The monitoring of the implementation of the Group’s ethics and compliance policy is based on an annual compliance procedure and a dashboard of some 15 indicators (including the distribution of ethics documentation, training, implementation of ethics policies, etc.).
At each organizational level, ethics and compliance officers produce an annual report on the work and progress accomplished by their entity in this area. This report is submitted to the relevant supervising entity and accompanied by a compliance letter from the manager certifying his or her commitment to the application of the ethics and compliance program within the organization for which he or she is responsible. The consolidated annual compliance report resulting from this process is submitted to the Group’s Executive Committee and to the ENGIE Board of Directors’ Ethics, Environment and Sustainable Development Committee (EESDC).
The respect of ethics principles, including especially prevention of corruption, influence peddling and fraud risks, risk of violation of the embargo policy, risk of lack of protection of personal data and risk of infringement on human rights, is integrated into the INCOME internal control program.
Internal and external audits are performed to assess policy implementation and, where applicable, define areas of improvement.
In 2015 the Group was awarded anti-corruption certification by Mazars, an accounting and auditing firm, and ADIT, a business intelligence firm.