Supplier Code of Conduct

1. Scope

This Code applies to any individual or legal entity supplying goods or services to AC PRIVATE - A List concierge, or to its clients on its behalf (the "Supplier"), and to the Supplier's directors, employees, agents and subcontractors involved in the relationship.

The Supplier undertakes to pass these requirements on to its own subcontractors and to ensure that they comply with them.

2. Compliance with laws and regulations

The Supplier complies with all laws and regulations applicable in the countries where it operates, including labour, tax, safety, consumer protection, data protection and international trade law. Where this Code is stricter than local law, the Supplier applies the more protective standard, within the limits of the law.

The Supplier holds and keeps up to date all permits, licences, insurance policies and registrations required for its business (for example: chauffeur licence, transport licence, travel operator registration, professional liability insurance) and provides them upon request.

3. Human rights and working conditions

• Absolute prohibition of forced or compulsory labour, debt bondage, human trafficking and any form of modern slavery.
• Prohibition of child labour: no one is employed below the legal minimum age; young workers are not assigned to hazardous or night work.
• Pay at least equal to the legal or collectively agreed minimum wage, paid regularly with clear payslips.
• Compliance with legal maximum working hours and rest periods, in particular for chauffeurs and security staff.
• No discrimination based on origin, gender, age, religion, disability, sexual orientation, opinion or any other protected characteristic.
• Prohibition of any moral or sexual harassment and degrading treatment.
• Respect for freedom of association and the right to collective bargaining.
• Prohibition of undeclared and illegal work; verification of employees' right to work.

4. Health and safety

The Supplier provides a safe and healthy working environment for its teams and ensures the safety of the clients entrusted to it: maintained and insured vehicles, trained and qualified staff, compliance with food hygiene, fire safety and public venue standards, and emergency plans suited to events. Any incident affecting a client is reported to AC PRIVATE - A List concierge without delay.

5. Anti-bribery and influence peddling

The Supplier prohibits any form of bribery, active or passive, public or private, and any influence peddling, in accordance in particular with French Law No. 2016-1691 of 9 December 2016 ("Sapin II") and equivalent applicable legislation.

• No payment, kickback or undue advantage is offered or accepted to obtain or retain business.
• Gifts and hospitality offered to AC PRIVATE - A List concierge staff must remain modest, occasional and transparent; cash and cash equivalents are prohibited.
• Facilitation payments are prohibited.
• Books and accounting records accurately reflect all transactions.

6. Money laundering, terrorist financing and sanctions

The Supplier complies with anti-money laundering and counter-terrorist financing (AML/CFT) regulations and with the economic sanctions and embargo regimes of the European Union, France and, where applicable, the United Nations. It does not deal with persons or entities subject to asset freezes. It agrees to provide information reasonably required for know-your-partner checks and reports any unusual transaction.

7. Fair competition

The Supplier complies with competition law: no price fixing, market sharing or exchange of commercially sensitive information with competitors. It refrains from misleading commercial practices and disparagement.

8. Conflicts of interest

The Supplier promptly discloses any situation that may create a conflict of interest, in particular a personal, family or financial link with an AC PRIVATE - A List concierge employee or a client. It does not directly solicit clients introduced by AC PRIVATE - A List concierge in order to bypass the relationship, unless agreed in writing beforehand.

9. Confidentiality and discretion

Discretion is at the heart of our business. The Supplier treats as strictly confidential all information relating to clients, their relatives, travel, habits, assets and requests, as well as the business information of AC PRIVATE - A List concierge.

• No photographs, videos, social media posts or press communication concerning a client, a residence or an event without prior written consent.
• No use of a client's name or image for promotional purposes.
• Signature of a non-disclosure agreement (NDA) where the assignment requires it; confidentiality obligations survive the end of the relationship.
• Access to information limited to those who need it to perform the service.

10. Personal data protection

The Supplier complies with Regulation (EU) 2016/679 (GDPR), the French Data Protection Act and any applicable regulation. When processing personal data on behalf of AC PRIVATE - A List concierge, it acts as a processor within the meaning of Article 28 GDPR: it processes data only on documented instructions, implements appropriate security measures, does not transfer data outside the European Economic Area without adequate safeguards, notifies any data breach without undue delay and returns or deletes the data at the end of the assignment.

11. Information security

The Supplier protects the systems and tools used in the relationship (strong passwords, multi-factor authentication where available, regular updates, protected devices). It remains vigilant against phishing and payment fraud, and verifies through a second channel any request to change bank details.

12. Environment

The Supplier complies with applicable environmental regulations and strives to reduce the impact of its activities: energy efficiency, reduction of waste and single-use plastics, lower-emission vehicles where possible, local and responsible sourcing, respect for animal welfare and protected species (no products derived from protected species without the required permits).

13. Service quality and brand image

The Supplier undertakes to deliver the service as agreed, with punctuality, courtesy and professionalism. It uses the AC PRIVATE - A List concierge name, logo or brand only with written consent, and refrains from any conduct likely to harm the reputation of the house or its clients.

14. Subcontracting

The Supplier entrusts all or part of a service to a third party only with the prior consent of AC PRIVATE - A List concierge. It remains responsible for its subcontractors' compliance with this Code.

15. Monitoring and verification

As part of its due diligence, AC PRIVATE - A List concierge may ask the Supplier for information, certificates or supporting documents (for example: social security compliance certificate, company registration extract, insurance certificates) and, with reasonable notice, carry out or commission compliance checks. The Supplier cooperates in good faith and promptly implements agreed corrective measures.

16. Reporting and non-retaliation

Anyone (Supplier, Supplier employee, client or third party) may report in good faith a suspected breach of this Code or of the law by writing to [email protected] with "Confidential report" in the subject line. Reports are handled confidentially; the reporter's identity is disclosed only with their consent or where required by law.

No retaliation is tolerated against anyone who has made a report in good faith, in accordance with whistleblower protection rules. Reports may also be made to the competent authorities.

17. Breaches

Any breach of this Code may lead AC PRIVATE - A List concierge to request a corrective action plan, suspend orders or terminate the relationship, under the conditions set out in the contract and by law, without prejudice to any other remedy.

18. Acceptance and updates

Accepting an order or continuing the relationship with AC PRIVATE - A List concierge constitutes acceptance of this Code. It may be updated; the version in force is the one published on this page. In case of discrepancy between language versions, the French version prevails.