Going further than compliance with applicable laws and regulations, Imerys carries on its activities ethically and transparently worldwide, while preserving the best interests of its stakeholders.

The Imerys Code of Business Conduct and Ethics, published in 2006, summarizes the principles that the Group expects of all of its employees, and the contractors, suppliers and other partners with whom it has forged close relations. The Code is regularly amended to take into account the geographic expansion of the Group’s activities, developments in its regulatory framework and compliance with the best practices of comparable corporations. It is designed to lead everyone, in his or her daily work, to behave in accordance with local legislation and observe the principles of responsibility, integrity, fairness and openness that are the Group’s values.

Published in 10 languages, the Code of Business Conduct and Ethics is available to anyone from Imerys web and intranet sites. It is presented in internal seminars and regularly covered in the Group’s magazine. Online training, initially created in the United States, is followed by all US employees, all of the Group’s other main managers and, since 2011, all new management recruits. As of the end of 2012, approximately 2,600 employees have been trained in the Group’s Code of Business Conduct and Ethics.

Since the end of 2010, the Group has set up a simplified annual reporting process that enables division management to report any infringements of this Code that may come to their knowledge with respect to the year in question. Finally, the Group’s general compliance program (including, in particular, the prevention of fraud and corruption risks and compliance with competition law) was reviewed in 2011 and tightened in 2012. The program was presented to the Audit Committee as part of its review of the Group’s main risks. For 2013, the program will include an update of anti-fraud, anti-corruption and competition policies, specific training sessions (including one specifically for members of the Group’s Executive Committee) and a self-appraisal campaign on these practices.

Imerys complies with the Universal Declaration of Human Rights and monitors the risk associated with the Group’s swift growth in emerging countries. The Group has placed special importance awareness and prevention of child labor since 2009: Operations managers on all Imerys operations in zones where vigilance is particularly recommended by indices such as FTSE4Good are trained in the relevant regulations. Application of the Child Labor protocol is systematically checked in the internal audits performed in those countries. In 2012, eight Imerys operations were audited (i.e. 32 operations since this work began in 2010). More generally, the Group intends to involve its suppliers in its Sustainable Development process. In 2012, five suppliers operating in zones judged as sensitive in terms of child labor underwent an audit on their compliance with international standards. A self-appraisal process for suppliers’ child labor prevention practices was set up over a scope representing 15% of Imerys’ purchases. Furthermore, a new Group-wide protocol designed to increase the control of supply chain management risks is to be rolled out in 2013. It formally lists ethics and human rights among the key topics.