Alcatel-Lucent

The Code has been translated into 22 languages and is posted on our Intranet site, which also provides links to additional resources. All employees globally are required to review the Code of Conduct and acknowledge their review and agreement to abide by its terms. Understanding of the Code is further reinforced through mandatory Ethics and Integrity Overview training as well as other specialized training in key compliance areas. At the end of 2010, approximately 84% completed Ethics and Integrity Overview training, with activities ongoing to drive completion of this requirement across the total Group population of 79, 796 employees.

In addition to the global training, targeted training on Anti-Corruption was updated and deployed in 2010 to a target audience of over 25,000 employees, including corporate executives and employees who interact or interface directly or indirectly with external parties.

Many of the Group's most important compliance messages to employees - including compliance alerts, messages and articles - are posted and available on the Group's intranet as well as through the Office of Business Integrity & Compliance website. An important component in the communication effort, the Office of Business Integrity & Compliance website consolidates essential compliance and business conduct resources in one central location. The Office of Business Integrity & Compliance monitors the number of visits to the site on a monthly basis through an internal tracking system. In 2010, there were 21,508 visits to the OBIC website!

Fundamental to the success of Alcatel-Lucent's Compliance Management System is the ability of employees to raise ethical questions and concerns without fear of retaliation. Under the Compliance Issues Reporting Methods initiative implemented by the Group, employees are encouraged to raise issues in the first instance with their direct line manager. There are times, however, when these first lines of communication are insufficient, for example where the employee perceives a conflict of interest. In these instances, employees are encouraged to use the Group's global Compliance Hotline (where consistent with local law) to report compliance issues, concerns, violations or suspected violations of law or company policy. The Compliance Hotline has been formally deployed in 114 countries and is available via a multilingual webface in 12 languages and via telephone access in more than 120 languages. The Company has a "no retaliation" policy, which specifically prohibits adverse action against employees who report in good faith suspected violations of law or company policy.

to adopting a zero-tolerance policy toward bribery, as well as developing an effective internal program to prevent it from happening within their own companies. PACI is a multi-stakeholder initiative that works with organizations including: The Basel Institute on Governance; The International Chamber of Commerce (ICC); The Organization for Economic Cooperation and Development (OECD); The United Nations Global Compact (GC); the Multilateral Development Banks and selected international financial institutions.

It was developed with the assistance of international companies which participated in the project. RESIST presents 22 scenarios, the initial seven examples deal with solicitation in the procurement process and were first published in 2009 (Phase 1). The 2010 RESIST edition adds another 15 scenarios which discuss solicitation of bribes in the context of project implementation and in day-to-day project operations (Phase 2). RESIST has been devised as a “user-friendly” tool for the benefit of small, medium and large enterprises to complement their compliance programs. Any company exposed to solicitation risks will find the toolkit a valuable resource tool to provoke open internal discussions on how to face dilemmas.

Out of 27 companies and organizations that were contributors, Alcatel-Lucent is the sole telecom/IT solution provider that not only contributed to Phases 1 and 2 but also whose delegate has been responsible since April 2009 as Chair for the global coordination among the four sponsors of Phase 2 that led, within fifteen months, to the release last June of the expanded edition of RESIST, which is available, free of charge, on each of the Sponsor’s websites. To access the RESIST tool, click here.

• The Alcatel-Lucent Ethics and Compliance Council, chaired by the Chief Compliance Officer, consists of senior level Group officials. It is responsible for overseeing and monitoring program status, both across the Group and within each business unit.
• The Operating Unit Compliance Council, consisting of compliance representatives from each business, or Operating Unit, is responsible for designing and implementing program elements and ensuring achievement of measurable results.
• The Compliance Program Owner community, consisting of the functional owners for the Group's key compliance program areas, is responsible for ensuring that each of these programs is fully integrated into business operations, effectively managed and consistent in quality across the organization.
• The Alcatel-Lucent Board of Directors, through the Audit and Finance Committee, provides program oversight and receives formal reports on overall program status at least twice per year.

Our compliance training system is designed both to educate employees about their personal and professional responsibilities under the Code of Conduct and to instil an ethical culture and a commitment to the highest levels of business conduct. The training program provides general background covering all of the Group's major compliance areas to all employees and specialized training to target audiences based on job function. Training courses are updated annually or as needed. All training and related communications are documented on a Compliance Training Roadmap, which is also updated regularly.

The Group has heightened its focus on middle management in recent years through enhanced communications and targeted training designed to enable supervisors to be more effective compliance role models, and ethical leaders.

Formal training on Anti-Corruption laws, policies and requirements is delivered over the web and through in-person sessions. A mandatory web-based Ethics and Integrity Overview course (deployed globally in July 2010) includes an entire section on Anti-Corruption. At the end of 2010, 84% of employees and completed this Overview and efforts are ongoing to ensure that completion spreads across the total Group population of 79,000+.