UPERGY, which attaches the utmost importance to acting in an irreproachable manner with its stakeholders, has adopted a code of conduct in accordance with the Sapin II law. It is available here: Download the code of conduct.

It is intended for all employees, members of executive and management committees, corporate officers of UPERGY and its subsidiaries worldwide.

It formalises the principles that the Group’s employees respect in the context of their professional activities. It completes the rules, procedures and standards defined in each country to which employees must continue to refer.

All persons acting on behalf of UPERGY are required to comply with this Code of Conduct, regardless of the location or nature of their work.

UPERGY ensures that its partners share the same values.

This detailed code describes the fundamental rules concerning the following subjects:

• Gifts, sign of courtesy and hospitality, entertainment
• Specific rules for public officials
• Donations to charitable or political organisations
• Patronage, sponsoring
• Facilitation payments
• Commitment to monitoring third parties.

However, this document may not answer all the questions that may arise and does not dispense with exercising one’s own judgement and using common sense. In the event of any doubt about what to do, the Group has set up assistance and advice tools.

In support of the code of conduct, UPERGY has developed a purchasing policy (download the purchasing policy) and a gift policy (download the gift policy) to comply with the principles of the Sapin II law.

If you witness or are the victim of a violation of the Code of Ethics or the Code of Conduct, please complete the form available at the following link, so that we can investigate your complaint.

You can also contact the Anticorruption Committee using the contact details below:

• lanceurdalerte@upergy.com
• anticorruption@upergy.com
• 04 26 10 21 09

Since 2012, UPERGY has followed the Global Compact principles on human rights, labour standards and the environment, which are the subject of a universal consensus and are based on the following texts:

The Global Compact invites companies to adopt, support and apply within their sphere of influence a set of fundamental values in the areas of human rights, labour standards, environment and anti-corruption.

Ethifinance was at the origin of the Gaïa Index, established to measure the ESG (Environment / Social / Governance) performance of companies. UPERGY has taken this voluntary step since 2012, and joined the Gaïa Index in 2018, which includes the 70 companies with the best ESG performance.

UPERGY’s ranking evolution below:

Ranking/number of companies evaluated	2020	2019	2018	2017	2016	2015	2014	2013	2012
General classification	83/230	80/230	66/230	89/230	103/230	74/230	87/230	74/230	88/229
Ranking sales und. 150M€	6/78	6/74	5/67	9/67	11/64	3/67	10/70	13/70	17/75
Distribution sector classification	5/19	5/21	4/22	6/23	6/23	10/27	5/25
Euronext Growth ranking	3/41	4/36	3/33	3/26

To view the Gaïa Upergy certificate: click here