Anti-corruption code of conduct
IS THIS A CASE OF CORRUPTION OR ANOTHER UNLAWFUL PRACTICE? HOW TO REACT
1 — I am opening a new Rexel agency in a fast-growing country and local authorities have asked for a small bonus to install our telephone lines. It appears to be commonplace in this country. Should I pay?
- No. If the payment claimed does not correspond to a legitimate installation fee, you should not have to pay. It could be a facilitation payment. A legal alternative should be found, in some cases it may be desirable to approach the immediate senior of the administrative officer whose practices seem questionable.
2 — I am negotiating the introduction of new products with a new client. A consultant who works for this client contacts me to say that he can help me by providing me with confidential information concerning this client.
- You must refuse this offer and inform your management. It will doubtless be necessary to alert your client that a third party is trying to negotiate confidential information about him.
3 — A salesperson of your team offers to give a gift to the purchasing manager of a client company to guarantee the renewal of a contract.
- Your salesperson must be prohibited from offering a gift that does not fall within the rules set out in the applicable ‘gifts and entertainment’ procedure. The salesperson must be told that their gift could be interpreted as seeking to influence the purchaser’s purchasing decisions and encourage them to take training in the risks of corruption.
4 — A supplier has just offered me products from his own brand. I don’t think it is very expensive. Can I accept it?
- You can accept if the gift does not affect your relationship with the supplier. You can accept inexpensive gifts or invitations. Products bearing a supplier logo, for example, are generally acceptable. If you have any doubt about the value of the product and how to deal with the object, you should seek advice from your Manager. If in doubt, never decide on your own.
5 — Can I give a Rexel client a ticket for a major rugby match that I cannot attend?
- It would be appropriate if someone from Rexel could accompany the client. The same rule applies when a supplier invites a Rexel employee. An invitation must necessarily be appropriate, reasonable and in keeping in view of the professional activity and the inviting party must participate.
6 — As part of my activity at Rexel, I organise many events, exhibitions, etc. The hotel where I often book has offered me a weekend all paid for my parents. It’s very kind of them. Can I accept it?
- No. Even if I do not benefit directly from this proposal, I know that if I accept it, it will be more difficult for me to be impartial in our future relations. The mere appearance of a conflict of interest is unacceptable. This offer should be politely declined, stating the reasons for the refusal.
7 — We have just won a call for tender from a new client. My sales manager informs me that the client would like to celebrate the event in a strip club. Can I accept?
- Invitations made by our partners, clients or suppliers must be reasonable and acceptable. An evening of this type is contrary to Rexel’s values. You would need to find an alternative and strive to preserve Rexel’s reputation at all times. In any case, cash should never be used for the ‘entertainment’ of our partners, clients, suppliers or employees.
8 — Rereading the expense notes, I think I have detected an error that strangely seems to have been overlooked. I’m hesitant about speaking to my Manager, as I don’t want to rub him up the wrong way. What should I do?
- You must let your Manager know. By ignoring the discrepancy noted you are making a professional mistake and are not serving Rexel’s long-term interests.
9 — A client would like to pay for their order from different accounts, using bank transfer, cheques and cash. Is this acceptable?
- Special attention should be paid to such requests and transactions. These requests could conceal money laundering activity. These payments can only be accepted on an exceptional basis and with the approval of your Manager. Special attention should be paid to proposals for cash payments, and those made by a person not appearing on the contract or from accounts that are not customary in the established business relationship or where the bank account is in a different country from the contracting company. Where the bank account is not in the name of the contracting company, the payment must be refused.
10 — My spouse works with a competitor of Rexel. We do not talk about our professional activities, but I am afraid of a delicate situation. What should I do?
- This situation could create the appearance of a conflict of interest. To protect yourself, you should talk to your Manager or human resources manager. You and your spouse must ensure that any professional, confidential or privileged information remains protected.
11 — I have found out that a friend of mine is working with a service provider. I do not see any conflict of interest because we never discuss our professional activities. Should I do something?
- You must report this to your Manager. Regarding conflict of interest, even if apparent or potential the golden rule is to unveil it and reveal the situation in detail. This situation should have no impact on the choice of the provider, if it turns out that this is the one that best serves the interests of Rexel, nevertheless you may be asked not to participate in the choice of this supplier.
12 — In preparing a response to a public call for tender, additional costs were incurred to hire a consultant whose role was not clearly identified. I just realised that this person is of the same family as one of the members of the commission who will examine the answers to the call for tenders.
- This situation is particularly sensitive and can be likened to insider influence. If the consultant has abused their influence with the decision-makers to try to get the contract, then this behaviour will be sanctioned in the same way as corruption.