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An impartial collegiate body made up of external members, the Business Ethics Committee of SNCF Réseau provides guidance on decisions relating to the independence of the infrastructure manager, conflict of interest management, and anti-corruption efforts.

A compliance framework to safeguard the independence of SNCF Réseau

In response to the recommendations issued by the Transport Regulatory Authority in its October 2024 report, SNCF Réseau launched an action plan to ensure the independence of the infrastructure manager.  

The goal: to strengthen the compliance framework that ensures the independence of the infrastructure manager and the application of the rules set out in its code of conduct.  

As part of this framework, the Business Ethics Committee—established in 2025—is tasked with providing assurance to the Chairman and CEO of SNCF Réseau regarding the soundness of the company’s decisions in this area. 

The Infrastructure Manager Independence programme

Members of the Business Ethics Committee

Reporting to the Chairman and CEO of SNCF Réseau, the Business Ethics Committee is made up of four qualified individuals from outside the SNCF Group, all of whom are entirely independent:  

  • Jacques Arrighi de Casanova, Honorary Section President of the Conseil d’État, serves as Chair of the Business Ethics Committee 
  • Dominique Pauthe, Honorary Adviser to the Cour de Cassation and President of the Cour de Justice de la République 
  • Martine Lombard, Emeritus Professor of Public Law, PhD in Public Law and Professor of Law (agrégé
  • Philippe Hayez, Senior Adviser to the Cour des Comptes and Chair of the Advisory Committee on Market Oversight at SNCF Réseau 

To ensure effective operational alignment, company representatives may take part in the Committee’s work in a non-voting capacity. 

The Committee may be consulted by: 

  • The Chairman and CEO of SNCF Réseau 
  • The Executive Managing Director for Corporate Affairs at SNCF Réseau 
  • The Managing Director of Finance and Procurement at SNCF Réseau, in connection with the company’s internal control processes 

Scope of responsibilities

The Business Ethics Committee may be consulted on any matter related to the independence of SNCF Réseau, including in particular: 

  • The compliance framework and its development 
  • Setting annual objectives 
  • Internal policy regarding referrals to the ethics committee 
  • Revision and updating of the code of conduct 
  • The confidential information management plan 
  • Communication and training plans 
  • Implementation of annual controls 
  • The annual report published by SNCF Réseau (opinion submitted to the Board of Directors) 

The Committee’s remit also extends to anti-corruption programmes, conflict of interest management and business ethics. 

An advisory role

The Committee does not hold decision-making powers. It issues opinions to the Chairman and CEO of SNCF Réseau to guide and improve business ethics practices.