Ethics and anti‑corruption
A resolute commitment
As a signatory to the UN Global Compact, Société de la Tour Eiffel has a proactive ethics and anti-corruption policy. We also refer to the MiddleNext Code, the code of ethics for the Fedération des Societés Immobilieres et Foncieres, and implement responsible purchasing charters. These schemes are regularly monitored to prevent abuse or malfunction.
Charters and codes
(French version only)
Internal rules of the Board of Directors as at November 2023
Internal rules of the Board of Directors as at 27 April 2022
Code of ethics – Société de la Tour Eiffel
Ethical and responsible
business conduct
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.
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.
Since 2022, employees have been given compulsory anti-corruption training, in electronic format plus a half-day of face-to-face training per employee.
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.
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.
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.
