18.104.22.168 Outside the European Union
The Group keeps a particularly watchful eye on the emergence of regulations that are similar to the E-Money and Payment Services directives in all countries in which it operates.
In several countries, regulations governing payment services and/or e-money sometimes take a similar approach to the European Union’s regulations, acknowledging the exceptional nature of the Employee Benefits offered by Edenred.
This is the case, for example, in Turkey, where regulations covering both payment services and e-money entered into force in June 2015. Just like the European Union’s E-Money and Payment Services directives, the Turkish regulations provide for the exclusion of instruments accepted within a “limited network” or which only grant access to “a limited range of goods or services”.
Since 2014, the Central Bank in Brazil has been in charge of regulating procedures for the issue and functioning of certain electronic payment instruments. Circular no. 3886 issued on March 26, 2018 recognized the specific nature of food and meal vouchers and excluded them from the Central Bank’s scope of supervision. Furthermore, resolution no. 150 of March 6, 2021 recognized the specific nature of fuel-card issuance and distribution services as well as maintenance services and excluded them from the Central Bank’s scope of supervision too. Edenred’s other businesses, including the freight business (Repom), are authorized by the Central Bank to operate in open-loop schemes as the issuer. Lastly, the rewards and prepaid solutions business where the Group is the issuer (ESPP) has submitted a request for accreditation, which was still being reviewed by the Central Bank at December 31, 2021.
1.6 Contractual relationships
1.6.1 Contractual relationships with clients
Master contracts are signed with major accounts that generate significant business volume, organizing business relations with these clients.
Such master contracts are generally signed following a call for bids and may cover one or several of the corporate clients’ facilities or subsidiaries. They are usually for periods of one to three years. In particular, they specify the terms of the compensation to be paid to the Edenred unit concerned and the frequency of invoicing and remittance.
For small and medium-sized enterprises and micro-enterprises with limited needs that require greater ordering flexibility, contractual relations are generally based on order forms containing Edenred’s general conditions of sale. As part of its digitalization process, the Group also makes use of online contractual agreements and simple, advanced or qualified electronic signatures.
1.6.2 Relations contractuelles avec les prestataires marchands
The affiliation of merchants accepting Edenred solutions is formalized by paper or electronic contracts between the Edenred subsidiary and each merchant.
In particular, these contracts specify the terms of the Edenred subsidiary’s compensation and the conditions and technical procedures governing the acceptance of the Edenred solutions.
1.6.3 Contractual relationships with suppliers and service providers
Relations between Edenred or its subsidiaries and external suppliers or service providers are governed by standard contracts. Close attention is paid to services with associated intellectual property rights in order to ensure that the rights of Edenred and its subsidiaries are clearly determined.
Edenred uses many suppliers and is not dependent on any single company. In order to benefit from powerful, scalable and secure technological infrastructures, the Group favors the use of public or private cloud-based IT solutions, from providers hailed by the market for the quality of their services and long-term viability. The Group has notably implemented global master agreements with leading providers of cloud-based solutions and the associated network aspects. These agreements are particularly demanding in terms of compliance, security and availability. To support the digitalization of the Group’s solutions, plastic card production, electronic payment services and technical acquisition or authorization services are also outsourced, with the appropriate diligence and care. Particular attention is also paid to the contractual and technical management of providers dealing with personal data, notably to ensure that the processing complies with applicable legislation such as the European General Data Protection Regulation (GDPR).