Valeo compliance program: zero tolerance

Objectives of the Group Compliance Program

Valeo’s impeccable business ethics results from its determination to run its operations in strict compliance with the highest ethical standards and the numerous applicable regulations.

End to end integrity requires discipline, determination, commitment and leadership at every stage, in every country, at every level.

At the direction of the board of Directors of Valeo and of its Chief executive Officer, Valeo has put in place a Compliance organization, the purposes of which is to:

  1. define Valeo’s Ethics and Compliance principles, program and policies
  2. define roles and responsibilities
  3. develop the awareness of Valeo’s employees
  4. set up an ecosystem of contributors, both fully convinced of the necessity of acting with integrity and committed to comply with solid compliance programs
  5. foster a culture of prevention and put in place controls as well as mechanisms to detect and correct inappropriate or illegal behavior
  6. continuously improve the effectiveness and efficiency of the programs
  7. enforce zero tolerance for non compliance

The Valeo Compliance program focuses on Antitrust, Anti-corruption, Export Control, Economic Sanctions, Data Protection, Human Rights and on protecting assets and information.

The Group’s Compliance Organization

The Compliance organization is based on several committees and the total commitment of Valeo’s management as well as the personnel’s mobilization.

Audit & Risks Committee

The Audit and Risks Committee of the Board of Directors is responsible for ensuring the effectiveness of the risk management and internal control systems. As such, it regularly ensures that Valeo maintains a comprehensive program to comply with all laws and regulations governing its business activities, and conducts its business in an ethical and responsible manner.

The Executive Committee

The Executive Committee, chaired by Valeo’s Chief Executive Officer, defines the directions and priorities of the Compliance Program, allocates the necessary means and resources, and oversees and manages its implementation.

Executive Committee members are then responsible for conveying Valeo impeccable business ethics and end-to-end integrity culture throughout the organization either directly or via their own leadership teams.

The Ethics and Compliance Office

The Chief Ethics, Compliance and Data Protection Officer, together with a team of Compliance professionals, initiates, manages and coordinates the implementation of the Compliance programs as defined by the Executive Committee.

Reporting to the CEO, Valeo’s Chief Ethics, Compliance and Data Protection Officer provides regular program updates to the Audit & Risks Committee and to the Board of Directors of Valeo. She also sits on the Executive and Liaison Committees and collaborates extensively and closely with their members. She also sits on the risk committee and chairs the Alert committee. All contribute actively, both individually and via their teams, to the effectiveness and efficiency of the Compliance programs of Valeo.

The Compliance Champions

In support of and in coordination with the Ethics and Compliance Office, a team of Compliance and Data Protection Champions and officers, are responsible for promoting the Compliance programs within their area of responsibility, at Business Group, local and functional levels (Sales, R&D, Projects, Finance, HR, Legal, Purchasing, etc.).

Acting as spokespersons of both their leadership and the Chief Ethics, Compliance and Data Protection Officer, Compliance and data protection Champions are also responsible for helping their peers and colleagues understand the policies and tools applicable to their activities in consultation with the Ethics and Compliance Office as needed.

The management team

E&C and Data protection roles and responsibilities are clearly allocated among the various managers. As a matter of fact, managers, from all countries and businesses, have a key role to play in advocating and enforcing Compliance among their teams throughout Valeo’s day-to-day operations.

Ultimately, managers are all expected to act as role models and convey a zero tolerance approach to non compliance.

Employees at large

All employees are expected to behave ethically. They are specifically responsible for knowing and understanding the Code of Business Ethics, the Compliance programs and the policies, for complying with approval procedures, for taking all training in due course, asking for help as needed and alerting in case of doubts.

Group Compliance Program

Policies and Guidelines

The Ethics and Compliance culture.of Valeo is built upon to pillars:

  • The Valeo Business Code of Ethics that lays out the fundamental principles and values that drive Valeo’s activities and operations. It reflects the Valeo way of doing business.
  • The Valeo Business Partners code of Conduct that describes how those values and principles apply to Valeo’s other stakeholders.

Consistent with the codes, Valeo has developed additional detailed programs:

  • An antitrust compliance program; Valeo complies with the competition laws in force in the European Union and in each country in which the Group operates. Valeo strictly prohibits the exchange of sensitive business data and illegal arrangements with competitors.
  • An anti corruption/anti bribery program: Fighting corruption and influence peddling is also an integral part of Valeo’s policy. A detailed anti-corruption program has been drawn up, covering gifts, entertainment and hospitality offered to non-Valeo beneficiaries (customers, suppliers, …) from both private and public sector. The program also covers relationships with agents, purchasing procedures, M&A due diligences, logistics chain risks, etc.
  • An Export Control and Economic Sanctions Compliance program: this program sets the framework of Valeo’s International sales, import and export activities.
  • A Data Protection program: it determines how to use and protect personal data in a truly international business environment and how to take data protection into consideration when engineering and developing products and technologies.
  • A Human Rights Protection program; This program focuses on the human rights aspects of Valeo’s and its supply chain partners’ operations.

Resources and support for employees

In order to help Valeo’s employees and in particular, HR, Purchasing, Sales, Project and R&D teams etc, a number of resources have been developed. These include Guidelines, FAQs, Dos and Don’ts, and recommendations for specific Valeo businesses or processes, dedicated handbooks and procedures.

Our aim is to provide all employees with the tools required to be proactive and make the right decisions. We have therefore made these tools available to everyone on a user-friendly Ethics and Compliance portal. We also want our employees to turn to the right people at the right time. Employees are therefore encouraged to consult their line managers, the Compliance Champions, the Legal team and/or any member of the Ethics and Compliance Office.

Education awareness, training:
the cornerstones of Ethics and Compliance

Education awareness

Education is provided and awareness is developed in a variety of ways, including orientation and induction programs, team meetings, annual elearning campaigns and dedicated in person and virtual training sessions. The Executive Management conveys an Ethics and Compliance culture and reminds staff our zero tolerance for Ethics and Compliance violations.


As stated in Valeo Compliance Training policy, training is an essential component of Valeo’s Ethics and Compliance Program.

It is available in the form of both live training sessions and e-learning programs, developed in multiple languages. It is mandatory for all executives and engineers and those who either are exposed in their day to day activity or take part in particular projects or operations, in line with Valeo’s policies. It is strongly recommended for all other staff, who are regularly encouraged to follow the Program; and new joiners are to take the Ethics and compliance program within a month from on boarding.

In addition, special modules have been integrated into Valeo’s Leadership Development programs as well as training geared to specific functions such as sales, supply chain and purchasing.

Failure to participate in mandatory Compliance training may result in disciplinary action.

Business partners’ Commitment

Valeo expects from its Business partners that they share the same business ethics and apply the same level of care, diligence and compliance to their operations.

Suppliers, service providers, third party intermediaries must comply with both the laws and regulations of the countries in which they operate. They also need to agree to the Valeo Business Partner Code of Conduct and to make sure that their team members assigned to a mission for Valeo, understand and agree to it.

Business partners’ awareness development

In order to develop their understanding and awareness of the Compliance programs and Valeo’s policies and expectations in that respect, Valeo Ethics & Compliance Office has:

  • Created a Business Partners Ethics and Compliance Library containing a handbook on each program (Anti-corruption, Antitrust, Export Control & Economic Sanctions, Data Protection and Human Rights),
  • Made free compliance awareness development e-learning available to Valeo’s Business partners; those modules are highly recommended for all business partners and they are mandatory for some of them, among whom agents and intermediaries and their teams assigned to a Valeo project or mission. Modules are available in English, French, German, Chinese, Japanese and Spanish.

Alerts: risk prevention

Prevention and detection are crucial. Employees and Business partners are encouraged to use Valeo Internal Whistleblowing system to alert about a known or suspected non-compliance resulting from Valeo’s activities directly or indirectly, as soon as they become aware of it.

To that effect, Valeo offers a dedicated Platform, operated by a Europe based third party provider, accessible globally and where Whistleblowers can in any of the languages spoken in a country where Valeo operates:

  • place their report, filling in a predefined questionnaire and/or recording a message and attaching any supporting documents,
  • chose to whom they want to report: either to the Group (to Group Authorised persons) or to local / Country contact (to Entity Authorised persons). The list of Authorised persons is available on the Platform,
  • create a secure Inbox in order to communicate with the chosen Authorised person in a secure and confidential way.

Except when prohibited by a law, the Whistleblowers can even remain anonymous, if they wish to. A detailed whistleblowing policy is available in 21 languages.

Alerts are treated seriously, objectively, confidentiality, in compliance with local laws and the specific Valeo Whistleblowing policy.

An Alert is a serious action. No whistleblower who reports a Compliance issue in good faith will be sanctioned in any way for doing so. Retaliation against whistleblowers is not permitted.

On the other hand, Alerts that are aimed at damaging the reputation of the reported person will not be tolerated either.

To report an issue or an actual or potential non compliance:

QR code to report an issue or an actual or potential non compliance

To place a request or claim with the Data Protection Office: