The alliance of operational excellence and ethical integrity lies at the very core of ChapsVision’s DNA.
ChapsVision, a specialist in sovereign data management, operates across both corporate and government markets with the strategic objective of strengthening Europe’s sovereignty in data processing. Given the sensitive nature of its activities, the Group has deemed it essential to establish a strict framework to ensure regulatory compliance and uphold the fundamental values set out in its Code of Conduct.
This reference document sets forth the ethical principles, values, and guidelines that employees are expected to follow in order to act responsibly and ethically, not only towards the company but also towards all stakeholders potentially affected by the Group’s activities.
In this context, ChapsVision established an Independent Ethics Committee in January 2023. Its role is to provide opinions on the Group’s proposed development strategies.
Members of the Independent Ethics Committee
Jean-David Levitte
Jean-David Levitte, member of the Académie des Sciences Morales et Politiques and Chairman of the Board of the Geneva Council for Security Policy (GCSP), has had an exceptionally distinguished diplomatic career.
From 2007 to 2012, he served as Diplomatic Advisor and Sherpa to President Nicolas Sarkozy.
From 2003 to 2007, he was Ambassador to Washington during the challenging period of the Iraq War.
From 2000 to 2002, he was Ambassador to the United Nations in New York, where he chaired the Security Council at the time of the September 11, 2001 attacks and negotiated the return of inspectors to Iraq in 2002.
He also spent sixteen years at the Élysée Palace, serving as Foreign Policy Advisor to three Presidents of the French Republic.
Yann Padova
Yann Padova, expert in data protection law and regulation, has held several key positions, notably serving as Secretary-General of the French Data Protection Authority (CNIL).
A graduate of Sciences Po Paris, he holds two Master’s degrees, one in Law and one in Economics, and is a lawyer at the Paris and Brussels Bars.
In 2015, he was appointed Member of the Board of the French Energy Regulatory Commission (CRE) by the President of the National Assembly.
He began his career as an Administrator at the National Assembly, particularly within the Law Committee.
He teaches digital and data law at Sciences Po Paris and Université Paris II Panthéon-Assas.
His career reflects deep expertise in IT, Internet, and cybercrime issues—a distinguished path dedicated to data protection and regulatory governance.
Claude Revel
Specialist in international strategic intelligence, geoeconomics, and trade policy. Former interministerial delegate for economic intelligence (2013–2015) and senior adviser at France’s Court of Auditors. She is currently Chair of France Sport Expertise, Director of Development at think tank SKEMA Publika, and an independent board member at Clasquin, where she chairs the CSR Committee. Author, lecturer, and active member of several policy think tanks, she has a long-standing career in both public service and private sector international strategy.
Francis Delon
Honorary Member of the French Council of State. He served in various judicial and advisory roles within the Council, at the Ministry of Foreign Affairs (1986–1993), and at France’s mission to the UN. He was Chief of Staff to the Minister of National Education (1995–1997), then Secretary General for National Defence and later for National Defence and Security (2004–2014). Until 2021, he chaired France’s independent National Commission for the Control of Intelligence Techniques.
Jan Kleijssen
Recipient of the 2023 AI Policy Leader Award from the Center for AI and Digital Policy (Washington DC). A key figure at the Council of Europe in AI regulation and its implications for human rights, rule of law, and democracy. Since joining the Council in 1983, he has held multiple senior posts, including Director of Information Society and Action against Crime (2011–2022) and Coordinator for Internet Governance (2018–2022).
Chaired by Ambassador Jean-David Levitte, and composed of impartial, highly experienced members including Francis Delon, Jan Kleijssen, and Yann Padova, the Committee plays a crucial role in achieving the Group’s ethical objectives and in ensuring compliance with the procedures designed to uphold them.
“At ChapsVision, we believe that ethics is a cornerstone of long-term success. Every day, our teams are driven by an unwavering commitment to ethical and technological excellence.”
While the Committee does not have the authority to represent the company, it provides valuable opinions to guide decision-making.
The Independent Ethics Committee may be consulted at the request of Olivier Dellenbach, CEO of ChapsVision, on ethical matters, in particular:
Areas of Focus
Strategic Direction
Recommending guidance on the company’s strategic direction, including target products, clients, and the TAMIS process, which validates business opportunities and monitors sales under strict rules.
Internal Compliance
Advising on the design and implementation of an internal compliance program.
Priority Measures
Providing recommendations on priority measures following audits, especially during events such as investor entry or acquisitions.
Mergers & Acquisitions
Issuing opinions on due diligence for growth operations, particularly regarding regulatory and reputational risks.
Alerts Management
Advising on alerts when difficult decisions arise for the internal compliance unit, including the professional whistleblowing procedure for reporting ethical violations.
Specific Risks
Providing opinions on risks linked to countries, products, or end-uses of products when the TAMIS process cannot yield a clear answer.
A word from our CEO
Olivier Dellenbach – CEO
“The nature of our business has reinforced my determination to ensure rigor and trust in the use and handling of data, particularly in the field of cybersecurity. The Independent Ethics Committee is designed to support ChapsVision in applying its Code of Conduct and adhering to its procedures. This Committee brings together distinguished experts whose experience ensures that ChapsVision and all Group entities rigorously uphold the standards they have set for themselves. We are honored by the creation of this Committee and grateful to its members for their commitment.”
