Code of Conduct for Employees
“How We Work” is the Code of Conduct for all our employees, members of management and members of the Board of Directors. Scroll down to explore our Code online.
Code of Conduct for External Business Partners
Our “Code of Conduct for External Business Partners” provides guidance throughout all our business relationships outside of Implenia. Read it to find out about the preconditions for a long-lasting successful partnership with us.
Download PDF “Code of Conduct for External Business Partners”
1. What we stand for
Our Values
EXCELLENCE
We meet the most demanding requirements in our projects, services and internal processes. We live up to Excellence by setting standards based on tradition and innovation that help us exceed our partners’ expectations. Today and tomorrow.
AGILITY
We recognise opportunities and threats at an early point in time, and we address them quickly – both strategically and operationally. We live up to Agility by being a highly mobile, passionate, multinational team that constantly looks for new and innovative ways of overcoming barriers, thus achieving the best value for our customers.
SUSTAINABILITY
We generate results that endure, and we protect our fellow human beings and the environment. We live up to Sustainability by working together to create a future worth living for everyone.
COLLABORATION
We merge our diverse market knowledge and insight with professional expertise to the benefit of our customers and other stakeholders. We live up to Collaboration by creating trust through fairness, transparency and respect - with all our partners.
INTEGRITY
We meet high ethical standards, are honest and act in accordance with the agreements we make. We live up to Integrity by being honest and reliable, acting respectfully and always doing so with a smile. 😊
WE DO
- We read our Code and Internal Rules available in our Implenia Management System, which is our primary source, and take part in training courses.
- We speak up when we have questions or when we become aware of potential violations of applicable laws, our Code or our Internal Rules.
- We act in a manner consistent with our company values.
- We cooperate fully when asked to participate in an investigation or audit.
Our Code cannot cover every topic, so if you are unsure whether your conduct complies with the principles of applicable laws, our Code or our Internal Rules, as a first step you should ask yourself the following questions:
2. Our Integrity
Protecting Company Interests
How do we remain loyal?
We always make business decisions objectively and fairly in the best interests of Implenia, and we do not allow our personal interests to prevent (or even appear to prevent) us from doing so.
WE DO
- We understand that the mere appearance of a conflict of interest can be damaging.
- We disclose any potential conflicts of interests to our supervisor and to Compliance.
- We obtain prior written approval from our HR Business Partner before seeking secondary employment and comply with our Group Table of Responsibilities when considering the acceptance of an external mandate (e.g. executive management, board of directors, board of trustees).
WE DON’T
- We do not take any ownership stake in a competitor or a third party that does business with Implenia.
- We neither supervise close friends or family members nor participate in hiring a close friend or family member.
- We do not seek business opportunities discovered through our role at Implenia that could interfere with Implenia's opportunities or our duties.
Give and Take
How do we handle gifts and invitations?
We avoid even the appearance of corruption and bribery and exchange gifts only when they are appropriate and are not meant to unduly influence decision-making. We make sure that all gifts comply with applicable value limits and are properly approved as per our Group Integrity Guidelines. Gifts can include services, loans, travel, promises, favours – anything of value.
WE DO
- We review each gift and invitation and assess the frequency and timing of gifts we receive from the same supplier/partner, the value of the gift and the potential intent of the gift giver.
- We make sure that any gift or invitation we provide to a third party complies with their internal rules.
- We exercise caution when an government official is involved.
- We seek the required approval when considering sponsorship of or contributions to any organisation or individual.
- We report to Compliance any third party’s attempt to improperly influence us.
WE DON’T
- We do not accept gifts or invitations if the third party expects to either receive benefits of any kind or improperly influence our decision-making.
- We do not accept gifts and invitations from external business partners at our home address.
- We do not make facilitation payments, or small payments meant to facilitate routine government actions, such as issuing permits.
- We do not exchange cash or cash equivalents such as gift cards with third parties.
Question
I am working on a project with a government-owned railway company, and an engineer who works for the railway company asks to travel to Implenia’s headquarters for discussions. Should Implenia pay for the travel?
Réponse
Non. Les employés d’organisations détenues ou contrôlées par un gouvernement peuvent être considérés comme des représentants du gouvernement, et tout cadeau fait à de tels représentants doit faire l’objet d’une approbation préalable, conformément à nos Directive en matière d’intégrité du Groupe.
Fair Play in the market
How do we behave fairly?
We stand up for free, fair and effective competition, and we refrain from taking measures that restrict it or distort the market. When interacting with third parties, particularly customers and competitors, we neither discuss any agreements nor enter into any conversations about prices, quantities, territories or markets that restrict or distort the market.
WE DO
- We familiarise ourselves with the justifications for setting up a joint venture, following due process and properly documenting our reasons when setting up or joining one.
- We always check the agenda prior to attending association meetings, conferences or meetings with competitors. Where competition-related topics are on the agenda, we request their removal or do not attend the meeting.
- We distance ourselves from any improper behaviour of competitors or suppliers, such as attempts to make informal agreements on prices or other terms.
WE DON’T
- We do not talk about our business strategies unless they are public knowledge, and we never use terms that imply restricting free trade, like “monopoly” or “monopolist.”
- We do not influence the pricing policies of third parties, nor do we threaten third parties with exclusion from future tenders.
Question
I am attending an industry meeting and sitting next to a competitor who is discussing his organisation’s pricing strategy. I am not discussing any information about Implenia, so is this OK?
Answer
No. Discussion of any competition-related information about any organisation is problematic and requires you to withdraw from the conversation and report the interaction to Compliance immediately.
3. Our commitment to our evironment
Thinking about tomorrow today
How can we act sustainably?
We pursue sustainable approaches, including making workplace decisions that reduce negative impacts on the climate and the environment and advocating for future-proof building standards. We consider sustainability/environmental aspects along the entire value chain when purchasing (e.g. closing material cycles and using recycled or recyclable products or products made from renewable raw materials), and we correct obvious misstatements that could lead to pollution or non-compliance with environmental laws. We support innovation and invest in sustainable new products and solutions. We never simply accept unsustainable practices but instead take action to combat and resolve them.
WE DO
- We are all role models! We act sustainably in all workplace decisions.
- We know our Sustainability Goals and work towards achieving them, and we comply with all applicable environmental laws, regulations, standards and sustainability targets, while implementing an effective system to identify and eliminate environmental threats.
- We immediately report environmental incidents to the appropriate supervisor and the Sustainability/Safety specialist who has to make a report in accordance with our Incident Management Report.
- We use equipment and machinery efficiently and switch them off when not in use.
- We take measures to prevent pollution and to reduce our carbon dioxide emissions and our consumption of energy and resources.
WE DON’T
- We do not generate avoidable waste. We recycle unavoidable waste whenever possible and dispose of the rest properly.
- We do not ignore environmental impacts and instead seek to address and limit their causes.
- We do not accept behaviour that could lead to pollution or non-compliance with environmental laws.
- We do not shy away from the potentially higher investment costs of a new product or solution. Instead, we think in life cycles and consider whether the life-cycle savings could be greater than the additional investment costs.
4. Our Assets, Knowledge and Resources
SHH!
How can we keep secrets things secret?
We keep secret the confidential information belonging to Implenia, our customers and our suppliers, and we never make use of inside information. We don’t disclose confidential information to third parties, including our family and friends, except when a nondisclosure agreement is in force and the Legal & Compliance Department approves of the disclosure. We neither use or share information that may affect the market price of Implenia shares or any other company's securities, nor do we use or share inside information for the purpose of trading any securities.
WE DO
- We protect our confidential information and trade secrets from unauthorised disclosure and misuse, even after we leave Implenia.
- We stay aware of where we are, who is around us and what they might see or overhear.
- We use social media responsibly and follow our Social Media Usage Directive.
WE DON’T
- We do not speak on behalf of Implenia to the media or any third party, and we contact Marketing/Communications if we receive a request from a journalist.
- We do not disclose confidential information to others within our organisation who are not entitled to it.
Question
My cousin works for an organisation that Implenia is going to acquire. I assume she also knows about the acquisition even though the information is confidential and not yet public, so is it OK to talk with her about it?
Answer
No. We keep confidential, non-public information secret from everyone, even those closest to us.
Careful use of company property
How do we use and protect our resources, data and assets?
We are committed to protecting Implenia's resources and assets from damage, misuse, waste, improper disposal or theft, and we use company resources only for the purposes for which they are intended. We are all responsible for the timely, accurate and complete keeping of company data, meaning we make sure we never lose, damage, falsify or misuse. All company resources and assets, such as physical assets, documents, knowledge and intellectual property, belong to Implenia. If we need to dispose of our resources or assets, we must do so in accordance with our Internal Rules and only if we are authorised to do so.
WE DO
- We always use assets according to our IT Acceptable Usage Policy Directive.
- We respect and protect our intellectual property and that of third parties in accordance with the terms of all applicable contracts and never use software that has been illegally copied or purchased.
- We maintain timely, accurate and complete records of our data, information and documents that we have created or for which we are responsible (such as annual reports, project or tender documents, expense claims or emails).
- We keep all business records and data safe, follow all of Implenia’s data security procedures and comply with any records management and document retention procedures.
- We always check our Table of Responsibilities and Rules and Regulations on Signing Authority and comply with them before signing contracts, checking invoices, etc.
WE DON’T
- We do not use our computer systems, company email accounts and the internet inappropriately, and we only grant access to IT tools when they are necessary to perform work tasks.
- We do not share our credentials (i.e. user name, password) with colleagues or any third parties.
- We do not lend, transfer, sell or donate company assets to third parties without proper authorisation.
- We do not use systems, (including company emails) in an abusive, disruptive or otherwise harmful manner. This includes creating, displaying, saving or sending pornographic images or racist or discriminatory content.
5. Our Working Environment
All equally different
How do we treat each other?
We maintain a safe, equitable, inclusive and diverse workplace where everyone can feel comfortable and is treated politely and respectfully and where differences are welcomed and leveraged to achieve better business results. We should avoid statements or actions that offend others, including any unpleasant or derogatory remarks or actions based on ethnic origin, skin colour, nationality, religion, beliefs, gender, gender identity, sexual orientation, age, culture, disability or family situation. We don’t ignore discrimination or harassment in the workplace, including unwanted verbal comments, gestures, remarks or touching. Instead, we take action.
WE DO
- We speak up and report harassing or discriminatory behaviour to our supervisor, HR or Compliance.
- We are all role models, and we treat others tactfully, politely, respectfully and equally well
- We adhere to basic labour and human rights contained in international conventions, programmes and standards, such as the United Nations Universal Declaration of Human Rights. In particular, we grant fair wages, freedom of association and do not tolerate child and forced labour.
WE DON’T
- We do not engage in harassing activities, including issuing verbal, non-verbal and written slights, humiliation, insults or threats, nor do we participate in any social exclusion or the ostracism or deliberate and persistent persecution of a person.
Safety first
How do we stay healthy and safe?
We care about and take responsibility for our own health and safety and the health and safety of others. We seek to eliminate hazards and reduce risks in order to avoid illnesses and injuries. We have a systematic approach to identify hazards and appropriately manage risks within each unit, project and joint venture.
WE DO
- We make ourselves aware of health and safety risks and eliminate or reduce them before we start working.
- We promote a Health & Safety culture by acting consistently in a responsible and exemplary manner.
- We report to our immediate supervisor or safety representative if safety or health at work is compromised in any way, including all incidents, even if near-misses.
- We follow our Safety Rules, and we say “stop” in unsafe or noncompliant situations.
WE DON’T
- We do not work under the influence of alcohol or other substances, and we do not organise an event where alcohol will be consumed after work on our premises without prior proper approval.
Question
I am working with equipment that has a broken safety mechanism. Replacing or repairing the equipment will put our team behind the project schedule. Should I continue to use the equipment?
Answer
No. We do not compromise on safety. While we pride ourselves on delivering on time, safety always comes first, and the equipment must be repaired or replaced before you continue using it.
Privacy
How do we respect each other’s privacy?
We keep personal information confidential and comply with applicable laws and our privacy principles. We securely collect, store, host, process, transmit and use personal data; we make sure we collect and use data only when we have a legal basis, when it is necessary and when it is for a specific business need; and we provide it only to authorised persons. We don’t share personal data outside our organisation unless required by law, when using a third party to collect or when we have obtained consent to do so from the individual concerned. When using third parties to collect, host, use or process personal data in any other way, we ensure that they process personal data only as we are permitted to do so, including by signing a data processing/sharing agreement and complying with our privacy principles.
WE DO
- We respect our colleagues’ privacy rights.
- We comply with the data protection principles outlined in our Group Data Protection Policy.
WE DON’T
- We do not collect “sensitive” personal information (especially regarding biometric data, such as facial or veins scans, or health status, ethnic origin, sexual orientation, political views or religion) without contacting our Data Protection Team for guidance.
- We do not provide access to personal data to any unauthorised persons within our organisation. Sharing such data is on a strict “need-to-know” basis.
6. Using our Code
We stand up for what is right
Speak Up! Ask Questions!
Only with our collective support can we have a successful compliance culture that enables our business to thrive.
Where can I make a report?
You can use our Speak Up Line kto report your concerns about compliance or a possible violation.
Who can make a report or ask a questions?
Implenia promotes a culture that encourages everyone to speak out freely. Any person, whether an employee or not, can make a good faith report of a potential case of misconduct. Such a report can also be made anonymously.
What happens when a potential case of misconduct is reported to Compliance?
Any suspected violations of this Code, other Internal Rules or applicable laws will be thoroughly investigated by Compliance. In the event of confirmed misconduct, the relevant decision-making body may impose sanctions.
What happens to the whistleblower?
Implenia does not tolerate retaliation against those who make good faith reports based on credible concerns. Anyone who knows of – or suspects – a violation of our Code, Internal Rules or laws should feel safe to report it.
7. Downloads
Download PDF documents here
