Pascal Imbert

Pascal Imbert


As part of Wavestone’s CSR approach, we are committed to a high level of business ethics and to fight against corruption, conflict of interest and any other form of fraud or illicit practice.​

To this end, we have carried out several actions, including adopting the Middlenext code of conduct, publishing our Business Ethics Charter and setting up an internal alert system.

In terms of ethical business practices, Wavestone is committed to fighting against corruption, conflicts of interest, and any other form of fraud or illegal activity. And more broadly, as part of our efforts to be a responsible employer, Wavestone wishes to combat harassment, sexism, racism, and every other form of discrimination.

Everyone should be able to pursue their career in a safe and ethical working environment.

Business Ethics Charter

Wavestone is committed to being a trusted partner by maintaining a transparent, responsible and sincere relationship with its clients, suppliers and partners. The Business Ethics Charter sets out the key principles to ensure this commitment while providing a clear framework for acceptable and unacceptable behavior and situations. It is addressed to all Wavestone stakeholders, whose employees must be aware of these principles and commit to respect them.

Report ​a non-compliant situation

An external system accessible to all, Whispli, lows questions to be asked and an unsuitable situation to be reported in a completely anonymous manner.​​

There can be various sorts of situations or behaviors that have an ethical aspect. They may relate to:

  • Instances of corruption, influence peddling, anti-competitive practices, conflicts of interest, fraud, etc.
  • Acts of discrimination, bullying, or sexual harassment, practices contrary to our health and safety policy, or violations of human rights and fundamental freedoms involving a Wavestone employee, etc.

If you are a witness/victim or have any doubt about such a situation, you can talk about it through the link below:

The Ethics Officers will confirm receipt of the query or alert, review its admissibility and manage its processing. The information transmitted is entirely anonymous.

The Ethics Officers 

Wavestone has designated Ethics Officers, representing all Wavestone functions, who can be called upon by employees in case of doubt on ethical issues in order to guide them in their decision. ​​

They are the designated contact persons on ethical matters for all the firm’s employees and receive special training on the application of the law within this field.

They are appointed by Wavestone’s CEO, Pascal Imbert, and are known for their skills, integrity, loyalty, and knowledge of the company.

CSR Manager

LE ROY Clément

Commercial Director

HR Manager

HR Manager

DREYFUS Jean-Jacob
Senior Manager, US

FOY Paul
Account Director, UK

Adoption of the Middlenext anti-corruption code of conduct

Wavestone’s management board has adopted the Middlenext anti-corruption code of conduct, published in December 2017. Integrated into Wavestone’s internal policies and procedures, this code is intended to be communicated to all.

This code has been developed to guide business conduct in order to prevent and detect corruption. It sets out the principles that employees must adhere to as they carry out their business activities and applies to all Wavestone employees, whatever their role or geographical location, as well as to anyone acting on the company’s behalf. Wavestone will ensure that its partners also share the same values.

The code’s detailed content describes the fundamental rules to be followed in terms of corruption and influence peddling concerning the following areas:

  • Specific rules for public officials
  • Gifts and invitations
  • Donations to charitable and political organizations
  • Patronage and sponsorship
  • Requests for facilitation payments
  • Third party surveillance
  • Conflicts of interest
  • Accounting records/Internal controls

As this code of conduct cannot deal with, or foresee, all cases of corruption or influence peddling that might occur, each employee must therefore exercise their own judgment and common sense.

To facilitate its application within Wavestone, this formal guide has been prepared based on tangible cases identified in workshops to illustrate the code’s main principles.

Other devices

Business ethics training is mandatory for all the firm’s employees, in the form of an e-learning program designed by Wavestone employees and based on concrete situations.

Finally, a corruption risk mapping has been drawn up.