ETHICS & COMPLIANCE

Operational implementation of the vigilance plan at entity level

Additional actions are required from the entities to ensure the effectiveness of the deployment of the vigilance plan and in particular coordination actions between the different Departments in charge of deployment and actions to inform the actors. The new internal control review dedicated to the effective deployment of the vigilance plan set up in 2020 shows that 51.7% of the Group's entities have effectively implemented these various actions. The Group's Ethics, Compliance & Privacy Department supports the entities in the deployment of these actions.

 

Distribution of the vigilance plan to the Excom Committee

It is requested to present/organise discussions within the management committee of each entity on the obligations of the law on the duty of vigilance and on the Group's vigilance plan. This requirement is increasingly deployed in the entities (71% of Group entities).

 

Association with internal stakeholders

At Business Unit level, they are also required to present the vigilance plan to their employee representative bodies. Entities that do not have employee representative bodies are encouraged to present the plan directly to employees.

 

Coordination

72% of the Group's entities have set up coordinated actions with the other Departments concerned by the topics covered by the Group's vigilance plan. Among the actions implemented within the Business Units to ensure the coordination of the various actors in charge of deploying the vigilance plan:

  • In the Africa Business Unit, regular discussions between the functions involved (Ethics, Purchasing, Health & Safety, CSR) have been organised through "vigilance committees". Four committees were held in 2020. These committees provide an opportunity to periodically discuss all issues related to the vigilance plan, and to share information among all departments in order to adopt a common approach to the duty of vigilance and the actions to be implemented in this regard. Also, on a regular basis, all departments have worked together on projects carried out by the Africa BU teams based on the type of risk identified and the actions to be implemented.
  • As for the APAC Business Unit, for example, a vigilance committee has been set up. The different functions are involved in coordinating their main actions.
  • In the MESCAT BU, the Vigilance Plan is communicated to all new joiners across the BU and the BU will be implementing a Vigilance committee in 2021.