Program of actions for preventing fraud and corruption
ENGIE is implementing a scheme to fight against corruption, which has been developed with regard to the UK Bribery Act and the US Foreign Corrupt Practices Act (FCPA) and which follows the guidelines of the Central Service for the Prevention of Corruption (French SCPC).
A commitment at the highest Group level
- The Group’s executives, particularly the CEO and the General Secretary, member of the Group Management Committee and the Group Ethics Officer, drive and supervise the ethics policy and ensure its effective implementation;
- A strong “zero tolerance” approach to ethics is part of the ethical standards and is regularly expressed by the CEO: “Our policy is very clear: zero tolerance with regard to fraud and corruption and complete commitment to ethical rules – those of the countries in which we operate and those we set for ourselves.”, Isabelle KOCHER, 2016 Ethics Convention
- The Group’s external commitments are made with organisations like EITI (Extractive Industries Transparency Initiative) which promotes transparency in the extracting investments made in certain countries), Global Compact with the publication of the reporting on the 10th principle against corruption, Transparency International France and with our suppliers and partners.
An assessment of ethical risks that takes into account the specific characteristics of our activities is integrated into the Group’s risk analysis process. The results are presented to the Group’s Steering Committee and to the Board of Directors’ Ethics, Environment and Sustainable Development Committee;
Establishing an anti-corruption compliance program
- A dedicated organisation supervised by the Ethics, Environment and Sustainable Development Committee, a specialised Board of Directors committee, has been established. This organisation is managed by the Group Secretary General. The Compliance Committee preside over it in order to drive the implementation of ethical action plans and compliance monitoring. As a dedicated department, the Ethics & Compliance Division develops policies and ensures the availability of tools and the implementation of ethical policies, coordinating a line of over 200 ethics officers;
- Responsibilities are defined at all levels of the managerial line;
- The Group’s “Ethics Charter”together with the “Ethics in Practice” guidelines is published on the Group’s website. These reference documents forbid bribery and corruption. The ethics charter and the “Ethics in Practice” guidelines are distributed to all new employees who commit to respect the ethics principles;
- In the framework of the Integrity Referential adopted in 2010 which sets out the action plan for the prevention and treatment of fraud and corruption, the Group has implemented specific policiesrelating to
- “Business Consultants” which applies four major principles to the business consultant selection process: the analysis of the legitimacy of their missions, the Due Diligence of all business consultants, establishing a compensation system, the traceability of selection files and decisions,
- gifts and hospitality and patronage and sponsorship,
- carrying out due diligence on all partners involved in investment projects,
- All major Group investments are assessed using criteria concerning the risk of corruption.
- An ethics, environmental and societal responsibility clause is integrated into contracts with the Group’s suppliers;
- Ethics is integrated into the annual appraisal process of management and employees;
- A confidential whistle-blowing system (email@example.com) is open to all Group employees;
- Managerial notification of ethics incidents is done via the INFORM’ethics tool. INFORM’ethics covers ethics incidents in six domains: accounting and financial integrity, conflicts of interest, social responsibility and human rights, business ethics, confidential information, and the protection of intangible property. The notification process applies to any such incidents, whether alleged or substantiated, and regardless of the monetary value involved. It applies as soon as the entity becomes aware of the occurrence of such alleged or substantiated ethics incident. Every reported matter is examined. In 2015, 155 reports were made. On average, over the previous years, approximately 40% of the matters reported via INFORM’ethics related to substantiated ethics incidents (as determined at the time of the notification or after examination) and were hence sanctioned;
- Ethics incidents are subject to systematic processing and implementation of corrective and preventive measures.
Communication, manager training and employee awareness
- An annual convention that brings together ethics officers and operational and functional Group managers provides an opportunity to affirm and reaffirm the Group’s ethical commitments;
- The Group carries out a series of awareness and training activities including an awareness seminar about the risk of fraud and corruption for senior executives, specific training for ethics officers, managers and the procurement line;
- E-learning is accessible to all employees.
- A self-evaluation questionnaire (COR 4) dealing with key ethical themes has been implemented within the framework of Internal Control;
- The roll-out and implementation of the anti-bribery system within the Group’s entities is undertaken through a procedure called the “annual ethics compliance procedure”;
- Audits are conducted across the field of ethics and compliance policies;
- The Group’s anti-corruption program was certified by Mazars-Adit in 2015.