This vigilance plan aims to identify and prevent the risks of negative impacts on people and the environment related to the Group's activities. It is based on four main vigilance measures related to human rights, health and safety, the environment and purchasing and on a common alert mechanism. Fully supported by the ethical organization, it benefits from its own steering, governance and dedicated monitoring.

Governance, management and actors of the vigilance plan

The alignment of the vigilance plan with the ethical approach

ENGIE wanted to set up a governance and a specific monitoring of the vigilance plan at the highest level of the company to ensure that the plan is properly deployed throughout the Group. 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 Secretary General. Fully linked to the company's ethical organization, the vigilance plan benefits from governance, monitoring mechanisms, resources and associated actors and is supervised at the highest level of the Group. Indeed, a report on the effective implementation of the plan is presented annually to the Committee on Ethics, Environment and Sustainable Development of the Board of Directors.


A transversal monitoring committee

A transversal monitoring committee

To ensure that the vigilance plan is implemented and to coordinate the various steps 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 it and ensuring that the plan is properly disseminated, that the various measures are coordinated, that the entities are made aware of it and for facilitating the feedback of information for the legal reporting requirement.

Aware of the need for dissemination and appropriation as close as possible to the field, specific actions related to the deployment of the vigilance plan at the local level, such as the organization of exchanges between the various sectors in charge of enforcing the vigilance plan or the application of the new ethics and vigilance clause in contractual relations, were requested from the entities.

Association with trade union organizations at both group and local level

The vigilance plan and its operational implementation are regularly presented to employee representative bodies and representatives via the existing committees: the European Works Council, the Committee on Ethics, the Environment and Sustainable Development, and the Board of Directors. At the local level, entities must present the vigilance plan and the obligations arising from the law to their employee representative organizations.

Dialogue with stakeholders at the operational level: A Group objective

To prevent and manage the human rights, environmental or societal impacts of its activities as effectively as possible, ENGIE has adopted a specific policy on "dialogue with stakeholders", a component of the Group's CSR policy.

The vigilance plan

Risk identification and management: the various approaches of vigilance

The plan is based on the Group's various risk identification and management approaches specific to each issue or area of vigilance, which have already been in place for several years:

The vigilance plan is also based on cross-functional processes related in particular to the identification and management of risks related to the Group's new activities, such as ethical due diligence, the evaluation of new projects required by the human rights and CSR policies, and the ethics and vigilance clause that is intended to be included in all contracts and adapted as necessary to each new contract according to its specific features and those of the co-contractor.

Alert mechanism

A Group mechanism open to all

As part of the application of the Sapin 2 law and the law on the duty of vigilance, the Group has strengthened its alert system by deploying a new alert system common to the entire Group and has defined a new policy on whistleblowers. This system is open to all employees, permanent or temporary, as well as to all its external stakeholders and covers all due diligence issues (linked to the Group's ethical commitments).

You wish to alert us to facts related to our activities that seem to you to be contrary to human rights, the health and safety of persons or the environment / Use the ENGIE alert system.

Whistleblowing System

Grievance mechanisms at the operational level:

At the local level, and depending on the risks they have identified, entities must, according to the human rights policy, set up appropriate mechanisms at the operational level to enable everyone who feels aggrieved by the Group's activities to alert them. In addition, the Group's dialogue policy with stakeholders has set the objective of covering 100% of industrial activities by 2020 with an appropriate dialogue and consultation mechanism.