The integrity referential provides a framework for “behaving honestly and promoting a culture of integrity”.

It comprises the policies below, among which several are part of the ENGIE anti-corruption program, which incorporates best international standards (UK Bribery Act, US Foreign Corrupt Practices Act (FCPA), French Sapin 2 law).

Due diligence policy

The Group has adopted several so-called ethical due diligence policies, which consist in investigating our third parties, namely our suppliers and subcontractors, our commercial consultants, our partners in the context of investment projects, beneficiaries of sponsorship, etc., before the beginning of any business relationship or partnership. This ensures that these parties do not represent any major ethics risks for ENGIE and that they are not in violation of any rules governing human rights, health and safety, and/or the environment). There are two levels of due diligence. The level 1 is carried out by the members of the ethics network. With regard to so-called enhanced due diligence (level 2), ENGIE has chosen to be part of an innovative trend by creating its own "team" of internal investigators (called C2A) who are responsible for carrying out these ethical investigations.

Due diligence policy for investment project partners

This policy covers the due diligence required for future partners for Commitments Committee, BU and Group projects.

Due diligence policy for corporate sponsorship and patronage:

This policy covers the due diligence required for future recipients of corporate sponsorship and patronage.

Due diligence policy for suppliers and direct sub-contractors:

This policy covers the due diligence required for future suppliers and direct sub-contractors.

Business Consultants policy:

To prevent any ethical risks that may arise over the course of a project, from the contract negotiation phase to its implementation, ENGIE has built a business consultant policy whose key elements include: an ethical due diligence of all business consultants, the analysis of the business rationale of their missions, a framework governing compensation, traceability of selection decisions and services provided.

Gift and hospitality policy

The Group wants to limit, as far as possible, the quantity and value of gifts and hospitality, whether they are given or received by Group employees.

The gifts and hospitality policy aims to prevent any type of corruption, conflict of interests or influence peddling. It outlines the general principles to respect in matters of gifts and hospitality, in particular for technical and study travel, relations with public authorities and invitations to events. It ensures transparent practices through information requirements, prior authorization and registration.

This ENGIE policy is applied in each BU, subsidiary and entity of the Group, and presented in the Code of Conduct for Business Relations.

NB: The GDF SUEZ Ethics and Compliance documents available at www.engie.com apply to the ENGIE Group until they are superseded.

Policy for the prevention of conflicts of interests

The policy for the prevention of conflict of interests aims to eliminate any doubts concerning the impartiality of a decision taken by a Group employee or his or her potential lack of loyalty in taking a decision, and to find adequate solutions in case of a conflict of interests, such as the possibility for employees to abstain without having to disclose the nature of their conflict of interests, in order to preserve employees' right to respect for their private life. This policy informs employees and guides them if facing such situation: it gives them examples of situations, and specifies the process for management and traceability in this matter.

Policy for the prevention of conflicts of interests

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Operating rules for Patronage and sponsorship

In addition to the due diligence policy for beneficiaries of sponsorship, these Operating Rules are intended to provide a framework for the support provided by the Group through its patronage and sponsorship efforts, in accordance with the law, particularly regarding fight against corruption and the Group integrity requirements. It ensures transparent practices by establishing rules for selecting projects, partners and activities. It also sets up a process for validating projects by the Patronage and Partnership Committees at the Group and within each BU.

Tax policy

ENGIE is committed to comply, with honesty and integrity, with relevant tax laws and regulations, and to pay its fair share of taxes in the countries in which it operates.

On principle, the Group avoids holding entities or assets not connected to a localized operational production in countries that are non-cooperative in fiscal terms.

Ethics, health & safety, social & environmental responsibility clause

ENGIE’s Ethical, health & safety, social & environmental responsibility clause must be inserted into all contracts with every Group supplier, service provider, subcontractor and partner, regardless of the entity with which they are working.

This clause includes the prohibition of all forms of corruption, compliance with competition and embargo rules and compliance with human rights standards and regulations. It directs the contracting party to review the Group’s ethical documents, requires it to follow the ethical rules outlined in these documents throughout the duration of the contract, and to ensure same respect of these rules by its own subcontractors if any. It also informs it of the contractual consequences in case of non-compliance with these rules.