Prevention of corruption
A “zero tolerance” policy concerning corruption
Aixial Group has a “zero tolerance” policy regarding corruption and strives to disseminate this message to all its stakeholders. In addition, Aixial Group carries out its activities in compliance with the national and international standards to which it is subject regarding the prevention and the detection of corruption acts.Aixial Group has defined and carries out its anti-corruption policy in compliance with the eight pillars prescribed by the Sapin II Law. This policy is formalized by a set of reference documents, guides and policies reaffirming the Group’s commitment and the guiding principles in the prevention of corruption.
A supervised practice of gifts and invitations offered or received
Aixial Group acknowledges that invitations and gifts offered or received can play an important role in developing good business relationships.However, these practices can sometimes be seen as a factor that influences business decisions, constituting therefore an act of corruption or leading to a conflict of interest. In order to monitor these behaviors, Aixial has issued a gift and hospitality policy that reaffirms the guiding principles, set out the criteria for granting or accepting gifts and invitations, and provides employees with recommendations when confronted
Are you a direct witness to an act of corruption, to an unethical behavior committed by Aixial?
In such case, you can use our whistleblowing system by logging into the secure platform:
Prevention and management of conflicts of interest
Each Aixial’s employee must perform his/her duties objectively. This is why the Group promotes transparency towards any situation that could give rise to a potential or proven conflict of interest.
The Group has a practical guide on conflicts of interest in order to increase employee awareness. The Group also provides several channels of information/communication to report situations of potential or proven conflicts of interest.
The Group’s policy on conflicts of interest is also reaffirmed in the Anti-corruption Code of Conduct and in the Ethics and Compliance Charter.
Management of lobbying and interest representation
Aixial Group undertakes to carry out its lobbying activities in accordance with applicable national and international laws and conventions, as well as its compliance policy.
The lobbying rules are reaffirmed in the Anti-corruption Code of Conduct. The Group ensures that lobbying activities are clear and transparent and do not aim at obtaining information in a dishonest manner. Aixail also ensures that the information provided is up-to-date, complete and accurate. To do so, lobbying actions require Management’s prior approval.
To date, the Aixial Group does not carry out any lobbying activity, which is why it does not appear in any register.
Should Aixial start developing this practice, it undertakes to comply with all of these obligations.
Compliance with international sanctions
Aixial Group operates in strict compliance with international sanctions regimes.
The Group’s compliance policy also covers prevention of risks in terms of violation of international sanctions. This is referred to in the “Ethics & Compliance in a nutshell” guide, distributed to all Managers and Ethics & Compliance ambassadors.
The due diligence of third parties, which has been implemented as part of anti-corruption measures, is also intended to prevent risks in terms of violation of international sanctions by Aixial Group.
Compliance with competition rules
Aixial Group and its employees comply with French, European and international competition law and the laws applicable in each of the countries in which the Group conducts its activity.
Aixial Group and its employees refrain from directly or indirectly hindering freedom of competition in all commercial transactions.They also refrain from adopting any unfair trading practices towards competitors and from striking any unlawful deals.
In order to achieve this objective, the Group disseminates practical sheets so as to make all employees aware of the necessity to comply with competition rules. The Group’s principles are also reaffirmed in the Ethics & Compliance Charter.
The Aixial Group provides employees with several information/communication channels to report non-compete situations.
Protection of personal data
Aixial takes all the necessary precautions to ensure that personal data is processed securely and in accordance with regulations.
The Group has a dedicated organization and governance and has created a Group DPO position. The Group DPO reports to Aixial’s Ethics & Compliance Group department and is involved in all matters in connection with the processing of personal data.
The DPO has all the necessary means to carry out his duties and has access to processing operations. He does not receive any instructions relating to the performance of his duties from the company and reports directly to the highest level of management of the company.
The Group DPO is responsible for coordinating and deploying, through a network of Data Protection Officers (DPOs) or Data Protection correspondents, the Group’s policies and processes in terms of personal data protection.
As such, a group personal data protection policy has been put in place in order to ensure consistency in the procedures and processes for the protection of personal data within the Group.
Aixial also mobilizes significant resources to train all its employees on issues relating to data security and confidentiality as well as the protection of personal data, whether through e-learning, face-to-face training or through the distribution of guides and guidelines.
Transparency of relationships between health professionals and pharmaceutical companies
The law of 29 December 2011 relating to the reinforcement of the sanitary safety of medicines and health products, known as the “Bertrand Law”, completed by the application decree of 21 May 2013, imposes obligations concerning the publication of links of interest between the health industries and other actors in the field of health, health professionals, students, learned societies, associations, media, etc.
The relationship between companies and these actors can take the form of agreements (called “conventions”), benefits (“in nature” or “in cash”) or remuneration. :
Conventions between companies and health actors are agreements involving commitments on both sides. For instance, it concerns participation in a congress as a speaker (obligation fulfilled by the professional), with transport and accommodation paid for (obligation fulfilled by the company). The agreements may also cover research or clinical trials on a health product, participation in a scientific congress, training activities, etc.
The benefits included in the Transparency – Health database cover everything that is allocated or paid without consideration by a company to a health actor (donation of equipment, meals, transport, accommodation, etc.) above a financial threshold set by law from 10 euros including tax.
Remuneration is the amount paid by companies to a health care provider (health professional or legal entity) in return for work or services rendered.
In order to comply with the regulations in force, the data relating to services from January 2012 onwards are published online and can be consulted on the single public website “Transparence Santé” (www.transparence.sante.gouv.fr).
We remind you that, like any person whose personal data is published within the transparency scheme, you have the right to access and rectify your data by contacting us at:
or by post:
221 bis boulevard Jean-Jaurès 92100 Boulogne-Billancourt
It is not possible for you to exercise a right to object to the collection, processing or publication of this data, since the transparency scheme is required by law.