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
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).
Yann Padova
Yann Padova, expert en droit des données personnelles et de la régulation, a occupé des postes clés, notamment en tant que secrétaire général de la CNIL. Diplômé de Sciences Po Paris, titulaire d’un Master 2 en droit, d’un Master 2 en économie, il est avocat aux barreaux de Paris et de Bruxelles. Il a été nommé membre du collège de la Commission de régulation de l’énergie par le Président de l’Assemblée nationale en 2015. Il a débuté sa carrière comme Administrateur à l’Assemblée nationale, en particulier à la Commission des Lois. Il enseigne le droit du numérique et des données à Sciences Po Paris et à Assas. Son parcours est marqué par sa maîtrise des enjeux liés à l’informatique, à l’Internet et à la cybercriminalité. Une carrière riche et influente au service de la protection des données personnelles et de la régulation.
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.
Le mot du PDG
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.”
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