Code of Ethics

Integrity, standards, responsibility and respect for others are the fundamental values underpinning the "Vallourec way".

The Code of Ethics embodies the values and principles of the Group. It is the binding thread that unites Vallourec Group employees and serves as a benchmark for the everyday activities. It reflects also the manner in which Vallourec seeks to conduct its relationship with all its partners.

The Vallourec way

The “Vallourec way” is based on a set of fundamental values that Vallourec wants all people working within the Group to share:

The Vallourec way

Integrity and transparency

Integrity should be the foundation of all decisions and practices in Vallourec.

In internal relations, transparency, a source of confidence between all Vallourec staff, requires a rapid flow of clear and objective information.

Standards and professionalism

High standards and professionalism are at the root of Vallourec's success in a global market that daily demands better performance. These values are the bases of its ambition of sustainable growth.

Performance and responsiveness

Satisfying internal and external customers is the key to Vallourec's long term success.

It is based on continuing innovation, and the quality and performance of Vallourec's products and services.

It requires responsiveness to address changes in markets. The Group's ability to adapt is one of its strengths, and the basis of its competitiveness and longstanding relations with customers.

Respect for people

Respect for men and women, their dignity, diversity and the variety of their cultures is at the heart of the commitment of Vallourec personnel.

It enriches each and every one. It contributes to the performance of all Vallourec personnel.

Respect begins with security, which is one of Vallourec's fundamental values.

Joint commitment

All Vallourec personnel jointly contribute to the Group's development.

This common aim is based on unity, fairness, listening, a sense of responsibility and teamwork.

Vallourec principles for action

Vallourec acts in accordance with its principles, which are founded on its values, reflecting the way in which Vallourec means to conduct its relations with all partners and other parties.

Those principles form a benchmark for the Group, especially in implementing its sustainable, responsible development plans.

Overall, Vallourec undertakes to run its business in accordance with international, national and local laws and regulations.

Vallourec principles for action

As regards shareholders

Vallourec strives to deserve the confidence of its shareholders by using the Group's resources effectively and responsibly.

Shareholders receive accurate, transparent, verifiable financial information in due time.

Vallourec strives to comply with the best recommendations on corporate governance and running the Group's business.

As regards customers

Vallourec pays attention to meeting the needs of its customers by having time for them, listening to them and showing initiative.

Vallourec is committed to supplying quality products and services to its customers and constantly improving its technologies and methods with a high standard of innovation and safety.

As regards suppliers

Vallourec strives to develop a relationship of confidence and partnership with its suppliers in order to best satisfy its customers' requirements.

Taking the interests of all into consideration and complying with fair contractual terms are the bases of relations between Vallourec and its suppliers.

Vallourec takes into account in the assessments of its suppliers the respect for the fundamental rights of their employees.

As regards employees

Vallourec reaffirms its commitment to the following Principles of Social Responsibility, in particular:*

· application of national laws and applicable international agreements;

· respect for human rights and fundamental universal principles that protect employees' dignity, respect and freedom;

· a secure, healthy working environment  ensuring the physical and mental integrity, health and safety of employees, which remain an absolute priority;

· the right for employees to associate and take part in collective negotiations;

· the use of permanent staff in numbers appropriate to the ongoing level of business, vocational training, compliance with regulations on working hours, staff participation in a process of continuing progress, fair, motivating pay policy.

*"Agreement on the Principles of Responsibility applicable in the Vallourec Group", approved by the European Committee on 9 April 2008.

As regards the environment

Vallourec strives to respect the environment and operates with sustainable development in mind.*

In particular, Vallourec ensures that its growth is based on optimal use of natural resources, especially where non-renewable resources are concerned such as certain raw materials and fossil fuels.

*Vallourec Sustainable Development Charter

As regards countries and communities in which Vallourec does business

Vallourec endeavours to respect local culture and practices in the countries and communities where it does business.

The Vallourec attitude: Rules of conduct

Vallourec’s confidence in the professionalism and integrity of people working within the Group is founded on their compliance with a number of rules. Without being a substitute for their individual sense of responsibility, these rules are a reference for all.

The Vallourec attitude: Rules of conduct

Conflict of interest

Any situation should be avoided where the personal interests of Vallourec personnel or of persons or entities to which they are linked may be in conflict with Vallourec's interests.
To determine whether there is a conflict of interest, Vallourec personnel must ensure that they act in the best interests of Vallourec, excluding any other consideration, especially personal.

The following situations can be considered as likely to result in conflicts of interest:

· any direct or indirect interest taken in a competitor, supplier, service provider or customer (existing or potential), other than the purchase of quoted shares in accordance with the rules on inside information;

· any professional or personal commitment outside Vallourec that might affect commitment to the duty to Vallourec, unless previously authorised by management.

· A potential conflict of interest situation must be brought to the attention of management and will be handled in accordance with the laws and regulations applicable.

Relations with third parties

Every individual at Vallourec exposes the Group's reputation, image and notoriety in his or her relations with third parties. Consequently, he or she must maintain fair, honest relations with them. Accordingly, Vallourec personnel are not allowed to:

· seek, accept or give gifts or invitations if it could influence a decision process or be perceived as doing so, and hence might constitute a corrupt act,

· give undertakings that are excessive in relation to the position they hold,

· behave in a denigrating, offhand or uncivil manner towards third parties with whom they are in contact.

If there are doubts as regards relations with a third party, Vallourec personnel immediately refer the matter to management.

Insider dealing

Vallourec personnel who have inside information that might influence the market price of Vallourec shares must not take initiatives that could result in insider dealing or trading.*
*Code of conduct on transactions of Vallourec shares and insider dealing or trading.


All Vallourec personnel must ensure that information of a confidential nature that they know of as a result of their work is protected.*
*Vallourec confidentiality charter

Conservation of assets

All Vallourec personnel ensure that the Company's assets are conserved, in accordance with Vallourec's interests.
Any form of waste or misuse must be avoided.

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Sustainability Report