Last updated: January 5, 2025

Introduction

The SIIA Ethical and Compliance Charter constitutes the framework that governs our commitments, values, and obligations regarding governance, integrity, and responsibility. This charter defines the fundamental principles that must guide all activities of the organization, ensuring compliance with legal standards, regulatory requirements, and the most rigorous international standards.

In a global context characterized by increased vigilance on issues of transparency, business ethics, and compliance with national and international regulations, SIIA reaffirms its unwavering commitment to fighting corruption, protecting data, preventing conflicts of interest, and respecting fundamental rights.

This charter applies to all stakeholders of SIIA, without exception:

• Executives and members of the executive committee

• Employees, freelancers, and consultants

• Strategic partners, suppliers, and subcontractors

• Clients and collaborators in their interactions with SIIA

Compliance with this charter is an essential condition for any collaboration with SIIA. Any violation of the established principles may lead to disciplinary and contractual sanctions, potentially resulting in the termination of business relationships and referral to the competent authorities.

Fundamental Principles

Integrity and Transparency

Integrity is a fundamental principle of all actions and decisions made by SIIA. We are committed to:

• Maintaining honest and transparent communication with all stakeholders.

• Ensuring traceability and absolute clarity in our business and contractual activities.

• Avoiding any form of misinformation, manipulation, or falsification of data and facts.

• Requiring systematic declarations of conflicts of interest in any business relationship.

All collaborators and partners of SIIA must refuse any action or decision contrary to the principles of integrity and loyalty.

Compliance with Laws and Regulations

SIIA is committed to complying with all applicable laws and regulations in the jurisdictions where it operates, particularly in the areas of:

• Protection of personal data (GDPR, CCPA, Data Protection Act).

• Fighting against corruption and money laundering (FCPA, UK Bribery Act, Sapin II Law).

• Compliance with competition rules and public procurement.

• Respect for local and international laws regarding trade and intellectual property.

Any failure to meet these obligations will expose offenders to disciplinary and legal actions.

Confidentiality and Data Protection

SIIA implements a strict privacy and data security policy based on the following principles:

• Rigorous protection of confidential, strategic, and personal information.

• Implementation of advanced cybersecurity protocols to prevent any data breach.

• Continuous training for staff on the risks associated with information leaks and cyberattacks.

• Restriction of access to sensitive data based on the principle of need-to-know.

Any violation of confidentiality rules will be considered a serious offense and may lead to immediate sanctions.

Fighting Corruption and Unfair Practices

SIIA adopts a zero-tolerance policy towards corruption, bribery, and anti-competitive practices. It is strictly prohibited:

• To offer or accept any undue advantage, illicit payment, or disproportionate gift aimed at influencing a decision.

• To resort to intermediaries or facilitators with the aim of circumventing regulatory obligations.

• To participate in illegal agreements, abuse of dominant position or fraudulent practices.

Any suspicion or attempt at corruption must be reported immediately to the Compliance and Ethics Committee via a confidential reporting channel.

Respect for Human Rights and Social Standards

SIIA ensures the application of international standards regarding human rights and fair working conditions:

• Strict refusal to engage in forced labor, human trafficking, or child exploitation.

• Promotion of equal opportunities and diversity, without discrimination based on origin, gender, religion, or sexual orientation.

• Respect for labor rights and safety standards ensuring decent and secure working conditions.

Any violation of these principles will result in the immediate exclusion of the concerned suppliers, partners, or collaborators.

Environmental Responsibility and Sustainable Development

SIIA recognizes the importance of reducing its environmental impact and integrating sustainable practices into its operations. To this end, we are committed to:

• Reducing our carbon footprint by limiting travel and prioritizing digital solutions.

• Working with suppliers who adhere to environmental and ethical standards.

• Promoting eco-responsible technologies and practices among our collaborators and partners.

Control and Compliance Mechanisms

Compliance and Control Committee

SIIA has established a Compliance and Ethics Committee tasked with:

• Overseeing the strict application of this charter and ensuring its compliance.

• Identifying and assessing risks of non-compliance and ethical breaches.

• Implementing internal controls and regular audits to prevent violations.

Reporting Mechanism for Violations

Any collaborator, client, or partner who is aware of a violation of the principles of this charter is required to report it immediately.

• A secure reporting channel is available: compliance@siiaworldwide.com.

• All reports will be subject to a rigorous and impartial investigation.

• Whistleblowers benefit from absolute protection against any form of retaliation.

Training and Awareness

Every SIIA employee receives mandatory training in ethics and compliance upon onboarding.

• Regular workshops are organized to ensure knowledge updates.

• A detailed guide on ethical best practices is provided to every employee.

Sanctions and Disciplinary Measures

General Principles of Sanctions

Respect for the ethical and compliance principles outlined in this charter is an essential obligation for all stakeholders of SIIA. Any proven violation or attempt at violation will result in sanctions proportional to the severity of the facts, which may include legal actions.

SIIA applies a strict and graduated approach to disciplinary sanctions, taking into account:

• The nature and severity of the offense (fraud, corruption, violation of confidentiality rules, discrimination, harassment, etc.).

• The intentionality of the act (unintentional lapse, gross negligence, premeditated action).

• The impact on the organization, partners, and stakeholders.

• The sanctions already applied in similar cases to ensure consistency and fairness in decisions.

No tolerance will be granted for serious violations of the charter, particularly those that may undermine the integrity of SIIA, its reputation, or its legal and regulatory commitments.

Types of Sanctions Applicable to Employees

Disciplinary sanctions applicable to employees and consultants of SIIA are graduated and include:

• Formal warning: Written notification reminding of the seriousness of the breach and requiring the collaborator to immediately comply with ethical requirements.

• Official reprimand: Notation in the employee's file, with an obligation to undergo compliance and ethics training.

• Temporary suspension: Disciplinary layoff with loss of remuneration based on the severity of the established facts.

• Dismissal for serious misconduct: Immediate termination of the employment contract without compensation, in case of intentional violation, fraud, corruption, or flagrant non-compliance with SIIA rules.

• Legal proceedings: In case of financial fraud, corruption, embezzlement, or serious violations of applicable regulations, SIIA may refer the competent authorities and initiate proceedings before the courts.

Sanctions Applicable to Partners, Suppliers, and Clients

Any non-compliance with SIIA's ethical commitments by a partner, supplier, or client may result in:

• An official reminder of contractual obligations, with a deadline to remedy established violations.

• Temporary suspension of the collaboration until adequate corrective measures are put in place.

• Immediate termination of the contract in case of serious breach or repeat violation.

• Legal proceedings and referral to the competent authorities, particularly in case of involvement in fraudulent practices, acts of corruption, or violations of human and social rights.

Investigation and Sanction Procedure

Any suspected violation of the Ethical and Compliance Charter is subject to a thorough investigation, conducted under the authority of the Compliance and Ethics Committee.

The steps of the disciplinary procedure are as follows:

1. Reporting the breach via the confidential compliance channel.

2. Preliminary assessment of the facts, with collection of evidence and testimonies.

3. In-depth internal investigation, conducted by the Compliance Committee impartially.

4. Notification of the concerned person, with the possibility to present their observations and defense.

5. Decision on the applicable sanction, with justified reasoning.

6. Implementation of the sanction and monitoring compliance with the required corrective measures.

Any employee, partner, or supplier who has been subjected to a disciplinary sanction may appeal to the Ethics Committee or competent judicial authorities if the sanction is deemed disproportionate or unfounded.

Commitment to Compliance

Obligation to Adhere to the Ethical Charter

Adherence to the principles outlined in this Charter is a non-negotiable condition for any collaboration with SIIA.

• All employees, consultants, and executives must sign a written commitment attesting to their understanding and acceptance of SIIA's compliance and ethical principles.

• Any partner, supplier, or subcontractor must adhere to SIIA's ethical and regulatory standards before any contractual engagement.

• Clients must be informed of SIIA's commitments regarding compliance and transparency and must comply in their interactions with the organization.

Commitment to respecting this charter is regularly re-evaluated and renewed as part of compliance audits.

Implementation of Training and Awareness Programs

SIIA implements a continuous training program to ensure that all employees, partners, and subcontractors master the ethical and regulatory requirements.

• Mandatory training on business ethics, anti-corruption, and data protection. • Practical workshops and situational exercises to raise awareness among teams about non-compliance risks.

• Availability of a detailed Code of Conduct, accessible to all, explaining the expected behaviors in common professional situations.

• Annual update sessions to ensure SIIA's practices align with legislative developments and best international practices.

Any employee or partner refusing to attend these trainings or failing to comply with compliance obligations is subject to immediate disciplinary or contractual sanctions.

Compliance Audits and Controls

SIIA regularly conducts internal and external audits to:

• Verify the effective adherence to the Ethical Charter within the organization.

• Assess the risk management and compliance processes in place.

• Identify areas for improvement to strengthen the culture of integrity and responsibility.

These audits continuously adapt control and sanction measures to regulatory changes and emerging risks.

Responsibility of Executives and Exemplarity

SIIA executives and management bear a particular responsibility in applying and promoting ethical principles. They must:

• Set an example by respecting and applying the charter in all their decisions.

• Encourage a culture of transparency and responsibility within teams.

• Immediately sanction any behavior contrary to SIIA's values

.Ethics and compliance are not abstract principles, but concrete and imperative requirements integrated into all activities of the organization.

This Ethical and Compliance Charter represents SIIA's irreversible commitment to respecting the highest international standards and ensuring exemplary governance.

Any breach of these principles will be treated with the utmost seriousness to preserve the integrity, reputation, and sustainability of SIIA.