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Ethics and Compliance

Code of Ethics

Code of Ethics

The Vallourec Code of Ethics defines Vallourec’s values (integrity and transparency, high standards and professionalism, performance and responsiveness, respect for people and collective commitment) and principles for action (fighting corruption, protecting Vallourec’s assets, establishing a relationship of trust with customers and suppliers, respecting employees, and living in the community) with regard to its employees, customers, suppliers, and stakeholders.

 

In 2016, an amended version of the Code of Ethics was adopted and deployed within the group in order to strengthen Vallourec’s commitments with regard to the fight against corruption and compliance with competition laws while maintaining Vallourec’s values and principles for action.

Much like the principles for action and the code of conduct that stem from them, these values demonstrate our commitment to conduct our business activities in an ethical manner and in accordance with the applicable laws and regulations.

Philippe Guillemot
Président du Conseil d’Administration & Directeur-Général

“Vallourec is a leader in premium tubular solutions primarily for the energy markets as well as for other industrial applications.  

We are proud of this position: it demonstrates our partners’ confidence in our ability to provide premium products and services in accordance with our values of integrity, transparency, high standards and professionalism, respect for people, collective commitment, and performance and responsiveness. 

Much like the principles for action and the code of conduct that stem from them, these values demonstrate our commitment to conduct our business activities in an ethical manner and in accordance with the applicable laws and regulations. 

Since the adoption of our Code of Ethics in 2009, we have made every effort to strengthen our internal Code of Conduct—specifically with regard to the fight against corruption and respect for free competition—with the consistent aim of achieving operational excellence at all levels. As a result, every employee is required to strictly observe these rules, since Vallourec does not tolerate any violation of them.” 

Our Values

Vallourec Values

Vallourec is based on strong values.

The Vallourec Code of Ethics is not a regulatory document for these values, but rather it defines the principles that guide Vallourec’s business activities in accordance with these values.

Integrity and transparency

Integrity has to be the foundation of all of Vallourec’s decisions and practices. In internal relationships, transparency—the source of trust among all Vallourec employees—requires a clear, objective, rapid flow of information. 

High standards and professionalism

High standards and professionalism are the basis of Vallourec’s success on a globalized market that requires a higher level of performance with each passing day. Its ambition to achieve sustainable growth is founded on these values. 

Performance and responsiveness

Customer satisfaction for both internal and external customers is the key to Vallourec’s long-term success. It is based on the constant innovation, quality, and performance of Vallourec products and services. It requires responsiveness to the evolution of the markets. Vallourec’s ability to adapt is one of its strengths. Its competitiveness and the longevity of its relationships with its customers are founded on this ability.

Respect for people

Respect for people, their dignity, their diversity, and the variety of their cultures is at the heart of the commitment made by Vallourec teams. It makes everyone’s life richer and contributes to everyone’s performance. Respect starts with safety, which is Vallourec’s top priority.

Collective commitment

All Vallourec employees collectively contribute to its development. This shared objective is based on solidarity, loyalty, an ability to listen attentively, a sense of responsibility, and teamwork.

Fight against corruption

Anti-Corruption Code of Conduct

The Vallourec Anti-Corruption Code of Conduct reinforces Vallourec’s commitment to its fight against corruption. Addressed to Vallourec employees as well as all of its partners, it specifies and describes behaviors that can be characteristic of acts of corruption or influence peddling using practical, concrete, and clear examples. It also indicates the proper way to behave if confronted with actions or situations that could mark acts of corruption or influence peddling.

ETHIC Certification Intelligence

In 2018, Vallourec’s anti-corruption program was certified by ETHIC Intelligence, an internationally renowned, independent certification agency. This certification indicates that the program is capable of preventing, detecting, and reducing the risk of corruption.

Vallourec: United Nations Global Compact partner

Vallourec has been a United Nations Global Compact partner since 2010. It has committed to promote and uphold the 10 fundamental principles of the United Nations Global Compact, which concern human rights, working conditions, the environment, and the fight against corruption. 

The authorities at Global Compact France have considered Vallourec to be at the “Advanced” level since 2016. This means that, worldwide, Vallourec belongs to the 10% of companies that are the most advanced with regard to compliance with Global Compact principles, including the principle on corruption prevention

Vallourec Integrity Line

Vallourec Integrity Line

In 2018, the group set up Vallourec Integrity Line, an alert system—accessible online 24/7 and available in eight languages—that enables actions or behaviors that conflict with the values and principles set forth in the Vallourec Code of Ethics to be reported from anywhere in the world. Vallourec Integrity Line can be accessed by not only Vallourec employees and intermittent and external partners but also customers, suppliers, service providers, and other external stakeholders.  

Code of conduct for securities markets

Code of conduct for securities markets

The listing of the shares and other financial instruments of Vallourec SA on the regulated market of Euronext Paris requires compliance with the regulations in force relating to the treatment of inside information the prevention of stock market offences by holders of inside information and the supervision of transactions on Vallourec’s securities. All these rules are essentially provided for by the MAR Regulation, its implementation regulations, as well as by the positions and recommendations of the ESMA and AMF.

In the name of the principles of transparency and equality between shareholders and investment professionals, the European and French regulators and the Autorité des Marchés Financiers (AMF) ensure that any buyer or seller of financial instruments has effective access to the same information, at the same time, concerning the financial instruments issued by listed companies.

In this context, Vallourec is required to communicate certain information to the market on a regular basis and must ensure that the personnel do not use or disclose to other Group personnel or external persons information that could have an influence on the price of its financial instruments. The regulations on the dissemination and use of certain information relating to Vallourec are accompanied by a strict framework for transactions on Vallourec’s securities.

Vallourec’s objective is to ensure compliance with the regulations in force and recommendations issued by the stock market authorities in the area of risk management related to the holding, disclosure or possible use of inside information.

The code of conduct for securities markets matters is intended to:

  • define the rules governing trading on Vallourec’s financial instruments applicable to the personnel of the Vallourec Group and, more generally, to remind the regulators in force to the extent that they are likely to have access to Inside Information or Privileged Information of the Vallourec Group; and
  • implement additional preventive measures to limit situations that could lead to insider trading. The attention of the personnel is drawn to the need to familiarize themselves with this code and to carefully comply with the regulations in force, insofar as violation of the regulations may result in administrative or criminal sanctions.


The attention of the personnel is drawn to the need to familiarize themselves with this code and to carefully comply with the regulations in force, insofar as violation of the regulations may result in administrative or criminal sanctions.