ETHICS & COMPLIANCE

Governance, management and actors of the vigilance plan

Integrating the vigilance plan into the ethical approach

ENGIE has set up a governance, an overall coordination and a specific monitoring of the vigilance plan at the highest level of the company to ensure the proper deployment of the plan throughout the Group and to effectively meet the objectives of the law. The Group's vigilance plan was validated by the Group's Executive Committee on 22 January 2018, which entrusted the Ethics, Compliance & Privacy Department with its management, under the responsibility of the General Secretary. Fully integrated into the company's ethical organisation, the vigilance plan benefits from the governance, monitoring systems, resources and actors involved and is monitored at the highest level of the Group. A report on the effective implementation of the plan is presented annually to the Ethics, Environment and Sustainable Development Committee of the Board of Directors.

 

A transversal monitoring committee

To ensure the deployment of the vigilance plan and to globally coordinate the various approaches involved, a specific inter-directional committee was set up as soon as the law was adopted in 2017. Initially responsible for reviewing existing policies in relation to the law and defining the Group's vigilance plan, it is now responsible for monitoring the plan and ensuring that it is correctly distributed, that the various measures are coordinated, that the entities are made aware of it and for facilitating the reporting of information to the Group.

The members are:

DepartmentDECPRSEGroup Purchasing DepartmentGlobal CareInternal ControlRisk
Business Unit (BU)MESCATAAPACEngie SolutionsLATAMNORAMUKGEM

 

Aware of the need for distribution and adoption as close to the field as possible, specific actions related to the deployment of the vigilance plan at local level, such as the organisation of exchanges between the various departments in charge of the application of the vigilance plan or the application of the new ethics and vigilance clause in the context of contractual relations, have been requested from the entities.

Progress

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Firstly, in 2020, as every year, a report on the effective implementation of the plan was presented to the Board of Directors' Ethics, Environment and Sustainable Development Committee in order to outline especially the priority areas for improvement.
In addition, the specific committee (multi-directional) in charge of the operational implementation of the plan especially allowed for Group coordination actions in 2020. For example, a Covid-19 coordination review was presented by the Health and Safety Department. The Group also has a monitoring role, alerting the Business Units to weak signals. The committee also made it possible to recommend areas for improvement as well as to share the actions and best practices implemented at Business Unit level.

Lastly, each entity must ensure that the vigilance plan is effectively deployed within its scope. The monitoring of these actions by the entities is integrated into the ethical compliance processes of internal control and the annual ethical compliance report.

In 2020, an internal control review dedicated to the deployment of the vigilance plan was implemented. It includes the following controls:

  • Ensuring that the obligations of the law and the vigilance plan are known to all (direct and indirect subsidiaries)
    • Presentation and discussion within the Excom committees of each entity
    • Information for employees
    • Presentation and discussions with the Staff Representative Institutions
  • Ensuring that the plan is deployed in all entities (direct and indirect subsidiaries)
    • Organisation of regular discussions with the various departments in charge of deploying the vigilance plan.
    • Reporting on the progress of actions and their implementation in all entities
  • Ensuring that the whistleblowing/alert system is communicated to internal and external stakeholders

In addition to this overall internal control review, internal control reviews specific to the various actions (human rights, health and safety, CSR, purchasing) are used to monitor the deployment of the various approaches of the vigilance plan. These controls are developed within each vigilance approach of this plan.

 

Possible contributions of Internal Control to the monitoring of the vigilance plan