Ethical Charter

OUR ETHICS

Our actions are based on integrity, responsibility, and respect for others. Our first principle is to observe everywhere and in all circumstances the laws and rules which apply to our activities. It is not enough to “recognize” values. They must be put into practice, thus moving from Ethics as a generality to “our ethics”, in particular.

All of us, from Board Members to ordinary employees, have an absolute obligation to never act in a manner calling into question the reputation of SUEZ or raising doubts about our ethics.

That is why we have stated our principles in an explicit and formal manner. Charters and Codes of Conduct set out the obligations we have contracted with our stakeholders, that means with the concentric circles by which we carry out our business activity:

• the first being our Group: shareholders, subsidiaries, and personnel,
  
• next, our market: customers, suppliers and the competition, and
  
• most broadly, our human and natural environment – the community and our planet.

Our values and our ethics apply first of all to ourselves, though we engage all our partners investment partners, minority shareholders, suppliers, and others – to share the same ethical imperatives as ours.

THE GROUP
GDF SUEZ and its shareholders
GDF SUEZ and its subsidiaries
GDF SUEZ and its employees

SUEZ applies high corporate governance standards with, among others, the objective of optimizing shareholder value through capital growth and return on investment.

In addition to respecting financial market regulations as established by regulatory authorities2, we strive to ensure equal treatment for all shareholders.

Within the prescribed time frame3, we attach particular importance to providing financial information which is accurate, truthful, and verifiable.

GDF SUEZ AND ITS SUBSIDIARIES

We are committed to ensure that SUEZ maintains open, clear, and well-balanced relations with subsidiaries, and that the same quality of relations prevails between and among Group companies as well. In particular, that between them there is a free flow of accurate and truthful information.

We are also concerned to maintain the same type of relations with investment partners and minority shareholders. We invite them to share the same ethical standards as ours.

Locally, in a spirit of fairness and consistency, subsidiaries adopt procedures which make it possible to achieve the principles of the present charter and to satisfy their requirements.

GDF SUEZ AND ITS EMPLOYEES

The growth of SUEZ depends upon the quality of its workforce. Consequently, a particular effort is made to nurture convivial workplace relations by:

• evaluating employees above all on their skills, and respecting their diversity and their personal lives,
• encouraging their professional and personal development,
• developing an open and constructive dialogue between employees based on mutual confidence,
• protecting the health and safety of our employees, and
• rewarding team spirit and employee involvement in the life of the Group, in particular by keeping the personnel informed of Group objectives and challenges.

GDF SUEZ AND THE MARKET
GDF SUEZ and its customers
GDF SUEZ and its suppliers
GDF SUEZ and its competition

GDF SUEZ AND ITS CUSTOMERS

We endeavor to respond to our customers’ expectations by being attentive and available, by offering our imagination and spirit of innovation, by constantly seeking to improve service quality, particularly services that protect customer health and safety, by taking the social dimension into account in our public services activities, and by carefully balancing their needs with our constraints in calculating our remuneration.

These service criteria and factors of customer satisfaction and sustainable development, presuppose:

• open dialogue, based on information that is fair and complete,
• transparent procedures, and
• respect for commitments and the rules of fair play.

• collective purchasing decisions, with all parties acting in a team spirit,
• fairness and equity governing relations with suppliers who must be shielded from abuse of significant market position or placed in a situation of dependence,
• buyers with ethics beyond reproach can only insulate themselves from risks inherent in their position by rigorously applying fair competition rules and regulations,
• incorporating environmental and social concerns in supplier selection criteria.

SUEZ encourages its commercial partners, subcontractors, and suppliers, if they have not already done so, to adopt their own ethical, environmental, and social standards, but also to honor those of SUEZ.

GDF SUEZ AND ITS COMPETITION

• We are committed to observing the rules of fair play6.
• We are fair in our dealings with the competition and do not use defamatory language in reference to them.
• We commit not to take advantage of significant or dominant positions to place a customer or supplier in a situation of dependency.
• We protect our confidential information and our trade secrets.
• We use only legal and above-board means to obtain information on our competition.

GDF SUEZ AND SOCIETY
GDF SUEZ and the community
GDF SUEZ and the planet

We condemn corruption in all its forms. An employee who respects this principle cannot, because of this, be subject to a negative performance evaluation, nor to any form of blame or reprisal.

By the nature of our activities, SUEZ operates at the very heart of communities where we are active. We therefore have an obligation to give full consideration to the interests of those communities. As permitted by law, we participate in works of community interest, philanthropy, and sponsorship.

We comply with all legislation that regulates the funding of political parties or candidates to elected office. Where there is no legislation or regulation covering this issue, we refrain from any financing of political activity.

GDF SUEZ AND THE PLANET

The environmental issue is especially important for SUEZ: our Environmental Charter strongly insists: "SUEZ identity and values are rooted in respect for the environment and the human race, which shapes the environment and depends upon it."

We acknowledge our particular responsibility to present and future generations for protecting the environment. We set our objectives in accordance with the principles of sustainable development and publish our results.

The Group respects local legal and regulatory prescriptions and is responsive to the needs of its customers, neighbors, employees, and the community at large, and is attentive to any emissions or other impacts of its activities. It is concerned to promote the sharing of its environmental objectives with its partners, suppliers, and the owners of the facilities it manages, as the case may be.

To this end, it has instituted within each Group company a unit that has developed an action plan and tracking indicators. It uses the most appropriate and economically feasible techniques and methods to promote sustainable development, and encourages research and innovation to develop expertise in relation to quality, safety, materials recovery and recycling, conserving natural resources, and reducing pollution.

CONCLUSION.
ETHICS, A SHARED RESPONSIBILITY

The Group makes decisions and adopts the necessary measures to see that its business ethics are respected at every level in the reporting chain. It is impossible, however, to anticipate every possibility and draft rules for each situation.

As mentioned at the head of many documents, there are a multitude of situations in daily life where one must use common sense and good judgment to determine appropriate behavior. Each employee is responsible for his or her professional conduct. The fact that a colleague or a competitor might have a different way of behaving is never a reason or an excuse for breaking the Group’s rules. Pursuit of commercial success or profit does not justify misconduct. It cannot be emphasized enough: beyond the rules applying to such and such a situation, each individual must be imbued with an ethical spirit. Those so motivated will always find support from the Group to help resolve moral dilemmas. It only requires discussing the situation with a supervisor, the company legal officer, general secretary, or Ethics Officer.