Governance

The Italian companies of the Lagardère Travel Retail Group (hereinafter the "Companies") have adopted a Code of Ethics which, in full compliance with the principles established by the Lagardère Group Code of Conduct, aims to define and communicate to its addressees the values ​​and the principles of the actions to which they must adhere in carrying out company activities.

Legislative Decree 231 of June 8, 2001 introduced into the Italian legal system, for legal entities, a system of criminal liability for certain crimes committed or attempted by directors, employees and subjects subjected to the management or supervision of companies, in the interest or for their benefit. The responsibility of the companies is excluded if they have been adopted and effectively implemented, before the commission of crimes, Organization, Management and Control Models ("231 Models") suitable to prevent the crimes themselves.

In compliance with the provisions of Legislative Decree 231 of 2001 and inspired by the guidelines provided by Confindustria, as well as in order to ensure correct and transparent conditions in the performance of company activities, the Italian companies of the Lagardère Travel Retail Group have adopted their own Organization, Management and Control Model pursuant to Legislative Decree 231/2001 and have established the

LS Travel Retail Italia S.r.l.

Procedure for Reports

The Italian Companies of  Lagardère Travel Retail Group (hereinafeter the “Companies”) make  ETHICS LINE platform (http://ethicsline.lagardere.com) available to any of the Group's stakeholders - employees and third parties who intend submit a disclosure in relation to any behavior or activity taking place within the framework of the Group's activities, perceived by the user as being unlawful or unethical, and presenting a certain level of seriousness.

WHAT CAN BE REPORTED​​

The platform can collect disclosures in the following areas:

  • Business secrecy – personal data breaches
  • Cybercrime
  • Human rights and fundamental freedoms violations
  • Environment and natural resources
  • Competition and unfair business practices
  • Conflicts of interest
  • Bribery and corruption
  • Discrimination, harassment, sexism
  • Health and safety of persons
  • Tax, accounting and financial crimes – internal fraud, money laundering
  • International economic sanctions and embargoes

Facts, information or documents, whatever their form or medium, covered by national defense secrecy, medical confidentiality or the secrecy of relations between a lawyer and his/her client, cannot be the subject of a disclosure on the Ethics Line platform.

In the interest of efficiency, the Group encourages its stakeholders to first turn to the usual reporting channels, and in particular:

  • for Group employees: managers, HR, staff representatives;
  • for third parties: business partners, internal contact points for the Group.

The Ethics Line platform is an alternative to these usual reporting channels for stakeholders who do not wish, for reasons of their own, to turn to their usual interlocutors.

PROCESSING OF A  DICLOSURE​

The recipients of the data are the external service provider operating the platform (Deloitte ) and a limited number of Lagardère Group [4] employees (Ethics Line Officers and entities punctually and temporarily solicited to process a disclosure). The data may be forwarded to the Group's external advisors and service providers (lawyers, auditors, etc.) for handling the disclosure.

PROTECTION OF REPORTING

The Lagardère Group guarantees the platform users confidential treatment of their information and ensures to protect their interests as well as those of people whose behavior could be the subject of a disclosure.

> Lagardère Group whistleblowing procedure can be accessed by clicking here
> Log a diclosure

 

Management Systems

Lagardère Travel Retail has chosen to organize its activities by defining an integrated system, aimed at providing services and creating safe products in compliance with the needs and expectations of customers.

The attention to the legal requirements, to the protection of environmental resources, to the needs of all the interested parties, has led Lagardère Travel Retail to adopt precise rules and adequate skills to effectively cope with present and future developments in the market and work world.

Whistleblowing Procedure – Ethics Line