother assets) to carry out or support ourpersonal political actiities

Q: I do soe olunteer work for a local candidate whose

policies are ery uch in line with LORAL alues. may Iuse the copy machine to run off a few yers?

A: No. Do not use company time or resources o any kind to

support political activities.

Q: my line anager has asked e if Id like to ake a

donation to his daughters ayoral capaign. Is this

appropriate?

A: No. Even i your supervisor isnt pressuring you, any such

request, however innocent, is inappropriate and could be

coercive.

Remember:If youre facing an issue around political activit ies,


discussing it with your management, your Public Relations




29/40

THE WAY WE WORK 27

LORAL is a rsposibl actor i socit, a oo

ibor a a cocr citiz committto t commitis i wic w o bsiss.W cora mplos to pla a activ roli t commit.

W ar all xpct to:

Support the philanthropic projects prootedby the LORAL Group, participating in thosewhich are of interest to us and to which our

individual prole brings an added valueEnsure that we only engage LORALin actions which reect our corporatephilanthropy strategy, and reect ourcorporate alues

Understand that philanthropy is a long-tercoitent, and that all actions, regardlessof sie, ust be engaged in with a clear planof how to deelop the partnership oer tie

CONTRIBUTION TO THECOmmUNITY

Q: A philanthropy prograe that I a inoled with in

y local counity has asked if LORAL can proidefree products to support their cause. I aware that there

is a large quantity of shapoo and bath gel that is going

to be destroyed because it is in the old packaging. I could

arrange to hae the picked up without anyone knowing.

Can I gie it to the?

A: LORAL wants to support you in your philanthropic eorts,

i they are in line with the Companys strategy. You should

notiy your manager, who can see i this particular charitable

cause is in line with LORALs strategy, and propose it to the

person responsible or philanthropy in your country.

Q: The hospital at which I olunteer each week is asking

eeryone to help recruit new olunteers, and would like

e to get LORAL ore inoled. I know that seeral of

y colleagues ight be interested. Should I speak with

the directly?

A: I this hospital represents an opportunity in line with

LORALs overall philanthropy strategy, you should speak to

your manager to see i it would be possible to engage the

Company in a partnership with the hospital. LORAL strives

to go beyond the cheque, and to develop partnerships

which combine cash and in-kind donations, employee

contributions, and especially sharing the expertise we have in

so many domains to help others. You could be the corporate

sponsor or this project, and develop a meaningul long-term

programme together.

Remember:If youre facing an issue around contribution to

the community, dont keep it to yourself. Youll get help and


Human Resources Manager (see also the chapter on OpenTalk).


30/40

28 THE WAY WE WORK

Q: The pollution control deice on a critical piece of

anufacturing equipent is faulty. Ie just learnt it willtake three days to obtain parts and ake a repair. Can

we really afford to halt production when we hae a huge

backlog of orders to full?

A: We have no choice. Our commitment to environmental

good practice takes precedence over short-term prots or

production schedules. The machine must not be run without

the required pollution controls. You should notiy your line

management to help you work out a solution.

Q: As long as we coply with local law, why do we hae

to follow LORALs enironental standards if it puts us at

a copetitie disadantage?

A: LORALs commitment to the environment goes beyond

simple legal compliance. I you eel that there are competitive

business issues at stake, you should discuss these with your

manager.

Remember:If youre facing an issue around the environment,


discussing it with your management, your Health and Safety



ENvIRONmENTAL STEWARDSHIP

LORAL rspcts t viromt, a sks to

miimis its viromtal impact. W aim tocommicat opl abot or acivmtsi tis ara, as wll as or calls.

Ma of t activitis ivolv i brii orprocts to markt av a irct impact o tviromt. It is vros rsposibilit tosk to rc tat impact wrvr possibl.evr small stp cots.

W ar all xpct to:

Ipleent LORALs coitent toenironentally-friendly processes

Faour the use of renewable raw aterialsand the deelopent of enironentally-friendly packaging

Consider how our behaiour in all aspectsof our work ipacts on the enironent,

so that we can reduce that ipact whereerpossible: for exaple, by cutting outunnecessary trael, saing water and energyand aoiding generating waste. Where wasteis unaoidable, we ust ensure aterialsare recycled or disposed of in a responsiblefashion. Een sall gestures, such asseparating food waste in copany eatingareas, can ake a difference

Take all necessary actions to preent andstop iolations of LORALs enironentalpolicy

Report iediately all spills or unusualeissions to the air or water to anageentor our Health and Safety manager


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LORAL 29

THE WAY WE WORK

ADDITIONAL RESOURCES

FOR mANAGERS

We do business with integrityThe LORAL SPIRIT


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30 THE WAY WE WORK

As a Maar, o av a a rsposibilit

bcas:

You set the exaple and proote ethicalconduct

You are a decision-aker faced with orecomplex and difcult issues

Your tea will coe to you for adiceand help

A as a Maar, o will also al witsbjcts wic ar rall ol cotrat a maarial lvl, aml:

Adertising and arketing

Insider trading

Supplier selection and fair treatentof suppliers

Fair copetitionTax

Q: Which is ore iportant for e as a manager: eeting

my obligations on nancial or business goals, or those ofthe LORAL SPIRIT and THE WAY WE WORK?

A: The two are completely compatible and directly connected.

Doing the right things or the right reasons is always good

business. The Companys interests are never served by

unlawul or unethical business practices.

THE mANAGERS ROLE


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THE WAY WE WORK 31

Q: my colleague has shown e a arketing proposal for

a body lotion which uses an extreely thin young odel.I think its distasteful in the least, and could lead us to

accusations of encouraging girls to stare theseles in

pursuit of an unhealthily thin physique. She said I was

being oer-sensitie and that the artwork had already

been sent for approal. What can I do about it?

A: Our advertising and promotion is designed to have the

maximum impact possible on our desired audience, so we must

own our responsibility or all the messages it communicates

or is seen to communicate. There is growing concern about

eating disorders among young women, and the health risks

associated with this. This has to be taken into account when

deciding on our advertising campaigns. This does not mean

that you cannot be creative, but you need to make sure

that the advertising message will not be misinterpreted as

encouraging unhealthy or damaging behaviour.

Q: I just deising a arketing prograe for a new

product. The R&D departent responsible has said that it

only reduces wrinkles, but y anager has told e to

say it eliinates wrinkles. I concerned that this isnt

entirely truthful. What is the right thing to do?

A: Overselling our products by making infated or exaggerated

claims or them is dishonest, and creates distrust among our

customer base. I the product does not eliminate wrinkles,

then you should not claim that it does.

Remember:If youre facing an issue around advertising and

marketing, dont keep it to yourself. Youll get help and support

from discussing it with your management, your Scientic

Manager, your Technico-Regulatory Manager or your Human


ADvERTISING AND mARKETING

LORALs avrtisi a markti is bas

o or procts itrisic caractristicsa prformac. Tis pricipl is sstialto wii a kpi t loalt of orcosmrs.

All of s ivolv i t markti apromotio of or procts ar xpct to:

Ensure that all adertising and prootionalaterial is based on proen perforance

and scientic dataGie a fair and truthful description and isualrepresentation of our products and theireffects

Endeaour to ensure that the purpose andcorrect usage of our products is readilyunderstandable by consuers

Be sensitie to the possible reaction ofreligious, ethnic, cultural or social groups toour adertising

Ensure that we do not undertake productplaceent with any outlets (Tv or radioprograes, againes or digital edia)whose strategy for attracting an audiencerelies on exploiting extree iolence,pornography or encouraging offensiebehaiour or hatred toward others.Such strategies are contrary to LORALs

principles

Take great care to ensure our actions areconsistent with the LORAL SPIRIT if we areenisaging adertising to children and youngpeople


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32 THE WAY WE WORK

Q: I not a legal expert. What exactly is inside

inforation?A: Inside inormation is a concept dened by law. In broad

terms, it relates to non-publicly available inormation which

a reasonable investor could consider important in making an

investment decision. Such inormation can relate to LORAL

but also to one o its customers or suppliers, or another

company with which LORAL is in contact. You will nd

additional inormation in our Stock Market Ethics document.

Q: Ie just heard that LORAL is about to acquire another

copany. This sounds like an excellent tie to buy stock

in one or the other or both, since the alues are bound

to rise when the deal is announced. Is it OK for e to go

ahead and do so?

A: No. As a LORAL employee, you are most likely to be

considered an insider and thereore cannot buy or sell stock

in either LORAL or the other company until the deal has

been announced to the public.

Q: I realise that I cant buy LORAL stock based on inside

inforation yself. But what if I just happened to

ention to y girlfriend that now ight possibly be a

good tie to buy would that be OK?

A: No. It would be as i you were buying it yoursel. Even i

all you heard was a rumour, you would still be encouraging its

spread, and that too is unethical.

Remember:If youre facing an issue around insider trading,

take the appropriate steps to resolve it. Youll get help and

support from discussing it with your management, your Legal



INSIDER TRADING

Wil LORAL os ot wis to rstrict t

from of mplos to mak appropriatprsoal ivstmts, ac of s mst alwasbar i mi t risk of bi s as aii isir trai w maki ivstmtcisios.

W ar all xpct to:

Be aware that using condential informationto ake inestents could fall within the

scope of insider trading lawsRefrain fro buying or selling shares inLORAL or any other copany if we haeinside inforation at that tie

Aoid disclosing such inside inforationto anyone outside the Copany, includingfaily ebers

Aoid disclosing such inside inforationto anyone within the copany, except on a

need-to-know basis

Protect inside inforation fro accidentaldisclosure


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THE WAY WE WORK 33

LORALs rlatiosip wit its spplirs

xts bo t prcas a livr ofoos a srvics. It is itral to t lo-trm sccss of or bsiss. W will bj b t alit of t rlatiosips wav wit or spplirs. I particlar, w willb scrtiis o ow w slct or spplirs,a ow t mostrat tir commitmtto oi bsiss rsposibl.

All of s ali wit spplirs ar

xpct to:

Select suppliers on the basis of opencopetitie bidding based on objectiecriteria for ealuating perforance andquality of serice; ensure that all supplieroffers are copared and considered fairlyand without faouritis

Be transparent about the bidding processand gie honest, sensitie feedback tofailed bids

Ensure that the Copanys General Tersof Purchase and Payent, which includesLORAL ethical expectations, are understoodand accepted by all suppliers whereer theyoperate

Proide feedback to suppliers based onobjectie, transparent and consistentindicators

Support suppliers in eeting LORALsexpectations but hae the courage to endthe relationship with those suppliers whopersistently fail to eet the

Pay suppliers on tie and according tothe agreed ters (proiding that thesupplier perfors according to the tersof the contract)

make sure that the supplier is not oerlydependent on LORAL business

SUPPLIER SELECTION AND FAIRTREATmENT OF SUPPLIERS

Refrain fro asking suppliers to ake

unreasonable concessions in order to win orretain business with LORAL. In particular,aoid reciprocal dealing. (This inolesstating or iplying that a decision to buygoods or serices is based on a reciprocalagreeent for the supplier to purchase ourown products or serices.)

Protect the suppliers condential infor-ation as if it were our own, in particularaking sure that we respect their copyrightand intellectual property

W ar pro of or rptatio for aliwit spplirs i a mtall spportiv aop wa. Ts rlatiosips ar bas o tpricipls of impartialit, fairss a loalta w rspct tir ipc a itit.LORAL will ot abs its markt positio toai favor.

Q: I am trying to nd a new supplier for ofce materials.

The rst one I contacted offers a good service, but at a

high price. The second isnt quite as good, but hes cheaper

(mainly because hes made a signicant discount in an

effort to win LORAL business). Can I tell the rst supplier

what price the second guy quoted, in order to try to get

his price down?

A: You can tell the rst supplier that you have a better price

oer elsewhere, but you should protect the identity o the

second supplier. Otherwise, you would be giving the rst

supplier price-sensitive inormation about his competitor, and

thats unethical.


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34 THE WAY WE WORK

Q: I hae found a really good supplier but he is just starting

up his business and LORAL is, for the oent, his onlyclient. Can I use hi?

A: Yes. There is no reason not to help this supplier start his

business. However, you should provide in the contract that he

is expected to nd other customers beore a certain period

o time and that, should he not do so, LORAL may consider

changing suppliers. I he is really good, this should not be a

problem.

Q: Someone told me condentially that one of our overseas

suppliers is under inestigation following allegations of

forced labour. The supplier hasnt told e any of this, and

on preious site isits theres been no reason for concern.

Should I ignore these ruours?

A: No. You should investigate, starting by asking the supplier

or inormation. I you are in any doubt, consider including them

in LORALs Social Audit programme, which involves sending

an external auditor to veriy the acts around employment

practices, working conditions and other issues.

Remember: If youre facing an issue around supplier

selection or treatment, dont keep it to yourself. Youll get help

and support from discussing it with your management, your

Purchasing Manager or your Human Resources Manager (see



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THE WAY WE WORK 35

FAIR COmPETITION

W rspct all actors i or profssioal spr,

icli comptitors. W trat tm t waw wol lik tm to trat s. Or positio aslar i t cosmtics istr riforcs ort to st a oo xampl i tis ara.

It is i or itrst to work i a istr wrbsiss practics ar rptabl. It maks orwork asir a riforcs t trst of orcstomrs. Sari a tp of iformatiosc as prici, costs or markti plas cala to t apparac, ral or prciv, ofprice xing, territorial division or other types ofmaiplatio or istortio of t fr markt.

W ar all xpct to:

Aoid any contact with copetitors wherecondential information is discussed

Aoid inducing custoers or suppliers to breachcontracts with copetitors

Refrain fro knowingly taking action to cut off a

copetitors sources of supply

Ensure that we do not establish exclusie dealingarrangeents (i.e. contracts that require acopany to buy or sell only to LORAL) withoutprior legal adice if LORAL could be consideredto hold a doinant position in the arket

Ensure that we do not ipose contracts which tieor bundle together different products or serices(e.g. those which require a buyer who wants one

product to buy a second tied product as well) orallow delity rebates without prior legal advice ifLORAL could be considered to hold a doinantposition in the arket

Refrain fro all disparaging rearks concerningcopetitors (including any false stateentsconcerning their products or serices)

Proptly disclose to our line anageent if wehae inadertently receied or used proprietaryor condential information which relates to

copetitors and legitiately belongs only tothe or to third parties

Collect copetitie inforation through

legitiate eans only and always identify

ourseles as a LORAL eployee whencollecting such inforation

Neer allow new recruits to LORAL to sharecondential information about competitors forwho they used to work

Q: I ran into one of our copetitors representaties at a

trade show recently. Oer a drink in the bar, he entioned

that his copany would soon ipleent a price increase

on seeral key products. This is really useful intelligence!

Who should I tell about it so we can take full adantage?

A: We do not share or exchange price or bid inormation

with competitors. This includes pricing policies, discounts,

promotions, royalties, warranties and terms and conditions o

sale. I a competitor volunteers such inormation, you should

bring the conversation to a close sensitively but immediately,

and alert your line management. While the exchange may

be intended innocently, it also could create the appearance

o price-xing or bid-rigging which is unethical and, in mostcountries, illegal.

Q: LORAL is a eber of the National Professional

Cosetics Association and I a LORALs representatie

for the Coercial Coittee. After one of the

Coittees onthly eetings, one of y colleagues, a

representatie of a ery well-known copetitor, suggested

that the ebers of the Coittee eet in a restaurant

to reinforce personal links and to speak off the record.

What should I do?

A: Do not accept the invitation, and immediately inorm

your Legal Department. We have an obligation to warn the

Association o such o-the-record meetings. Remember

that contact with competitors must remain exceptional and

limited to non-specic, non-sensitive, non-strategic topics.

Strictly avoid inormal contact and even social events with

competitors. I during authorised ocial contact with

competitors, you realise that sensitive issues are about to be

discussed, just leave the meeting and get the act that you

let registered in the minutes.


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36 THE WAY WE WORK

TAX

LORAL aims to b a oo corporat citiz

wrvr it oprats. A k lmt of tis isrspcti all rlvat tax laws, sri tatlocal tax obligations are correctly fullled (bothocmtatio a alis), a pai ifll all local a atioal taxs as rir btos laws.

W ar all xpct to:

Ensure that LORAL does not knowingly

eade its tax obligationsPlay our part in keeping accurate andcoprehensie books and records

Q: I hae been approached by a supplier who says he has

a cast-iron way to sae us oney. Hes offering to re-route

the paperwork for purchasing the Christas order of their

goods ia a third country to aoid paying sales tax (vAT)

that they would otherwise charge us. It sounds like acleer schee can I gie it the go-ahead?

A: No. Any attempt to evade meeting our tax obligations in

ull which is in eect what this would be is illegal and

unethical. LORALs budgeting includes provisions to pay all

legitimate taxes.

Remember:If youre facing an issue around tax, dont keep it

to yourself. Youll get help and support from discussing it with

your line management, your Finance Manager, your Legal



Q: Ie found out that one of our ain copetitors will be

launching a new product shortly that could hae seriousiplications for our sales and arketing strategies. We

desperately need to nd out more about it, whatever it

takes. Gien how crucial this is, can we hire soeone

to sort through their trash in search of clues as to their

launch strategy?

A: No. This is wholly unethical behaviour, which could be

severely damaging to our reputation or integrity. LORAL

can never be party to such activities. Apart rom the act

that such espionage is inappropriate, just ask yoursel how

it would look i it came out in the newspaper! We can only

collect competitive inormation through legitimate means.

Such means include examining our competitors products and

using publicly available sources, such as promotional leafets,

annual reports, competitors displays at trade shows, and

aggregated industry data that does not disclose company-

specic inormation.

Q: Six onths ago, I hired soeone who used to work

for a copetitor. While there, she gained soe hugely

aluable research expertise in a key area for us. Indeed,

that experience was one of the ain reasons I hired her.Obiously, Ie taken great care to ensure she doesnt pass

on any condential information to us, but surely theres a

tie liit, after which she can share her knowledge freely?

Otherwise, it would just be taking all this condentiality

stuff to extrees, wouldnt it?

A: No. There is no time limit on protecting condential

inormation. Your recruit should have been hired on the basis

o the research she would be able to do or us, not that

conducted in the past or our competitor. It may even be

appropriate to transer her to a dierent department, whereshe wont eel under any pressure to pass on condential

knowledge.

Remember:If youre facing an issue around fair competition,


discussing it with your management, your Legal Department

or your Human Resources Manager (see also the chapter on

Open Talk).


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LORAL is osetting all the carbon emissions resulting rom the

creation, production and distribution o the Code o Business Ethics.

This is our rst climate neutral document.

We are doing so via Climate Care, one o the most reputable

companies providing osets.

Published by:Group Director o Ethics

LORAL

41, rue Martre

92117 CLICHY

FRANCE

http://ethics.loreal.wans

Photographs:

Jean-Jacques Ceccarini, Carole Bellache, Micheline Pelletier/

Gamma, Kitty Sirichaiwat, David Arraez, LORAL Recherche, all

rights reserved

Design:

Futerra Sustainability Communications Ltd

www.uterra.co.uk

This document was printed using biodegradable vegetable inks

and low-alcohol print technology. It is made rom paper certied by

the Forest Stewardship Council and containing 50% recycled post-

consumer waste. We chose a printer with an independently certied

ISO 14001 environmental management system.


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