To be able to assess the degree to which it complies with its practices and its ethics commitments, the Group has incorporated ethics governance into a structural framework.
Organization and dedicated structures
Within the General Secretariat, the Ethics and Compliance Department oversees objectives in these two areas and ensures they are met. Its missions:
- to suggest wording for the underlying principles and references in this field,
- to drive implementation by the business lines and functional departments,
- to organize internal and external reporting.
The Ethics and Compliance Department also runs the global network of some 140 ethics officers, carry out objectives across the various entities. It offers support such as: training modules in business ethics, translation of basic texts into the Group’s main languages, educational presentations, etc.
Involvement of the Group’s management chain
Ethics are driven and overseen at the highest corporate level by the Chairman and CEO, and by the General Secretary who is an Executive Committee member and the Group’s Chief Ethics Officer. The directors of GDF SUEZ are the key guarantors of ethics compliance. However, responsibility for ethics and compliance flows throughout all levels of the management chain:
- each business line director has appointed a business compliance officer selected from their respective executive committees;
- the Ethics Steering Committee, composed of Ethics and Compliance Department managers and the business lines’ ethics officers, drives and monitors the ethics action plans and checks that the proposed measures are implemented operationally;
- the Compliance Committee, chaired by the Group Ethics Officer, drives and monitors the implementation of compliance procedures. It highlights any dysfunctions and ensures that the appropriate remedies are applied. It reports to the governance bodies and to General Management on the application and monitoring of the GDF SUEZ ethics mechanism.
- A compliance procedure monitors the implementation of the Group’s ethics policy within the entities. Ethics officers prepare a report of the progress and organization of ethics in their entity. The ethics officers’ reports, along with a letter of compliance from the manager of the entity, are sent via the business ethics officers to the Chairman and CEO. The Group Ethics Officer uses these to produce the GDF SUEZ Annual Compliance Report.
- The Ethics and Compliance Department has implemented a procedure for reporting ethics incidents, called INFORM’Ethics, which has been rolled out to the business lines and business units. The incidents are reviewed by the Compliance Committee, which can request any follow-up audits and special investigations it considers necessary.
- Lastly, with regard to risk management, the ethics risks review along with the associated action plans prepared as part of the Group’s risk management (Enterprise Risk Management) are incorporated into the Group’s risk review.
- These various ethics steering instruments will soon be compiled in a Group Ethics Compliance Management Reference which will provide a single point of entry for anyone wishing to understand the procedures in place.