Ethics and loyalty of practices

/ October 09, 2023

Our ethics charter is based on 9 principles:
1.   Respecting human rights and the dignity of every individual;
2.   Work together;
3.   Protecting our tangible and intangible assets;
4.   Comply with applicable laws and regulations;
5.   Fight against fraudulent behavior;
6.   Prevent all forms of corruption;
7.   Respect the principles of loyalty, fairness and integrity;
8.   Respect the corporate image;
9.   Comply with the measures taken to protect the environment.

For more information, you can consult our deontology and ethics booklet.
You can also consult the charter for the use of IT resources and services.

Reporting system

To ensure compliance with our Code of Ethics, we have established a whistleblowing system and a procedure for reporting any practices that go against the rules of transparency and ethics.
The following reporting system defines the terms of application and implementation of the Code of Ethics. It describes the monitoring and warning system for acts of noncompliance with the provisions of the Code of Ethics.

Rollout of the system

A professional alert is any report, made in good faith, by an employee of the company, to alert on a violation of the provisions of the code of ethics, which could severely affect the activity of the company or seriously engage its responsibility.
The Code of Ethics and its application mechanism will be widely publicized to help employees understand its importance not only for the company but also for their professional careers.

Reporting procedure

Reporting is performed by whistleblowers

The referents collect and process the report sent to them.
The ethics committee decides on the report of the referents.

The whistleblower

All whistleblowers are required to disclose their identity to the whistleblower referents and the Ethics Committee, who will keep it confidential.
To be processed, all alerts must determine the nature and volume of the information they contain.
The whistleblower will receive an acknowledgement from the referent as proof that his/her alert has been recorded.
Anonymous reports are processed provided that the seriousness of the facts reported is sufficiently and convincingly established, with details allowing the referent to assess their relevance for inclusion in the reporting system.

The referents

The referent is the direct contact person for the whistleblower. He or she is responsible for the following tasks:

He records the alert by assigning it a number, and issues and delivers an acknowledgment of receipt to the whistleblower;
He examines the alert and ensures its processing within no more than 30 days after its registration;
He particularly ensures that the rights, freedoms and legitimate interests of all persons who may be affected by this alert are safeguarded;
He presents the Ethics Committee with the investigation’s outcome and the proposals for actions to be taken on the alerts handled.
He ensures the proper use of the reporting system by regularly reminding whistleblowers of the purpose of the system and the types conduct that can be reported.

The referent undertakes not to use the data collected for purposes other than the management of alerts, to guarantee their confidentiality, to respect the limited storage period of the data and to ensure the destruction or the restitution of all the physical or electronic media containing personal data, at the end of his or her assignment.
The referents are appointed for a period of 3 years.

Ethics Committee

The ethics committee:

Manages the reporting system;
Rules on the reports of the referents, within a period not exceeding one week.
Recommends, if necessary, investigations or audits to assist in the decision-making process. In this case, the Ethics Officer will inform the whistleblower of the Ethics Committee's decision;
Meets when convened by the referents
The Ethics Committee is appointed for a period of 3 years.

Data retention period

The retention period for data collected under the reporting mechanism is 5 years.

Child labour and human rights

SNIM does not employ any minors and ensures scrupulous respect for Mauritanian labour rights and ILO conventions. In this respect, forced labour and all forms of slavery are banned from our practices.
We also strive to follow up our various subcontractors and suppliers to ensure that they respect our values as outlined in our ethics charter and our supplier code of conduct.

For more information, please refer to the CSR report
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