The Group Legal and Regulatory Affairs Department regularly leads campaigns to educate and raise awareness among executive managers from the Group’s subsidiaries about competition law.
The measures taken by Edenred to identify and manage competition risks are outlined in section 18.104.22.168, page 72.
Through its tax policy, the Group pledges to comply with transparency requirements and with its obligations to report and pay taxes.
The Group’s tax policy aims to protect the Group’s interests in accordance with applicable local and international rules and standards.
Generally speaking, the Group does not engage in speculative activities that would incur a tax risk or structure its operations in such a way that does not reflect the economic reality of its business and its operations.
22.214.171.124.2 Suppliers and subcontractors
Reliance on subcontracting
The majority of outside contractors used by Edenred are hired to provide IT services. The Group requires its subsidiaries to ensure that subcontractors are employed in strict observance of the applicable regulations and labor laws concerning, for example, work shifts, the basis for calculating hours worked, and encourages compliance through awareness measures with CSR correspondents. By virtue of its Charter of Ethics, Edenred is committed not to using forced or concealed labor, and to refusing to work or immediately stopping working with suppliers and service providers that use employees working under duress or threat, or that are not in compliance with the applicable regulations.
Description of the Supply Chain
Edenred’s primary partners are card providers, IT suppliers (providing software and hardware), and for some subsidiaries paper-vouchers providers. The supply chain for the Group’s smart cards is divided into two main stages, the Manufacturing phase and the Personalization phase which are located mainly in Latin America and Europe, closed to Edenred’s geographies:
- the Manufacturing phase includes the manufacture of the body of the card, along with specific background requested by each subsidiary, and the chip inserted into the body of the card. Manufacturers generally only have a few factories of this type around the world, 6 of which serve Edenred’s subsidiaries for each of its largest suppliers. In all, 30% of cards issued are from local manufacture sites;
- At this stage, the card itself is not usable because the chip does not yet have any application. The cards are then sent to personalization centers where applications will be installed on the chip and a unique card number will be assigned as well as a validity date, a scheme, a cardholder. This stage is generally carried out close (or in a nearby country) to the subsidiaries. More than 90% of cards are personalized locally, in order to meet logistical constraints but also to allow a certain flexibility and greater interaction between Edenred and its partners. At the end of the personalization process, the card is sent either to the subsidiary when further processing is required, or to the client company's address or directly to the user.
Inclusion of social and environmental issues in purchasing policy
Since 2016, Edenred has distributed a new version of its Charter of Ethics that applies to every business partner, subcontractor and supplier, enjoining them to abide by ethical, environmental and employee relations guidelines that comply with the charter’s values. The charter plays a critical role in laying the foundations for dialogue with suppliers.
Purchasing policy is decentralized to the subsidiary level. However, a Group Purchasing Department was created in October 2017. The Group has a few suppliers identified as key partners with whom it has international framework agreements. Examples include contracts with the printers or card suppliers selected in local and international tenders. These agreements include clauses on compliance with labor laws in the country of production. The Group has a preference for environmentally friendly materials such as FSC-certified and/or recycled paper and vegetable-based inks without jeopardizing voucher security. In addition, environmental criteria were included in the call for tenders for material for smart cards in 2020.
A clause on the Charter of Ethics was prepared in 2018 by the Group’s Legal Department. It states, “The supplier acknowledges that it is aware of and understands the Edenred Charter of Ethics and the professional integrity and compliance rules it covers, and pledges to apply and uphold these principles. The supplier also ensures that its subcontractors, employees, agents and representatives fully comply with the Edenred Charter of Ethics in fulfilling their respective obligations under this agreement”.
This clause is stipulated in documents for tender bids, to which the Charter of Ethics was attached. Since 2020, the Group has also included it in contracts signed with suppliers.
126.96.36.199.3 Integrating ethics issues at subsidiaries
In 2020, subsidiaries in Taiwan, Mexico and several other countries organized training and/or workshops on ethical issues. In Brazil, Edenred organized a compliance week for the third consecutive year. Experts were invited to talk about the fight against corruption, personal data protection and the General Personal Data Protection law, the importance of the Code of ethics and risk management, anti-competition practices and risks related to IT and cybersecurity. Throughout the year, mandatory training was provided to employees via e-learning modules. A module is also available on the Edenred Brazil Charter of Ethics.