Back to the main page of ENGIE's vigilance plan
This due diligence is implemented within the framework of several policies:
- Due diligence of sponsorship beneficiaries & partnerships;
- Due diligence of partners in investment projects;
- Embargo policy;
- Due diligence of Business consultants;
- Due diligence of suppliers and subcontractors.
- Due Diligence on Clients
Focus on two policies: the one relating to partners in the context of investment projects and the one relating to suppliers and subcontractors.
As part of the investment projects
All investment projects, going through the GBU and Group investment committees, whether for sale, acquisition, partnership or other investment, are subject to systematic due diligence.
Each entity must, prior to any of these investment projects, make a list of its co-contractors (whether the customer, the supplier or direct subcontractor, the joint venture partner or the project company, etc.) and carry out due diligence.
This due diligence must draw up an exhaustive table of the risks presented by the company (country risk, human rights risk, environmental risk, health and safety risk, corruption risk, money laundering risk, existence of an ethical process, etc).
With suppliers and subcontractors
The term "Supplier" refers to companies with which the Group and its entities have a direct contractual relationship, which includes: on the one hand, companies that supply a good; and on the other hand, those that provide a service, whether or not in addition to a good supply, and which are called "direct subcontractors or subcontractors of rank 1".
Due diligence must be carried out at least on all the Group's preferred and strategic suppliers, as well as on the major suppliers. In parallel, each entity performs the same exercise on the suppliers it has identified as being at risk.
If necessary, ENGIE also carries out due diligence on the entire supply chain to ensure compliance with our ethical rules and our vigilance plan.
In addition, the identification of one or more risks leads to the implementation of preventive or remediation mechanisms or procedures (in particular via ethical clauses with the possibility of terminating the contract, monitoring of the company, etc.).
Once a risk has been identified, ENGIE evaluates and builds the best solution and proposes appropriate remediation measures.
The evaluation of the severity of the identified risk determines whether or not to consider a contractual outcome with the third party. Only if the risk is assessed as too important or uncontrollable should the project be stopped for ethical reasons. However, as soon as the risk is considered to be under control, even though it exists, a contractual outcome can be envisaged.
In 2024, 100% of the partners in the Group’s investment projects were subject to due diligence, including a systematic study of “vigilance” issues.
Due diligence is performed on third parties (suppliers, subcontractors, partners, ordering contractors, etc.) in accordance with the due diligence policies requirements, with the help of specialized tools. In 2024, the Group's Ethics & Compliance Officers and Ethics Correspondents reported that more than 30,000 level 1 due diligence were carried out using the due diligence tools.
In addition, the procurement department systematically evaluates the Group's new strategic, preferred and major Suppliers through a due diligence carried out before contracting. The Group has set up a dedicated team in charge of carrying out the due diligence of key Suppliers and has equipped itself with a new digital tool providing an ethical risk score covering five dimensions: country risk, activities at risk, politically exposed persons, sanctions and controversies. ENGIE also uses EcoVadis for environmental aspects, human rights and ethics. In 2024, approximately 1,200 recurring key Suppliers (Strategic, Preferred and Major) representing almost 60% of total expenditure, were subject to due diligence.
Some assessments can be supplemented by on-site audits.
