Main parties involved in Ethics
ENGIE’s ethical commitment is managed at the highest level of the Group, under the impetus of the Group’s Board of Directors and General Management.
A strong message of zero tolerance with respect to ethics – especially in the fight against fraud and corruption – runs throughout the Group’s ethics and compliance framework. This message is regularly communicated by the the Group's Presidency and passed on by managers at all Group levels.
The Group's senior executives, particularly the Chief Executive Officer and the members of the Executive Committee, including the General Secretary, drive and oversee ENGIE's ethics and compliance policy and ensure that it is properly applied.
For Group CEO Isabelle Kocher: “Our policy is very clear: zero tolerance, particularly regarding fraud and corruption, and complete commitment to compliance with ethical rules – those of the countries in which we operate and those we set for ourselves.” (introduction of ENGIE’s Ethics charter).
The ENGIE Board of Directors' via its Ethics, Environment and Sustainable Development Committee (“EESDC”) oversees the ethics and compliance organization and monitors respect of the individual and collective values underlying the Group's action, and of the rules of conduct to be followed by every employee. It ensures that the Group has adequate means to apply these values and rules.
The Compliance Committee supports ENGIE’s ethics and compliance actions. Chaired by the Group’s General Secretary, it is made up of the Group Internal Audit Director, the Group Internal Control Director, the Group Legal Director and the Group Ethics & Compliance Director.
The Committee evaluates the treatment of ethical incidents and monitors the process for updating the Group’s ² system.
The Group Ethics, Compliance & Privacy Department
Within the General Secretary, the Group Ethics, Compliance & Privacy Department manages the integration of ethics into the Group’s strategy, management and practices. It proposes the policies and procedures in terms of ethics and compliance and drives their application by BUs, Businesses and functional departments.
It provides managers and employees with the required tools: ethics training, documentation, reporting tools, solutions for raising alerts in case of potential ethics breaches, advice and support, etc.
It advises the Group's Executive Management, the Newcorp Departments and the members of the Ethics & Compliance network.
The Group Ethics, Compliance & Privacy Department monitors ethics incident declarations (including incidents involving personal data or data breaches) and their treatment within the Group.
It centralizes the various elements in the Group’s ethics risk analysis including the mapping of corruption risks carried out by the Group's Business Units, manages the annual ethics compliance process and, in collaboration with the Internal Audit Department, evaluates the effective implementation of the ethics and compliance policies defined by the Group.
The Ethics & Compliance and the Data Privacy managers Networks
The Group’s Ethics, Compliance & Privacy Department, leads the Ethics & Compliance network made up of more than 300 people (from Bus, entities and Newcorp). It also leads the Bus Data Privacy managers and Data Privacy Managers Correspondent Network.
Members of the Ethics & Compliance network include the BUs Ethics and Compliance Officers, their deputies and Ethics & Compliance Officers from each entity. Most members also carry out other missions (legal, health & safety, HR, etc.). In Ethics & Compliance matters, they report to the network, so called authoritative. The members of the Ethics & Compliance are responsible for relaying the Group Ethics, Compliance & Privacy Department’s missions throughout their BUs and entities.
The Ethics & Compliance network also relies on ethics correspondents, who relay the missions of the Group Ethics, Compliance & Privacy Department within Businesses and functional departments at ENGIE’s headquarters.
Mobilizing all of these parties contributes to the Group’s exemplary practices in ethics, compliance and Data Privacy.
Ethics, Compliance and Data Privacy responsibilities are exercised at all levels of the management line. At each level of the organization, Ethics & Compliance Officers, Ethics Correspondents and Data Privacy Managers advise and support their manager who guarantees that Group Ethics, Compliance and Data Privacy systems are applied.