CSR -  Economic

HGH is committed to the highest standards of business ethics and professional conduct and expects all employees and other persons acting on its behalf to uphold this commitment. In accordance with this commitment, the Group has adopted an Economic & Trade Sanctions Policy, which is applicable to all directors, officers, employees, agents, representatives, other associated persons of HGH, and Third-Party Intermediaries.

In brief, HGH Personnel shall comply with all applicable trade sanctions laws, including the European Union (“E.U.”) sanctions regulations, as implemented in France, and other member states in which the Group operates, and certain sanctions regulations promulgated by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) applicable to the Group (collectively, “Trade Sanctions Laws”). Certain OFAC sanctions (e.g., OFAC sanctions targeting Cuba and Iran) apply to the Group’s business dealings in certain circumstances, even when such dealings do not involve the United States or U.S. individuals or entities. Furthermore, certain U.S. sanctions would apply to the Group. In particular, U.S. sanctions can target non-U.S. entities for engaging in certain dealings with Iran, North Korea, and Russia.

HGH periodically enters into contracts with agents, representatives, consultants, business partners, contractors, suppliers, and other partners. HGH ensures that its Third Party Intermediaries are aware of and comply with HGH policy and with applicable laws, including anti-bribery laws such as Sapin II, the U.K. Bribery Act (“UKBA”), and the U.S. Foreign Corrupt Practices Act (“FCPA”).

HGH, is committed to conducting all aspects of its business in keeping with the highest legal and ethical standards and expects all employees and other persons acting on its behalf to uphold this commitment. In accordance with this commitment, HGH has adopted an Anti-Corruption Compliance Policy, which is applicable to all directors, officers, employees, agents, representatives and other associated persons of HGH (collectively “Group Personnel”).

In brief, HGH will not tolerate bribery, kickbacks, or corruption of any kind, directly or through third parties, whether or not explicitly prohibited by this Policy or by law. Group Personnel are not permitted to give or offer anything of value (including gifts, hospitality, or meals) to anyone for the purpose of improperly obtaining or retaining a business advantage. Similarly, Group Personnel may not solicit or accept such improper payments or benefits.

This Policy and the internal controls have been designed to prevent bribery from occurring, avoid the appearance of wrongdoing and enable HGH to respond promptly and effectively to any inquiries about its conduct and the conduct of those acting on HGH’s behalf.

HGH pays particular attention to the selection of partners and suppliers. Each collaboration is subject to in-depth review to verify that partners share socially responsible and environmentally friendly practices. This vigilance allows HGH to build lasting relationships based on trust, but also to control its value chain. A committed supplier contributes directly to the credibility and overall performance of the company.