ORANGE COMPLIANCE ETHICS:
Orange Liberia (OLIB) and Orange S. A. have implemented a compliance policy based on respect for a set of values and principles contained in:
Ø The Orange Group’s Code of Ethics and Anti-Corruption Policy, available at www.orange.com and .
Ø The national, European and international legal and regulatory provisions applicable Orange Liberia in the conduct of its activities including, without limitation, the Executive Order n°38 of January 6, 2012 establishing an administrative code of conduct for member of the executive branch of government of the President of Liberia and the Act of legislature prescribing a national code of conduct for all public officials and employees of the government of the republic of Liberia (esp. part IX – Gifts, Bribes and Conflicts of interest) dated June 20, 2014 ; the Universal Declaration of Human Rights, International Labour Organization standards, OECD guidelines (particularly regarding efforts to fight corruption), the US Foreign Corrupt Practices Act, the UK Bribery Act, Law n. 2016-1691 of 9 December 2016 relating to the transparency, the fight against corruption and the modernization of the economic life (also called “Loi Sapin II Act”), and the French criminal code pertaining to financial and economic misdemeanors and crimes as well as international trade sanctions (embargoes) including any sanctions that may be in force as a result of a resolution passed pursuant to Chapter VII of the UN Charter by the UN Security Council, any sanction that may have been imposed by the European Union (including DGT and OFSI), the United States Government (including OFAC), the French Government or applicable law, and watch list. These lists are, notably, the "Consolidated Travel Ban and Assets Freeze List" published by the United Nations Sanctions Committee, the "Specially Designated Nationals and Blocked Persons list" maintained by the OFAC, and the consolidated list of people, groups and entities subject to EU financial sanctions.
These values and principles are referred to hereafter as the "Rules", including any subsequent modifications.
The Parties undertake to comply with the Rules. In addition, they undertake on their behalf, and obtain from their executives, employees, affiliates, subcontractors and their respective representatives, that they undertake:
Ø to implement the direct and indirect means appropriate for the effective implementation and maintenance of a compliance program to ensure compliance with the Rules;
Ø that (i) each of the persons referred to above and who will intervene, directly or indirectly, in any way whatsoever, in the performance of the Contract and (ii) all direct or indirect means, technical, financial and implemented in the performance of the Contract, comply with the Rules.
In order to ensure compliance with the Rules throughout the duration of the Contract, each Party undertakes, on the one hand, to fulfil the requests of the other Party to obtain all the elements justifying its compliance with the Rules, and on the other hand, to inform the other Party without delay of any breach of the Rules committed by it or any of the persons referred to above, as well as the corrective measures put in place to comply with the Rules.
The Parties declare that they are not registered on sanctions lists, in particular the "Consolidated Travel Ban and Assets Freeze List" published by the United Nations Sanctions Committee, the "Specially Designated Nationals and Blocked Persons List" retained by the OFAC, the “Asset Freeze Target List” maintained by the UK Ministry of Finance and the consolidated list of persons and entities subject to European financial sanctions. In the event that this statement is no longer accurate for a Party, the Party undertakes to inform the other Party in writing.
In the event of non-compliance by one of the Parties with the Rules and commitments referred to above, the other Party may terminate the Contract with immediate effect, thirty (30) days from a formal notice to comply with them remained without effect, without prejudice to the damages that could be attributed to the offending Party.
CORPORATE SOCIAL RESPONSIBILITY (CSR)
Orange may introduce some modifications to the Contractor Code of Conduct to always comply with any law, regulation or judicial decision. The last updated version of the Code of Conduct is available on:
In particular, in accordance with the French Law No. 2017-399 of 27 March, 2017 on the “duty of care of parent companies and ordering companies”, the Parties undertake to prevent harm to human rights and fundamental freedoms, health and safety of persons, and to the environment, in the course of their business activities.
Each Party undertakes to refrain and require its subcontractors and all people under its control, to refrain from using child or forced labor and fight against all discriminations.
The Parties will meet regularly to review the indicators related to the compliance with the CSR Rules and their assessment or to define an action plan and follow-up measures, where needed.
In case of sub-contracting, the Contractor shall take all necessary steps with its subcontractors and all people under its control to ensure that they comply with the CSR Rules and to ensure that Orange can access to their premises. The means of intervention applicable to the above operations shall be defined jointly by Orange and the Supplier.
Please consult Orange anti-corruption policy here