Ethics and Compliance Charter

Introduction

The Ethics and Compliance Charter of NeuriaLabs constitutes the reference framework that governs our commitments, values, and obligations concerning governance, integrity, and responsibility. This charter defines the fundamental principles that must guide all of the organization's activities, ensuring compliance with legal standards, regulatory requirements, and the most rigorous international standards.

In a global context marked by increased vigilance on issues of transparency, business ethics, and compliance with national and international regulations, NeuriaLabs affirms its unwavering commitment to the fight against corruption, data protection, conflict of interest prevention, and respect for fundamental rights.

This charter applies to all stakeholders of NeuriaLabs, without exception:

  • Leaders and members of the executive committee

  • Employees, freelancers, and consultants

  • Strategic partners, suppliers, and subcontractors

  • Clients and collaborators in the context of their relationships with NeuriaLabs

Compliance with this charter is an essential condition for any collaboration with NeuriaLabs. Any violation of the established principles may result in disciplinary and contractual sanctions, potentially leading to the termination of business relationships and referral to the competent authorities.

Fundamental Principles

Integrity and Transparency

Integrity is a fundamental principle of all actions and decisions taken by NeuriaLabs. We commit to:

  • Maintaining honest and transparent communication with all stakeholders.

  • Ensuring traceability and absolute clarity in our business and contractual activities.

  • Avoiding any form of misinformation, manipulation, or falsification of data and facts.

  • Requiring systematic disclosure of conflicts of interest in all business relationships.

All collaborators and partners of NeuriaLabs must refuse any action or decision that contradicts the principles of integrity and loyalty.

Respect for Laws and Regulations

NeuriaLabs is committed to respecting all applicable laws and regulations in the jurisdictions where it operates, particularly concerning:

  • Data protection (GDPR, CCPA, Data Protection Act).

  • The fight against corruption and money laundering (FCPA, UK Bribery Act, Sapin II Law).

  • Compliance with competition and public procurement rules.

  • Respect for local and international legislations regarding trade and intellectual property.

Any breach of these obligations will expose offenders to disciplinary and legal proceedings.

Confidentiality and Data Protection

NeuriaLabs enforces a strict policy on confidentiality and data security based on the following principles:

  • Rigorous protection of confidential, strategic, and personal information.

  • Implementation of advanced cybersecurity protocols to prevent any data breach.

  • Ongoing training for employees on the risks related to information leaks and cyberattacks.

  • Restricting access to sensitive data based on the need-to-know principle.

Any violation of confidentiality rules will be considered a serious offense and may result in immediate sanctions.

Combating Corruption and Unfair Practices

NeuriaLabs adopts a zero-tolerance policy towards corruption, bribery, and anti-competitive practices. It is strictly forbidden to:

  • Offer or accept any undue advantage, illicit payment, or disproportionate gift aimed at influencing a decision.

  • Use intermediaries or facilitators in order to circumvent regulatory obligations.

  • Engage in illegal agreements, abuse of dominant position, or fraudulent practices.

Any suspicion or attempt of corruption must be reported immediately to the Compliance and Ethics Committee via a confidential reporting channel.

Respect for Human Rights and Social Norms

NeuriaLabs ensures the application of international standards relating to human rights and fair working conditions:

  • Strict refusal of any involvement in forced labor, human trafficking, or child exploitation.

  • Promotion of equal opportunities and diversity, without discrimination based on origin, gender, religion, or sexual orientation.

  • Respect for labor rights and safety standards ensuring dignified and secure working conditions.

Any violation of these principles will result in the immediate exclusion of the relevant suppliers, partners, or collaborators.

Environmental Responsibility and Sustainable Development

NeuriaLabs recognizes the importance of reducing its environmental impact and integrating sustainable practices into its operations. In this regard, we commit to:

  • Reducing our carbon footprint by limiting travel and prioritizing digital solutions.

  • Working with suppliers who respect environmental and ethical standards.

  • Promoting eco-responsible technologies and practices among our collaborators and partners.

Control and Compliance Mechanisms

Compliance and Control Committee

NeuriaLabs has established a Compliance and Ethics Committee responsible for:

  • Overseeing the strict application of this charter and ensuring its compliance.

  • Identifying and assessing risks of non-compliance and ethical breaches.

  • Implementing internal controls and regular audits to prevent violations.

Reporting Violations Mechanism

Any employee, client, or partner who becomes aware of a violation of the principles of this charter is required to report it immediately.

  • A secure reporting channel is available: contact@neurialabs.com.

  • All reports will be subject to a thorough and impartial investigation.

  • Whistleblowers are granted absolute protection against any form of retaliation.

Training and Awareness

Each employee of NeuriaLabs receives mandatory training on ethics and compliance from the outset of their employment.

  • Regular workshops are organized to ensure an update of knowledge.

  • A detailed guide on good ethical practices is provided to each employee.

Sanctions and Disciplinary Measures

General Principles of Sanctions

Compliance with the ethical and compliance principles set out in this charter is a fundamental obligation for all stakeholders of NeuriaLabs. Any proven violation or attempted violation will result in sanctions proportionate to the severity of the facts, which may include legal action.

NeuriaLabs applies a strict and graduated approach to disciplinary sanctions, considering:

  • The nature and severity of the offense (fraud, corruption, breach of confidentiality rules, discrimination, harassment, etc.).

  • The intentionality of the act (unintentional breach, gross negligence, premeditated action).

  • The impact on the organization, partners, and stakeholders.

  • The sanctions already applied in similar cases to ensure consistency and fairness in decisions.

No tolerance will be granted for serious violations of the charter, especially those that could harm the integrity of NeuriaLabs, its reputation, or its legal and regulatory commitments.

Types of Sanctions Applicable to Employees

Disciplinary sanctions applicable to employees and consultants of NeuriaLabs are graduated and include:

  • Formal warning: Written notification reminding of the seriousness of the breach and requiring the employee to immediately comply with ethical requirements.

  • Official reprimand: Note placed in the employee’s file, with the obligation to undergo ethics and compliance training.

  • Temporary suspension: Disciplinary leave with loss of pay depending on the gravity of the observed offenses.

  • Dismissal for serious misconduct: Immediate termination of the employment contract without indemnities in cases of intentional violation, fraud, corruption, or blatant disregard for the rules of NeuriaLabs.

  • Legal action: In cases of financial fraud, corruption, embezzlement, or serious violations of applicable regulations, NeuriaLabs may refer the matter to the competent authorities and initiate proceedings in court.

Sanctions Applicable to Partners, Suppliers, and Clients

Any non-compliance with the ethical commitments of NeuriaLabs by a partner, supplier, or client may result in:

  • An official reminder of contractual obligations, accompanied by a deadline to remedy the identified breaches.

  • The temporary suspension of collaboration until adequate corrective measures are implemented.

  • The immediate termination of the contract in cases of serious breaches or repeat offenses.

  • Legal proceedings and referral to the competent authorities, particularly in cases of involvement in fraudulent practices, acts of corruption, or violations of human and social rights.

Investigation and Sanction Procedure

Any presumed violation of the Ethics and Compliance Charter will be subject to a thorough investigation conducted under the authority of the Compliance and Ethics Committee.

The steps of the disciplinary procedure are as follows:

  1. Reporting the violation via the confidential compliance channel.

  2. Preliminary assessment of the facts, collecting evidence and testimonies.

  3. Thorough internal investigation, conducted by the Compliance Committee impartially.

  4. Notification of the person concerned, with the opportunity to present observations and defense.

  5. Decision-making on the applicable sanction, with reasoned justification.

  6. Implementation of the sanction and monitoring of compliance with the required corrective measures.

Any employee, partner, or supplier subject to a disciplinary sanction may appeal to the Ethics Committee or the competent judicial authorities if the sanction is deemed disproportionate or unfounded.

Commitment to Compliance

Obligation to Adhere to the Ethics Charter

Adhering to the principles set out in this Charter is a non-negotiable condition for any collaboration with NeuriaLabs.

  • All employees, consultants, and leaders must sign a written commitment attesting to their understanding and acceptance of NeuriaLabs' compliance and ethics principles.

  • Any partner, supplier, or subcontractor must adhere to the ethical and regulatory standards of NeuriaLabs before any contractual agreement.

  • Clients must be informed of NeuriaLabs’ commitments regarding compliance and transparency and must comply with them in their interactions with the organization.

Commitment to respecting this charter is regularly re-evaluated and renewed as part of compliance audits.

Deployment of Training and Awareness Programs

NeuriaLabs implements a continuous training program to ensure that all collaborators, partners, and subcontractors understand the ethical and regulatory requirements.

  • Mandatory training on business ethics, anti-corruption, and data protection.

  • Practical workshops and simulations to raise awareness about non-compliance risks.

  • Provision of a detailed Code of Conduct, accessible to all, explaining expected behaviors in common professional situations.

  • Annual update sessions to ensure alignment of NeuriaLabs’ practices with legislative changes and best international practices.

Any employee or partner refusing to attend these trainings or failing to comply with the obligations of compliance will be subject to immediate disciplinary or contractual sanctions.

Compliance Audits and Controls

NeuriaLabs regularly conducts internal and external audits to:

  • Verify the effective compliance with the Ethics Charter within the organization.

  • Assess the risk management and compliance processes implemented.

  • Identify areas for improvement to strengthen the culture of integrity and responsibility.

These audits allow for ongoing adaptation of control and sanction measures to regulatory changes and emerging risks.

Accountability of Leaders and Exemplarity

Leaders and executives of NeuriaLabs have a particular responsibility in applying and promoting ethical principles. They must:

  • Set an example by respecting and applying the charter in all their decisions.

  • Encourage a culture of transparency and accountability within teams.

  • Immediately sanction any behavior contrary to the values of NeuriaLabs.

Ethics and compliance are not abstract principles, but concrete and imperative requirements integrated into all of the organization’s activities.

This Ethics and Compliance Charter constitutes an irreversible commitment of NeuriaLabs to uphold the most demanding international standards and to ensure exemplary governance.

Any breach of these principles will be treated with the utmost rigor in order to preserve the integrity, reputation, and sustainability of NeuriaLabs.