Our

Code of
Business
Ethics
 How to use our
Code of Business Ethics?
Our Code of Business Ethics helps all team members understand how to behave
and act in the right way. It is a framework for support if we are unclear. It is
impossible for us to envision and prepare for every single business situation that
may pose an ethical dilemma. Accordingly, we do not claim that this document
is definitive or exhaustive. In three areas where ethical issues are particularly
sensitive—fair competition, bribery and corruption prevention, and conflict of
interest—there are specific detailed Group policies that supplement the high level
overviews in our Code of Business Ethics.

Moreover, our Code of Business Ethics does not rule out the need to exercise
good judgment, but aims to provide guidance for all of us to do so. When in doubt,
you should ask yourself the following questions:
> Is it legal?
> Does it comply with generally-accepted industry regulations or normal industry
practices?
> Is it in line with the Group Values, Code of Business Ethics and Blue Book?
> Does it feel right?
> Would I be comfortable explaining it to fellow team members, team leaders,
clients, family or, externally, to the press?

If the answer to even one of the questions above is ‘no’, probably it is not the right
thing to do. Open a dialogue with your team leader, your Ethics & Compliance Officer
or HR manager to make the appropriate decision, and to be sure we continue “doing
the right thing”. Find your Ethics & Compliance Officer on your Group and local
websites—see Appendix for links.

If you have raised a concern locally and you think that it has not been handled
properly or in the exceptional case that it is inappropriate to raise the issue locally,
you can reach out to ‘SpeakUp’, Capgemini’s phone/web based helpline—see
Appendix for link.

>> Our Code of Business Ethics

is for all team members, of all the companies of the Group
collectively referred to in this document as “the Group”.

“World’s Most Ethical Companies” and “Ethisphere” names and marks are registered trademarks of Ethisphere LLC.

2 Capgemini. Our Code of Business Ethics

Table of Contents
Seven Values lie at the heart
of everything that the Group does . . . . . . . . . . . . . . . 04
The Board of Directors . . . . . . . . . . . . . . . . . . . . . . 06
Message from the Chairman
and CEO . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 08
Commitment from our Group Executive Board . . . . . . . 10

1. Our Code of Business Ethics . . . . . . 11

1.1 What is our Code of Business Ethics? . . . . . . . . . . . . 12
1.2 Who is it for and what are our roles? . . . . . . . . . . . . 12
1.3 SpeakUp . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

2. People . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
2.1 Health and safety . . . . . . . . . . . . . . . . . . . . . . . . 16
2.2 Equality, diversity and inclusion . . . . . . . . . . . . . . . 17
2.3 Harassment . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
2.4 Open dialogue . . . . . . . . . . . . . . . . . . . . . . . . . . 19
2.5 Behavior at work and work-related events . . . . . . . . . 20

3. Business Integrity . . . . . . . . . . . . . . . . 21
3.1 Fair competition . . . . . . . . . . . . . . . . . . . . . . . . . 22
3.2 Bribery and corruption . . . . . . . . . . . . . . . . . . . . . 24
3.3 Conflict of interest . . . . . . . . . . . . . . . . . . . . . . . 26
3.4 Insider trading . . . . . . . . . . . . . . . . . . . . . . . . . . 27
3.5 Accurate and correct business
and financial information . . . . . . . . . . . . . . . . . . . 28
3.6 Political activities . . . . . . . . . . . . . . . . . . . . . . . . 29

4. Business Relationships . . . . . . . . . . . 31
4.1 Working with our clients . . . . . . . . . . . . . . . . . . . . 32
4.2 Working with our alliance
and other business partners . . . . . . . . . . . . . . . . . 34
4.3 Working with our suppliers . . . . . . . . . . . . . . . . . . 36

5. Group and Third-Party Assets . . . . 37

5.1 Intellectual property . . . . . . . . . . . . . . . . . . . . . . 38
5.2 Confidential information . . . . . . . . . . . . . . . . . . . 39
5.3 Protecting personal data . . . . . . . . . . . . . . . . . . . 40
5.4 Appropriate use of Group and third-party
assets and resources . . . . . . . . . . . . . . . . . . . . . . 42

6. Corporate Social Responsibility . . 43

6.1 Contributing to the communities . . . . . . . . . . . . . . 44
6.2 Minimizing our impact on the environment . . . . . . . . 45

Appendix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46

Version 2.8

3
Seven Values

4 Capgemini. Our Code of Business Ethics

Seven Values lie at the heart of
everything that the Group does.
Since the creation of the Group in 1967, our culture and business practices have been inspired
and guided by our seven core Values. These are the guiding principles that we collectively and
individually stand for and are at the heart of our approach as an ethical and responsible business.

These Values are not only rules of behavior; they also provide the basis for our rules of conduct
and principles of action. They shape our sustainable ethical culture, our “Group DNA”, producing
a mindset encompassing integrity and ethical behavior.

Our Values are important for respecting, defending and upholding the Group as an ethical and
responsible business and for protecting our reputation.

HONESTY, loyalty, integrity, uprightness, a complete refusal to use any underhanded

method to help win business or gain any kind of advantage. Neither growth, nor profit nor
independence have any real worth unless they are won through complete honesty and probity.
And everyone in the Group knows that any lack of openness and integrity in our business dealings
will be penalized at once.

BOLDNESS, which implies a flair for entrepreneurship, and a desire to take

considered risks and show commitment (naturally linked to a firm determination to uphold
one’s commitments). This is the very soul of competitiveness: firmness in making decisions or in
forcing their implementation, an acceptance periodically to challenge one’s orientations and the
status quo. Boldness also needs to be combined with a certain level of prudence and a particular
clear sightedness, without which a bold manager is, in reality, merely dangerously reckless.

TRUST, meaning the willingness to empower both individuals and teams; to have
decisions made as close as possible to the point where they will be put into practice.
Trust also means giving priority, within the company, to real openness toward other people
and the widest possible sharing of ideas and information.

FREEDOM, which means independence in thought, judgment and deeds,

and entrepreneurial spirit, creativity. It also means tolerance, respect for others, for different
cultures and customs: an essential quality in a Group of over 200,000 people of around
120 different nationalities.

FUN, means feeling good about being part of the company or one’s team, feeling proud
of what one does, feeling a sense of accomplishment in the search for better quality and greater
efficiency, feeling part of a challenging project.

MODESTY, that is simplicity, the very opposite of affectation, pretension, pomposity,

arrogance and boastfulness. Simplicity does not imply naivety (simple does not mean simpleton!);
it is more about being discreet, showing natural modesty, common sense, being attentive to others
and taking the trouble to be understood by them. It is about being frank in work relationships,
loosening up, having a sense of humor.

TEAM SPIRIT, meaning solidarity, friendship, fidelity, generosity, fairness in

sharing the benefits of collective work; accepting responsibilities and an instinctive willingness
to support common efforts when the storm is raging.

5
The Board of Directors

The Board of Directors

of Capgemini SE
The undersigned, Members of the Board
of Directors of Capgemini SE express
by their signature their endorsement and
their individual and collective support to
the provisions of the Code of Business Ethics.

6 Capgemini. Our Code of Business Ethics

Paul Hermelin, Daniel Bernard Anne Bouverot Xiaoqun Clever
Group Chairman & CEO

Laura Desmond Laurence Dors Robert Fretel Siân Herbert-Jones

Kevin Masters Xavier Musca Frédéric Oudéa Patrick Pouyanné

Pierre Pringuet Lucia Sinapi-Thomas

7
Message from the Chairman and CEO

Message from the Chairman

and CEO
When, in 1967, a small French startup ventured into
a then emerging market, it set out with no guarantee
of success, but it moved forward nevertheless with
conviction—with an unshakeable belief—that it had
a part to play in shaping the future.
That small startup is today the Capgemini Group—
our Group.

By closely partnering with our clients as they step

into the future, and by constantly pushing to bring
out the best in our people, we have made a truly
remarkable contribution to the global techno­logical
transformation. We have become a forerunner in
an industry that has transformed the way we live,
work, and play.

Throughout this incredible journey, we have

remained true to principles that have governed us
from the start: an entrepreneurial spirit, a passion
for clients, belief in our people, and extremely high
expectations with regard to both performance and
ethical behavior.

From the outset, our belief in a certain way of doing

business—our commitment to our 7 core Values—
has set us apart. Our team is located worldwide,
but we share a common culture based on honesty,
trust, and respect for each other’s backgrounds
and contributions to our joint enterprise. Being a
values-based organization has guided our behavior
throughout the many evolutions our Group has
seen, whilst allowing us the freedom needed to
adapt to our fast-evolving marketplace—and the
boldness we need to lead.

8 Capgemini. Our Code of Business Ethics

With the digital age still dawning, it’s clear that our As your Chairman and CEO, I assume full responsibility
adventure is only just beginning. The exponential for keeping ethics as the keystone of our business, and
rise of information and communication technology for acting in a way that is exemplary. In sponsoring
means that the horizon is unfolding every day, every our Code of Business Ethics, I also aim to support
hour, all around the world. This spectacular digital you in adopting ethical behavior with regard to
transformation opens up to our clients and our Group all stakeholders, be they clients, team members,
new worlds of opportunity. The ethical challenges, partners and suppliers, or shareholders.
however, remain. Our code of ethics is as valuable
In his introduction to the very first edition of our
an asset today as it ever was, in that it provides
Code of Ethics, our founder Serge Kampf foresaw
the compass that will enable us to navigate our way
a time when a strong ethical track record would be
forward through these new worlds.
considered a competitive advantage. In this respect,
as in so many, he was visionary: the future he foresaw
It will continue to be a challenge to assure the
is now.
growth and profitability we need to assure our
independence, but we are well-equipped to move I therefore count on you to familiarize yourselves
forward boldly into tomorrow. With our adventurous with the content of our Code and, above all, to put
spirit and high requirements with regard to its rules and principles into action. Only by your full
performance, I have no doubt that we will continue to and enthusiastic engagement can you help ensure
work at the forefront of our industry, accompanying that Capgemini’s growth is sustainable well into
the most demanding clients on the most demanding the future.
missions—a true Leader for Leaders. But we owe
it to our clients and ourselves to remember at all
Paul HERMELIN
times, and in all situations, who we are, and how we
Chairman and CEO
work: a reputation built up over decades can be lost
overnight by one misguided action.

9
Group Executive Board Members

Commitment from our

Group Executive Board

Paul Hermelin, Jean-Philippe Bol, Anirban Bose, Thierry Delaporte,

Group Chairman & CEO Cloud & Infra Services GBL Financial Services SBU Chief Operating Officer

Aiman Ezzat, Carole Ferrand, Cyril Garcia Hubert Giraud,

Chief Operating Officer Chief Financial Officer Capgemini Invent Human Resources

Patrick Nicolet, Olivier Sevillia,

Chief Technology Officer Europe SBU

10 Capgemini. Our Code of Business Ethics

1. Our Code of
Business Ethics
Since the Group was founded, we have
always believed that a profitable and
sustainable business cannot exist without
sound ethics and integrity. This lies at the
very heart of our decentralized organization.
Our Code of Business Ethics is our ongoing
commitment to maintaining and promoting
world class standards of business integrity
and trust wherever we operate.

11
Section 1: Our Code of Business Ethics

1.1 What is our 1.2 Who is it

Code of Business for and what
Ethics? are our roles?
Our Code of Business Ethics encapsulates our respect for the Our Code of Business Ethics is for all team members of all
law and for individuals, and our responsibilities to our clients the companies of the Group.
and stakeholders. It provides the basis for our ethical culture.
It applies to all of us, both team leaders and team members,
As a basic rule, we respect international, national and local at any level of the Group. If you are in a leadership position
laws and regulations in the countries in which we work and or in a team leader role, you need to understand that these
undertake all necessary commitments to adhere to them. Our positions imply additional responsibilities to uphold our
Blue Book sets out common internal guidelines, procedures ethical behavior. It is Group policy that no one will be retaliated
and policies that govern our operation as a Group and provide against for raising any concerns in good faith regarding
further in-depth guidance. The Blue Book is available on our practices that may violate this Code of Business Ethics.
Group and local websites—see Appendix for links.

The Group has always been a “Values-based” organization: AS A TEAM MEMBER

our Values are a part of our “Group DNA” and lead all of us
to adopt an ethical mindset and ethical behavior in our daily
MY ROLE IS TO:
business activities. > Know and understand our Code of Business Ethics;
> Act consistently with our Code of Business Ethics, and if
Our Code of Business Ethics sets out, explains and formalizes in doubt seek guidance from your team leader, human
the Values, rules of conduct and behavior, and the principles resources manager, a lawyer in the legal department or your
of action that we expect from ourselves and that are required country’s Ethics & Compliance Officer; and
of us in our relationships with stakeholders. Our Code of > Demonstrate and live our Values, rules of conduct, our
Business Ethics is embedded in the Blue Book. It prevails over behavior and principles of action.
any business level policy or procedure.

In the following sections of this Code of Business Ethics, we

aim to provide clarity and guidance, especially in fields that can AS A TEAM LEADER I HAVE
pose ethical dilemmas. In such areas, exercising good judgment ADDITIONAL RESPONSIBILITIES
can be complex because you are in a gray area and there is AND MY ROLE IS TO:
a risk of breaking the law, sometimes even unknowingly. > Lead by example and maintain, promote and live our Code
In these situations, any misconduct could compromise our of Business Ethics in my daily work;
ethical culture, damage the Group’s reputation and potentially
lead to significant sanctions. In three areas where ethical > Ensure that our Code of Business Ethics is alive within my
issues are particularly sensitive—fair competition, bribery and team;
corruption prevention, and conflict of interest—there are > Ensure that I am familiar with the Code of Business Ethics
specific detailed Group policies that supplement the high level since my team members may come to me for advice and
overviews in our Code of Business Ethics. guidance on certain issues in our Code of Business Ethics;
and
We must follow our Code of Business Ethics no matter > Identify compliance risks, and make the appropriate decisions
where we operate or whatever the economic circumstances. regarding issues relevant to my area of responsibility.
Following the Code of Business Ethics is mandatory for Group
compliance.

12 Capgemini. Our Code of Business Ethics

1.3 SpeakUp

SpeakUp is a web and phone-based ethics concerns

reporting and incident management tool, operated by
an independent service provider, and made available
by Capgemini to team members, customers, suppliers,
and business partners. SpeakUp complies with legal
requirements in jurisdictions that have whistleblowing
regulations. By upholding our people’s freedom to raise
concerns and empowering us to put ethics into action,
SpeakUp also contributes to safeguarding Capgemini’s
culture of openness and our high ethical standards.

SpeakUp is voluntary, confidential, and allows anonymity,

unless stated differently by a country’s local law. It ensures
fairness, organizational justice, and prompt, systematic
investigation. Capgemini trusts and expects team members
to use SpeakUp in good faith and will firmly prohibit
retaliation against whomever raises or helps address a
legitimate concern.

Use SpeakUp to report concerns and request advice or

guidance about actions or behaviors that are:
— not aligned with our Values, our Code of Business Ethics,
or related ethics and compliance policies, or
— not in compliance with applicable laws, or
— that may significantly affect vital interests of Capgemini
and its affiliates.

SpeakUp is not a grievance helpline; it is not a platform to

raise issues in relation to performance review, compensation,
and career development. However, actions and behaviors
which are not aligned to our Values and Code of Business
Ethics e.g. workplace harassment, discrimination, retaliation,
sexual harassment, etc. are within the scope of SpeakUp.

Please read the SpeakUp policy for more information;

country specific regulations are identified under the policy.

www.capgemini.com/speakup

13
Section 2: People

14 Capgemini. Our Code of Business Ethics

2. People

We are committed to
providing a safe and
inclusive work environment.

15
Section 2: People

2.1 Health and safety

We are committed to looking after the health and safety of

team members, whether working on our own sites or on our
clients’ sites.

WHAT DOES THIS MEAN?

> Follow the rules. The Group takes its health and safety responsibility very seriously and
we are all expected to comply with, and adhere to, any relevant legislation and emergency
procedures. When working on a client’s site, we are also expected to observe and
cooperate with any client rules regarding health and safety and emergency procedures.
When travelling on business we are expected to comply with and follow applicable Group
policies—see Appendix for the link.
> Be supportive. We expect our team leaders to look after the health and safety of their team
members.
> Be pro-active. We all have the responsibility of identifying and reporting to our local health
and safety representative or team leader any form of behavior that could present a hazard
or risk or any situation that may compromise the health and safety of the team members.

WHAT IS EXPECTED OF ME?

> It is my duty to familiarize myself with and follow the Group’s health and safety policies,
my clients’ health and safety policies, and any emergency procedures that are provided to
me in accordance with applicable laws.
> I must follow mobility Group guidelines and Group Travel and Security policies when traveling.

PRACTICAL EXAMPLES
I am working on a client site and have meetings in I am working on a project and my partner has
the production environment. What are my responsibilities problems that require my presence at home:
with regard to health and safety? this may have an impact on the way I work and
It is your responsibility to familiarize yourself with the client’s where I can work. What should I do?
health and safety policies, for example by requesting that your Raise the concern with your team leader so that
team leader obtains a copy of their health and safety handbook/ you can discuss appropriate ways to help you
policy. If you are working in an industrial environment, make sure continue to do your work. If you are the team
you don’t miss any health and safety courses the client offers. leader, then you should take your team members’
If there is a real concern for the health and safety of you or personal circumstances into account as far as
your team, raise the issue immediately with your team leader possible. If you are unsure what to do, speak with
who must raise it with the client, if necessary. If you are the team your human resources manager.
leader, checking the client’s health and safety policies should be
one of your first priorities at the start of a project.

DISCUSS OPENLY AND SHARE YOUR CONCERNS: If you are facing an issue involving health and safety of one of your
team members, do not keep it to yourself. You will get help and support by discussing it with your team leader or your
human resources manager.

16 Capgemini. Our Code of Business Ethics

2.2 Equality, diversity
and inclusion
We are proud of our diversity. It enriches and enables us to
be thought leaders in our chosen markets. As individuals, we
are entitled to equal opportunity and fair treatment.

WHAT DOES THIS MEAN?

> Performance matters. The Group is committed to being a “Talented Company” and seeks
to reward people on the basis of achievement and performance. We assess our fellow team
members and recruitment candidates on the basis of merit and qualifications directly related
to professional competence and behavior.
> Equal opportunity and fair treatment. We aim to provide equal opportunities and fair
treatment, irrespective of social, cultural, ethnic or national origins, religious or other
beliefs, caste, gender, marital status, pregnancy status, sexual orientation, disability,
age, and trade union membership. We are committed to complying with all employment
discrimination laws.
> Freedom. We respect individuals’ cultures and customs, including their religious beliefs.
The Group does not support any religious organizations.

WHAT IS EXPECTED OF ME?

> I assess fellow team members on the basis of professional competence, behavior and
achievements.
> I am expected not to tolerate any jokes, language, gestures or other behavior that may
offend people, make them feel discriminated against or create a hostile environment.
> I cooperate with my colleagues irrespective of social, cultural, ethnic or national origins,
religious or other beliefs, caste, gender, marital status, pregnancy status, sexual orientation,
disability, age, or trade union membership.

PRACTICAL EXAMPLES
I want to make sure I have a diverse team. In my I am a team leader and one of my team members
recruitment activities, should I favor people from has expressed his/her disabilities to me. Does
minority groups over other candidates? the Group have facilities to ensure this person can
We should always assess candidates equally on the basis continue to do the job required of them?
of merit and professional competence. In our recruitment Yes. The Group has tools, technology and processes
activities, we should request any recruitment firm to to assist people with disabilities and ensure they can
present a diverse set of candidates, reflecting the society continue to do their job. Please contact your local human
in which we live. resources department for more information on what
is available.

DISCUSS OPENLY AND SHARE YOUR CONCERNS: If you are facing an issue involving equality, diversity and inclusion,
do not keep it to yourself. You will get help and support by discussing it with your team leader or your human resources
manager.

17
Section 2: People

2.3 Harassment

We all have a right to be treated, and a duty to treat others,

with respect and courtesy.

WHAT DOES THIS MEAN?

> Respect in the workplace. The Group is expected to maintain a work environment that is
free of harassment; this includes intimidation, unwelcome sexual advances, threats and acts
of violence.
> Zero tolerance. We do not tolerate any form of harassment or violence or any action that
creates a threatening workplace; this includes any attitude, form of behavior or situation that
may be specified as harassment. Any breach of the rules may result in disciplinary sanctions.

WHAT IS EXPECTED OF ME?

> I do not make remarks, jokes or display material that may offend a member of a particular
race, religion or gender as this could be considered harassment.
> I must respect others, and I must not accept any form of harassment or violence in
the workplace.
> I must not tolerate or engage in any form of retaliation, revenge or victimization with regard
to an individual who has claimed to be harassed.

PRACTICAL EXAMPLES
My team leader can be quite demanding and One of my fellow team members always stands
intimidating. He/she often makes unreasonable very closely behind me and touches my back
requests, argues and makes fun of me in front of my and shoulders while I am working at my desk.
fellow team members. Is this a form of harassment? It makes me feel very uncomfortable.
If your team leader is intimidating or treats you with Is this a form of harassment?
disrespect this could be classified as harassment. This could be a form of harassment. If you can, ask
If you feel that you or any of your fellow team members your fellow team member to refrain from touching you.
are not treated professionally you can raise the issue If you feel that the matter has not been addressed
directly with your team leader. If you feel uncomfortable properly, you can raise the issue with your team leader.
with this approach, discuss the matter with your human If you feel uncomfortable with this approach, discuss
resources manager instead. the matter with your human resources manager instead.

DISCUSS OPENLY AND SHARE YOUR CONCERNS: If you are facing an issue involving harassment, do not keep it
to yourself. You will get help and support by discussing it with your team leader or your human resources manager.

18 Capgemini. Our Code of Business Ethics

2.4 Open dialogue

We believe that effective communication is a prerequisite

for an open and inclusive culture.

WHAT DOES THIS MEAN?

> Open dialogue. Our Values of “Team spirit” and “Trust” encourage us to work together and to
recognize the importance of open dialogue. We strongly encourage open dialogue through
team meetings, conference calls, forums and employee surveys, in which we can express our
opinions freely.
> Open and constructive employee relations.
— We facilitate open dialogue through our International Works Council (IWC), the official
representative body of the Group, enabling dialogue between Group management and
people representatives across the Group.
— At the local level, we support open dialogue with people representatives or other
relevant employee representative bodies, and follow the processes provided for under
local legislation, regulations and agreements.
— We uphold freedom of association.

WHAT IS EXPECTED OF ME?

> I make sure that we have an open and inclusive culture and that I engage positively in open
dialogue, focusing on successful outcomes.
> Whether as a team member or a team leader it is important that I understand and live
the Values of the Group: this will enable me to encourage and support an environment of
open dialogue.

PRACTICAL EXAMPLES
I am a new team leader. What is expected of me to I’ve filled in the employee survey and have
make sure I maintain an open dialogue with my team not had any feedback or results. Should I have
members? received something?
As a team leader, you should set up regular team Yes. We encourage open dialogue and we use
meetings or conference calls that enable dialogue and our employee survey as a way to give you the ability
address the concerns of your team. to freely express your views. It is the role of the team
leader to make sure that the results are discussed
and fed back to you.
If you are a team leader it is your responsibility to make
sure that you implement the action plans, resulting from
the survey, for your area of responsibility.

DISCUSS OPENLY AND SHARE YOUR CONCERNS: If you are facing an issue involving open dialogue, do not keep
it to yourself. You will get help and support by discussing it with your team leader or your human resources manager.

19
Section 2: People

2.5 Behavior at work

and work-related events
As representatives of the Group our behavior at work and
work-related events can have an effect on the Group and our
own professional reputation. We are expected to respect
socially acceptable rules of behavior.

WHAT DOES THIS MEAN?

> Professionalism. We are expected to respect personal and cultural differences to ensure
that everyone enjoys a comfortable atmosphere at work and work-related events. We need
to make sure there is no sense of exclusion, discrimination or harassment.
— At any work-related event, we are all responsible for ensuring our behavior is professional,
reasonable and appropriate and that it does not damage the Group’s or our own
professional reputations.

WHAT IS EXPECTED OF ME?

> I am sensitive to personal beliefs and cultural differences and I do not impose my personal
opinions on others at work and work-related events.
> At work and work-related events, I must not let alcohol affect my behavior and judgment.
I must not engage in the unlawful use or possession of drugs and I must respect the relevant
smoking policies.
> If I am at a business event, I must remember that I represent the Group so I need to be aware
of how my behavior will be perceived by others.

PRACTICAL EXAMPLES
I attended a social event organized by my department During a work-related event, the discussion
and was uncomfortable with the amount of alcohol turned to politics. My colleague took an aggressive
consumed. Is this behavior appropriate? approach to push his/her political opinion.
When we are at a social event organized by the Group, we Is this appropriate?
are expected to behave appropriately. Consumption The Group respects personal opinions. However,
of alcohol during work-related events should not affect these should not be used to convince or manipulate
our behavior or judgment. This also applies to Group fellow team members.
training sessions at internal and external locations. It is worth remembering that topics involving politics,
In addition, as team members of a multi cultural Group, religion and sexuality can be highly sensitive, and
we must show respect and consideration for different you should consider refraining from addressing topics
cultures. In many countries where the Group operates, that may be deemed personal, objectionable or even
and for many of our people, alcohol is restricted or offensive.
even prohibited.

DISCUSS OPENLY AND SHARE YOUR CONCERNS: If you are facing an issue involving behavior at work and work-
related event, do not keep it to yourself. You will get help and support by discussing it with your team leader or your
human resources manager.

20 Capgemini. Our Code of Business Ethics

3. Business
Integrity
As a business we are
committed to act responsibly
in the market place.

21
Section 3: Business Integrity

3.1 Fair competition

The Group competes vigorously but fairly for its clients’

business. The majority of the countries in which we operate
have competition or antitrust laws, and trade regulations
designed to protect such competition. The Group is commit­
ted to comply with all applicable competition and antitrust
laws, and regulations.

WHAT DOES THIS MEAN?

> The basic rule. While the specific competition laws of each country (also called “antitrust
laws” in certain countries) vary, there are a number of common themes:
— Prohibited agreements and practices. Agreements (written or simply understood) to
fix prices, allocate clients or markets, coordinate bids, undertake boycotts, or exclude
competitors are generally not permitted. Practices among companies that have the same
effect or object as such agreements are also prohibited.
— Unlawful dominance. Large market players in certain markets have less flexibility in
making specific business decisions, including refusing to deal with other companies and
making acquisitions.
> Prohibited conduct. We do not discuss, provide to or exchange with a competitor: prices,
terms of sale, division of markets (whether by geography, product or otherwise), allocation
of customers, costs, profits or profit margins, or other activity that may restrain competition.
> Understand the consequences. Even being accused of violating these laws can have serious
consequences both for the Group and its team members. The Group could be forced to pay
significant criminal and civil fines or settlements; and individual employees may face large
fines, years of imprisonment and disciplinary actions.
> Consult the experts. The legal department is there to help you understand and comply
with complex competition and antitrust laws. Ask questions if you have concerns about the
Group’s behavior or our business partners’ and suppliers’ behavior.

The Group has provided detailed guidance on compliance with competition laws in the Group
Competition Laws Policy, available on your Group and local websites—see Appendix for the link.

WHAT IS EXPECTED OF ME?

> It is my responsibility to read and understand the Group Competition Laws Policy so that
I do not enter into any improper practices.
> It is my responsibility to seek help from the legal department if and when there is any question
or doubt as to how the Group Competition Laws Policy is applied in a given situation.
> I must be careful about how I interact with the Group’s competitors at conferences, events and
industry associations and social functions, and be mindful of the appearance of impropriety.
> I should not use unlawful or unethical means to obtain competitors’ information.
> I should be aware that any verbal or written exchange with competitors may be damaging
to the Group.
> I must respect my own and other people’s prior employment obligations and should not force
anyone to violate any of their obligations towards previous employers.

DISCUSS WITH A LAWYER IN THE LEGAL DEPARTMENT: If you are facing an issue involving fair competition and
competition laws, do not keep it to yourself. You should discuss the issue directly with a lawyer in the legal department.

22 Capgemini. Our Code of Business Ethics

PRACTICAL EXAMPLES

At an industry event, one of my counterparts, a competitor,

tells me that his or her group is planning to increase
its fees by 17% across the company in the coming year,
and asks what our plans are. What should I do?
Competitors should not share information about their future
pricing plans. You should immediately tell your counterpart
that his or her comment and question are inappropriate, and
make a memorable exit from the room.
Call your legal department to tell them what happened and
how you responded.
Failure to take either of these steps can lead to years of
investigations, litigation, and, potentially, prison time.

I have worked with a number of different clients in one

specific industry. What should I do if they ask me about their
competitors’ practices?
You should tell the client that protecting our clients’ privacy
is very important to us. The client should appreciate that, just
as we will not tell their competitors what they are doing, we will
not tell them about the competitors.
In addition to being the ethical response to such a question,
this also protects the Group from being seen as aiding industry
participants in coordinating their conduct through the exchange
of competitive sensitive information in violation of competition
and antitrust laws.

I am responding to a tender from a client when one of my

counterparts, a competitor, calls me to discuss the bidding
process and tells me that his or her company will only bid
for a portion of the project. He or she is wondering whether
we would be bidding for the same portion or whether
we would not be more interested in the client’s business
in other parts of the world. What should I do?
In many countries sharing information on tenders and how
competitors will bid is a criminal offense. You should immediately
tell your counterpart that his or her inquiry is inappropriate and
terminate the telephone call.
Call your legal department to tell them what happened and
how you responded.
Failure to take either of these steps can lead to years of
investigations, litigation, and, potentially, prison time.
Remember that even an oral contact by telephone can be
proved by telephone logs, so do not underestimate the
potential damage of such contacts.

23
Section 3: Business Integrity

3.2 Bribery and corruption

Our ability to win business depends solely on the value we

bring to our clients. The Group is committed to preventing
any violation of anti-corruption and anti-bribery laws in
every jurisdiction in which it operates.

WHAT DOES THIS MEAN?

> Comply. Bribery, including influence peddling, is an offense carrying criminal and civil
penalties in most jurisdictions where we operate.
— Anti-bribery and anti-corruption laws prohibit offering, promising or paying anything
of value to obtain an undue advantage from a government official or any private
individual—such as to act or refrain from acting in a manner that is favorable to the
Group or to any of its clients.
— The definition of “government official” in anti-corruption laws is broad, and it includes,
among other persons, employees of companies that are partially owned by a government
agency, as well as employees of political parties and candidates of political office.
— Further, it is prohibited to request or authorize any third party to make any such offers,
promises or payments.
— It is also prohibited to receive anything of value from any individual which is or may be
perceived to be given to influence the Group or any of its clients.
> Commissions. In the course of our sales activities, we do not tolerate any payment of
commission to third parties nor do we accept any commission from third parties unless
specifically authorized by the Group. When authorized by the Group, we may receive referral
fees from third-party vendors such as third-party software or hardware companies. However,
these referral fees should always be made transparent to the client.
> Understand the consequences. Failure to comply with anti-corruption and anti-bribery
laws not only exposes the Group to civil and criminal penalties, but could subject any team
member to civil penalties, criminal punishment—including possible imprisonment—and
disciplinary action.
> Zero tolerance. The Group has zero tolerance for any form of bribery and corruption or any
acts that may be perceived to be bribery or corruption. Toleration of bribery or corruption
is unacceptable business conduct wherever the Group operates.

We have provided specific guidance on this topic in the Group Anti-Corruption Policy—
see Appendix for the link.

WHAT IS EXPECTED OF ME?

> It is my responsibility to know, understand, and comply with the Group Anti-Corruption Policy
and to complete the mandatory trainings on the topic.
> It is my responsibility to know, understand and comply with the anti-corruption and anti-
bribery laws in the jurisdictions were I work.
> It is my responsibility to seek help from the legal department if and when there is any
question or doubt as to how to comply with the Group Anti-Corruption Policy.

DISCUSS WITH A LAWYER IN THE LEGAL DEPARTMENT: If you are facing an issue involving bribery and corruption,
do not keep it to yourself. You should discuss the issue directly with a lawyer in the legal department.

24 Capgemini. Our Code of Business Ethics

PRACTICAL EXAMPLES

I am about to give a small gift to our client.

What steps should I follow before doing so?
Before giving any Group client a gift, you should assess
whether that gift is permitted by applicable laws,
the Group Anti-Corruption Policy and the known internal
rules of the recipient’s employer. Gifts must only occur
in connection with a legitimate business, not be made to
gain an undue advantage or unduly influence an action,
and must have a reasonable value and be infrequently
given to the same recipient. If intended for public officials,
any entertainment, gift or travel must be cleared in advance
by your legal department. You must abide by any advice
given to you. You will find additional practical examples in
the Group Anti-Corruption Policy.

25
Section 3: Business Integrity

3.3 Conflict of interest

We must be careful not to take actions that may conflict

with the Group’s interests or could lead to damaging
its reputation.

WHAT DOES THIS MEAN?

> Loyalty and good faith. As an employee of the Group, we are bound by a duty of loyalty
and the obligation to act in good faith.
> Conflict of interest. A potential conflict of interest arises when we have several
contradictory interests at the same time. When a personal interest is in contradiction
to the Group’s interests, we risk violating our duty of loyalty. This occurs any time the
potential for direct or indirect personal gain can or does influence a decision connected
to our business. Consequently, we must avoid situations where our personal interests
could conflict with the Group’s interests.

We have provided detailed guidance on conflicts of interest in the Group Conflict of

Interest Policy—see Appendix for the link

WHAT IS EXPECTED OF ME?

> I must not engage in outside activities that compete with the Group or assist a Group
competitor.
> I must report any potential conflict of interest to my team leader or human resources
manager.
> I must award business solely on the basis of merit and not on the basis of personal
relationships or potential personal gain.
> I must not use or disclose any business information or opportunities obtained through my
work for personal advantage or personal gain.
> If I am unsure whether my interest puts me in a potential situation of conflict of interest,
I should discuss the matter with my team leader.

PRACTICAL EXAMPLES
My partner works for a competitor. What should I be aware of? One of my close family relations works at
You should be aware that this is an extremely sensitive situation a leading recruitment agency that we often
and should be disclosed in writing to your manager. If you and use. Is this a potential conflict of interest?
your partner discuss any business information whatsoever you risk It depends on several factors such as the
violating the competition laws in your country. Both you and your individual handling the agency in question,
partner could be committing a criminal act if you discuss pricing or what your role is, or what your close relation’s
business opportunities. role is. Because this situation presents a potential
You should know what these laws are, and, if you have any doubt conflict of interest, you should be transparent
whatsoever about them, consult your Country’s Ethics & Compliance about the issue and notify your team leader.
Officer. Appropriate measures should be taken, such as
In addition, discussing business information with your partner may ensuring you are not involved on the account,
violate confidentiality obligations. to avoid any appearance of a conflict of interest.

DISCUSS OPENLY AND SHARE YOUR CONCERNS: If you are facing an issue involving a conflict of interest, do not keep
it to yourself. You will get help and support by discussing it with your team leader or your human resources manager.

26 Capgemini. Our Code of Business Ethics

3.4 Insider trading

We have to exercise the utmost caution when considering

transactions that involve the shares of the Group, of our
clients, business partners or suppliers. Disseminating insider
information or making any transaction based on insider
information is prohibited.

WHAT DOES THIS MEAN?

> Zero tolerance. Insider information is any non-public information that, if known, would
reasonably be expected to be used by an investor in deciding whether to buy, sell or hold
such security.
— The Group strictly prohibits the trading of Capgemini SE shares or any other Group-
related securities during the “closed periods”—see Appendix for the link. Independently
of closed periods, we should not buy or sell Group shares and/or other related securities
when aware of any insider information. Similar restrictions apply to trading any publicly
listed shares or other related securities of the Group’s current or potential clients,
business partners or suppliers when in possession of insider information.
— Disseminating insider information or using insider information can lead to criminal
sanctions.

WHAT IS EXPECTED OF ME?

> I am prohibited from disseminating insider information.
> I am not allowed to make investment decisions based on confidential or insider information.
> When assigned to a project that involves a merger, acquisition or joint venture, I am expected
to disclose shares and other related securities that I hold in this other company, other than
those held through mutual funds or similar vehicles where I have no discretion.
> I am not allowed to buy or sell Capgemini SE shares or any other Group-related securities
during closed periods.

PRACTICAL EXAMPLES
Can I trade in Capgemini SE shares at any time I am working on a client system that gives me access
of the year? to client information. If I buy or sell these client
No. The Group has strict policies on this issue and shares, could this be considered insider trading?
has defined closed periods in which buying and selling Yes, especially if you have access to sensitive client
Capgemini SE shares or any other Group-related information. In addition, we may have to respect our
securities is prohibited. The Group notifies all team clients’ closed periods in the same way that we do
members of the closed periods. for our Group.

DISCUSS WITH A LAWYER IN THE LEGAL DEPARTMENT: If you are facing an issue involving insider trading, do not
keep it to yourself. You should discuss the issue directly with a lawyer in the legal department.

27
Section 3: Business Integrity

3.5 Accurate and

correct business and
financial information
We are responsible for ensuring that we maintain and release
accurate and correct business and financial information in a
transparent and timely manner.

WHAT DOES THIS MEAN?

> Commitment to accuracy. The Group is committed to communicate accurate and relevant
information to its shareholders on a regular basis.
> Group effort. We all create information relating to the Group, its clients, team members,
business partners or suppliers. We must ensure that we produce accurate and correct
business information and manage documents with the utmost care and to the best of our
knowledge.
> Zero tolerance. We must know and comply with all relevant laws, regulations and internal
rules concerning business information and, most importantly, financial business information.
Any infringement of laws and regulations can potentially result in fines and criminal charges.

WHAT IS EXPECTED OF ME?

> I must ensure I know and comply with all relevant legal, contractual and internal requirements
concerning the documentation and maintenance of business records relevant to my sphere
of influence.
> I must not produce any documentation that may mislead or deceive the recipient.
> I must obtain the relevant approval when responding to internal or external financial inquiries.
> I must securely store confidential business records (including back-ups).

PRACTICAL EXAMPLES
I have been contacted by an external party to provide financial I have to do several appraisals for
performance information on one of our Strategic Business Units. members of my team. Is there anything
Am I allowed to provide them with the information? I should be careful about in terms
No. The communication of financial information comes directly under of storing this information?
the responsibility of the Group CFO through either Group financial Yes. As with any other documented
control or the investor relations departments. You should not disclose information, all appraisal information needs
any financial performance information concerning the Group without to be accurate and stored centrally within
prior authorization. the appropriate local record management
system.

DISCUSS WITH A LAWYER IN THE LEGAL DEPARTMENT: If you are facing an issue involving accurate and correct
business and financial information, do not keep it to yourself. You should discuss the issue directly with a lawyer in the
legal department.

28 Capgemini. Our Code of Business Ethics

3.6 Political activities

The Group does not support political parties.

WHAT DOES THIS MEAN?

> No Group contributions. We do not make any cash or in-kind contributions to political
parties on behalf of the Group. This includes direct and indirect support through intermediary
organizations.
> Promote respect. We respect the rights of individuals to participate, as individuals, in politics.
However, we should never represent or endorse a political party on behalf of the Group.

WHAT IS EXPECTED OF ME?

> I should not use the Group’s name to endorse a political activity or event, or represent
the Group in any political activities.
> I will not use any of the Group’s resources or cash to make a contribution to a political party.

PRACTICAL EXAMPLES
My client is asking us to support their lobbying It appears that the political party in power is about
activities and they want us to add our name to their to change. Could we offer an Accelerated Solutions
lobbying list. Is this acceptable? Environment (ASE) for free to help one of the
No. Lobbying refers to trying to influence government political parties on their strategy formulation?
legislation, regulations or decision-making. You We should never make any cash donations or provide
should inform our client that we cannot lobby on behalf free use of the Group’s resources when dealing with
of our clients or support their lobbying activities. political parties since this may be considered a donation
or in-kind contribution in support of the political party.
Can I undertake lobbying activities? Is this However, we are allowed to treat political parties as
a political activity? clients and engage on a commercial, fee-paying basis.
Because lobbying implicates anti-bribery and anti- Because even this arrangement implicates anti-bribery
corruption laws—candidates and political parties may and anti-corruption laws—political parties may be
be deemed “government officials”—you should take deemed a “government official”—you should take great
great care. Any lobbying on behalf of the Group should care to involve a lawyer from your legal department, your
be approved by the Group and should be transparent. Country’s Ethics & Compliance Officer or the Group Chief
Ethics & Compliance Officer.

DISCUSS OPENLY AND SHARE YOUR CONCERNS: If you are facing an issue involving political activities, do not keep it
to yourself. You will get help and support by discussing it with your team leader or your human resources manager.

29
Section 3: Business Integrity

30 Capgemini. Our Code of Business Ethics

4. Business
Relationships
We are committed to
delivering value and building
longstanding relationships
based on mutual trust
with our clients and at
the same time achieving
a profitable and sustainable
growth for the Group.

31
Section 4: Business Relationships

4.1 Working with

our clients
We are dedicated to delivering profitable and sustainable
growth by working together with our clients to deliver value
through our expertise and behavior.

WHAT DOES THIS MEAN?

> Client first. We think “client first” and we measure our success in terms of the value we bring
to our clients. Delivering excellence to our clients is our priority.
— We mobilize the right talent to meet our client’s requirements.
— We respect our clients and we work in an open and transparent manner.
— As an independent IT services provider, we objectively evaluate software
and hardware solutions to meet the client’s requirements.
— We work collaboratively with our clients by building a long-term, distinctive
relationship based on mutual trust.
— We share our expertise and knowledge with our clients with a view to their short- and
long-term development and we learn from them for our own development purposes.
> Maintaining our standards. We expect clients to behave according to Group legal and
ethical expectations.

WHAT IS EXPECTED OF ME?

> I use all my talents and capabilities when I work with my client.
> I behave ethically and responsibly with my client.
> I listen to my client and work collaboratively.
> I understand the trust my client has in me and I take bold action to maintain it.
> I do not advise my client to do anything that I do not believe is aligned to his/her interests.
> I communicate openly with my clients. I am transparent and tell them the truth. In case of
delicate or bad news, I get appropriate advice from my team leader or management so I can
communicate openly with my client.

DISCUSS OPENLY AND SHARE YOUR CONCERNS: If you are facing an issue involving working with our clients, do not
keep it to yourself. You will get help and support by discussing it with your team leader or with your legal department.

32 Capgemini. Our Code of Business Ethics

PRACTICAL EXAMPLES

A client wants us to undertake a project but I am of the opinion

that there is no real business case and that this is not the right
course of action. What can I do?
If you consider that the project will not generate real value for the client or
if the solution requested by the client will not provide a suitable answer to
the business problem, you should first try to influence the client’s point of
view. Ultimately, if you feel you are acting against the client’s interest, you
should decline the project.

My client asks me, in the spirit of collaboration, to perform extra

work without the corresponding change order request or price
adjustment. Is this acceptable?
No. You should follow the specified Group processes and make sure
you do not over-deliver with regard to the contract. You should always
ensure that a corresponding change order and, if appropriate, price
adjustment is completed. Being paid appropriately for a service should
not affect good collaboration.

My client has suggested that sponsoring its annual sports event would
help us to obtain a particular deal. What can I do?
You cannot enter into this type of reciprocal bargaining process because
developing good, long standing collaboration with clients does not imply
accepting unfair sales methods. This type of reciprocal dealing could
also raise bribery concerns in certain jurisdictions.

I am about to make a deal with a client for whom I know some referral
fees will be paid by a supplier to the Group. What should I do?
You should adopt a transparent attitude and tell the client. However,
in some countries, giving or receiving referral fees in connection with
obtaining or retaining business may be prohibited. You should know and
follow that country’s law with respect to giving or receiving referral fees.
If you have any doubt about legality, consult your legal department.

My client’s team received a special team bonus for their good

work, to which I contributed substantially. They propose that
I should be given a share of the bonus. Can I accept?
No. You cannot accept a payment by the client or its employees. To do
so would compromise your position and your affiliation to the Group.

My client, who is also a Group service provider, is trying to impose

contractual terms upon us which are unreasonable and quite different
from those we are negotiating with them as one of our suppliers.
Can we use this opportunity to redress the balance and ask for
“reciprocal treatment”?
Yes, it is perfectly acceptable to seek similar terms and conditions when we
negotiate with the same party both as a client and as a provider. However,
you should take into account the context of the situation (including, if
relevant, the sales strategy) and the relevant bargaining positions of either
party when taking this approach.

33
Section 4: Business Relationships

4.2 Working with

our alliance and other
business partners
We work with alliance and other business partners to bring
added value to our clients, and expect our partners to comply
fully with the law.

WHAT DOES THIS MEAN?

> Ethical collaboration. We work with our business partners in a collaborative and ethical way
to deliver value to our clients.
— We work with business partners who have values and modes of behavior that are aligned
to our principles.
— We are transparent with our clients about our relationships with our business partners.
Our clients will be informed of any business relationships or referral fee agreements we
have with respect to the services we are offering them. The disclosure must be in writing,
and may be a general advance notice in the client contract terms.
— We understand that, when dealing with public sector clients, it could be illegal for the
Group to receive any referral fees.
— We expect our business partners to comply with the law, including laws prohibiting
bribery and corruption and fair competition.

WHAT IS EXPECTED OF ME?

> I will not make an agreement with a business partner that is against the interests of our client.
> I will not make an agreement with a business partner that violates the law.
> I will work collaboratively and ethically with our business partners and ensure that clients are
aware of our relationships with business partners.

DISCUSS OPENLY AND SHARE YOUR CONCERNS: If you are facing an issue involving working with our alliances and
others business partners, do not keep it to yourself. You will get help and support by discussing it with your team leader
or your legal department.

34 Capgemini. Our Code of Business Ethics

PRACTICAL EXAMPLES

We are bidding with one of our business partners for a large

international project where we have a referral fee agreement.
This agreement includes a country where there may be restrictions
on referral fees, although I am unsure of this fact. How do I find
out whether I could be offering something illegal?
In some countries, the giving or receiving of referral fees in connection with
obtaining or retaining business is a criminal offense. You should know and
follow that country’s law with respect to receiving referral fees. If you do not
know such country’s law or have any doubt whatsoever about the legality
of referral fees, you should consult your legal department. If the Group
can lawfully receive referral fees in the country in question, you should be
transparent and inform your client about such fees.

One of our business partners offers a comprehensive and

well-known solution whereas an alternative open source solution
exists, which may be used free of charge. What can I do?
You should always take the client’s interests into account and never
advise anything that does not concur with your client’s interests. An open
source solution, while free, may not be the best solution for the client.
Each case should be judged on its own merits. You should always
communicate openly with clients and ensure you are acting in the best
interests of your client. If the client’s and the Group’s interests conflict
or appear to conflict, you should discuss them with your team leader
and take his/her advice.

35
Section 4: Business Relationships

4.3 Working with

our suppliers
We work with our suppliers and commit to sound and
sustainable procurement procedures. We expect our
suppliers to comply fully with the laws in the countries in
which they operate.

WHAT DOES THIS MEAN?

> Fair and ethical treatment. We are committed to treating our suppliers and contractors
fairly and we expect our suppliers to conduct their business with us on a fair and ethical basis.
— We strongly discourage reciprocal dealings, such as agreeing to buy from suppliers
provided they buy from us.
— We expect our suppliers to conduct their business with us on a fair and ethical basis
and in compliance with our Supplier Standards of Conduct—see Appendix for the link.
— We expect our suppliers to comply with the laws of the countries in which they operate,
including laws prohibiting bribery and corruption and fair competition.

WHAT IS EXPECTED OF ME?

> I am expected to treat suppliers fairly and make decisions based on quality and price.
> I will never agree with our suppliers to do anything that would be against the interests of our
client.
> I will not make an agreement with our suppliers that violates the laws of the country or
countries in which I work.
> If I am procuring anything on behalf of the Group, I must follow the Supplier Standards of
Conduct when selecting new or evaluating current suppliers.
> I will refrain from reciprocal dealings without specific authorization.

PRACTICAL EXAMPLES
I recently went on a site visit to one of I am in negotiations with the procurement officer
our key suppliers and I am concerned about of one of our key suppliers. I think the supplier can
their environmental practices. What should I do? benefit from our Group services. Can I propose that
Raise your concern with your team leader or your local they buy our products in return for keeping
procurement team. The Group has a Supplier Standards our business?
of Conduct in place to monitor the environmental No. As a Group we refrain from reciprocal dealings,
and social practices of our suppliers in order to ensure only in exceptional situations and with prior authorization
a sustainable supply chain. is this allowed.

DISCUSS OPENLY AND SHARE YOUR CONCERNS: If you are facing an issue involving working with our suppliers,
do not keep it to yourself. You will get help and support by discussing it with your team leader or your legal department.

36 Capgemini. Our Code of Business Ethics

5. Group and
Third-Party Assets
We are expected to maintain
the security and integrity of
the assets of the Group and
of the third-parties we work
with. We use them responsibly
and professionally.

37
Section 5: Group and Third-Party Assets

5.1 Intellectual property

Intellectual property is one of the Group’s most valuable

assets. We need to ensure the validity and integrity of
all intellectual property rights belonging to the Group,
through copyrights, patents, trademarks, trade secrets and
confidentiality. We must respect the intellectual property
rights of our clients, competitors, business partners and
suppliers.

WHAT DOES THIS MEAN?

> Group property. Any intellectual property produced by Group employees while working for
the Group remains the property of the Group or of its clients, depending on the terms of the
contract signed with the relevant client.
— We should not put at risk any Group or client intellectual property, whether or not formally
protected, during our employment or after we have left the Group.

WHAT IS EXPECTED OF ME?

> I need to understand the concept of intellectual property.
> I must ensure that I correctly use any intellectual property owned by the Group or by any
third-party.

PRACTICAL EXAMPLES
I am working in a team that is developing I just did some research on our competitors and
a new methodology. Can I personally re-use the found a great offering. Can I copy the offering and
methodology outside my work with the Group? modify the material for our own offer development?
No. Any intellectual property, including methodology, No. We do not take any third-party intellectual property
software, hardware, processes, tools and know-how without authorization. Unauthorized use of others’
produced while working for the Group remain the intellectual property can expose the Group and even
property of the Group or of its client. individual team members to civil law suits and damages.

DISCUSS OPENLY AND SHARE YOUR CONCERNS: If you are facing an issue involving intellectual property, do not keep
it to yourself. You will get help and support by discussing it with your team leader or your legal department.

38 Capgemini. Our Code of Business Ethics

5.2 Confidential
information
We are expected to preserve confidential information
belonging to the Group or our team members, clients,
business partners and suppliers.

WHAT DOES THIS MEAN?

> Confidential information. Information is deemed “confidential” if it is defined as such by law
or by contract. The following categories of information are almost always confidential:
— Information provided by our clients, suppliers, and business partners that the Group has
committed not to disclose.
— Information regarding our commercial and economic strategy.
— Information about our recruitment and wage policies.
— Personal data.
— Know-how, trade secrets, patents and software developed within the Group.
> Protection. We take appropriate and reasonable measures, including relevant security
measures, to protect confidential information concerning the Group, its team members,
clients, business partners and suppliers:
— We must maintain the confidentiality of our clients’ or suppliers’ business information.
We must strictly adhere to any commitments the Group has made to a client, a business
partner or a supplier with regard to confidentiality. When working for several clients,
we must take the necessary steps to protect against the transfer of their confidential
information from one client to another.
— When our employment with the Group ends, we are required to return all confidential
information in our possession and respect our confidentiality obligations.

WHAT IS EXPECTED OF ME?

> I am expected to protect the Group and our team members’, clients’, business partners’ and
suppliers’ confidential information from unauthorized disclosure or access.
> I must avoid discussing confidential information in public where conversations can be overheard.

PRACTICAL EXAMPLES I often travel and I like to save confidential data

on a USB key. Is this appropriate?
I often work off site or at home. What are my responsi­bilities If you travel frequently and need to have confidential informa­
in terms of confidential information? tion on a USB key or any other portable device, you should get it
All confidential information should be treated with the same encrypted to prevent it from unauthorized use or disclosures.
standards of security whether off site or in the office. Hard copies
must not be accessible to unauthorized parties and must be I am very active on social networks. Can I make
disposed of appropriately. It is advisable to avoid taking confidential refe­rence to my current role and responsibilities
hard copies outside the office environment. within the Group on these websites?
Yes. You are allowed to profile your role and responsibilities,
I am traveling with a colleague to an off-site location. as long as you do not disclose any confidential information.
Is it appropriate to talk about work in public? However, given today’s world it may be advisable to minimize
You can talk about work but should be careful your conver­sation or even refrain from making such references in case your
is not overheard. You should not mention the name of the Group, comments are taken out of context. Always remember your
any client, business partner or individual names where they can be association with the Group in a social network. You should not
overheard. Take extra care when participating in phone calls in public represent or speak on behalf of the Group unless explicitly
spaces or using your laptop when people can look over your shoulder. authorized to do so.

DISCUSS OPENLY AND SHARE YOUR CONCERNS: If you are facing an issue involving confidential information, do not
keep it to yourself. You will get help and support by discussing it with your team leader or your legal department.

39
Section 5: Group and Third-Party Assets

5.3 Protecting
personal data
Legal data protection and legal data security are crucial for
each affiliate of Capgemini. The financial and reputational
risks are high. Capgemini has created a strong internal data
protection organization and a solid Data Protection Program
to protect the company against these risks.

WHAT DOES THIS MEAN?

> A broad notion. The notion of personal data is very broad since it refers to any type of
data which enables to identify an individual either directly or indirectly. As a result, not only
information such as the name, last name, email address will be considered as personal data
but also information such as log information, IP addresses since these data enable to identify
the individual indirectly.
> An extensive application. It has to be noted that data protection regulations apply to
any processing of personal data irrespective of the context in which the personal data is
being processed. In other words, personal data processed in the business context or in an
employment relationship are subject to the same rules as in relation to private processing
activities.
> Data protection is not only a EU centric matter. Although data protection is very often
perceived as a European centric matter, it has to be noted that more and more legislations
out of the EU are adopted in relation to the protection of personal data and they are very
much influenced by the European legal requirements. Moreover, Capgemini is convinced that
for data protection obligations to be effectively implemented throughout the organization,
it needs to apply the same principles irrespective of the geographies.
> Rules apply also for data processing. Capgemini takes data protection very seriously and
has therefore defined a range of policies and procedures which define the commitments
Capgemini takes when processing personal data both on its behalf and on behalf of its
customers.

WHAT IS EXPECTED OF ME?

> I must follow the Data Protection training which is available on MyLearning.
> Always make sure that when I collect personal data it is for a specific reason and that
the personal data I collect are only those which I strictly need. I don’t collect personal data
just in case they may be useful in the future.
> I should document properly the processing activities I launch using the tools provided by the
data protection community.
> I should comply with Personal Data Protection laws of jurisdictions from which the personal
data is collected and in which it is processed or used.

DISCUSS OPENLY AND SHARE YOUR CONCERNS: If you are facing an issue involving protecting personal data, do not
keep it to yourself. You will get help and support by discussing it with your local Data Protection Officer.

40 Capgemini. Our Code of Business Ethics

PRACTICAL EXAMPLES

A business partner wants to send his/her training opportunities

to everyone in my department and has asked me for the e-mail list.
Can I provide the list to him/her?
No, before sharing such information you need to verify with your local
Data Protection Officer what is the way forward. Your local Data Protection
Officer will help you determining which are the measures to take into
account and to implement.

We entered into a contract, with a client based in the European

Union (EU), which will require the handling of personal data relating
to their clients and employees. Part of the services are rendered
by the Group in India. Can I send personal data to India?
In the EU, stringent laws regulate the protection of personal data.
When exported outside the EU, we need to offer at least an equivalent
level of protection. For this very purpose, Capgemini has adopted Binding
Corporate Rules which guarantee that any personal data transfer to
another Capgemini entity out of the EU benefit from an adequate level
of protection. However, in order to tackle the different requirements
inferred by a data transfer to or access from Capgemini India, please revert
to your local Data Protection Officer.

I have received information, sent in error, concerning the salaries

of my team members. What should I do?
As soon as you become aware of this you should avoid reading and using
the information. Delete the email and contact the person who sent
it to you. If you receive a hard copy, return it to the sender in a sealed
envelope. You should not use this information in any way for any purposes.
You should also contact immediately your local Data Protection Officer or
the competent cybersecurity officer to report this incident.

41
Section 5: Group and Third-Party Assets

5.4 Appropriate use

of Group and third-party
assets and resources
We are personally accountable for the protection of the Group
and third-party assets and resources under our control.

WHAT DOES THIS MEAN?

> Responsible and professional use. We use assets and resources that belong to the Group
to help us achieve our business goals.
— We take care of third-party assets and resources as if they are our own.
— We must not access, use or attempt to use Group or third-party electronic resources to
access, store, send, post or publish material that is inappropriate. This includes material
that is pornographic, sexually exploitative, obscene, racist, sexist or in any other way
discriminatory, threatening or harassing, personally offensive, defamatory or illegal.
— We are expected to take the necessary steps to protect any assets and resources of
the Group and/or third-parties which are under our control against loss, theft and
unauthorized disclosure.

WHAT IS EXPECTED OF ME?

> I take care to protect Group and third-party assets and resources.
> I must use the Group’s physical and electronic resources only for business purposes, except
for minor circumstances in which personal use is permitted.
> I acknowledge that use of the Group network to transmit or store material is under the
control of the Group.
> I am expected to read and understand my local IT security or use policy.

PRACTICAL EXAMPLES
I am organizing a large personal event outside I am going out for lunch. What should I think about
work and need to make sure I have enough flyers in terms of security before I leave my desk?
to distribute. Can I use the Group photocopiers? Where applicable, always wear your security pass,
No. This is not appropriate use of Group resources. lock your computer/laptop screen and make sure that
any confidential or sensitive information is stored away.
Can I use my work Internet access to browse If you have a laptop, make sure it is physically locked
the Internet for personal purposes? to prevent loss or theft.
Limited use of communication tools such as e-mail
and the Internet may be acceptable, as long as it does
not incur any costs and does not interfere with your
job responsibilities.
In general, during non-working hours you may use your
professional laptop incidentally for personal purposes.
However, you must not install unauthorized software.

DISCUSS OPENLY AND SHARE YOUR CONCERNS: If you are facing an issue involving the appropriate use of Group and
third-party assets and resources, do not keep it to yourself. You will get help and support by discussing it with your team
leader or your human resources manager.

42 Capgemini. Our Code of Business Ethics

6. Corporate Social
Responsibility
As responsible citizens,
we support the communities
and respect the environment
in which we operate.

43
Section 6: Responsible Citizenship

6.1 Contributing
to the communities
The Group wishes to have a positive impact on the
communities in which it lives and operates. As a major
global employer, it works with national and international
organizations on community projects.

WHAT DOES THIS MEAN?

> Community, education and diversity. We focus on community projects that are aligned
with our corporate purpose and values. Our main community projects focus on the themes of
education and diversity.
> Get involved. We actively encourage team members, at all levels, to get involved in our
community activities and donate time, energy and creativity.

WHAT IS EXPECTED OF ME?

> I am encouraged to participate in our community activities.
> I will obtain relevant approvals before using work time for community projects.
> I will obtain the relevant approvals before using the Group name and resources to support an
organization.

PRACTICAL EXAMPLES
I would like to participate in a volunteering activity I am actively involved with a local community group
with our local charity during a working week. Does and we are organizing a large event. Can the Group
the Group allow for volunteering days? sponsor or donate meeting rooms for the event?
Check your local policies on what is allowed. In some Any donations, gifts or in-kind contributions need to
countries, certain Group companies allow for a number be approved. Check with your team leader what level
of days to be booked for volunteering, especially when of approval is required. The legal department, tax
participating in a volunteering event with an organization department, the human resources department and even
supported by the Group. the communications department may be involved. Also
check whether the organization you wish to donate to
complies with Group policies; the Group does not sponsor
religious or political organizations.

DISCUSS OPENLY AND SHARE YOUR CONCERNS: If you are facing an issue involving contributing to the communities,
do not keep it to yourself. You will get help and support by discussing it with your team leader or your human resources
manager.

44 Capgemini. Our Code of Business Ethics

6.2 Minimizing our impact
on the environment
We recognize that business activities have impacts on the
environment, and we are committed to minimizing these
impacts.

WHAT DOES THIS MEAN?

> Respect the environment. The Group is committed to identifying and complying with any
legal and other relevant requirements related to the environmental impacts of its operations.
— We seek to minimize the negative environmental impact of the Group’s business activities.
These include greenhouse gas emissions from energy consumption in our offices, data
centers and business travel; our waste and IT asset management; and our procurement
activities.
> Innovate to reduce impact. We use and adapt our capabilities and expertise to help our
clients reduce their environmental impact and meet their environmental objectives.

WHAT IS EXPECTED OF ME?

> I adhere to environmental laws and relevant Group and local policies.
> I am expected to minimize the impact of my work on the environment. This includes developing
innovative offers to clients and striving to minimize negative environmental impact, saving
energy in our offices and data centers, making informed choices on business travel and in
procurement activities, contributing to recycling schemes and other environmental initiatives.
> I seek ways to innovate with my clients to leverage our business and technology knowledge
to help our clients with their environmental objectives.

PRACTICAL EXAMPLES
I am traveling abroad and there is an option to I am always told to switch off lights and print
go by train or by plane. What do I choose? double-sided. Do my personal actions really make
First of all check whether it is essential to travel. a difference?
The Group offers numerous virtual working tools, In many of the countries in which we operate, we have
such as videoconferencing. If you do need to travel, implemented successful environmental initiatives such
look to balance time, costs and environmental impact. as switching to double-sided printing, which has
This will help you to make the appropriate solution dramatically reduced paper consumption. Your individual
that can support the priorities of our environmental contribution makes a difference. In a Group of our
objectives balanced with the needs of our business. size, everyone saving several sheets of paper a day
or switching off the lights soon adds up.

DISCUSS OPENLY AND SHARE YOUR CONCERNS: If you are facing an issue involving a particular impact on the
environment, do not keep it to yourself. You will get help and support by discussing it with your team leader or your
human resources manager.

45
Appendix
1. Code of Business Ethics
https://talent.capgemini.com/global/pages/about_us/our_group/ethicsandcompliance/policies__guidelines/policies/code_of_business_ethics/

2. Group Conflict of Interest Policy

https://talent.capgemini.com/global/pages/about_us/our_group/ethicsandcompliance/policies__guidelines/policies/conflict_of_interest/

3. SpeakUp Policy
https://talent.capgemini.com/global/pages/about_us/our_group/ethicsandcompliance/speakup/

4. Ethics & Compliance Talent Hub

https://talent.capgemini.com/global/pages/about_us/our_group/ethicsandcompliance/

5. Ethics & Compliance Network

https://talent.capgemini.com/global/pages/about_us/our_group/ethicsandcompliance/ethics__compliance_network_new/

6. Blue Book
https://talent.capgemini.com/global/pages/about_us/our_group/ethicsandcompliance/policies__guidelines/policies/blue_book_intro/

7. Group Anti-Corruption Policy

https://talent.capgemini.com/global/pages/about_us/our_group/ethicsandcompliance/policies__guidelines/policies/Group_Anti_Corruption_Policy/

8. Group Competition Laws Policy

https://talent.capgemini.com/global/pages/about_us/our_group/ethicsandcompliance/policies__guidelines/policies/group_competition_laws_policy/

9. Supplier Standards of Conduct

https://talent.capgemini.com/media_library/Medias/About_Competitiveness_in_Action/Capgemini_Supplier_Standards_of_Conduct_-_V5.2.pdf

10. Social Media Guidelines

https://talent.capgemini.com/global/pages/about_us/global_functions/ethicsandcompliance/policies__guidelines/guidelines/social_media_guidelines/

11. Closed Periods

https://talent.capgemini.com/global/pages/hubs/global_functions/Finance_Community/Rules_and_Policies/closed_periods/

The information contained in this document is proprietary.

Copyright © 2020 Capgemini. All rights reserved.
Graphic design: Avant Midi. April 2020 — Version 2.8

46 Capgemini. Our Code of Business Ethics

Contact:
Philippe CHRISTELLE
Chief Ethics & Compliance Officer
Chief Audit Officer

Capgemini
Place de l’Étoile – 11, rue de Tilsitt
75 017 PARIS – France

The Ethics & Compliance Hub

on Talent website:
http://talent.capgemini.com/
ethicsandcompliance

47
Learn more about us at

www.capgemini.com