As part of Wavestone’s CSR approach, we are committed to a high level of business ethics and to fight against corruption, conflict of interest and any other form of fraud or illicit practice.
To this end, we have implemented a strong framework across our geographies, compliant with local regulations and aligned with the Middlenext Anti-Corruption Code of Conduct.
Wavestone is committed to preventing and fighting any instance of fraud, illegal activity or any behavior not aligned with its principles. More broadly, as part of our efforts to be a responsible employer, Wavestone strives to combat harassment, sexism, racism and every other form of discrimination.
Everyone at Wavestone should be able to pursue their career in a safe and ethical working environment.
Middlenext Anti-corruption Code of Conduct
Wavestone Management Board has adopted the Middlenext Anti-corruption Code of Conduct, published in December 2017. Integrated into Wavestone legacy’s internal policies and procedures, this code is communicated to all.
The Code’s detailed content describes the fundamental rules to be followed in terms of corruption and influence peddling concerning the following areas:
- Specific rules for public officials
- Gifts and invitations
- Donations to charitable and political organizations
- Patronage and sponsorship
- Requests for facilitation payments
- Third party surveillance
- Conflicts of interest
- Accounting records/Internal controls
As this Code of Conduct cannot deal with, or foresee, all cases of corruption or influence peddling that might occur, each employee must therefore exercise their own judgment and common sense.
Commitment to Business Ethics
Wavestone is committed to being a trusted partner by maintaining a transparent, responsible and sincere relationship with its clients, suppliers and partners. Key documents outline the principles to ensure business ethics commitment while providing a clear framework for acceptable and unacceptable behavior and situations. A training in Business Ethics and implementation of this commitment is mandatory for all Wavestone employees.
Wavestone Legacy
Read our Business Ethics Charter
Q_Perior Legacy
Applicable for Wavestone’s operations in the DACH region, the Business Partner Code of Conduct sets out the most important principles for legal and regulatory compliance as well as for morally and ethically impeccable behavior in business dealings. Some other topics like environmental and natural resources protection are also regulated by this document.
Empowerment and protection of whistleblowers
Wavestone is dedicated to giving whistleblowers a voice and ensuring their continuous protection. Our reporting systems aim at preventing, identifying and counteracting potential misconducts. It gives employees, partners and other stakeholders the opportunity to report violations of the Business Ethics Charter, the Code of Conduct, other corporate policies, and other potential misconduct. Our system is designed and executed to maintain a high level of confidentiality, to respect the anonymity of the whistleblowers, and to strictly forbid any form of retaliation.
An external system accessible to all, Whispli (opens in a new tab), allows questions to be asked and an unsuitable situation to be reported in a completely anonymous manner.
The Ethics Officers
Internal Ethics Officers will confirm receipt of the question or alert, review its admissibility and conduct the necessary actions. Ethics Officers, representing all functions, can be called upon by employees in case of doubt on ethical issues to guide them in their decision. Ethics Officers are the designated contact persons on ethical matters for all the firm’s employees and receive special training on the application of the law within this field. They are appointed by Wavestone’s CEO and are known for their skills, integrity, loyalty, and knowledge of the company.
List of Ethics Officers
- Hélène Cambournac, CSR Manager
- Clément Le Roy, Partner
- Anne Régnier, Commercial Director
- Cécile Trinquier, HR Manager
- Hugo Couverture, HR Manager
- Jean-Jacob Dreyfus, Senior Manager, US
- Clare Allan, Associate Partner, UK
Q_Perior
During the ongoing transition period, Wavestone maintains the ethical frameworks in place in Q_Perior historic perimeter.
If you would like to report violations or give information about possible misconduct, you can contact us confidentially and anonymously via our whistleblower portal:
External compliance officer can be reached out by e-mail at wavestone@compliance.12tower.de.
You may send inquiries to the Compliance & Legal department to legal@wavestone.eu.