ethics in practical commercial relations

Si vous avez des questions sur les lignesdirectrices présentées dans ce document ousi vous avez connaissance d'une situation quienfreint ces règles, contactez leDéontologue de votre entité.Toutes ces requêtes et alertes seront traitées demanière confidentielle.

l'éthique de la relation commerciale

ethics incommercialpractical

guide

relations

Bertrand CamusChief executive officer

Ethics values have always been at the core of SUEZ’s strategyand development.

With our single brand and the common mission of “securingtogether the essential resources for our future”, compliancewith the ethics values of the Group by all its employees iscritical.

This guide of ethics in commercial relations has beenprepared for the purposes of reasserting our values and ofguiding employees in their practical implementation. It formspart of the existing referential and details, for the whole rangeof commercial relations, the ethics principles of the Group.

It is crucial that all employees fully comply with these rules.Its ethics values are at the core of SUEZ’s winning spirit, andcompliance therewith is necessary in order to achieve ourambition to become the global leader in environmentalservices. These values are a condition for the pride that weeach feel as part of the Group.

I expect each of you to refer to this document and to ensurethat it is complied with, thereby affirming SUEZ’s ethicalcommitment, in order to contribute together to the success ofour Group.

This practical guide “Ethics in CommercialRelations” details SUEZ’s ethical rulesgoverning commercial relations, in accordancewith the fundamental principles of the Group’sEthics Charter. It complements the guide“Ethics in Practice” and the other documentsof the Group and of the entities, providingadditional guidance to employees of the Groupacross the whole range of commercialrelations.

This practical guide forms part of SUEZ’scommitment to raise ethical standards inbusiness relations and guide employees’behavior in their day-to-day interactions withthe various stakeholders in commercialrelations.

introduction

ethics in commercial relations

This document sets out guidelines, to which theemployees of the Group must refer.

As this guide cannot comprehensively address allsituations employees of the Group may face, it islegitimate for employees to have doubts or questions inrespect of the full understanding of these principlesand their implications in specific practical situations.

You should consult your management, your entity’sEthics Officer and your legal department to discussthese questions and to report on the practicalapplication of the rules.


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The contact details of your entity’s Ethics Officerare available on your entity’s intranet or may berequested at [email protected]

The Group’s Ethics Officer may also be contacteddirectly at the following address: [email protected]

Principle of subsidiarity

Managers are primarily responsible for adapting these rules totheir local regulations and context, and for ensuring that theyare made known to, and understood by, all employees undertheir responsibility.

They must also provide guidance and encourage their employeesto discuss their ethical concerns and their questions regardingthe application of the rules. They should not hesitate to informtheir line manager or the entity’s Ethics Officer of any difficultiesencountered in applying this policy. Finally, it is up to managersto verify that their employees correctly follow the rules they arerequired to apply.

However, it is primarily through the example of their ownbehaviour that managers communicate the message of ethicalpractice and the meaning of compliance to their employees.

Everyone, regardless of their position, is responsible for theirown behavior and for the consequences of their decisions. If anemployee commits an unethical act, depending on thecircumstances, he or she may be liable for disciplinary,administrative, and perhaps, even legal civil or criminalsanctions. In the case of an unethical instruction, both the

This practical guide applies to all SUEZ entities.The rules detailed herein are to be complied with by allemployees in their commercial dealings withcustomers, consumer organizations, private and publicauthorities, partners, competitors, subcontractors andgoods or services providers.

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All employees of theGroup must act inaccordance with theethical values of theGroup, and in particularwith the rules set out inthis guide.

They should also promotesuch rules externally andensure that the Groupworks with third partieswho undertake to complytherewith.

scope of implementation

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Employees should,whenever the needarises, seek advice asto the practicalapplication of the rulesset out in this guide.

If you have any query as to the guidelines set out in this documentor if you become aware of any situation which does not comply withthese, contact the Ethics Officer of your entity.

All such requests and alerts will be treated confidentially.

person carrying it out and the person giving it are at fault.Anyone pressurized to act against the principles of the Groupshould feel free to speak about it to someone who can give themguidance.

Seeking advice or reporting an ethical incident

Due to the complexity and diversity of situations, and thenecessity to discourage unethical behaviors, employees areencouraged to discuss these issues with their management line,other managers with skills relevant to the question (humanresources, safety, legal, etc.), a personnel representative, iflegally permitted, and, of course, the Ethics Officer of his or herentity or the Group’s Ethics Officer. Such discussions will remainstrictly confidential. Moreover, anyone who in good faithexpresses concerns relating to ethical matters or compliancewill not be exposed to any sanction as a consequence of theirinitiative.

Employees should also report to managers or to their entity’sEthics Officer any situation which comes to their knowledge andcould constitute a violation of the ethical rules set out in thisguide.

For further details as to the role of Ethics Officers, please referto the Group Ethics Charter and the guide “Ethics in Practice”.

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The definition of corruption covers the whole spectrum ofcommercial relations: such acts are prohibited in relations withclients and their technical advisors, as well as competitors,partners, suppliers or sub-contractors.Corruption can be defined as the conduct of a person who soli-cits or accepts a gift or, more generally, a favor, in order to ob-tain or retain business or any other undue advantage in nationalor international activities. • Corruption can be direct or indirect (i.e. through

intermediaries or to the benefit of a third party).• Corruption can be active (to offer, promise or solicit an

advantage) or passive (to receive an advantage). • Corruption can materialize through gifts or any other

advantages, whether financial or not (services or otherbenefits in kind, e.g. employment of a related person) andirrespective of their value.

• Corruption can be towards a public official, elected official orperson holding political responsibilities, or a private party.

• Corruption can be sanctioned even if it is committed in aforeign country.

anti-corruption rulesThe Group has a «zero tolerance» policy oncorruption. Acts of corruption are illegal and unethical. They arecontrary to the Group’s ethical values and wouldseriously damage the reputation of the Group. Theywould jeopardize its businesses in both public andprivate sectors at the Group’s global level.

Any doubts or questionsas to which acts mayconstitute corruptionshould be raised withyour management, yourlegal department or theEthics Officer of yourentity.


In the context of a bidding process for agovernment entity, a public agent tells

me that it would be better if wesubcontracted part of the services to a

designated specific company. Aftercarrying out the relevant investigations,

I discover that this company is managedby a friend of his.

Can I accept it?

A public agent cannot impose adesignated subcontractor withwhich he or she has close ties, forbeing awarded a contract. You have to refuse as this is a formof indirect corruption, and toinform your management and yourlegal department.

A bidding process is ongoing, and Iknow that the daughter of a director of

the company having launched the bid islooking for an internship. It seems thatif we hire her as a trainee, we will have

a better chance to be awarded thecontract.

Should I do it?

You cannot hire a potential client’semployee or director’s relative orfriend, in order to increase thechance of being awarded acontract. It is active corruption, even if it isnot a financial, tangible and directadvantage.

I am making a deal in a foreign country.A public official recommends that I hire

a local “consultant” whom he knows,who will help accelerate the process for

getting all the permits which we needfrom the local authorities.

Can we accept to hire and pay thisconsultant?

Such a recommendation issuspicious; hiring a specificconsultant designated by a publicofficial would probably amount to aprohibited facilitation payment. You must inform your managementand your legal department.In any event, the Commercial orInstitutional Consultant Proceduremust be complied with.

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Facilitation payments, i.e. payments which are made toinduce public officials to perform their functions, suchas issuing licenses or permits, or processing theformalities of customs clearance, are generallyprohibited.

Consult your legal department for further details as tolocal rules.



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Definition of acceptable and non-acceptable gifts:

Giving and/or receiving gifts or advantages are permitted undercertain conditions: • These practices must strictly comply with all laws applying to

the Group (including foreign laws which apply to actscommitted outside their territory). They should comply with theGroup’s ethical principles. Special attention must be had torules applying to public officials.

• A gift can be acceptable if the following conditions are met: the timing of the gift: giving or receiving gifts at certain timesof the year, such as annual public holidays, can be a tradition;however gifts should never be given or received just before adecision is to be made (e.g. for the award of a contract);the value of the gift and the frequency: the frequency and thereasonable value of gifts and hospitality must be assessed inaccordance with the local laws and the local cost of living inorder to ensure that the decision-making process remainsneutral for each party in the business relationship;the intention of the different parties: no one should ask for agift, and no one should give a gift with a view to influencing thebehavior of others. The gift must never affect impartialdecision-making. It has to be given or received in good faith.

gifts policy Gifts, hospitality, entertainment or other advantagesmay help strengthen commercial relations with clientsor suppliers. However, these practices may in somecases be seen as an unfair advantage and amount toan ethical breach and/or corruption.

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Governing principles in the Group:

• Gifts must remain strictly exceptional in their frequency andlimited in their value.

• Gifts may not be given or received by third parties such asrelatives or friends.

• Each entity must set rules for gifts to be offered or received byemployees. These rules shall set out a maximum amount (ordifferent limits for different geographic areas) for such giftsand an approval procedure involving top management for anyexceptional gifts above such limit. These rules shall be subjectto the Group Ethic Officer’s prior approval.

• Any travel invitation given or received in a professional contextmust be subject to prior approval from management and fromthe Ethics Officer of your entity.

• A process of traceability needs to be put in place by themanagement of each Group entity. Either an annual report or aregister of gifts exceeding the thresholds set out locally asdescribed above shall be kept. Such gifts shall also bereported by Ethics Officers in their annual ethics report.

As is the case for thedifferent situationsdescribed in this guide,management shallexercise special cautionin this respect.

Employees must actwith honesty,independence, goodfaith, prudence andtransparency.


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technical trips

Due to the nature of the activities of the Group, it may be useful, forcommercial purposes, to organize technical trips with potentialclients. Employees of the Group may also be invited to such trips bysuppliers or sub-contractors.However, such trips may only be undertaken if:

• they conform to the principles set out above;

• they are of a purely professional nature and only the relevantprofessionals participate in the trip;

• they are organized at the nearest location with the relevanttechnology (site, professional fair…);

• the expenses covered are reasonable and justified, and only relateto professional activities.

RememberThese rules apply to relations with public local orforeign authorities as well as with privateparties.Your management must be consulted. It might beadvisable to keep written track of the decisionsmade, especially of those which requiredthorough discussions between several people.

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If you have any doubts, if you are facing anissue which seems unclear, do not hesitate tocontact the Ethics Officer of your entity.

We just closed an important deal.

Can I invite the client to therestaurant?

The deal is closed. You can invitethe client, but do not forget, itcannot be too expensive, it must bewithin the limits set for your entity.

Around New Year time, I receive anexpensive gift from a customer.

Can I accept it?

For certain annual public holidays,it is a tradition to offer and receivegifts. But those gifts cannot be tooexpensive (within the limits set foryour entity). If not, you have to decline the gift.If you think it would harm thebusiness relationship, seek advicefrom your management to find asolution.

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Governing principles in the Group

• The selected initiatives must be in strict compliance with locallegislation and be consistent with the Group’s purpose andEthics Charter.

• The Group’s policy is to refrain from any funding of politicalactivities. In countries where this type of funding is allowed,the Group may, under certain conditions, considercontributions or forms of support. In any case, these should bereduced to a minimum and remain the exception, whileavoiding any semblance of partisan or biased attitudes. Inaddition, attending any political event as a representative of theGroup must be subject to prior approval by the managementand comply with disclosure and reporting requirements. In anyevent, SUEZ entities must refrain from contributing to thefunding of institutions, parties or candidates holding viewswhich are non-democratic or non-compliant with humanrights.

• The Group’s, or as applicable your BU’s, Sponsorship,Patronage and Partnership Procedure must be complied withprior to execution of the corresponding contracts.

patronage and sponsorship

Corporate patronage and partnership initiatives are permittedunder the applicable Group policy. They reflect a civic-minded and socially responsible approach.They also show the will of the Group to promote and protect atits level, Human Rights. The group acts as a corporate citizen and encourages initiativesrelated to the community, culture, the environment andbiodiversity as well as solidarity and economic and socialintegration.

Refer to the Group’sor your BU’sSponsorship,Patronage andPartnershipProcedure.


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relationswith clientsSUEZ entities must uphold and promote integrity inbusiness relationships with clients.

They must act in accordance with the Group’s ethicalstandards, comply with all applicable laws (notablycompetition regulation), and respect human rights.

They must respect principles of fair competition andact with transparency and integrity.

The Group must provide clients with the professionalstandards and the quality of services expected locally,keep commitments, and provide accurate andcomplete information, for long-lasting relationships.

ReminderWhen an entity of the Group decides to engagecommercial or institutional consultants, thecorresponding Group procedure must becomplied with.


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Advantages can be considered as unfair irrespective of:

• the type of procurement (public or private);

• the moment when such advantage is granted: it can occur wellahead of the moment when its benefit materializes;

• the personal benefit (or absence thereof) for the persongranting an advantage: such behavior is distinct from, and notnecessarily related to, acts of corruption;

• the form the advantage takes.

No entity of the Group can benefit from illegal advantages, suchas restrictions to free access to market and equality betweencompetitors forbidden by applicable laws.

All employees must inform their managers of any situationswhere any entity of the Group has been made an offer of undueadvantages.

undue advantages restraint of competitionA company is granted an undue advantage when it isillegally favored over competitors. More generally,employees must strictly refrain from any act aiming atobtaining any advantage or privilege constituting arestraint to fair competition.

If you have anydoubts or if you arefacing an issuewhich seemsunclear, contact theyour manager or theEthics Officer ofyour entity.


A local elected official tells me that hiscity will issue a request for proposals

for a project in which the Group is likelyto be interested. He proposes to give me

the instructions to bidders before theyare officially made public, so that we

can comment on them and the city canadapt them to our favor before they are

publicly issued.

I have not solicited such a favor orpromised any advantage in return to this

official.

Can I accept his proposal?

Such a proposal is very likelyillegal and could unduly favor theGroup over competitors. In suchcase, it must not be accepted. Inany event, you must report it toyour management, your legaldepartment and the Ethics Officerof your entity.In addition, it would of course becontrary to the Group’s ethics tosuggest a client to:• provide for, in a request for

proposals, an unjustifiedtechnical requirement whichwould be so specific that it wouldautomatically and illegally favorthe Group over competitors;

• unduly relying on exceptions tothe rules of public procurement(such as artificially splitting ascope into different smallcontracts, relying on emergencyor specificity of technology,having recourse to an“amendment” to an existingcontract for a very broad scope)for the sole purpose of excludingcompetition and favoring theGroup.

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This is particularly sensitive if you, or someone close to you,have interests in a company or body that is a client, competitoror supplier of the company. It is also relevant if you are engagedin a professional or optional activity outside the company.

All employees of the Group are obliged to avoid all situationswhere their interests could conflict with those of the Group or ofany of its entities and are expected to act with the highest levelof professionalism. Even the appearance of a conflict of interestscan be negative for the Group.

conflict of interestsA conflict of interest is a situation in which thejudgment of a person who is acting in a professionalcapacity may be influenced by a secondary interest,distinct from that of the company.

This is the case when an employee finds him or herselfin a situation where he or she might make a decisionnot on the grounds of his/her company’s interests, but,notably, on the grounds of personal interests, orinterests of a relative or friend.

You should report to your management anypotential conflict of interests you may


Employees of the SUEZ Group who hold elective public offices (incountries where this is allowed), and in particular local electiveoffices in areas or cities where the Group has signed contracts,should also pay special attention to conflicts of interests. Theyshall exercise their elective responsibilities in a strictly personalcapacity and shall not, in this framework, represent or defend theinterests of the Group or of any of its activities.

Therefore, employees of the Group holding elective public officesmust not participate in any discussions or any votes as to theaward of any contract pertaining to an activity of the Group or asto any decision relating to such a contract (and should ensurethat their non-participation is explicitly set out in thecorresponding minutes and decisions).

More generally, employees of the Group should refrain fromaccepting elective responsibilities having a connection withactivities of the Group.

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If you have any doubtsas to which situationscan create a conflict ofinterests, you shouldconsult with yourentity’s Ethics Officerand your management.

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ReminderThe Group’s financial officers are required to report anypotential or actual conflicts of interests to their linemanager or their entity’s Ethics Officer, in accordancewith the Group’s “Code of Conduct for FinancialOfficers”.In addition, all people having access to privilegedinformation, notably those designated as insiders bythe Group’s legal department, must comply with theCode of Conduct related to the Prevention of the Use ofPrivileged Information and Securities Transaction.

In the event that any of your relatives or friendsholds an elective office, or more generally hasresponsibilities, in a public entity which is apotential client for the Group, you should informyour management and your entity’s Ethics Officerin order to take adequate precautions so that noconflict of interests may arise.


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During my spare time, I am an activemember of a consumer association.

Does this occupation create apotential conflict of interests?

In the event that you have anydoubt in such respect, you shouldrefer to your management andyour entity’s Ethics Officer.

In addition to working for the Group inthe waste business, I am a city council

member in the town where I live. A callfor tenders has been initiated for

municipal water supply. Can I be a member of the

elaboration and/or decisioncommittee?

If you are a local elected officer,you have to decline participation inany such committees when itrelates to any tenders having aconnection with any of theactivities of the Group.

My entity will enter into negotiationswith an industrial client. A relative of

mine holds a management position inthis company, with decision-making

power over the project.

What should I do?

Even if you are not directly involved inthese negotiations, you shoulddisclose it to your management andyour entity’s Ethics Officer so thatrelevant measures can be taken inthe light of this situation.

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They must therefore liaise with the legal department for detailsas to applicable regulations, which cover a wide range ofbehaviors and practices.

Whether in the context of public procurement or privatemarkets, entities of the Group cannot enter into any practiceswhich, in any way, contravene the legal principles of fair, loyal,transparent and equal competition. The Group rejects all anti-competitive practices infringing applicable laws.

Employees of the Group must also protect the confidentiality ofinformation, i.e. both of information pertaining to the Group andof information lawfully exchanged with competitors whenspecific circumstances allow it.

relations withcompetitorsIn the context of their activities, entities of the Groupmay be in contact with competitors.The Group’s employees must act in strict conformitywith the ethical principles of the Group and withcompetition laws.

Although suchcontacts are notprohibited per se,special care must behad in this respect.

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All competition issuesshould be referred toyour entity’s legaldepartment and to theGroup competitionlaw department.

RememberCompetition regulation prohibits any agreementsor practices between competitors, notably duringbid preparation and submission, amounting to:

• joint price or margin fixing;• market sharing;• unfair exclusion of competitors;• prohibited exchange of commercially

sensitive information;• submission of deceptive competing tenders.

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A partnership with a competitor iscontemplated for a number of specific

projects, which size is too significant forthe Group to have the necessary

resources to carry them out without apartner.

Would such a partnership becontrary to competition rules?

Associating with a competitor ispossible only in limited cases;attention must be paid to thecontext, to the characteristics ofthe agreement and to the contentsof the discussion. You mustimmediately seek advice from thelegal department of your entityand, if necessary, from the Groupcompetition law department.

A competitor calls me because he wouldlike to know whether the Group intendsto submit offers for certain projects and

is ready to tell me which projects hiscompany is interested in. He does not

ask any details as to prices or technicalsolutions.

What should I do?

Exchanging sensitive informationwith competitors as to futuretenders is illegal, when suchinformation is likely to have aninfluence on competitors’ offers.You must report this request to yourmanagement and legal department.In any event, employees of theGroup must protect theconfidentiality of sensitiveinformation relating to the Group’sactivities.

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It occurs when a company agrees, in the context of a call fortenders and in order to favor a competitor, to submit a bid atconditions (notably in terms of price) which are knowingly not asgood as the said competitor’s offer or at conditions which willnot be accepted by the client (excessive price, unacceptablequalifications or deviations…).Such practice cannot be tolerated by the Group as it is a clearviolation of its ethical principles.

cover biddingCover bidding is a form of bid rigging, which gives theappearance of genuine competition.

A competitor is interested in a projectand fears that they are going to be the

only company submitting an offer forsuch project. The Group does not intend

to submit a bid for said project. They askus whether we can nonetheless submit

an offer, for example at an excessiveprice, to make sure that the client may

not consider the call for tendersunsuccessful.

What should we do?

Submitting such an offer wouldamount to cover bidding and istherefore strictly illegal. Such apractice could lead to convictionsand sanctions for the Group even ifthe Group receives no financial orother compensation in this respect.You must report this request to yourmanagement and legal department.

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Accordingly, the choice of partners must be impartial anddemanding, on the basis of their professionalism andcompetitiveness, and of their values, with a view to building arelationship of trust.

relations with partnersEmployees of the Group must act in accordance withthe ethical principles of the Group when dealing withpartners, and must ensure that current andcontemplated partners also abide by these principles.

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The creation of a consortium or a joint venture (whetherincorporated or not) or, more generally, the setting up ofpartnerships are a common feature of the activities of the Group.

The purpose of such an association, the selection of the relevantpartners, the scope and terms of the partnerships and theiractual functioning must be consistent with the ethical values ofthe Group and comply with all applicable laws. They must alsobe technically and economically justified.

consortia, joint ventures and other partnerships


Relations withpartners must betransparent andloyal, with dueprecaution as toconfidentiality ofinformationdisclosed.


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My entity is operating a facility inconsortium with another company.

Although we apply the strict health andsafety rules of the Group, I have become

aware that our partner does not abideby the same standards for its employeesand that there are safety issues on site.

Should I report such concerns?

You should immediately inform yourmanagement, the contract managerand your entity’s Ethics Officer sothat adequate measures andremedies to this unacceptablesituation can be taken.

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My entity has performed a contract witha company which business is

complementary to the activities of theGroup. We are very satisfied with this

partnership and contemplate enteringinto a longer term partnership through

a framework agreement for a number offuture similar projects.

Is this possible?

The acceptability and the legalityof such a long term partnershipdepend on varied characteristics(notably exclusivity provisions,duration of the agreement,respective experience andqualifications of the Group and thepartner) and on its compliancewith applicable competition laws.Before initiating any suchdiscussions, you should consultyour management and your legaldepartment.

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The decision to haverecourse to atechnicalconsultancy firmmust meet a real andjustified need forexternal expertise,for a clearly definedscope.

This situation could be complex and requires special attention,as no confidential information should be exchanged with thecontracting authority’s consultant. You must seek advice fromyour management and your legal department as to adequateprecautions to avoid situations which would be prejudicial to theGroup under the laws applicable to corruption, competition andpublic tendering.

technical consultancy firmsRelations with technical consultancy firms must becarefully addressed, especially when such consultancyfirms also act as advisors to a contracting authority orto competitors. Indeed, technical consultancy firmsthus have access to confidential and sensitiveinformation.

RememberIf you have any doubts, if you are facing an issuewhich seems unclear, do not hesitate to contactthe Ethics Officer of your entity.



27Employees of the Group dealing with subcontractors andsuppliers must comply with the ethical values of the Group andensure that these third parties share and respect these values. Inparticular:• applicable laws and internal procedures must be complied with;• relations must be based on equity, transparency and

impartiality;• mutual commitments must be kept;• the confidentiality of information exchanged must be preserved;• the Group’s commitments with regards to ethical standards,

sustainable development and corporate responsibility must beknown and maintained;

• conflicts of interests must be avoided;• competition rules must be complied with.

SUEZ intends to maintain respectful and balancedrelationships with its suppliers and subcontractors,and to enhance a culture of integrity.

relations with suppliers and subcontractors

Ethical principlesapplying to relationswith suppliers aredescribed in details inthe “Ethics in SupplierRelations” Guide.

The applicablepurchasing governanceand procedures mustalso be complied with.


My brother now owns a company whichsells a type of equipment that my entityregularly buys. I know that the productsare of very good quality and my brother

would probably give us a discount.

Can I sign a contract with mybrother’s company?

You are clearly in a situation ofconflict of interests. The principlesset out on page 16 as to conflicts ofinterests also apply in this situation.You must refer the situation to yourmanager prior to any decision andthe applicable purchasingprocedures must be applied.

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One of our usual suppliers is inviting meto a conference abroad.

Can I accept this invitation?

Such an invitation amounts to a gift.You must therefore act inaccordance with the rules set outon page 8. You should consult withyour manager and your entity’sEthics Officer. In any event, yourentity should bear the costs oftravel and accommodation.

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If you have anydoubts, if you arefacing an issuewhich seemsunclear, do nothesitate to contactthe Ethics Officer ofyour entity.

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ReminderThe applicable Embargo Procedure must becomplied with.

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These documents are available on the Group’s website at thefollowing address: www.suez.com/en/Who-we-are/A-committed-group/Ethics-and-transparency

They are also available, together with the other ethics documentsof the Group and of your entity, on your entity’s intranet.

The following procedures are also available on your entity’sintranet:

• Commercial or Institutional Consultant Procedure;

• Sponsorship, Patronage and Partnership Procedure;

• Code of Conduct for Financial Officers;

• Code of Conduct related to the Prevention of the Use ofPrivileged Information and Securities Transaction;

• Embargo Procedure.

documents andcontacts

The ethics policy of the Group is detailed in the Group’sEthics Charter and in the guide “Ethics in Practice”.


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documents and contacts

The Group’s competition law department contact detailscan be requested from your entity’s legal department orat [email protected]

All queries in this respect may be referred to theGroup’s Ethics Officer at [email protected] to your entity’s Ethics Officer, which contact detailscan be found on your entity’s intranet or requested [email protected]


Tour CB 21 - 16 place de l’Iris 92040 Paris La Défense cedex - France Tél. +33(0)1 58 81 20 00 - Fax +33(0)1 58 81 25 00

www.suez.com

ethics in practical commercial relations

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