Technip Code of · PDF fileBehavior at Work ... the ethical behaviors expected of you ... Our Code of Conduct covers a wide range of topics. Sometimes you may need more

Technip

Code of Conduct

Table of ContentsFOREWORDMessage from our Charmain and CEO . . . . . . . . . . . 3

SECTION 1 INTRODUCTIONWhat is Technip’s Code of Conduct? . . . . . . . . . . . . . 6

The Foundation: Our Corporate Values . . . . . . . . . . 7

One Technip . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Sustainable Development . . . . . . . . . . . . . . . . . . . . . . . 9

What To Do If I Have A Concern . . . . . . . . . . . . . . . . 10

How Do I Speak Up? . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

SECTION 2 PROTECTING PEOPLEHuman Rights . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Behavior at Work . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Diversity And Equal Opportunities . . . . . . . . . . . . . 17

Fair Employment Practices . . . . . . . . . . . . . . . . . . . . . 18

Privacy And Conf identiality . . . . . . . . . . . . . . . . . . . . 19

On-Site Security . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Travel Security . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

Health, Safety And Environment (HSE) . . . . . . . . . . 27

Community Involvement. . . . . . . . . . . . . . . . . . . . . . . 29

SECTION 3 ANTI-CORRUPTION AND COMPLIANCEOur Ethics And Compliance Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

Anti-Corruption And Legal Compliance . . . . . . . . . 34

Competition And Antivirust Laws . . . . . . . . . . . . . . 37

Conflict Of Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

Gifts, Entertainment And Hospitality . . . . . . . . . . . 41

Political Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44

Donations And Sponsorship . . . . . . . . . . . . . . . . . . . . 46

SECTION 4 PROTECTING OUR ASSETS AND FINANCIAL INTEGRITYAccurate Books And Records . . . . . . . . . . . . . . . . . . 50

Internal Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

Protection Of Intellectual Property . . . . . . . . . . . . . 60

Information Security . . . . . . . . . . . . . . . . . . . . . . . . . . . 62

SECTION 5 COMMUNICATIONS AND SOCIAL MEDIACorporate Image and Brand . . . . . . . . . . . . . . . . . . . . 66

External Communications . . . . . . . . . . . . . . . . . . . . . . 68

Social Media . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69

Technip Code of Conduct 1

Message from our Chairman and CEO

2

Foreword

Building trust is what secures our success for tomorrow.

“”

Trust is the foundation on which our reputation was built, it increases our stakeholder’s confidence in us, our products and our services. Developing and maintaining that trust depends on how we conduct our business and ourselves.

This Code of Conduct is a framework and a set of guidelines that will help all of us make the right decisions that take our business further. It summarizes, clarifies and updates our existing principles and standards for employee conduct so that we can all act consistently and exemplify our values. Building trust by upholding our core values is what secures our success for tomorrow.

Preserving the trust of our stakeholders is the responsibility of every individual in the Company. Our individual contribution will strengthen the collective foundation on which we build our business, and our future.

Therefore, I ask each of you to read and to conduct your activities consistently with our Code of Conduct.

Thierry Pilenko Chairman and Chief Executive Off icer


4

Section 1 I Introduction

Section 1

Introduction

What is Technip’s Code

of Conduct?

The Foundation:Our Corporate

Values

One Technip

Sustainable Development

What To Do If I Have a Concern

How Do I Speak Up?

6

7

8

9

10

11


What is Technip’s Code of Conduct?

All of us, without exception. This includes off icers, direct employees and contract staff, and all agents and business partners who work on behalf of Technip or in our name. We use our best efforts to make sure our minority-owned aff iliates and joint venture partners follow our Code of Conduct or equivalent principles.

Furthermore, we aspire to develop business relationships with like-minded clients, suppliers, and business partners who are guided by a similar set of principles of business conduct. This Code should be shared and discussed with clients, suppliers and our business partners to better explain our rules of conduct and reinforce our culture of accountability.

Any employee who violates Technip’s Code of Conduct will be subject to disciplinary proceedings in accordance with applicable rules and regulations.

This Code of Conduct is a guide to the business conduct expected of all of us at Technip*. It explains how to behave within Technip when dealing with each other and our stakeholders. It is also designed to guide you in your decision-making.

This Code works in conjunction with the Golden Book and our Group Operating Principles & Standards (“GOPS”). The Code describes the ethical behaviors expected of you and of the Company. The Golden Book sets forth the management principles

and responsibilities for the Group. Our GOPS govern how Technip conducts business operations. Our Golden Book and GOPS are published on the Technip intranet on the Group’s website, so do not hesitate to refer to them when you need a fuller explanation of Technip’s principles.

Our Code of Conduct covers a wide range of topics. Sometimes you may need more information on a specif ic subject to fully understand what is required. We will highlight where you can f ind it throughout the Code.

WHO MUST FOLLOW THE CODE?

CODE OF CONDUCT TRAINING

Several Code of Conduct training courses will be made available. Our training programs are a vital key to reinforcing ethics, compliance and competence in the Organization. You are expected to accept Code of Conduct related training requests. Speak with your manager about any training you wish to take. Where possible and applicable, our business partners can also take our online training covering specif ic topics contained within this Code.

* In this document, references to ‘Technip’, ‘Company’, and ‘Group’ refer to Technip S.A. and its aff iliated companies

6



of Conduct?

The Foundation: Our Corporate

Values

One Technip



How Do I Speak Up?

The Foundation: Our Corporate Values

We live and work according to our values. They are at the root of our accomplishments and underpin our Code of Conduct.

Our conduct speaks louder than words. That is why we strive to always do the right thing wherever business takes us. That means not only acting transparently and keeping commitments, but also ensuring the safety of people and sustainable practices within the community and across the planet. Safety, ethics, security and respect always take us further.

“Doing The Right Thing” translated in behaviors:

Acts with the highest standard of honesty, integrity and fairness;

Complies with the letter and the spirit of Technip standards and charters;

Takes all proactive and corrective actions related to Health, Safety, Environment and Security.

We believe in prof itable projects based on sustainable relationships. We seek to enhance our performance and share the benef its of every achievement with our stakeholders: clients, employees, shareholders, partners, suppliers and local communities. Fair returns take us all further.

“Encouraging a Fair Return For All” translated in bevahiors:

Anticipates client needs and meets their short-term and long-term objectives;

Encourages and supports other employees to reach their maximum potential;

Sustainably shares the benef its of every achievement with partners inside and outside Technip.

DOING THE RIGHT THING TRUSTING THE TEAM You already know the feeling that comes from joining together to successfully solve a major challenge. Our ability to combine talents and deliver success makes us unique. We value diversity, and have passion and true belief in each person’s contribution. It is the trust and conf idence between team members and between teams that take us further.

“Trusting the Team” translated in behaviors:

Motivates and empowers others to achieve common objectives;

Takes the opportunity to build diverse teams and values their varied approaches to work;

Fosters cooperation and transparency across teams, functions, segments, entities, countries and regions.

ENCOURAGING A FAIR RETURN FOR ALL

BUILDING THE FUTUREAt Technip, we are building the future through today’s most ambitious energy infrastructure projects. We are also creating the conditions that will generate tomorrow’s game-changing innovations by developing our people. Entrepreneurial attitude, quality, investment and anticipation are at the very heart of how we are taking it further

“Building the Future” translated in behaviors:

Builds expertise and fosters innovation to achieve professional excellence;

Commits to excellence in quality and continuous improvement;

Reinforces Technip‘s capabilities by mentoring others and transferring knowledge.


One TechnipOne Technip is the result of everyone sharing the same values, vision and mission.

At Technip, we believe that combining our strengths empowers us to be and act as a single entity. It also enables us to align our behaviors and aim for the same objectives.

By communicating as One Technip and behaving like One Technip, people will see

us as one company and will engage more broadly and deeply with us. With a clear, consistent expression of who we are, we will see the benef its of improved eff iciency, less duplication and a better return on our investment. Through this unif ied approach there will be greater understanding and visibility among all of our stakeholders, improved unity and cross-company integration.

8



of Conduct?


Values

One Technip



How Do I Speak Up?


Technip is a responsible industrial group that is committed to balancing short and long term interests while doing business. Our business decisions integrate economic, ethics & compliance, health, safety, security, environmental and social considerations while reducing our technical, non-technical and f inancial risks.

Embedding Sustainable Development in everything we do and building trust with our stakeholders is the basis of Technip’s approach to create long-term added value and foster prof itable and sustainable growth. This approach will drive Technip’s activities towards a more socially, economically and environmentally sustainable World.

Through our innovative and sustainable project approach, we strive to meet the world energy challenge while contributing to the success and development of all our stakeholders. The key to success is ensuring that we engage regularly with our stakeholders to take into account their views and expectations.

We measure our commitment through regular and transparent reporting.

Find out more at http://www.technip.com/en/sustainability

Sustainable Development is a topic which involves many disciplines and this should be kept in mind as you read this Code, especially in the following areas:

Human Resources and Social Performance;

Anti-Corruption and Compliance; Procurement; Quality; Health, Safety and Environment; Community Involvement; Security.


http://www.technip.com/en/sustainability

http://www.technip.com/en/sustainability

What To Do If I Have A Concern?

Technip operates in many different countries and industries. As a result, the Code cannot cover every situation that you may face. If you are unsure how to resolve a situation, ask yourself these questions:

Are my actions legal? Are my actions consistent with Technip’s values?

Do my actions set a good example? Would Technip be comfortable if the action taken was published on the front page of a newspaper?

Would I be comfortable talking about my actions with my colleagues, family and friends?

Have I asked for advice from others who have knowledge on the topic so I can make an informed decision?

If you answer no to any of these questions,

stop and ask for advice from:

Your direct manager or someone else in your management;

A Compliance Off icer; Your Human Resources representative; Your local legal department; A trusted colleague.

The important thing is to not leave your concerns unresolved. In some cases, however, it may be appropriate for you to raise an alert using our whistleblowing procedure (See How Do I Speak Up).

10



of Conduct?


Values

One Technip



How Do I Speak Up?

How Do I Speak Up?Violations of laws and regulations can have serious consequences for the persons involved as well as for Technip. Therefore, we must remain alert to any risk of legal or regulatory non-compliance. Informing management of any non-compliance should be a reflex in our everyday business.

HOW DO I RAISE AN ALERT?Technip has a zero tolerance policy on retaliation against employees for whistleblowing. Anyone who is responsible for inappropriate conduct or retaliatory measures will be subject to disciplinary sanctions in accordance with applicable rules and regulations, including the potential termination of their employment. Report the details of any retaliation to the Ethics and Compliance Committee right away. The Committee will take the appropriate measures to protect you.

If you suspect a violation has or may occur, you have the responsibility to report it to management. You can use the Whistleblowing Procedure if you have reason to believe that there are any irregularities or fraud in the accounting, internal controls, audit or f inancial areas — or if you suspect any act of corruption has or may occur. You can raise an alert in several ways:

Directly to the Ethics and Compliance Committee; Via the dedicated reporting hotline to speak with an independent third party.

Treat all information related to your report as conf idential. All information, data and identities are treated and kept conf idential. No matter what reporting channel you use, the Ethics and Compliance Committee will receive the complaint and make sure that the information is collected and stored securely.

FURTHER READINGFOR MORE INFORMATION SEE THE WHISTLEBLOWING PROCEDURE: See the GOPS series 25 – Compliance

Visit the Group Link Procedures page for Compliance: http://thelink.exnet.technip.com/sites/groupmain/proceduresandstandards/Pages/Compliance.aspx

Visit the Ethics and Compliance Group Link homepage: http://thelink.exnet.technip.com/sites/groupmain/AboutTechnip/Ethics_and_compliance/Pages/EthicsAndCompliance.aspx

For external parties, please visit www.technip.com or contact us at http://www.technip.com/en/contacts for further information

WILL I GET IN TROUBLE FOR WHISTLEBLOWING?


http://thelink.exnet.technip.com/sites/groupmain/proceduresandstandards/Pages/Compliance.aspx


http://thelink.exnet.technip.com/sites/groupmain/AboutTechnip/Ethics_and_compliance/Pages/EthicsAndCompliance.aspx



www.technip.com

http://www.technip.com/en/contacts

12

Section 2 I Protecting People

Section 2

Protecting People

Human Rights

Behavior at Work

Diversity and Equal

Opportunities

Fair Employment

Practices

Privacy and Conf identiality

On-Site Security

Travel Security

Health, Safety and

Environment (HSE)

Community Involvement

14

15

17

18

19

21

24

27

29


Human Rights

Technip is a signatory to the United Nations Global Compact, which covers human rights, working and environmental standards as well as f ighting against corruption.

The Group respects the letter and spirit of all human rights legislation in force and adheres to the International Labor Organization’s Fundamental Conventions regarding the elimination of discrimination, the freedom of association, the effective recognition of the right to collective bargaining, the abolition of child labor and the eradication of forced compulsory labor.

In line with our Technip Ethics, Social, Security, Health and Safety, and Sustainable Development Charters and policies, we must all promote the respect for human rights of employees by:

Using the Group’s values (see page 8) to guide employment relationships. We also expect our employees to live by our values in their dealings with and/or on behalf of Technip;

Implementing our Charters and Policies to all entities of Technip Group taking into account local legislation and international best practices, cultural differences and local specif icities of the countries in which Technip operates;

Having regular and open dialogue with our employees and their representatives, if any, concerning signif icant decisions that will directly affect them.

Technip’s reputation is built on the personal behaviors of our employees across the world. The Code of Conduct provides complementary guidance beyond compliance with the relevant laws and regulations that apply to each employee throughout the world. All of us must understand and follow these principles:

Treat people with dignity and responsibility;

Act without discrimination and prejudice of any kind;

Refuse moral and sexual harassment, social injustice, slave labor, and the use of child labor;

Promote equality in the workplace with salaries compatible with the market, with a clear policy of social benef its, and by valuing human life;

Ensure cooperation through regular inspections and audits to verify that our values are implemented throughout the Company.

Our commitment extends to our business partners, subcontractors and suppliers. All our external partners must also respect these laws, rules and regulations. It is important for Technip that our partners adhere to our principles.

FURTHER READINGFOR MORE INFORMATION ON HUMAN RIGHTS: Technip’s Social Charter

http://thelink.exnet.technip.com/sites/groupmain/AboutTechnip/Charters_Policies/Pages/home.aspx

Visit the Sustainable Development Group Link homepage: http://thelink.exnet.technip.com/sites/groupmain/Sustainable_Development/Pages/home.aspx


THE BASICS HOW TO BEHAVE

14


Human Rights

Behavior at Work

Diversity and Equal

Opportunities

Fair Employment

Practices


On-Site Security

Travel Security

Health, Safety and

Environment (HSE)




http://thelink.exnet.technip.com/sites/groupmain/Sustainable_Development/Pages/home.aspx


www.technip.com


Behavior at Work

At Technip we believe that all our employees are entitled to fair treatment, courtesy and respect, wherever they are working – in the off ice, on vessels, on industrial and construction sites and even when working in client off ices. Technip does not tolerate any form of abuse or harassment and will not tolerate any action, conduct or behavior that is humiliating, intimidating or hostile. Where differences exist as the result of local customs, norms, laws or regulations, we apply either the Code or local requirements – whichever sets the highest standard of behavior. In this way, we will maintain a culture of trust and mutual respect and dialogue throughout our business. We listen, motivate and support others to achieve common objectives and we value the contributions of others. This is also in line with our Group Value “Trusting the team”.

FURTHER READINGFOR MORE INFORMATION ON WORKPLACE CONDUCT: See the GOPS series 12 – Human Resources & Communications

Visit the Human Resources Group Link homepage: http://thelink.exnet.technip.com/sites/groupmain/HumanResources/human_resources_in_technip/Pages/home.aspx

Technip’s Social Charter: http://thelink.exnet.technip.com/sites/groupmain/AboutTechnip/Charters_Policies/Pages/home.aspx


Continued on page 16

Encourage disclosure of any indirect harassment such as physical or social isolation, or silent treatment, or indecent proposals for employment advantages. All our employees should be particularly sensitive to actions or behaviors that may be acceptable in one culture but not in another. Trust the team and do not accept any disparagement of colleagues. The success of every achievement, as well as of every failure, should be shared. We have to be open minded, transfer our knowledge and share information as needed, subject to Technip’s rules on conf identiality. Foster an objective approach based on mutual respect to recognize each other’s contribution.



http://thelink.exnet.technip.com/sites/groupmain/HumanResources/human_resources_in_technip/Pages/home.aspx





www.technip.com


THE DO’S: RULES TO ALWAYS FOLLOW

THE DON’TS: THINGS TO NEVER DO

Abstain from any sexual harassment such as unwelcome sexual advances, or sexual suggestions;

Ensure that you do not create a hostile or intimidating work environment which could affect an individual’s employment opportunity or performance;

Abstain from humiliating, denigrating or injuring another person with racial, ethnic, religious, age-related, or sexual jokes or insults;

Ensure that you do not distribute offensive materials, including inappropriate pictures or cartoons;

Abstain from any disclosure of personal information or spreading of malicious rumors.

Engage in behavior (physically or verbally) that could be characterized as offensive, intimidating, malicious or insulting;

Make inappropriate jokes or comments. If you are not sure whether something is inappropriate it is better to assume it is;

Be afraid to speak up and tell a person if you are upset by his or her actions or behavior. Explain why and ask them to stop.

16


Human Rights

Behavior at Work

Diversity and Equal

Opportunities

Fair Employment

Practices


On-Site Security

Travel Security

Health, Safety and

Environment (HSE)


Diversity And Equal Opportunities

Make sure your behaviors, communications, actions and decisions (e.g. related to recruitment, selection, evaluation, compensation, development, etc.) are not influenced by: race, color, religion, gender, age, ethnic origin, nationality, sexual orientation, marital status or disability. All of these forms of discrimination are prohibited, from the hiring stage through the employee’s entire career with the company. Follow local labor and employment legislation and be aware of cultural factors that might impact decisions. Support and promote Technip’s commitment to building diverse teams and valuing their varied approaches to work. Finally, ensure that our suppliers, customers and business partners are aware of Technip’s diversity policy.

Technip is a global company based in more than 48 countries. Our strength is the diversity of ourpeople. Technip ensures that employment-related decisions are based on relevant qualif ications, demonstrated skills, performance and other job related factors. Technip does not tolerate unlawful discrimination related to employment. Gender Diversity is a strategic priority for Technip and specif ic Gender Intelligent Leadership Behaviors have been def ined to foster an inclusive work environment. Finally, we ensure that our suppliers, customers and business partners are aware of Technip’s diversity and equal opportunities policies.

FURTHER READINGFOR MORE INFORMATION ON DIVERSITY AND EQUAL OPPORTUNITIES: See the Gender Intelligent Leadership Behaviors on the Gender Diversity intranet

site: http://thelink.exnet.technip.com/sites/groupmain/AboutTechnip/ Gender_Diversity/Pages/default.aspx

See the GOPS series 12 – Human Resources & Communications

Visit the Human Resource Group Link homepage: http://thelink.exnet.technip.com/sites/groupmain/HumanResources/human_resources_in_technip/Pages/home.aspx

Technip’s Social Charter: http://thelink.exnet.technip.com/sites/groupmain/AboutTechnip/Charters_Policies/Pages/home.aspx


HOW TO BEHAVETHE BASICS


http://thelink.exnet.technip.com/sites/groupmain/AboutTechnip/ Gender_Diversity/Pages/default.aspx

http://thelink.exnet.technip.com/sites/groupmain/AboutTechnip/ Gender_Diversity/Pages/default.aspx






www.technip.com


Fair Employment Practices

Our long-term hiring and employee development decisions are fair and objective. Therefore, family members can only be hired based on qualif ications, performance, skills and experience.

In the interests of good governance and transparency, you must refrain from any interference in the recruitment process of family and relatives. Respect the principle of fair employment and non-interference in all aspects of your relatives’ employment throughout their career with the company. This includes decisions relating to their compensation, promotion, transfers and other employment development. This also applies to relationships that develop after the initial hiring of an employee. You must avoid being in a direct or indirect reporting relationship with a family member. If such a situation occurs, promptly inform your line manager and human resources manager in writing.

If you have a conflict of interest due to a relative who is employed by one of our suppliers, customers or business partners, please refer to the section on Conflicts of Interest.

Q My child recently graduated from college with an engineering degree. Is it ok for me to recommend they apply for a job?

A Although we do not give priority to hiring family members and relatives, we do encourage and give priority to children of employees for internships, graduation assignments, training periods and short-term employment during holidays.

FURTHER READINGFOR MORE INFORMATION ON RECRUITMENT: See the GOPS series 12 – Human Resources & Communications

Visit the Human Resources Group Link homepage: http://thelink.exnet.technip.com/sites/groupmain/HumanResources/human_resources_in_technip/Pages/home.aspx


HOW TO BEHAVE

THE BASICS WARNING SIGNS

FREQUENTLY ASKED QUESTIONS

18


Human Rights

Behavior at Work

Diversity and Equal

Opportunities

Fair Employment

Practices


On-Site Security

Travel Security

Health, Safety and

Environment (HSE)





www.technip.com


Privacy And Conf identiality

All of us are expected to respect the right to privacy and conf identiality of personal data of other employees.

If you are authorized to access personal data, you must:

Only access information with a valid business reason and use it for the purpose for which it was collected and adhere to the highest standards of conf identiality when using it;

Ensure that such information is not provided to anyone outside of Technip without the proper authorizations;

Only hold this information as long as necessary to meet the legal or business reason for which the authorization was given;

If you f ind unprotected personal data, immediately inform the person responsible for its security;

Be aware of the data protection requirements of the law applicable in the country where you work.

Privacy concerns exist whenever personal information about an employee or third party is collected and stored electronically. Personal Data refers to any information relating to a person who is or can be identif ied directly or indirectly by reference to an identif ication number or to one or more factors specif ic to the person. We are committed to protect Personal Data stored in information systems by designing and implementing security measures. In addition, many countries regulate Personal Data of company representatives in business-to-business transactions. Technip is committed to handling Personal Data responsibly and in compliance with all applicable privacy laws. At Technip, access to personal data is strictly limited to employees who have appropriate authorization and a clear business need for that information. We respect the personal lives of employees and therefore Technip does not normally take an interest in their personal conduct outside work unless such conduct has an impact on the performance of the employee or affects the reputation or legitimate business interest of Technip.




FURTHER READINGFOR MORE INFORMATION ON PERSONAL DATA PROTECTION: Visit the Group Link homepage for Information Security.

http://thelink.exnet.technip.com/sites/groupmain/Security/InformationSecurity/Pages/default.aspx

Read the charter of Use of Information Systems which can be found on the Group Link homepage for Information Security or you can contact the Data Privacy Officer




Obtain and process Personal Data fairly; Keep it only for a specif ic lawful

purpose; Use and disclose it only in ways compatible with these purposes;

Keep it safe and secure; Keep it accurate, complete and up-to-date;

Ensure that it is adequate, relevant and not excessive;

Give a copy of his or her Personal Data to an individual, on request;

Apply a clean desk policy if you manage personal information;

Perform a legal declaration if the country where you work requires this for databases containing personal information;

Ensure the security of IT systems that store personal data.

Retain the data for longer than is necessary to complete the legal purpose for which it was collected.

20


Human Rights

Behavior at Work

Diversity and Equal

Opportunities

Fair Employment

Practices


On-Site Security

Travel Security

Health, Safety and

Environment (HSE)




www.technip.com


On-Site Security

Security requires the commitment of everyone to ensure the protection of all. You are the primary caretaker of your security. This is why it is essential that you know and respect the security measures in place at your working site, whether that is in the off ice, a plant, or construction site. For more information you can review the Technip Security Handbook, which provides all practical security recommendations to follow. When you receive a security message following a change in the security context of your working environment, comply with the new security measures and ensure your colleagues are aware of the message. Be aware of the emergency procedures applicable to your working environment so you know what to do in case of an incident. For example, it is important that you know where to muster if required to do so. You can ask your local Security Manager or local Emergency Response coordinator for more information. If anything seems suspicious to you, immediately report it to your manager or to the security manager within your entity. This will help us to prevent incidents or security breaches. If you are the victim of a theft in the off ice or on site, or if you witness a security breach, immediately report it to your security manager.

Security at the workplace is a system of behaviors, measures and practical procedures aimed at protecting employees from malicious human acts such as theft, unlawful entry, attacks, bombing, sabotage, kidnappings, and so on. Our security systems also aim to protect our Clients’ or partners’ employees when they are on a Technip work site. Our objective is to ensure the permanent security of Technip staff wherever they operate. The Security team implements security systems to protect staff and crew members at work and provides training to ensure staff awareness of the minimum security precautions they should follow in their daily work activities. A robust emergency response and recovery process has been developed to provide an eff icient and quick management of incidents that may occur.




There are several situations where your watchfulness and awareness may help prevent serious harm to people or leaks of conf idential information. For example, if you receive a package or letter from a suspect origin, do not open it or try to identify the contents. Immediately contact your security manager. Also, if you see an unauthorized person in the off ice or a restricted access area, inform your Security Manager.

Q What items are forbidden on sites or vessels?

A A n y we a p o n t h at co u l d h a r m employees is not allowed in Technip offices, plants or project sites, unless carried by a person formally authorized by Technip Security.

Q Can I refuse to have my baggage searched by Security Personnel when I am boarding or de-boarding a vessel?

A No. International regulations apply in all international port facilities where a Technip vessel may call or operate. These regulations allow authorized personnel at the port facility to establish security measures to control the access to the ship, notably by inspecting and searching people, baggage (including carry-on items), personal effects, vehicles and their contents. The purpose of these laws is to prevent smuggling of illegal products.

WARNING SIGNS FREQUENTLY

ASKED QUESTIONS

22


Human Rights

Behavior at Work

Diversity and Equal

Opportunities

Fair Employment

Practices


On-Site Security

Travel Security

Health, Safety and

Environment (HSE)



Ensure you have the local manager’s duty phone number in case of a security incident;

Make sure you badge is visible when working in the off ice or on a project site; Accompany your visitors in the off ice or on a project site.


Leave your personal belongings unattended;

Leave doors unlocked when leaving the off ice.

FURTHER READING See the GOPS series 13 - Security

Visit the Group Link Procedures page for Security: http://thelink.exnet.technip.com/sites/groupmain/proceduresandstandards/Pages/Security.aspx

For more information on the key security contacts for your area, see the Traveler’s Booklet on the Security Intranet.

Visit the Security Group Link homepage: http://thelink.exnet.technip.com/sites/groupmain/Security/Pages/default.aspx



http://thelink.exnet.technip.com/sites/groupmain/proceduresandstandards/Pages/Security.aspx

http://thelink.exnet.technip.com/sites/groupmain/proceduresandstandards/Pages/Security.aspx

http://thelink.exnet.technip.com/sites/groupmain/Security/Pages/default.aspx


www.technip.com


Travel Security. . .  to specif ic security measures. In this case, you will be briefed on local security measures and will have go through induction prior to or upon your arrival in country. Technip has developed emergency response (ER) processes. Be sure you have been briefed on what to do in case of emergency and that you have the local emergency numbers with you. If you are confronted with an emergency such as a riot, demonstrations, assault, or attack, alert the local ER contact as soon as possible so we can support you.

Check the Technip Country Risk Map regularly (see call-out box) to stay informed of the risk ranking of the country where you are working / travelling. Be aware of any specif ic security measures to be implemented as a result of the risk-ranking index. Follow the Technip security recommendations and travel requirements for the country where you are working. The Technip Security Handbook provides general security practical precautions to follow during your mission abroad. There is a Traveller’s Booklet for each country where we operate that gives relevant information and key-contact details for that country (see the Further Reading section). Before travelling to a foreign country, prepare for your journey by verifying the “travel checklists” available in the booklets and following the advice provided by the local security manager. During your mission abroad, always follow the general security precautions to reduce your exposure to risks. Certain areas within a Region or country are subject   . . .

Our employees travel all over the world. Travelling in a foreign or unknown environment can be risky. These risks increase as we work in more challenging environments. We are committed to ensuring the protection of our employees in transit and at their f inal destinations. Our dedicated security procedures and measures are implemented in sensitive environments to mitigate the security risks our employees may be exposed to and enable a smooth execution of their activities in secure conditions. Our security processes are designed to adjust to local context and risk factors.

Q Should I use my own means of transport if I am not met at my arrival at the airport as planned?

A In case Meet and Greet personnel do not show up at the airport, you must remain at the agreed meeting point and contact your Meet and Greet contact or local security manager. They will give you the instructions to follow.

Q Do the security recommendations in high-risk countries apply outside working hours?

A As part of your mission or mobilization to a foreign country where there are high security risks, your security is Technip’s priority at all times, including outside working hours. The security measures are there for your protection for the entire duration of your mission abroad and yo u h ave to fo l l ow t h e se c u r i t y instructions at all times. For further information, you can contact your local secur i ty correspondent who i s in permanent liaison with Technip Security Division.

HOW TO BEHAVE

THE BASICS


24


Human Rights

Behavior at Work

Diversity and Equal

Opportunities

Fair Employment

Practices


On-Site Security

Travel Security

Health, Safety and

Environment (HSE)


Before you leave: Read the Incomers Booklet of your country of destination prior to departure;

Notify the security correspondent at least 2 weeks (or earlier for some locations) before you travel;

Include your travel details in your notif ication to the local security team so they can prepare for your journey and organize the security arrangements;

Ensure your contact details are complete and accurate in the Travel Security Database through the completion of your mission in case the security team needs to contact you;

Have a list of the key-contacts on paper and register them on your mobile phone;

Be aware of do’s/don’ts at hotels in high-risk areas. More information can be found in the Technip Security Handbook;

Ensure you have a means of communication that works in your country of destination;

Read the latest security information before traveling to a foreign country.

In country: Pay attention to personal belongings in crowded places and public areas;

Beware of questionable offers such as advantageous exchange rates, sightseeing visits or organized tours, and offers of free services;

Be aware of the local laws to avoid being caught unaware;

Be sensitive to cultural and religious differences when traveling in a foreign place;

Be aware of general behavior to follow at police and military checkpoints and in general adopt a neutral attitude, following the instructions of the off icers.

Display excessive items or signs of wealth, or carry visible items identifying your Company in environments where the security risks are higher;

Use public computers to read your emails;

Withdraw money in ATMs in Level 3 countries, prefer banks.





FURTHER READING See the GOPS series 13 - Security

Visit the Group Link Procedures page for Security: http://thelink.exnet.technip.com/sites/groupmain/proceduresandstandards/ Pages/Security.aspx

Visit the Security Group Link homepage: http://thelink.exnet.technip.com/sites/groupmain/Security/Pages/default.aspx


Several security tools and handbooks were developed to inform our staff on the security recommendations when they travel or operate in a foreign environment:

Technip Security Handbook is a guide aimed at all staff that provides security recommendations to follow at the off ice and during missions abroad. The Handbook gives general security advice to prevent security risks in your daily activities and when travelling. A focus is made on security precautions to follow in sensitive countries where staff may be exposed to higher security risks. Technip Security Handbook is available on the Security Intranet or on request from your local security manager.

Country Travelers’ Booklets are developed for each country and provide relevant information on the country and security guidelines to be followed by all travelers. The booklets also contain the key-contacts and emergency contact details in case of need. Each booklet is updated on a regular basis to ensure our staff have the latest information prior to departure. The Travelers’ Booklets are available on the Security Intranet.

Technip Country Risk Map is based on 4 level security risks (1 = secure areas, 4= highly sensitive areas where no operations are allowed):

For travels to Level 1 countries: Normal vigilance and security precautions should be applied. No specif ic security approval is required.

For travels to Level 2 countries: you must notify the local/regional security manager of your travel who will inform you if you need to follow specif ic security measures.

For travels to Level 3 countries, you need to have the formal approval from your local security manager. Dedicated security measures will be implemented for your arrival at the airport, your transportation and your accommodation.

The Country Risk Map is available on the Security Intranet and is updated on a permanent basis based on the Country Security Risk Assessment carried out by the security team.

FOR MORE INFORMATION...

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Human Rights

Behavior at Work

Diversity and Equal

Opportunities

Fair Employment

Practices


On-Site Security

Travel Security

Health, Safety and

Environment (HSE)


http://thelink.exnet.technip.com/sites/groupmain/proceduresandstandards/ Pages/Security.aspx

http://thelink.exnet.technip.com/sites/groupmain/proceduresandstandards/ Pages/Security.aspx



www.technip.com


FURTHER READING FOR MORE INFORMATION ON HEALTH, SAFETY AND ENVIRONMENT: See the GOPS series 11- HSE Management

Visit the HSE Group Link homepage: http://thelink.exnet.technip.com/sites/groupmain/Hse/Pages/Home.aspx


Health, Safety And Environment (HSE)

. . .   Always intervene if health, safety or environmental rules are not respected, or an unsafe act or condition is observed.

Managers have further duties to:

At all times, act as a role model by demonstrating positive HSE behaviors in the workplace;

Make employees, contractors and suppliers aware of applicable HSE rules, procedures and expected HSE behaviors;

Ensure effective health, safety and environmental management systems and procedures are in place and functioning for the site or area of your responsibility;

Ensure that the required HSE related training is provided to the people who report to you;

Follow-up and correct any non-compliance that has been brought to your attention;

Ensure that the HSE related risks are properly assessed and the appropriate safety measures are put in place prior to the commencement of work;

Ensure that everybody understands that they have the right and responsibility to stop the work or refuse to work in unsafe conditions and that they are encouraged to do so when done in good faith;

Praise good HSE practices and challenge poor ones.

Our clients, neighbors, shareholders, and employees expect excellent HSE performance from Technip at all times. This includes engineering, procurement, and execution of our operations. We strive to implement the most eff icient and environmentally friendly solutions available, and we reduce the impact of our activities wherever possible. The key to HSE success is visible and effective leadership that relies on systems and procedures that have a strong focus on the active management of the risks present in the execution of our projects. We, therefore, expect all our employees to take specif ic and effective actions to protect the health and safety of our people and which minimize the impact of our activities on the environment.

Know and comply with the applicable health, safety and environmental rules and regulations;

Always comply with the 12 Safety Actions;

Always understand the risks related to a job and implement the required measures toprotect health, safety and environment before beginning operations;  . . .


HOW TO BEHAVE

THE BASICS


http://thelink.exnet.technip.com/sites/groupmain/Hse/Pages/Home.aspx

http://thelink.exnet.technip.com/sites/groupmain/Hse/Pages/Home.aspx

www.technip.com




Use the correct tools safely to carry out the job;

Work with the correct Personal Protective Equipement;

Obtain authorization before entering a conf ined space;

Observe the applicable speed limits and driving policies;

Intervene when you see an unsafe act or condition;

Perform a HSE Tool Box Talk and work with a permit or safe system of work.

Use alcohol or drugs while working or driving;

Be exposed to a fall or work at height without protection;

Perform tasks for which you are not trained or competent;

Remove safety isolation/equipement/barriers;

Expose yourself or others to the risk of dropped or falling objects;

Walk under suspended loads.

Q Should I always intervene if someone does not comply with the HSE rules?

A Everybody makes mistakes and can have a bad day. For most situations, the person may not even be aware of the danger or non-compliance. Always intervene in any unsafe or non-compliant situation – you could save a life!

Q Can I stop the work if I feel that it cannot be done safely?

A Yes, everybody has the right to stop the job if safety is at risk. Talk to your line manager about your doubts. Ask for their advice on the situation. If you do not feel comfortable speaking with your line manager, or in the event you both cannot f ind a safe way to perform the work, speak with your local HSE manager.

Q One of my colleagues was nearly hit by a piece of falling metal. I know he didn’t report it. What should I do?

A First, talk to your colleague about the benef its of reporting the incident. People tend to down play near misses or misguidedly try to protect a colleague who may have made a mistake. Explain that inc ident report ing helps HSE management make better HSE safety systems, procedures, personal protective equipment, training and equipment. Reporting helps us to understand where risks come from so we can take steps to mitigate the danger.


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Human Rights

Behavior at Work

Diversity and Equal

Opportunities

Fair Employment

Practices


On-Site Security

Travel Security

Health, Safety and

Environment (HSE)


FURTHER READINGFOR MORE INFORMATION ON COMMUNITY INVOLVEMENT: Visit the Sustainable Development Group Link homepage: http://thelink.exnet.

technip.com/sites/groupmain/Sustainable_Development/Pages/home.aspx



We encourage our operating centers and project teams to develop their own initiatives of support for local communities in respect of cultural heritage and applicable legislation. Ethics and compliance are at the forefront of these initiatives, and we put a particular emphasis on issues related to child welfare, health, education, and inclusion of disabled persons.

We must aim to:

Design sustainable development initiatives with a focus on long-term added value;

Engage with the local communities impacted by our activities in close coordination with our clients and contribute to community social and economic self-sustainability;

Anticipate and minimize any potential disruptions to the community;

Mitigate any negative impacts to local communities from our activities;

Contribute to grow local employment by fostering training, technology and skill transfer;

Respect local cultures and be aware of local practices and traditions as well as legislation and cultural factors that may impact behaviors and decisions.

Technip is committed to encouraging a fair return for the local communities with initiatives bringing long-term added value. We believe in the execution of prof itable projects based on sustainable and balanced relationships. We strive to share the benef its of our successes with all our stakeholders and in particular with the local communities. We pride ourselves on increasing opportunities for local companies and creating employment in the local communities. When working with local communities, our approach is one of dialog, relationship of trust and respect. Technip considers local communities as essential stakeholders. Obtaining their involvement and support is essential to the success of a project.





www.technip.com


30

Section 3 I Anti-Corruption and Compliance

Section 3

Anti-Corruption

and Compliance

Our Ethics And Compliance

Organization

Anti-Corruption And Legal

Compliance

Competition And Antitrust

Laws

Conflict of Interest

Gifts, Entertainment

And Hospitality

Political Activities

Donations And Sponsorship

32

34

37

39

41

44

46


Technip’s compliance organization is a dedicated structure that stretches from the Board of Directors to every level of the Group. The Ethics and Governance Committee is composed of Board members and assists the Board of Directors in promoting ethical and governance best practices.

Reporting directly to the Chairman and CEO, the Ethics and Compliance Committee is composed of 11 senior managers from across the Group representing every major area of Technip’s operations. It oversees the implementation of Technip’s Ethics Charter and related policies and procedures. Chaired by the Group Chief Compliance Off icer (“CCO”), the Committee submits an annual review to the Chairman and CEO and recommends improvements where necessary.

The Group Compliance policies and procedures are composed of:

“Doing Business Globally – Technip Anti-Corruption Policy & Guide” provides a clear and comprehensive operational framework for conducting Technip’s business in every country in which we operate with honesty and integrity.

GROUP COMPLIANCE POLICIES AND PROCEDURES

Our Ethics And Compliance Organization

“Know Your Commercial Consultant – Due Diligence Procedure” describes how to investigate the background and reputation of our prospective commercial consultants to ensure that they will fully comply with our Anti-Corruption Policy.

The CCO reports directly to the Group General Counsel and the Board of Directors via the Ethics and Governance Committee. The duties of the CCO include applying and enforcing the Ethics Charter and all applicable anti-corruption policies and procedures throughout the Group.

There are Regional Compliance Off icers for every Region and Business Unit of Technip. Each of them reports to the CCO on compliance issues within their Regions. They are in charge of ensuring the effective implementation of Technip’s anti-corruption and compliance policies at the Regional and Business Unit level.

This dedicated structure ensures that the policies and procedures of our compliance program are effectively and eff iciently implemented Group wide.

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These policies and procedures can be found on the Group’s intranet page.

Using the framework of the GOPs, the Golden Book and Technip’s values, the Compliance organization oversees Technip’s activities as they relate to the rest of the topics in this chapter.

“Know Your Joint Venture and Consortium Partner Due Diligence Procedure” provides a clear framework on how to investigate the background and reputation of our potential Joint Venture and Consortium partners to ensure that each Joint Venture and Consortium can be formed and operated consistent with international anti-corruption laws.

“Subcontracting General Principles” includes a due diligence process to ensure our subcontractors will conduct their activities in accordance with Technip’s values and international anti-corruption laws.

“Know Your Processing Agent [Customs Agent and Freight Forwarder] Due Diligence Procedure” is used to assess whether our processing agents (such as customs agents or freight forwarders) will conduct their activities in accordance with international anti-corruption laws.

“Social Donations and Charitable Contributions Due Diligence Procedure” is used to ascertain whether social donations and charitable contributions are not disguised illegal payments to government off icials in violation of international anti-corruption laws.

“Gifts and Hospitality” instruction assists employees to ensure that gifts and hospitality, whether received or given as part of usual courtesy of business, are not and cannot be considered bribes.

“Whistleblowing Procedure” establishes a conf idential means by which employees can report any irregularity or fraud in the accounting, internal controls, audit or f inancial areas as well as any act of corruption.

FURTHER READINGFOR MORE INFORMATION ON THE TECHNIP’S COMPLIANCE ORGANIZATION PLEASE GO TO THE ETHICS AND COMPLIANCE GROUP LINK HOMEPAGE: http://thelink.exnet.technip.com/sites/groupmain/proceduresandstandards/

Pages/Compliance.aspx





www.technip.com


THE BASICSCorruption is the diversion of a process by dishonest practices to obtain certain benef its. Offering bribes is one common form of corruption, which consists in offering remuneration to someone in return for a favorable decision.

At Technip, all acts of corruption are strictly forbidden. Technip is committed to complying with all international and national legislation against illegal payments.

The Group has established anti-corruption policies and procedures (as well as policies for maintaining Accurate Books and Records; see page 31) that help us to prevent, detect, and react to improper dealings whenever they arise. We must all ensure that we follow these policies and procedures, and that we never engage in corruption of public or private individuals or entities.

WARNING SIGNS

. . . either directly or through a third party, any payment or supply of services, gifts or leisure activities to obtain or retain a market or competitive advantage. This rule applies to transactions with government off icials, companies and private persons. Before entering into a relationship with a business partner you must ensure the appropriate due diligence has been conducted. Contact your Regional Compliance Off icer for guidance if you are unsure which Compliance Procedure to apply.

In the lifecycle of a business relationship or transaction, “red flags” may arise from time to time. We must all be vigilant of these risks and address them promptly if and when they occur. They are warning signs that may indicate a heightened possibility of corruption and require further investigation. In addition to any of the red flags highlighted in the GOPS that are applicable to the relationship, we should be sure to document and resolve the occurrence of any of the following situations:

Request by a commercial consultant to have a commission paid before the announcement of an award decision;

The third party does not reveal their ultimate ownership structure;

The compensation requested is not in line with the services provided;

The commercial consultant submits an invoice for vaguely described services or cannot provide detail of the actions they took on Technip’s behalf as agreed in the contract.

If any warning signs are observed, promptly contact your Regional Compliance Off icer or local legal department for assistance in resolving the issue.

Anti-Corruption And Legal Compliance

HOW TO BEHAVEThere are many laws and regulations in place where we do business that ban acts of corruption to obtain or retain a market advantage or benef it of any other kind. These laws generally prohibit the bribery of public or private individuals in the conduct of their duties. We must always conduct business in accordance with these laws as well as the local anti-corruption laws of the jurisdictions where we operate. It is also strictly prohibited to make payments or provide other objects of value such as gifts, loans, discounts, and excessive hospitality expenses or use the company’s funds or assets to influence a decision under any circumstances. All of us must refrain from offering, giving, promising or soliciting, . . .

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Q Who i s cons idered a publ ic or government off icial?

A These terms are broadly interpreted to inc lude any person work ing for a governmental body as well as any political party candidate and any business owned and/or operated by a government off icial. In addition, “government” includes all branches, levels and subdivisions of any government. Government off icials include:

Any elected or appointed government off icial or representative;

An employee, official, contractor, consultant or representative of a government or any department, agency or state-owned or state-controlled enterprise;

Any employee or person acting for or on behalf of a government official, agency, or enterprise performing a governmental function, such as a licensing off icial or a tax agent;

Any political party, officer, employee or person acting for or on behalf of a political party or candidate for public off ice;

A person in the service of a government, including members of the military, police or civil service;

An employee or person acting on behalf

of a public international organization, s u c h a s t h e U n i t e d N a t i o n s , International Monetary Fund, and the World Bank;

Employees of Non-Governmental organizations, such as Transparency International;

Family members and relatives of any of the above.

Q I am attending an international trade show where Technip i s one of the exhibitors. We plan to give away Technip branded promotional materials and I may invite some of the visitors, who may be government officials, out for drinks. Will I be in violation of anti-corruption laws?

A Providing promotional materials to our clients is a legitimate expense when the materials are designed to demonstrate or explain our products and services. Anti-corruption laws do not prevent you from providing legitimate hospitality, even if it is given to a government official. However, always be careful to ensure that the expenses are moderate and always follow the instructions in the Gifts and Hospitality Instruction and are accurately recorded in the books and records.


FURTHER READINGFOR MORE INFORMATION ON ANTI-CORRUPTION AND COMPLIANCE: See the GOPS series 25 - Compliance









www.technip.com




Refuse to take or give any bribe or personal benef it;

Resist any such pressure, and contact your manager;

Inform your manager of any attempted corruption, request for illicit payment or any other corrupt practice;

Use the whistleblowing system to report any act of corruption or any attempt to conceal corruption from the appropriate audit to the Ethics and Compliance Committee and take the initiative to prevent the unlawful behavior;

Check the character and integrity of every third party with whom we work and ensure that he/she understands Technip’s position on corruption;

Record all transactions on behalf of Technip accurately and honestly in Company accounts;

Be courteous and cheerful in defending Technip practices;

Make careful inquires about the origin of any money we receive or acquire;

Check the legitimacy of the destination of any payment we make;

Seek advice from your manager or Regional Compliance Off icer if you have any doubt about payments that you have been requested to make.

Offer illegal payments or bribes, for any reasons (direct or indirect offer);

Use charitable contributions to hide acts of corruption;

Use third parties to offer or accept bribes or facilitation payments indirectly.

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And Hospitality



Competition And Antitrust Laws

Competition laws — sometimes referred to as anti-trust laws — govern how companies compete in the market place. The underlying philosophy of competition laws is that an economy in which suppliers compete independently will produce the highest level of consumer benef it.

Competition laws impact our activities. Generally, competition law prohibits companies from colluding to undermine competition. It also regulates the behavior of companies that have a dominant market position, as well as requiring prior review and approval for certain transactions, such as mergers and acquisitions, which could substantially reduce or affect competition in the market.

At Technip, our objective is to conduct our business with the highest standards of honesty, integrity and fairness and to offer opportunities for success to all our suppliers, partners and subcontractors in a spirit of fair competition and mutually benef icial collaboration.

Go about business as usual without engaging in prohibited behaviors such as: price f ixing, bid rigging, allocating markets, territories or clients among competitors, single branding, tying, bundling, boycotting or discriminating among specif ic customers or suppliers unless legitimately and objectively justif ied, etc.

Any action that might appear compromising and/or could trigger an investigation;

Entering into an anti-competitive agreement with competitors;

Exchange sensitive information with competitors;

Holding regular meetings with competitors.

THE BASICS

HOW TO BEHAVE

WARNING SIGNS


Q During a conversation with a former co l l e a g u e w h o n ow wo r k s fo r a competitor, he says it would be crazy to quote less than €50 Million for a new project. How should I respond?

A Tell your former colleague that you are now competitors and that all talk related to your respective companies should be avoided. Any comment on pricing with a compet i tor may be a breach of competition laws.

Q After a long day at a conference, a competitor approached me and asked to talk in private about a supplier we both use that is trying to renegotiate its contract.

A Do not engage in these type of “off the record” discussions. Refrain from any discussion related to competition.





Familiarize yourself with competition law in your business and jurisdiction. Ask legal for advice;

Carefully note the origin of any information that you may collect on the market regarding competition;

Consider whether the reasons for entering into an agreement with a competitor are legitimate;

Keep records of meeting with competitors;

Pay particular attention to exclusivity agreements or other similar agreements;

Pay particular attention to the existence and operation of purchasing groups in which the Company desires to participate;

Seek guidance from your legal department if you have to deal with R&D or transfer technology agreements;

Seek guidance from your legal department and obtain approval from the proper level of management before entering into any Trade Association.

Agree with competitors:- On prices or any rates;- To share a market, divide any market

or customers, or allocate bids or agree on quotas;

- To exchange information regarding prices, sales volumes, terms of sale (including contractual terms), market shares, production capacities or cost structure including by telephone or during informal meetings;

- To discuss the commercial or industrial policy of the Group;

- To participate in collective action intended, or having the effect of preferring or eliminating a competitor, or granting it a preferential treatment, or exercising pressure or retaliatory measures or boycotting a customer.

Abuse purchasing power; Communicate or exchange information with competing buyers regarding our purchasing policies;

Give any conf idential information on a supplier to its competitors.

FURTHER READINGFOR MORE INFORMATION ON COMPETITION AND ANTITRUST LAWS CONTACT YOUR RELEVANT REGIONAL COMPLIANCE OFFICER: http://thelink.exnet.technip.com/sites/groupmain/AboutTechnip/

Ethics_and_compliance/Pages/Who_is_who.aspx


38



Organization


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Laws



And Hospitality



http://thelink.exnet.technip.com/sites/groupmain/AboutTechnip/Ethics_and_compliance/Pages/Who_is_who.aspx

http://thelink.exnet.technip.com/sites/groupmain/AboutTechnip/Ethics_and_compliance/Pages/Who_is_who.aspx

www.technip.com


Conflict Of Interest

Situations that might be interpreted as generating a conflict of interest. These include participating in an evaluation, meeting or decision-making process that could benef it you or a member of your family (for example, a procurement decision that would benef it a company that you’ve invested in or that employs a member of your family). Other examples include holding an outside job or employment that could affect your performance at Technip or influencing the hiring, job evaluation or compensation of a family member. If you are in a situation like this, promptly inform your line manager and human resources manager in writing.

Accepting anything more than a modest gift or entertainment from a person or organization doing business, or expecting to do business, with Technip.

A conflict of interest may occur when an employee has a f inancial, business or personal interest or activity that interferes or appears to interfere with Technip’s interests. There are many situations that are or could be perceived as a conflict of interest.

You are expected to make informed business choices in the best interest of the Company. Any situation in which your personal interests, or the interests of your close relations, are or appear to be in conflict with Technip’s interests must be avoided.

When you conduct professional activities, you must act only in Technip’s interest. Refrain from taking advantage of any situation, either directly or through a third party, for your own gain or that of others.

Strictly comply with the regulations that apply in your country and with the Technip procedures in specif ic areas of activity, such as procurement, subcontracting, and business development.

Disclose in writing to your manager and your local legal counsel all of your outside interests that create or could appear to create a conflict of interest.

Avoid misusing Technip resources for personal gain. This includes Technip off ice equipment, time, resources and intellectual property.

Any information you obtain through your position at Technip should not be used for personal gain.

Get approval prior to taking a position with an outside business while working for Technip.

THE BASICS

HOW TO BEHAVE

WARNING SIGNS

Q While performing my job, I discovered a great business opportunity that may be worth a lot of money. May I take the opportunity for myself?

A Sometimes you may come across a business opportunity while working for Technip. Generally, if the opportunity is within Technip’s line of work, disclose the opportunity to Technip. Outside jobs or employment that could affect your performance at Technip must be avoided. If you are unsure, seek the advice of your manager.






Understand the concept of conflicts of interest;

Remain aware of any actual or apparent conflicts;

Know how to remove yourself or protect against the dangers a conflict of interest presents, such as removing yourself from the position that creates the conflict by delegating to someone else;

Disclose any conflicts to your manager, and seek advice on how to avoid the conflict, remove yourself from it, or protect yourself and the company from the consequences of the conflict.

Assume that a conflict does not matter because it is too small or petty;

Let a conflict linger for a long time before taking action.

FURTHER READINGFOR MORE INFORMATION ON CONFLICT OF INTEREST: See the Ethics Charter: http://thelink.exnet.technip.com/sites/

groupmain/AboutTechnip/Charters_Policies/Pages/home.aspx


40



Organization


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www.technip.com


Gifts, Entertainment And Hospitality

When someone receives anything of value and doesn’t pay the fair market value of the item, they have received a gift. Entertainment and hospitality are def ined as receiving anything of value, such as meals, drinks, admission tickets, transportation, travel costs, accommodation, allowances, subsistence, educational courses, club dues, and greens fees. They are forms of gift giving that may constitute acts of corruption and can expose you and the Company to civil and criminal penalties and prosecution.

. . .  should never influence decisions or be seen as having an influence on those receiving them. However, Technip permits the giving and receiving of business gifts and hospitality that are usual and customary business courtesies.

Occasionally exchanging small gifts or invitations of only nominal value may make a legitimate contribution to good business relations.

When you are presented with a gift, or are offering someone a gift, refer to this chart. If the gift satisf ies all of the categories, the gift is likely permissible.

In some countries, refusing a gift may be considered as offensive according to local custom. In these specif ic situations, you may accept the gift and record it in the Company’s gift register. If you have any questions about local customs, contact your Regional Compliance Off icer.

Do not grant or accept any undue benef it, whether monetary or non-monetary, directly or indirectly, to or from any government off icial, client, supplier, vendor, subcontractor or any other third party. Gifts or invitations . . .

ACCEPTABLEGIFTS ARE:

PERMITTED UNDER LOCAL

LAW AND REGULATION

GIVEN IN GOOD FAITH

DIRECTLY CONNECTED

TO A BUSINESS RELATED PURPOSE

REASONABLE IN VALUE

THE BASICS

HOW TO BEHAVE



FURTHER READINGFOR MORE INFORMATION ON GIFTS AND HOSPITALITY: See the Group Instruction series 25 - Compliance




Some gifts and hospitality are by their nature illicit and are prohibited by Technip.

These include cash payments, personal services, loans, gifts and invitations of an improper nature or to improper places, events or meals in which the commercial partner does not participate and gifts or invitations at periods when important commercial decision are being taken.

Q I have received a gift that complies with the Gifts and Hospitality Instruction. Is there anything more I need to do?

A Yes. All gifts should be recorded in the Gifts and Entertainment registry maintained by your Regional Compliance Off icer. Contact your RCO for instructions on how to register a gift.

Q I have been offered a gift that I think is intended to influence a business decision. What should I do?

A All gifts should be given openly and transparently, and should not be intended to influence a business relationship. Politely refuse the gift and report it to your l ine manager or the Regional Compliance Off icer.

WARNING SIGNS FREQUENTLY ASKED QUESTIONS

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www.technip.com



Tell your manager about any gift or invitation offered or accepted, whatever its value;

Inform your business partner about Technip’s policy on gifts and entertainment at the beginning of every new business relationship;

Speak to your manager if a supplier or a subcontractor offers you gifts or invitations of signif icant value;

Ask for your manager’s approval before offering gifts or invitations to representatives of a government off icial;

Accept or offer restaurant invitations only if they are linked to a particular event;

Understand local customs and laws before offering or receiving gifts, leisure activities or other benef its;

Take into account the company policy of the person receiving the gift or invitation;

Record all gifts offered and received, accurately and duly supported by invoices and receipts (if relevant), in the company books and records;

Seek advice from your manager or from your Regional Compliance Off icer if you are not completely sure.


Solicit gifts or invitations; Offer or accept gifts, or provide a service that you would have diff iculty explaining to your colleagues, your family or the media;

Accept gifts or hospitality from potential suppliers who could place you in a situation of obligations, especially during critical phases of a decision making or award process;

Accept an offer that exceeds what is considered acceptable at Technip.



Beware of being solicited for charitable donations to a specif ic foundation or charitable organization. It may be a veiled request for a political contribution. Follow the proper procedure for conducting due diligence prior to making any donations. You must ensure that such donations are not for the purposes of supporting political activity, and that it meets the requirements of the Social Donations and Charitable Contributions Due Diligence Procedure. If you are solicited for such a contribution, contact your Regional Compliance Off icer for guidance.

As a member of civil society, Technip observes strict political, religious and philosophical neutrality. Therefore, Technip’s policy is to not make f inancial contribution to political candidates, elected representatives or political parties.

Technip also respects the personal political aff iliations of its employees. Nevertheless, these aff iliations must not affect the activities or image of Technip nor may they affect the political neutrality of the Company.

Participate in political activities in your own name and outside of work;

Never use Technip premises, equipment or any other assets for political activities;

Never make a political statement on behalf of Technip or associate Technip with your personal political views;

Do not use Technip’s corporate image to support your political views;

Respect the beliefs of others; If you participate in the political decision making processes that concern Technip, recuse yourself from them.

Q I am active in the local political community where I live. Do I need to disclose these activities to Technip?

A Only in ce r ta in in s tances w i l l disclosure be required. Speak with your Regional Compliance Off icer to f ind out if disclosure is appropriate in your case.

Q I have been asked to contribute to a political party candidate’s campaign. Am I allowed to make such donations?

A Yes, as long as the donation is personal. Donations must not be made on behalf of Technip or in order to benefit Technip in any way.

THE BASICS

HOW TO BEHAVE

WARNING SIGNS


44



Organization


Compliance


Laws



And Hospitality





Exercise your freedom of opinion and political activity outside the scope of your employment contract, at your own expense and on an exclusively personal basis;

Explain clearly that you only represent your own personal views when participating in political activities;

Get your manager’s approval before communicating in Technip’s name with government representatives on political matters;

Think of Technip’s reputation and how the public would perceive your actions when interacting with government representatives;

Seek advice from your manager or Regional Compliance Off icer if you are solicited for a political donation;

Notify your manager if a government off icial contacts you outside your normal activities.

Use your position at Technip to urge anyone to make political contributions or to support a political party;

Use or allow the use of Technip’s assets or resources for a political campaign, party or candidate;

Use donations for community benef it to hide political contributions.

FURTHER READINGFOR MORE INFORMATION ON POLITICAL ACTIVITIES: See the GOPS series 25 - Compliance







www.technip.com



Social donations and contributions are gifts given for a charitable purpose or to support a particular cause. A donation or charitable contribution can be in the form of cash, services and new or used goods. They also include emergency or humanitarian aid, development aid support, and medical care assistance.As a responsible corporate citizen, Technip believes in contributing to the communities where we conduct business by supporting worthy causes, organizations, and activities. Any donation or sponsorship on behalf of Technip must be approved according to the GOPS concerning social donations and charitable contributions.

When contributing to local communities on behalf of Technip, ensure that such giving is in line with our corporate values, charters and GOPS. If there is a local charity or social program that, in your opinion, shares similar values with Technip, inform your Regional Compliance Off icer. All approved donations must be properly accounted for and accurately reported in the Company’s books.

The main risk is that donations could be considered disguised illegal payments. To avoid these risks, Technip only f inances associations and foundations or takes part in sponsorship projects whose activities are legally acceptable and in line with the values and priorities of the Group.

Q While at a jobsite, I was approached by a local community member about giving a donation to their charitable organization. What should I do?

A You are free to give to charitable organizations on your own behalf. But be careful that such donations are used for their intended purpose. If the request has been made for Technip to donate, refer it to your Regional Compliance Officer for further consideration.

THE BASICS

HOW TO BEHAVE

WARNING SIGNS


46



Organization


Compliance


Laws



And Hospitality



Promote the development of local communities through charitable donations that are in line with our values and GOPS;

Ensure that charitable organizations do not use donations for illegal purposes;

Make all donations in good faith.

Give donations that are unreasonably large in value;

Give any donation if it is illegal under local laws and regulations.

FURTHER READINGFOR MORE INFORMATION ON DONATIONS AND SPONSORSHIPS: See the GOPS series 25 - Compliance









www.technip.com


48

Section 4 I Financial Integrity and Protecting Our Assets

Section 4

Financial Integrity and

Protecting Our Assets

Accurate Books And Records

Internal Controls

Quality

Protection Of Intellectual

Property

Information Security

49

54

57

60

62


Accurate Books and Records

Accurate Books and Records refers to all the f inancial and non-f inancial business information that we record and report. It must be done honestly, accurately, exhaustively and objectively to protect our credibility and reputation, meet our legal and regulatory obligations, fulf ill our responsibility to shareholders and other stakeholders, and inform and support our business decisions and actions.

Accurate Books and Records includes:

Creating records that are up-to-date, accurate, reliable, verif iable and in line with applicable rules, laws, regulations as well as Group’s policies;

Presenting fair, complete, accurate, timely and understandable reports for internal and external users;

Safeguarding the assets of the Group to minimize risk of f inancial loss;

Developing and maintaining robust costing systems that provide high-quality f inancial information and support the Group’s strategic management initiatives.

Although most visible in f inance, treasury, accounting, payroll, tax, and controlling departments, Accurate Books and Records applies to all departments and employees.

When you are booking a complex f inancial transaction, creating purchase orders, recording your timesheet or f iling an expense report, you are creating a f inancial record that needs to comply with these guidelines. We never tolerate fraud.

You understand management’s expectations relevant to your position and you follow the applicable accounting and reporting laws, policies and procedures (e.g. IFRS, local GAAP, GOPS, tax, and f inancial market authorities’ regulations).

You are part of a company-wide team and you interact with your colleagues in other entities, locations, departments to make sure that you capture the true nature of all events that affect the company’s past, current or future f inancial situation.

You avoid performing duties that should be separate under the established rules of independent review and approval.

If you are uncertain of the right way to record or report a transaction, speak to your Manager. Inform your supervisor when you believe a record or report does not accurately reflect the underlying transaction. Make suggestions for ad-hoc corrections and long-term improvements. Never hide an error—whether it is yours or someone else’s.

Report any concerns and irregularities in auditing or internal controls f irst to your line manager. If you feel that this does not resolve the issue, consider using the Whistleblowing Procedure.

Be conscious of the conf idential nature of the f inancial information you handle. Do not give or grant access to conf idential information to outsiders or use it for personal gain. When in doubt, ask your manager before you distribute information.


50



Internal Controls

Quality

Protection of Intellectual

Property


Beware of any activities that do not respect the following principles:

Authorization: The transaction you are recording or the information you are distributing has been authorized by the correct person(s);

Validity & clarity: Our f inancial records should only reflect events that have actually happened, or events we know will happen with a high degree of certainty;

Appropriate accounting treatment: Records and reports are created in line with the applicable rules, which are consistently applied;

Completeness & accuracy: The information captured in our f inancial (and non-f inancial) systems must be complete and accurate;

Dissemination of information: Exchange information with your colleagues in all entities, locations and departments involved in the events and transactions you are recording while respecting the rules of conf identiality;

Timeliness: Every manager should establish f irm but realistic timelines for the processing of f inancial records as well as deadlines for f inancial reporting, and every employee should strive to adhere to them.

Q I was given a journal entry to record that I don’t understand. Should I enter it anyway?

A No. Ask the person who sent you the entry to explain it to you. Ask your line manager or another knowledgeable person if you have doubts about the va l id i ty, author i zat ion or cor rect accounting of the transaction. Do not accept a duty unless you are sure you fully understood what to do and how to do it. Sometimes, there may not be time for formal training, but you should ask for on-the-job instruction. I t is your l ine manager’s responsibility to provide you with all necessary training.

Q A Project Manager has asked me to record a transaction, although it won’t be completed until after the quarter ends. Should I do what he asks?

A Generally, no. Reporting a transaction that is not yet complete would likely be a m i s re p re se n t at i o n a n d m ay eve n constitute fraud. Discuss your concern with your line manager. If you are not comfortable with his or her approach, seek help from your Regional Compliance Officer or report to the Whistleblower Hotline.

Q I discovered an accounting error that resulted in allocating labor costs to the wrong project. The client hasn’t noticed, and I don’t want to get my colleague who booked the entry in trouble. What should I do?

A Mistakes should never be covered up, but should be immediately disclosed in full. Correct the accounting error and let the other departments involved know of the correction.


WARNING SIGNS FREQUENTLY

ASKED QUESTIONS



Know the external and internal reporting standards (IFRS, GAAP, GOPS and Guidelines) and ensure they are followed;

Ensure all transactions are properly authorized and recorded accurately and completely;

Submit, record and authorize only valid transactions;

Record transactions timely, minimizing errors caused by delays between transactions and their recording;

Ensure all counterparties are appropriately set up in the company’s systems. This includes customers, suppliers, agents, professional advisers, JV partners and any other business partners;

Ensure that no undisclosed or unrecorded amount, fund or asset is established or maintained;

Watch out for unauthorized payments or invoices as described in the Anti-Corruption section of this Code;

Ensure that all books and records are supported by documentation to provide an auditable record of the transaction;

Co-operate fully with Internal Audit, Group Internal Control and external auditors. If requested, allow them unrestricted access to staff and documents (subject to legal constraints);

Report any concerns or irregularities in respect of accounting, auditing or internal controls matters;

Make sure that you have up-to-date policies and procedures.

52



Internal Controls

Quality


Property



Falsify a report, document or record, or make a deliberately false or misleading entry in them;

Record invalid transactions; especially if they are likely to defraud anyone of money, property or honest services;

Establish accounts, companies or arrangements to circumvent or frustrate Technip controls, policies or procedures;

Influence others to do anything that could compromise the integrity of Technip’s f inancial records and reports;

Commit Technip to contractual or other f inancial obligations unless you are authorized to do so;

Process transactions without proper validation;

Sell, transfer or dispose of company assets without the proper documentation and authorization;

Neglect education of employees concerning company’s compliance and reporting duties;

Obstruct or influence the authorized activities of a regulator. This might include concealing, altering, destroying or tampering with information.

FURTHER READINGYOUR DEPARTMENT MANAGER SHOULD BE ABLE TO GIVE YOU THE SPECIFIC RULES AND REGULATIONS THAT APPLY TO YOUR FUNCTION AND POSITION. THEY MAY INCLUDE: International & national law (e.g. tax laws) > GOPS series 14 – Finances & Control

International Financial Reporting Standards (IFRS) > Guidelines series14 – Finances & Control

Local accounting standards (GAAP) > Group Instructions series 14 – Finances & Control

Financial market regulations (e.g. disclosure, audit & filing rules) > Departmental policies & procedures

Visit the Group Link Procedures page for Finances and Control: http://thelink.exnet.technip.com/sites/groupmain/proceduresandstandards/Pages/Finances_Control.aspx



http://thelink.exnet.technip.com/sites/groupmain/proceduresandstandards/Pages/Finances_Control.aspx



www.technip.com


Internal Controls

Internal Control is conducted to provide reasonable assurance that Technip is meeting its objectives in terms of operations, reporting and compliance. It consists in f ive integrated components: control environment, risk assessment, control activities, information and communication, and monitoring activities.

Effective Internal Control requires that the f ive components and their associated principles be present, functioning and operating together in an integrated manner down and across the organization at all levels. They are embedded in the Group’s processes, procedures and day-to-day activities related to operations, reporting and compliance. They are regularly updated to keep them consistent with our business environment and adapted to our organization, processes, IT systems and laws and regulations.

We document and communicate policies and procedures that support Internal Control activities. The rules def ined by the “Golden Book”, the “GOPS” and the “Group Instructions” are mandatory and build a global framework in which the regions, the business units and the projects can def ine their own policies and procedures.

We comply with the segregation of duties principle. We consider implementing compensating controls when duties cannot be segregated. The concept of segregation of duties is to separate the following responsibilities in each business processes:

Custody of assets; Record keeping; Authorization; Reconciliation.

We perform on a yearly basis a fair self-assessment of our internal controls and provide accurate information to the Management and the Audit Committee about the Internal Control system …

… eff iciency. We timely remediate the def iciencies detected as a result of this assessment process.

Be informed about roles, responsibilities and delegation of authorities that apply within the organization you belong to and in the organization you work with.

Even in an emergency, or under the pressure of your manager, a colleague, or a third party, never accept to bypass the approved segregation of duties or the delegation of authority arrangements, because you may be responsible for inappropriate payment(s) or transaction(s) recording.

Understand the Internal Controls relevant to your position and follow the policies and the procedures related to those controls.

Feel responsible for maintaining effective internal controls embedded in the processes under your responsibility in order to prevent with a reasonable insurance the risks of loss of assets, misstatement, or fraud.

Promote the added value of Internal Control; controls and oversight aim not only at limiting the number of errors and risks, but also at saving time by doing the right thing the f irst time in the right way.

Perform a fair assessment of your internal controls effectiveness and remediate promptly any weakness.

If you are not aware of the business controls in place in your work activities, speak to your Manager and look at the Group and Regions policies available on the Technip’s intranet. ...

THE BASICS

HOW TO BEHAVE

54



Internal Controls

Quality


Property


... Report any concerns and irregularities in respect of accounting, auditing or internal controls matters to your line Manager, or if you don’t feel comfortable with that, consider using the whistleblowing procedure.

Internal Control will probably be compromised if the following principles are not in place:

Tone at the top: Managers create an environment favorable to Internal Control;

Walk the talk: Managers lead by example when it comes to Internal Control;

Segregation of duties: Proper separation of duties is in place to reduce the likelihood that one person is able to completely control a process or function from beginning to end;

Maintain up to date: Internal controls are adapted to f it the current business and operational environment and comply with the Internal Control principles;

Trust but verify: Managers trust their teams, but checks are put in place and used to ensure that the activities of employees comply with Internal Control;

Nothing to hide: An annual process of self-assessment is conducted annually, involving employees from different departments, who test controls on instruction from Corporate.

Q “Control environment” is one of the f ive integrated components of the Internal Control, but what is it?

A I t means the overa l l at t i tude , awareness and actions of directors and management regarding the Internal Control system and its importance to the organization.

Q What’s the connection between “three way matching” and Internal Control?

A According to the segregation of duties, employees involved in recording vendor invoices in the cash disbursement system use three way matching to reconcile the purchase order, receiving documents and vendor invoice. They, therefore, must not perform any of the following duties: The purchasing or receiving process; Modifying vendor master f iles; Record keeping responsibilities for inventories, purchase payables or return.

Q Who can inform me about delegation of authority?

A The delegations of authority are usually kept by the legal or by the treasury department for those pertaining to bank accounts. With the exception of bank accounts, and when appropriate, the benef iciaries are allowed to sub-delegate. B e fo re s i g n i n g a n y d o c u m e n t o r authorizing any transaction in the name of a Technip Company, you must always ask yourself whether you have been empowered to do so. If you’re not sure, speak to your manager, to the legal department, or the treasury department for matters in connection with bank accounts.


WARNING SIGNS





Have a clear picture of your empowerments;

Preserve an effective segregation of duties;

Always comply with internal controls and behave as an example;

Design controls that aim at doing things right the f irst time;

Put forward your best effort to continuously improve internal control processes in your area of responsibilities;

Develop and maintain reliable f inancial and management data;

Promote adherence to laws, regulations, contracts and management directives;

Ensure that the internal reporting standards (See, GOPS and Guidelines) are followed at all times;

Propose remediation for any ineffective control you detect in your day-to-day activities.

Forget to emphasize the duty to report; Process transactions without proper validation of authorities;

Bypass the controls or the delegation of authorities;

Perform actions, issue reconciliations, grant authorizations or deliver assets in the name of others without having been empowered to do so;

View Internal Control as a coercive or negative activity;

Consider def iciencies detected as a sanction rather than as an opportunity to improve the processes you are involved in;

Think Internal Control takes time away from our core activities.

FURTHER READINGYOUR DEPARTMENT MANAGER SHOULD BE ABLE TO PROVIDE YOU WITH THE SPECIFIC INTERNAL CONTROL RULES THAT APPLY TO YOUR FUNCTION AND POSITION, INCLUDING: GOPS, Guidelines & Group Instructions series 14 – Finances & Control

Departmental policies and procedures

Internal Control Instructions and Risks and Control Matrices

Or Visit the Group Link Procedures page for Finances and Control: http://thelink.exnet.technip.com/sites/groupmain/proceduresandstandards/Pages/Finances_Control.aspx


56



Internal Controls

Quality


Property





www.technip.com


Quality

Quality refers to both the quality of the products and services delivered by Technip to our clients, and the quality of all the operations that contribute to the optimal, reliable and safe delivery of these products and services.

Technip’s goal is to be a leader in the energy industry by providing excellent quality in whatever we do, reliable product and asset integrity, during both project execution and installation lifecycle.

Quality at Technip is focused on the following principles:

Empowered and accountable quality leaders;

Focus on operational tasks; Do it right the f irst time; Assess risks and prioritize resources accordingly;

Knowledge is shared and accessible.

Q In the case of a major quality incident on a project what should I do?

A Evaluate the impact on our reputation, product performance, schedule and cost and issue a Quality Alert to help other projects avoid the same thing happening to them.

Q R e g a r d i n g s u p p l i e r s a n d subcontractors, how can I balance cost, schedule and quality?

A Always use the right level of supplier/subcontractor qualification audit and inspection resource to prevent the delivery of poor quality products or services.

THE BASICS FREQUENTLY

ASKED QUESTIONS



Managers and their teams have further responsibilities through QUARTZ (Group Quality Program):

Quality Leadership: Lead by example and promote quality awareness;

Operational Performance: Promote Client Satisfaction Surveys on all projects and the measurement of our internal performance—to set targets for improvement;

Business Excellence: Identify key areas to deploy resources for continuous improvement;

Quality Alerts: Promote problem awareness, looking for solutions and sharing information across the Group;

Knowledge Management: Focus on lessons learned and project f inal report to “Share What Works”;

Suppliers & Subcontractors Management: Assess criticality rating of the commodities, for supplier/subcontractor pro-active risk management.

Be a role model for an enhanced Culture of Excellence and Continuous Improvement, and ask our people to show PASSION for QUALITY.

All employees should always:

Know and comply with the applicable quality standards and regulations;

Cultivate a quality climate by setting an outstanding behavior;

Understand the risks related to quality and implement the required measures to prevent non-conformities;

Intervene if quality standards are not strictly applied;

Look for information, standards and support that may facilitate doing things right the f irst time;

Seek to reach or exceed Client’s satisfaction, meeting all the agreed requirements;

Aim to do things better (in Quality and HSE), faster (on schedule) and more cost effectively (on budget), while always respecting applicable standards and requirements;

Work as a team, alerting on quality issues and sharing information and best practices;

Integrate suppliers and subcontractors into our activities to deliver excellence together with them.

HOW TO BEHAVE

58



Internal Controls

Quality


Property



Lead by example and focus on Client satisfaction;

Be proactive and monitor performance to deliver quality on time and on budget to specif ication;

Follow the standards and strive for continuous improvement;

Communicate quality issues, share lessons learned and best practices;

Balance business risks, costs and resources, focusing on critical issues, and f ix them;

Collaborate with Suppliers and Subcontractors.


Compromise quality; Underestimate business requirements and risks;

Be reluctant to change or make improvements;

Hide quality issues or incidents; Perform critical tasks without knowing requirements and standard practices;

Underestimate the impact of poor quality.

FURTHER READINGFOR MORE INFORMATION ON QUALITY: See the GOPS series 10 – Quality Management

Visit the Group Link Procedure page for Quality Management: http://thelink.exnet.technip.com/sites/groupmain/proceduresandstandards/Pages/Quality_Management.aspx

Visit the Quality Group Link homepage: http://thelink.exnet.technip.com/sites/groupmain/Quality/Pages/QUARTZ.aspx



http://thelink.exnet.technip.com/sites/groupmain/proceduresandstandards/Pages/Quality_Management.aspx



http://thelink.exnet.technip.com/sites/groupmain/Quality/Pages/QUARTZ.aspx

http://thelink.exnet.technip.com/sites/groupmain/Quality/Pages/QUARTZ.aspx

www.technip.com


Protection Of Intellectual Property

Technip’s intellectual property and know-how are valuable assets. It is one of the foundations of our competitive market advantage. Our intellectual property is embodied in our product offerings, and it becomes the basis for the solutions that solve our Clients’ increasingly complex requirements. We must all protect Technip’s patents, copyrights, trademarks, trade secrets and our other proprietary information.

At the same time, Technip must ensure that it respects the intellectual property rights of others. Technip is responsible for protecting third-party intellectual property that it is authorized to use. Technip complies with all laws, regulations and contractual obligations regarding the valid intellectual property rights of others. Unauthorized use of intellectual property can result in severe civil and criminal penalties for the company and the employee.

To avoid these risks, and to protect our intellectual property, we must ensure that new products, software, processes, and services are reviewed for new inventions or trade secrets, and that they do not infringe on the intellectual property rights of others.


60



Internal Controls

Quality


Property



Submit possible new inventions to the Group Intellectual Property Department by submitting to them a signed “Inventor Questionnaire Form”;

Discuss the use of third party intellectual property or conf idential information with your regional legal department;

Comply with the use of Technip’s branding, see the section on Corporate Image and Brand for more information.


Divulge a previous employer’s conf idential or proprietary information;

Provide information about a new service or product before a patent application has been f iled, or the Group Intellectual Property Department has decided not to pursue a patent;

Discuss Technip conf idential or proprietary information with third parties;

Disclose a third party’s proprietary information when Technip has an obligation to keep it conf idential.

FURTHER READINGFOR MORE INFORMATION: See the GOPS series 15 – General Counsel

Visit the Group Link Procedures page for General Counsel: http://thelink.exnet.technip.com/sites/groupmain/proceduresandstandards/Pages/General_Counsel.aspx



http://thelink.exnet.technip.com/sites/groupmain/proceduresandstandards/Pages/General_Counsel.aspx



www.technip.com



Information security seeks to preserve the conf identiality, integrity, and availability of information in order to reduce the risk and the impact of a potential threat to our business and operations. Protection of Technip know-how is crucial to preserving our business and competitiveness on a daily basis. IT Security aims at protecting this know-how and reducing the risk of IT disruptions.

Comply with the security standards and with the Charter of Use of Information Systems. Learn about internal control procedures and contractual conf identiality clauses, especially on Projects. Read information security news and alerts from the Security and IT Department.

Although “cyber-attacks” are complex, they always start with an imprudent act or a lack of awareness. Therefore, the most important thing you can do is read awareness information and remain vigilant at all times, and especially when handling emails, browsing the web or taking outside phone calls.

Most cyber-attacks come through one of three channels:

Email: A malicious email usually has the following characteristics: It contains a link to an external website and/or an attachment;

It comes from an external email address; It looks like it was sent by a well-established institution (including Technip).

Web: Be vigilant when you browse the web. Do not click on a link that seems suspicious, and do not download any f ile from an untrusted source.

Phone calls: External fraudsters may use them to try to obtain information about Technip. Watch out for: The phone number displayed on your phone is an external one;

The caller takes on the identity of someone in Technip or one of its partner, to get the information he/she wants.

To crosscheck that the phone call was from a legitimate Technip person, call the person the caller claims to be or contact him/her through another channel like email.

FURTHER READING See the GOPS series 24 – Information Technology Visit the Group Link Procedures page for Information Technology: http://thelink.

exnet.technip.com/sites/groupmain/proceduresandstandards/Pages/Information_Technology.aspx

You may receive security alerts from your IT and/or Security Departments. Read them carefully. Also, read these two booklets: “Information Security and Privacy within Technip”, explains what is at stake, how to protect sensitive information on a daily basis, and how to reduce the risks of a malicious IT attack. “External Fraud: How to detect and react?” covers external financial fraud attempts, the organization that has been set up within Technip to prevent them and several scenario of external frauds.

Visit the Information Security Group Link homepage: http://thelink.exnet.technip.com/sites/groupmain/Security/ITSecurityAndInfoProtection/Pages/default.aspx


HOW TO BEHAVE

THE BASICS WARNING SIGNS

62



Internal Controls

Quality


Property


http://thelink.exnet.technip.com/sites/groupmain/proceduresandstandards/Pages/Information_Technology.aspx



http://thelink.exnet.technip.com/sites/groupmain/Security/ITSecurityAndInfoProtection/Pages/default.aspx

http://thelink.exnet.technip.com/sites/groupmain/Security/ITSecurityAndInfoProtection/Pages/default.aspx

www.technip.com




Beware of suspicious emails and phone calls, especially when from someone you don’t know or if they contain a link;

Apply a clean-desk policy; Remain vigilant and report any potential incident involving conf idential or sensitive information;

Keep a discreet attitude in all circumstances;

Take care of conf idential data; If you are the owner of data, you are responsible for classifying the information according to the three levels (“Internal Conf idential”, “Conf idential”, “no mention”). See the Guideline “GL 13403 Data Classif ication and Transmission”;

On projects, classif ication levels may change, remain informed and follow the relevant guidelines release by project management;

As a rule of thumb, Technip’s data must remain on Technip’s IT Systems. Don’t share it on untrusted external websites;

Most cyber-attacks start with a malicious email. Forward suspicious messages to the Technip Scam email adress;

Do not connect to your Technip mailbox from a public computer;

All laptops must be protected by a startup password in addition to the Windows password. If your laptop does not have one, contact your IT Helpdesk.

Open links or attachments in suspicious emails;

Send any professional data to your personal email address;

Use public sharing websites to exchange professional documents;

Enter conf idential information into online translation tools;

Use your Technip email address to register on websites for a private use;

Use the same password for all websites; Disclose your travel plans on social media;

Leave your laptop or smartphone unattended in a public area;

Give any information about Technip or Projects to unknown persons over the phone. If you receive a suspicious phone call, send a message to the Money Fraud email adress.


64

Section 5 I Communications and Social Media

Corporate Image and Brand

External Communications

Social Media

66

68

69

Section 5

Communi- cations

and Social Media


Corporate Image and Brand

Our brand is an asset we need to protect. It is what makes us unique for all of our stakeholders. It is the personality that we express not only through our visual communications but also through our collective and individual behaviors.

Our brand identity encompasses our vision, mission and values. As with all human communication, the way we speak and the words and messages we choose are extremely relevant to the image that we project. Messaging encompasses the types of things we say and the tone we choose to express them in.

You have a role to play in protecting and preserving our image. You are an ambassador of Technip and as such, you must behave in conformity with our standards and principles, as detailed in this Code.

Any communications that don’t respect the spirit or the letter of our Brand Manual;

Inconsistent and inaccurate communications;

Any communications that you are embarrassed about.

Everyone in Technip is a Brand Ambassador. It is up to every single one of us to maintain and protect Technip’s reputation. It is critical that you follow the spirit and the letter of our Brand Manual. Consistent communications with all of our stakeholders is the foundation for our brand, our corporate image and our commercial success.


WARNING SIGNS

66


Corporate Image

and Brand


Social Media

Q How do values contribute to Technip’s business success?

A The va lues that we bel ieve in , communicate and act on, translate into sustainable solutions for our customers, the environment and the communities that we work in. Working at Technip means working with people who are dedicated to taking the success of our customers further. Our values support the fact that we always go the extra mile.

Q How do our corporate values relate the company’s vision for the future? How are they linked to our strategy?

A Technip’s vision for the future is to “meet the world energy challenge through our projects”; we work with our clients to br ing energy to the wor ld with a sustainable project approach. This vision is a perfect match to our values because we are doing the right thing for the world by building the future through the trust we have in our team but a l so by encouraging a fair return for all.


FURTHER READINGFOR MORE INFORMATION, YOU CAN REFER TO THE BRAND IDENTITY MANUAL, AND BRAND TOOLS IN THE LINK GROUP. Visit the Brand Identity Group Link homepage: http://thelink.exnet.technip.com/

sites/groupmain/AboutTechnip/Identity/Pages/home.aspx

Visit the Brand Tools Group Link homepage: http://thelink.exnet.technip.com/sites/groupmain/AboutTechnip/Brand_Tools/Pages/home.aspx

To learn more about our brand, a dedicated e-learning is available on Technip University intranet site.



http://thelink.exnet.technip.com/sites/groupmain/AboutTechnip/Identity/Pages/home.aspx

http://thelink.exnet.technip.com/sites/groupmain/AboutTechnip/Identity/Pages/home.aspx

http://thelink.exnet.technip.com/sites/groupmain/AboutTechnip/Brand_Tools/Pages/home.aspx

http://thelink.exnet.technip.com/sites/groupmain/AboutTechnip/Brand_Tools/Pages/home.aspx

www.technip.com



Procedures are currently in place to ensure that the Group’s external communications are produced and conveyed in a coordinated approach and properly reflect Technip’s global image.

Given its global presence, f inancial market reporting regulations and renowned technical expertise, Technip must be particularly vigilant with respect to any external dissemination of information. Any misinterpretation could negatively affect the Group’s image and f inancial performance.

Only the following people are authorized to release external information:

Chairman and CEO and Executive Committee members;

By delegation and within the framework of internal procedures, Group Communications Public Relations or Investor Relations Department managers;

Any external Group communications must be authorized by at least one of the above.

Technip personnel are not authorized to provide or issue Group-related information to outside parties without the Group’s expressed authorization.


FURTHER READINGFOR MORE INFORMATION: See the GOPS series 12 – Human Resources & Communications


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If contacted by external parties such as journalists, f inancial analysts, investors and shareholders, please do not respond to their questions and refer them to the Group Public Relations (Group Communications department) or Investor Relations teams so that they screen the request and decide how to answer it. You can also contact your Regional or Entity Communications Manager.

Moreover, if you deliver a speech in the presence of the above-mentioned outside parties (for example during a conference or an exhibition) or if you meet one of them by chance, do not divulge conf idential or privileged information.

WARNING SIGNSTHE DO’S:

RULES TO ALWAYS FOLLOW

The Golden Rule is: There is no “Off the Record”;

Whoever you meet, share information with care;

Only disclose information that is public, which means it has been published on Technip’s website: www.technip.com.


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Social Media

Social media is changing the way we interact and do business. Everything our employees post about Technip can impact the Company’s reputation. Equally, everything published online remains for a very long time and in some cases, cannot be undone. Therefore, social media should be used responsibly.

Speak for yourself and be transparent: it is important to understand the difference between mentioning the company and speaking on behalf of it. The Group Communications Department owns the Technip external media and press policy and the corporate social media strategy. Communications personnel are Technip’s only off icial spokespersons in the social space. Whenever you participate in social media and discuss topics related to the Group, make it clear that you are expressing your own opinions and that your comments do not represent the Group …

… Be responsible and respectful: when communicating online, pay particular attention to issues that are sensitive to Technip’s business and its clients, partners and suppliers, such as the price of oil and gas, oil spills, and other topics. In all discussions, use facts and references for your statements when possible. If you are unsure about whether a post is appropriate to share, it is better not to post it at all. If you realize you have published an inaccurate statement, acknowledge your mistake and correct it as soon as possible. Be polite and keep in mind that cultural differences may impede understanding. Avoid using remarks that could be interpreted as offensive and use a respectful tone even when disagreeing with others. Protect information, conf identiality, privacy and intellectual property: Technip rules apply to social media, and your obligations as a Technip employee are the same in the digital world as in the physical world. When engaging in social media, never share conf idential or sensitive information such as f inancial and commercial data, or any information related to ongoing projects, research and development, legal matters and strategy.

HOW TO BEHAVE

THE BASICS

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The content you post must represent your own personal views;

Everything you publish online should already be publicly available to journalists, clients or competitors. Never post conf idential, sensitive or proprietary information;

Avoid comments about persons or companies that could be perceived as negative or defamatory;

For security reasons, keep work-related travel or geographical positions conf idential;

Obtain written permission from the Community Manager prior to posting any Technip photo, video or logo;

Comply with laws and regulations governing intellectual property rights, including copyrights and trademarks.

FURTHER READINGFOR MORE INFORMATION: Please contact the Technip Community Manager for questions, comments,

permission for images, to share information that you would like to post to our social media accounts or to report an incorrect or defamatory statement seen online.

For more information, refer to Guidelines series 12 – Human Resources & Communications available on the Link.



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Technip Code of Conduct

For more information: www.technip.com

www.technip.com

Documents

Technip Code of · PDF fileBehavior at Work ... the ethical behaviors expected of you ... Our Code of Conduct covers a wide range of topics. Sometimes you may need more