Ethics and compliance

Ethics and Compliance

For Dassault Systèmes, pursuing ethical and sustainable growth is a fundamental value and one of the pillars of our corporate social responsibility policy.

Promoting Strong Business Ethics

Compliance with the rules of ethics and international standards is an integral part of the purpose of Dassault Systèmes, which is “to imagine sustainable innovations capable of harmonizing products, nature and life”.

Since its creation, the Company has developed its culture and built its reputation on different fundamental principles, particularly the creation of long-term relationships with its stakeholder – employees, customers, partners, shareholders, regulatory bodies and government agencies – as well as high-quality products with high added-value. Confidence and integrity, supported by rigorous ethics and regulatory compliance, are at the heart of Dassault Systèmes’ commitments for sustainable and ethical growth.

The Company’s commitment concerning business ethics and corporate social responsibility is asserted through:

  • rules applicable to all Dassault Systèmes employees;
  • an ethics and compliance governance system;
  • employees awareness-raising and training.

Dassault Systèmes’ business ethics rules are formalized in corporate governance policies and procedures, in particular through its Code of Business Conduct, introduced in 2004, and its Corporate Social Responsibility Principles.

Code of Business Conduct

This Code describes the manner in which the Company expects its business to be conducted.

It addresses issues including:

  1. compliance with regulations applicable to Dassault Systèmes’ businesses;
  2. individual interactions within the Company and with its ecosystem and;
  3. protecting the Company’s assets (in particular, Dassault Systèmes’ intellectual property and that of its customers and partners).

The Code also refers to specific policies on the fight against corruption and influence-peddling, personal data protection, conflicts of interest and insider trading.

In 2020, the new version of the Code of Business Conduct was rolled out within the Company following the review and modernization process carried out in 2019 to take account of the new rules regarding the fight against corruption (French Sapin  2 Law) and personal data protection (GDPR). This Code also includes references to the Company’s policies, in particular concerning competition law and export controls.

English version

Corporate Social Responsibility Principles

The Corporate Social Responsibility Principles are based upon international standards – also referred to in the new version of the Code of Business Conduct – relative to human and social rights and the protection of the environment, as laid down in the United Nations International Bill of Human Rights, the International Convention on the Rights of the Child, the OECD Guidelines for Multinational Enterprises and the Fundamental Conventions of the International Labor Organization.

These Principles provide for the following:

  • prohibiting the employment of school-aged children (and in any event those under 15 years of age), banning forced labor and other forms of modern slavery as well as all forms of discrimination (in recruitment as well as career development and employment termination);
  • providing satisfactory working conditions guarantees to preserve employee health and safety;
  • complying with minimum legal and regulatory requirements concerning pay, freedom of association and the protection of labor union rights and the right to collective bargaining;
  • ensuring zero tolerance for corruption and influence peddling;
  • complying with regulations relating to the protection of personal data and the protection of the environment.

The Code of Business Conduct and the Corporate Social Responsibility Principles serve as a reference for Dassault Systèmes employees, to guide their behavior and interactions in their daily business activities. They also strive to inspire the Company’s partners and suppliers.

English version

Dassault Systèmes’ ethics and compliance governance system relies on an Ethics Committee and a Business Ethics and Compliance department.

They deal with all investigations relating to ethics and compliance, including in connection with the protection of intellectual property, confidentiality, the fight against corruption and fraud, compliance with rules regarding competition and the control of exports, the protection of personal data, IT security, ethics in work relations, in particular the fight against discrimination and harassment, the use of social media and networks and the monitoring of potential conflicts of interest.

The Ethics Committee

The Company’s Ethics Committee meets once a month.

Its members are: the Company’s General Secretary, the Executive Vice President, Chief People & Information Officer, the General Counsel, the Internal Audit Director, the CEO’s Chief of Staff and the Director of the Business Ethics and Compliance department.The Committee ensures that employees comply with the rules laid down in the Code of Business Conduct. It is thus tasked with investigating any alleged breaches brought to its attention, in particular through the Company’s whistleblowing procedure.

The Business Ethics and Compliance department

This department reports to the Company’s General Counsel.

It is responsible for ensuring the implementation and respect of the Code of Business Conduct of Dassault Systèmes, as well as the specific Dassault Systèmes policies, recommendations and procedures regarding ethics and compliance.

Its role is to define and implement Dassault Systèmes’ ethics and compliance program in coordination with the Ethics Committee. It is tasked with the following, in coordination with other Company’s departments:

  • promoting a culture of integrity within the Group, in particular by ensuring that employees are adequately trained and informed;
  • assessing Dassault Systèmes’ ethics and compliance risks and preventing them;
  • conducting investigations in order to deal with the breaches that arise, or help the local teams to do so;
  • assessing the ethics and compliance procedures and putting forward proposals to the Ethics Committee concerning any upgrade to Dassault Systèmes’ ethics and compliance program.

The Business Ethics and Compliance department assesses and investigates all the alerts it receives, in particular through the whistleblowing procedure. This gives rise to the opening of formal investigations by the Business Ethics and Compliance department, which are then submitted to the Ethics Committee.

Employees awareness raising and training

Employee awareness raising and training, especially concerning fight against corruption, are an essential pillar of the Company’s commitment in terms of ethics and compliance.

A mandatory online training course on ethics and compliance is thus an integral part of the onboarding program for all new employees. This course, available in 11 languages, comprises 13 modules, each of which is broken down into a theory section followed by practical applications in a question/ answer format. The topics covered include:

  • the fight against corruption;
  • protection of intellectual property;
  • personal data protection;
  • respect for confidentiality;
  • ethics in the workplace with a focus on potential harassment and discrimination situations;
  • compliance with competition law;
  • strict monitoring of exports;
  • IT security;
  • prevention of conflicts of interest, etc.

Focus on Ethics & Compliance topics

Human Rights

Dassault Systèmes’ commitment to sustainable and ethical growth rests on the fundamental value of respect for Human Rights.

Dassault Systèmes' commitments in this regard are formalized in the Corporate Social Responsibility Principles which were strengthened in the new version of the Code of Business Conduct. This Code reasserts that Dassault Systèmes is committed to providing a work environment which is free from any form of discrimination, harassment or intimidation and to ensuring that its employees, clients and partners are treated in a respectful way at all times.

Moreover Dassault Systèmes publishes each year  a statement of the measures it has taken to combat modern slavery and human trafficking, as required by the UK’s Modern Slavery Act.

Dassault Systèmes Modern Slavery Transparency Statements

Dassault Systèmes UK LTD Modern Slavery Transparency Statements

UK Tax Strategy (PDF) - English version

Dassault Systèmes also promotes corporate social responsibility within its ecosystem, as its suppliers and partners are required to abide by these CSR Principles. Most Dassault Systèmes companies’ standard contracts and general purchasing terms and conditions thus provide for the right to immediately terminate the contract in the event of a supplier’s breach of any of these Principles. Furthermore, the Company is committed to “Responsible Purchasing” characterized in particular by the implementation of a 3DS Sustainable Charter with Suppliers which includes these Principles.

Learn More about Responsible Purchasing

In order to manage and mitigate risks of non-compliance regarding Human Rights and fundamental freedoms throughout the Company, Dassault Systèmes relies on its mandatory online training course “Understanding ethics and compliance rules”, as well as its internal whistleblowing procedure, introduced within the scope of the French law relative to the duty of vigilance of parent companies. The procedure enables Dassault Systèmes employees to report any risk of serious violation of Human Rights or fundamental freedoms.

At Dassault Systèmes, the goal is to prevent risks of discrimination or harassment and to ensure working conditions that preserve people’s health and safety. In addition, the banning of discrimination is part of the Company's internal policies and procedures, particularly concerning recruitment processes and managerial training. The new version of the Code of Business Conduct includes clear definitions of harassment and discrimination, along with examples. Furthermore, the Company implements a policy of inclusion for persons with disabilities and pays special attention to gender equality issues.

Vigilance Plan

Dassault Systèmes is committed to conducting its activities in compliance with the laws of the countries in which it operates and in accordance with international standards.

In accordance with the French Law of March 27, 2017 relative to the duty of vigilance of parent companies and contracting undertakings, Dassault Systèmes set up every year a vigilance plan covering the following three areas: human rights and fundamental freedoms, the health and safety of persons and the environment.

The vigilance plan is based on the Dassault Systèmes internal whistleblowing procedure, the mapping of Dassault Systèmes and supplier risks and the related assessments, risk prevention and mitigation measures and a procedure to monitor the measures.

Dassault Systèmes exercises vigilance through recurring actions to deepen the knowledge of its employees such as (i) monitoring and updating online training courses pertaining to ethics, compliance and security, crisis management, environmental responsibility and (ii) posts published on its internal platform. In addition to the Company’s whistleblowing procedure, the software for preventing non-compliance issues and the control points put in place by internal audit in its audit model are also tools for exercising vigilance.

The vigilance plan is implemented by the Company’s various stakeholders, i.e. mainly the Procurement department, Internal Audit department and Human Resources department.

It is monitored by a Steering Committee composed of members of these departments and of the Business Ethics and Compliance department, which are also responsible for the assessment of these procedures.

Each year Dassault Systèmes reports in its Universal Registration Document on (1) the results of the implementation of the vigilance plan pertaining to the last financial year and (2) the main measures of the new vigilance plan to be implemented.

To have a view on the Dassault Systèmes vigilance plans implemented since 2018, please see Dassault Systèmes Annual Reports.

Personal Data Protection

Dassault Systèmes has always recognized data protection as an important topic for its customers and other stakeholders in the digital age and understands the responsibility that comes with the handling and protection of personal data. With the introduction of the European Union (EU) General Data Protection Regulation and other local data protection legislation all over the world, Dassault Systèmes has extended its data protection commitments to maintain its solutions with capabilities that will enable its stakeholders to manage their privacy compliance programs.

The fight against Corruption

In addition to promoting strong business ethics, Dassault Systèmes asserts its commitment to sustainable, ethical growth through its anti-corruption program.

The Code of Business Conduct is the main pillar of the Company’s anti-corruption program. It reiterates the Company’s zero-tolerance policy regarding corruption and influence peddling, including bribes and facilitation payments, irrespective of local customs or commercial pressure, even if this results in the loss of business opportunities.

Accordingly, Dassault Systèmes’ employees must remain vigilant and comply with applicable laws and regulations. They must never, either directly or indirectly, encourage, offer, attempt to offer, authorize, promise or accept any form of advantage (e.g. payments, gifts, bribes or kickbacks) to obtain or retain a contract or to secure any improper advantage, even if they think they are acting in the best interest of Dassault Systèmes.

Examples :

  • gifts and invitations must be of reasonable amounts, as defined in the Anti-Corruption Policy. They must be compatible with local customs and practices and comply with applicable laws. They must be appropriate and must not include items that are likely to be embarrassing for the Company in the event of their public disclosure;
  • Dassault Systèmes makes no political contributions and provides no advantages in the aim of promoting or supporting a particular political party or public official. The Company’s employees are prohibited from using any Company resources to provide any advantage to political parties or public officials.

The provisions of the Code of Business Conduct relating to the fight against corruption are supplemented with the following policies and procedures:

  • a “Dassault Systèmes Anti-corruption Policy” (updated in December 2017 and July 2019);
  • the “Dassault Systèmes Guidelines for dealing with Intermediaries” (June 2017);
  • the “Dassault Systèmes Guidelines on Conflicts of Interests” (April 2017);
  • a “Dassault Systèmes Internal Whistleblowing Procedure” (updated in December 2017).

English version

 

 The Company’s program for corruption prevention is based not only on these policies, guidelines, whistleblowing procedure, communications and employee awareness/training programs, but also on:

  • the Business Ethics and Compliance department;
  • a specific corruption and influence peddling risks mapping, periodically updated, in line with the Company’s activities;
  • an internal control and audit system;
  • stringent operational processes;
  • a community of Compliance Ambassadors composed of legal, financial and operational experts who provide support to the Business Ethics and Compliance department in the Company’s local entities.

The risks of corruption and influence peddling arising from the Company’s business model include the following:

  • its reliance on intermediaries (distributors, agents and system integrators). Such intermediaries are independent third parties and are fully liable for their actions, but the Company could, in certain circumstances (negligence or willful blindness), be held liable in the event such intermediaries were to make illicit payments to generate revenue;
  • trading directly or indirectly with clients deemed in “higher risk countries” and/or qualified as “public officials”.

Dassault Systèmes systematically manages these risks through the policies, procedures and training courses described above. In particular, the Company has strengthened its policy of applying reasonable diligence in the selection of intermediaries, through additional processes including a self-administered questionnaire, reputational checks via compliance databases, the verification of the services performed by the agents and the approval of the Business Ethics and Compliance department. Accounting controls are also carried out by the dedicated teams. Moreover, the Internal Audit department may include specific checks as part of the evaluation of Internal Control or ad hoc audits in order to prevent or detect possible cases of fraud or non-compliance with the Company’s rules and procedures.

The Company’s anti-corruption training course includes raising the awareness of its employees on the risks of dealing with public officials. For example, the Company’s rules concerning gifts and invitations are stricter for public officials.

Moreover, in certain countries with higher risks of corruption, Dassault Systèmes’ distributors are specifically made aware of the Company’s policies and “zero tolerance” rules concerning corruption through on-sites training.

Lastly, Dassault Systèmes measures the performance of its anti-corruption program through key performance indicators that cover its mandatory training courses’ implementation rate.

Competition Law

Competition law is designed to protect and encourage competition between economic players.

The rules of competition law prohibit unfair business practices as well as sharing commercially sensitive or strategic information with competitors. Failure to comply with applicable competition rules could expose Dassault Systèmes, its directors and employees to administrative and criminal sanctions, as well as heavy fines and damage to the reputation of Dassault Systèmes.

Dassault Systèmes’ policy imposes strict compliance with national and supranational rules regarding competition law in all countries in which we operate. Dassault Systèmes is vigorously competing on its markets.

Dassault Systèmes interacts with its suppliers, customers and distributors in compliance with all applicable competition rules.

Dassault Systèmes has put several measures in place in order to raise awareness and ensure compliance with competition law, including e-learnings and various trainings.

Export Compliance

As 3DS is a global company with a geographically diverse employee, customer, and partner base developing products with global reach, it is important for employees and all other stakeholders to understand export control rules. Adherence to export control and sanctions laws is essential to maintaining the privilege of export. Failure to comply may subject 3DS and 3DS personnel and 3DS counterparties to penalties, including fines, imprisonment, and loss of export privileges. The adverse publicity resulting from such penalties, or mere allegations of export control violation, can seriously damage 3DS’ business and reputation.

The purpose of these guidelines is to alert all 3DS Personnel and 3DS Counterparties, in all jurisdictions, to the basic requirements of export control and sanctions laws and to set out guidelines to ensure compliance with those laws.

DOWNLOAD EXPORT COMPLIANCE GUIDELINES

The export control classification numbers (ECCN) set forth herein are subject to change as product functionality changes or applicable regulations change. These ECCN are a Dassault Systèmes self-classification of its software products based on its knowledge of the U.S. Export Administration Regulations. Dassault Systèmes shall not be liable for any damages or costs of any type arising out of or in any way connected with the use of these ECCN.

The information available on this webpage is for informational purposes only and does not constitute advice by Dassault Systèmes as to any particular set of facts, and does not represent any undertaking by Dassault Systèmes to keep the user advised as to all relevant export controls development. Dassault Systèmes strongly encourages users to seek competent legal counsel for advice.

DOWNLOAD ECCN FILE

For additional information on Export Controls you can go to the Wassenaar web page.

IMPORTANT: There is no established schedule for updating this Tool.

3DS software products fall under the "General Software Note" which releases them from list based controls except in the U.S.

Whistleblowing procedure

According to laws in force, any third party may report an ethics breach to Dassault Systèmes.

The identity of a person reporting an ethics breach remains strictly confidential and will not be disclosed to persons other than those specifically in charge of whistleblowing within Dassault Systèmes. Furthermore, Dassault Systèmes prohibits any retaliation against a whistleblower acting in good faith and will protect their identity.

For more information, Dassault Systèmes Internal Whistleblowing Procedure is mentioned into the  Code of Business Conduct.

Disability agreement

Dassault Systèmes commits to long-term and increasingly inclusive disability policies through the approval of its sixth consecutive agreement.

Gender Equality Index

Discover the scores of Dassault Systèmes SE, Dassault Data Services SAS and Dassault Systèmes Provence SAS.

Quality Compliance

Dassault Systèmes is deeply committed to creating quality solutions that allow our customers to meet the critical business requirements of the industries in which they operate.