GEODIS third parties qualification and onboarding process helps us understand who we are doing business with. It aims at providing transparency to our supply chain, identifying potential risks, making sure that your Company shares our values and that you are committed to comply with the highest standards.
You are asked to read this document, provide mandatory information and evidences — in compliance with laws, regulations and GEODIS ’policies — and send a copy to your GEODIS focal point.
Information about collection and use of personal data
A company of the GEODIS Group intends to enter into a business relationship with your company. With this document, we wish to inform you about collection and use of data and personal data your Company may provide in connection with the approval process GEODIS applies for potential business partners, vendors, suppliers and agents.
Why GEODIS Requires
This data processing is necessary to comply with applicable legal compliance obligations with the purpose of identifying and avoiding potential ground for infringements.
Before any of GEODIS entities worldwide (“GEODIS”) enter into a new business relationship with a business partners, vendors, suppliers and agents, GEODIS conducts a research and assessment of the integrity of the prospective business partner as well as its Key Persons.
“Key Persons” are individuals who have a considerable influence on the Company’s business activities based on either their position or their shareholding – in particular directors, officers as well as shareholders with a significant amount of shares or voting power.
What data your Company collects and transmits to GEODIS
Company collects and transmits to GEODIS its own data (Contact data, general information about its business, ownership and management and the prospective relationship including the remuneration model, the background and circumstances of the Company’s engagement) and personal data of its Key Persons such as, but not limited to, name, surname, date of birth and criminal record information (collectively the data). Company hereby represents and warrants that any such data is validly collected and that it and each of the Key Persons have each consented to provide such data and that such data be transmitted, collected and stored by GEODIS.
What GEODIS does with the data
GEODIS acts as data controller and stores the said data in its network and in an intranet-based software tool that helps GEODIS to quickly and transparently assess integrity risks, decide on the approval of the envisaged business relationship with the Company and document and provide proof of GEODIS ’diligent review.
Such diligent review includes without limitation verifying any such data against databases or tools that provide for:
- lists of sanctioned parties compiled by authorities,
- information about relevant and significant litigation or other legal proceedings,
- information about Company’s (or its Key Persons) being withdrawn or removed from the Trade register or equivalent,
- potential connections with government officials and/or political exposure,
- publicly available information. (including adverse media)
Access to data will be strictly limited to a small number of certain GEODIS key employees involved in the approval process on a strict need-to-know basis. This may also include access by employees of certain GEODIS entities in countries outside the European Union.
GEODIS may disclose collected data to law enforcement agencies auditors, attorneys or other third parties, if necessary to protect GEODIS ’interests, in particular in the course of legal procedures.
Data will be deleted as soon as its knowledge is no longer needed for the purpose as stated above or required to be retained by law.
Your Rights
Your Company or any of its Key Persons have the right to be informed about the personal data GEODIS stores about it / them and to have any inaccurate data corrected. The data controller is the GEODIS entity that initiated the approval process. To exercise the above referenced rights in relation to personal data, please contact dpo@geodis.com. Company undertakes to validly notify each of the Key Persons of the above.
Confirmation
Your Company hereby confirms:
• it acknowledges and agrees that your Company and the GEODIS entity concerned both qualify as separate controllers in respect of their processing related to the data shared for the purpose of completing the Know your Partner Program and are thus separately responsible for complying with applicable data protection requirements and for their respective own data processing.
• it consents to the collection, processing, storage and use of the Company’s data as stated above,
• it authorizes the individuals and representatives named and the individuals or representatives of GEODIS entities to provide GEODIS with information about the Company’s business relationship with such individual or representative and hereby exempts such individuals and representatives from their respective confidentiality obligations, and
• that your Company will provide personal data of the Key Persons only to the extent that the Company is entitled hereto in accordance with applicable law. Your Company will inform the Key Persons and obtain their consent to the extent required by law, in particular with regard to the purpose of the data collection and processing as well as the recipients. The Company will provide GEODIS with copies of the information and the consent upon request (a sample for such information is attached), and
• data provided by your Company is correct to the best of its knowledge.
GEODIS SUPPLIER CODE OF CONDUCT
Thank you for joining Geodis in its commitment to integrity in business. By signing this Supplier Code of Conduct, you agree to the following:
Compliance with laws and regulations
GEODIS is committed to comply with the principles of the United Nations Global Compact.
You agree to comply with all national laws, regulations and requirements applicable in the countries in which you operate for us or on our behalf.
You also agree to comply with and promote the highest standards of integrity during business interactions with or on behalf of GEODIS.
Human rights and fundamental freedoms
Forced labor and slavery
You agree to ensure that no forced labor is taking place within your company or in your subcontracting chain and that all employment is voluntary.
Child labor
You agree not to use child labor, unless specifically approved in writing by GEODIS and provided this is compliant with local laws. The term “child” refers to any person employed under the age of 18 years old. GEODIS supports the use of legitimate workplace apprenticeship programs which comply with all laws and regulations applicable to such apprenticeship programs.
Compensation and working hours
You agree to comply with all applicable wages and hour laws and regulations, including those related to minimum wages, overtime hours, piece rates and other elements of compensation, and provide legally mandated benefits.
Discrimination
You agree not discriminate in hiring and employment practices on any ground including but not limited to grounds of race, religion, age, nationality, social or ethnic origin, sexual orientation, gender, gender identity or expression, marital status, pregnancy, political affiliation, or disability.
Human rights, respect and dignity
You agree not complicit in any human rights abuse (child labor, slavery, war, internal repression, terrorism, human trafficking, modern slavery, illegal work etc.), harming others or breaching any of the principles promoted by GEODIS.
You agree to ensure a workforce free of corporal punishment, threats of violence or other forms of physical coercion or harassment. You also treat all personnel with dignity and respect.
Occupational health and safety
You agree to implement and constantly improve strict standards to ensure hygiene, health and safety in the workplace, in compliance with all applicable laws and regulations.
This means that you agree to implement the appropriate necessary means to ensure the knowledge of all policies, procedures and procedure. This includes a management system for reporting, investigating any dangerous situations and achieving a safer working environment
You also agree to ensure compliance with health and safety principles with your own suppliers and contractors.
Anti-bribery and corruption
You agree to comply with international anti-bribery and corruption standards as indicated in the OECD convention and all applicable laws and regulations (such as the Foreign Corrupt Practices Act in the USA, the United Kingdom Bribery Act 2010, French law Sapin II, etc.).
In particular you understand and agree to comply with GEODIS’ zero tolerance policy on bribery and corruption that strictly prohibits:
– any form of bribe to private parties (such as GEODIS’ employees or clients) and/or public officials, either directly or indirectly, in an attempt to unduly influence the behavior of these individuals
– Any facilitation payment.
For the purpose of this section, public officials shall any person working for a State entity or who is considered as a public official under local law, including for a public company or public body, or performing a public service mission. A state entity is defined as:
– Any States or state services (federal, national or local)
– Any government or any department, agency, or territorial administrations, including members of a royal family
– Any organisations or agencies controlled or directed by a State,
– Any State-owned or government controlled entity (e.g. a national oil company or a public hospital),
– Any international public organisations (UN, OECD, etc.),
– political parties including electoral candidates
– and any person acting in an official capacity for or on behalf of any of the above
You agree to train all persons expected to work on GEODIS business on anti-bribery and corruption.
You agree to refrain from offering any gift to GEODIS employees. Business-related entertainment or social contact may be appropriate, only if compliant with GEODI’ Gifts and invitations policy regarding amounts and authorization process.
No conflict of interest
You agree to disclose should your Company or any of its personnel or representatives have an actual or perceived conflict with GEODIS or GEODIS’ personnel.
Competition and anti-trust laws and regulations
You agree to comply with all applicable competition and anti-trust laws and regulations such as those adopted by the European Union and the United States.
Export laws and other regulations
You agree to comply with all applicable export laws and regulations adopted by the United Nations Security Council, the European Union, the United States which impose controls and sanctions against countries, entities, individuals and goods. You abide to these export controls and sanctions laws which give countries legal control notably over the shipment, disclosure of information, goods, services and transaction across national borders.
You also agree to comply with all applicable regulations regarding customs and transportation (including licenses notably for the transportation of hazardous material).
Security
You agree to maintain adequate security procedures to guard against the introduction of non-manifested cargo, and to handle properly hazardous item and any irregularity. GEODIS’ clients entrust their goods to us for transport or storage and they may also ask GEODIS or GEODIS’’ Suppliers to work in their premises and utilize their equipment. You also have the duty to protect and preserve all goods and resources from any deterioration, theft, misuse or misappropriation.
Data and privacy
You agree to respect the individuals and guarantee each person’s right to privacy. You undertake to treat personal or sensitive information as confidential and to administer it in compliance with the applicable laws in each country in which we do business.
You also treat any sensitive information as confidential (including but not limited to data pertaining to GEODIS documents, contracts and information, as well as technologies and software). It is strictly forbidden to divulge such information, or to use it for any purposes other than the services for which you have been selected.
Business continuity and emergency preparedness
You agree to be prepared to conduct business as normally as possible, in case of major disruptions (e.g. natural disasters, software viruses, strikes, etc.). As such, you agree to implement business continuity plans, emergency plans to protect GEODIS, employees, third party staff, as well as the environment.
Protecting the environment
You agree to comply with all laws and regulations relating to environmental protection and to join GEODIS in our dedication to the protection of human health, natural resources and the global environment, not only by complying with the law, but also by integrating sound environmental practices into your business decisions.
GEODIS may require you to provide relevant data on climate protection (e.g., emission data).
Subcontractors
Should GEODIS permit the use of sub-tier subcontractors for the provision of services to or on behalf of GEODIS, you agree to hold your subcontractors with equivalent and, in all cases, not less stringent terms principles as those set forth herein with regard to ethics, values, duty to comply with applicable laws, principles and obligations with your ownsubcontractors. You shall get assurance that your own subcontractors do not themselves further
subcontract without GEODIS’ prior approval.
Disclosure of information
You agree not to disclose confidential or proprietary information of GEODIS and that might have an adverse impact on GEODIS Group of companies ’performance or reputation.
“Confidential Information” shall be regarded as any, or, all information in whatever form whether disclosed verbally or in writing, or, whether eye readable or machine readable, or in any other representation of the form including, but not limited to the form, materials and design of any relevant equipment in whole or in part including any associated methods of operation and applications thereof, processes, formulae, plans, strategies, data, designs, specifications, photographs, drawings, technical literature and any related material made available by the Discloser to the Recipient.
Whistleblowing
You understand that Ethics and Compliance are key to GEODIS and are aware that GEODIS’ whistleblowing system is made available to you should you wish to disclose any non-compliance you witnessed in your interactions with or on behalf of GEODIS.
You may reach out o your point of contact at GEODIS or report any concern or non-compliance on the Geodis Ethics Alert System at https://wrs.expolink.co.uk/geodis
Compliance with GEODIS’ Supplier Code of Conduct
You agree that upon reasonable notice and on a scope limited to the services provided to or on behalf of GEODIS, GEODIS is entitled to check the compliance of your Company with the requirements of this Supplier Code of Conduct. If GEODIS becomes aware of any actions or event not complying with this Code of Conduct or has a reasonable belief that your Company is in breach with this Code of Conduct, GEODIS can either demand that corrective measures be taken or terminate for material breach, any contractual relationship with your Company.
Representations and warranties by the Supplier
You confirm that neither the corporate entity you represent, nor any of your affiliates, parent or sister companies, ultimate parent, nor any of your executives or employees, are under current criminal investigation or has been subject to any civil or criminal enforcement actions in your home country or abroad, for improper conduct or unethical behavior or breach of duty or laws and violation of the principles stated in this Supplier Code of Conduct, notably with regards to anti-corruption, child labor, forced labor and slavery, human rights, export control and sanctions, data and privacy protection, competition laws.
You agree that if, at any time, the representations, warranties and certifications herein are no longer accurate and complete, you will immediately notify GEODIS and provide any requested information.
Instructions
As a third party working with GEODIS, you are asked to provide this mandatory information, in compliance with laws, regulations and GEODIS’ policies.
The information you provide must be detailed, accurate and precise as it is used to perform a compliance review of your organization. The latter may include a legal analysis to determine whether GEODIS faces risk under local and international laws as a result of the contemplated relationship with you. (Please do not respond “n/a” or “not applicable” to any question without explaining why the question is not applicable to you). If your response to any question is not sufficiently detailed, is vague, or is incomplete, this will result (1) in delays in the evaluation process, and (2) in not qualifying you as a supplier to GEODIS. Any documents presented which are not in English should be accompanied by an English language translation.
GEODIS may also use the information to address and resolve any compliance issues that are identified through this process or at a later stage of our business relationships.
A major focus of attention is related to the identification of the actual subcontracting chain: we want to know which third party(ies) actually perform(s) the service you apply for. If you are required to subcontract a part or all the subject matter of the contract, we ask you to expressly indicate it.
Questions have been tailored to seek only information that is relevant to GEODIS’ compliance policies and conform to data protection and privacy requirements. The information collected may be transmitted in confidence to GEODIS employees, GEODIS external legal counsel and/or regulatory authorities. GEODIS will store and retain this information in accordance with its policies and procedures
Definitions
- Management includes all Directors, Officers, members of a company’s Board of Directors or any equivalent or comparable governing body or group as well as any individual that is legally and officially authorized to bind the Company (such as the CEO, President, General Manager or equivalent.)
- Company includes any company, corporation, partnership, limited liability company or other entity which responds to this questionnaire.
- GEODIS means the GEODIS entity Company shall provide services to as well as any affiliated (whether subsidiaries, branches, direct or indirect owner, branches) Company which pertains to the GEODIS Group as amended from time to time;
Government official includes any official, officer or employee contractor, consultant employed by or representative of any and all branches, levels and subdivisions
- national, state, local or band/tribe government,
- public international organization (such as the United Nations),
- agency or company subject to a country’s public procurement laws and
- the sole purpose of this questionnaire, we will also consider any political party, officer, employee or person acting for or on behalf of a political party or candidate for public office and their entities as well as political candidates
- company that is owned or controlled by a government, organization, agency or company of any of the above
Owner: includes any direct or indirect shareholder(s) or owner(s) (including the beneficiaries of any trust) including but not limited to the ultimate beneficial owners (i.e., a natural person/individual owning such company) and any intermediate entities or persons owning an interest in that company.