Integrated
Governance

Consideration of ESG issues
and business ethics

Société de la Tour Eiffel has set up specific ESG governance bodies to ensure that ESG issues are taken into account at the highest decision-making level. Referring to the Middlenext Code, it conducts its relations with its stakeholders in an ethical spirit.

Integration of ESG issues into every decision‑making process

Creation in 2022 of a dedicated specialist Board Committee (Environmental, Social and Governance Committee) to ensure that the highest level of governance is involved;

Creation in 2022 of a dedicated CSR & Innovation Department, to enable greater cross-functionality of sustainable development issues in both operational departments and support functions, and to accelerate deployment of our sustainable performance. It fits naturally into the CSR Committee, which has been in existence since 2014.

Ethical and responsible
business conduct

INTERNAL ETHICS CHARTER

All Société de la Tour Eiffel employees and General Management have signed an Ethics Charter (French version only) first introduced in 2016. This Charter was inspired by the UN Global Compact and sets out universal principles in the areas of human rights, working conditions, the environment and the fight against corruption. Specifically with regard to corruption, the Charter establishes a strict gifts and entertainment policy for employees and encourages them to avoid any situation that could involve a conflict of interest between their private interests and those of Société de la Tour Eiffel.

ETHICS ADVISOR

In 2023, an external ethics advisor was appointed to advise all employees on all ethical issues, including corruption. The Ethics Advisor reports anonymously to General Management, so employees can consult him or her in complete confidence. This officer is independent of and in addition to the mandatory whistleblowing procedure available.

FIGHTING CORRUPTION – TRAINING

Since 2022, employees have been given compulsory anti-corruption training, in electronic format plus a half-day of face-to-face training per employee.

PROCEDURE FOR PREVENTING INSIDER TRADING

Employees and directors are made aware of the risk of insider trading as soon as they join the Company. A compliance officer acts as an advisor to anyone who has questions on this subject.

MANAGING CONFLICTS OF INTEREST

Internal regulations set out the steps members of the Board of Directors need to take to avoid conflicts of interest. At operational level, calls for tender are processed on a platform that allows bids to be opened simultaneously at the end of the submission deadline. Calls for tender are accompanied by analysis reports that provide objective information to help with choosing the company with which to sign the contract.

COMBATING TAX EVASION

The risk of tax evasion does not apply to the Company. As it has SIIC (Listed Real Estate Investment Company) status, it is not liable for corporation tax. The tax is passed on to shareholders who receive a dividend. The bank responsible for paying the dividend declares it to the Treasury Department of the French State (DGFiP) on behalf of all shareholders, regardless of their tax residence.