The Group’s human rights approach

Respect for human rights is at the heart of ENGIE’s Ethics Code of Conduct, its policies, in particular its Duty of Vigilance Policy – Human Rights, and its Vigilance Plan. The ENGIE Group also relies on the recommendations of the United Nations Guiding Principles on Business and Human Rights, which it considers to be a useful framework for reference and interpretation.

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The Group’s human rights approach thus aims to identify, prevent and manage the risks of human rights violations against any person, in particular employees, local communities, users and customers, throughout ENGIE’s value chain. It also aims to ensure that any incident relating to human rights is dealt with appropriately.

Risk mapping

The potential major risks of negative impacts on the human rights of any individual related to the Group’s activities relate to the fundamental rights of workers. More broadly, the Group’s human rights challenges are as follows:

Infographic outlining ENGIE’s main human rights, working conditions, local community rights, subcontracting, and employee security issues.
This infographic summarizes the main human rights, labour, subcontracting, and security issues considered by ENGIE for employees, local communities, and business partners.

Assessment of subsidiaries

Self-assessment and risk analysis tools are deployed annually for all entities. The entities participate in INCOME COR4 (human rights internal control) and ERM analyses (My Ethics Risks) to assess the human rights risks.

In particular, all entities must annually assess their activities with regard to their impact on human rights using a dedicated self-diagnostic grid as part of the overall risk management policy (ERM process). These assessments make it possible in particular to identify the risks specific to each of the Group’s entities: (1) the risk factors intrinsic to the entity’s specific activities and (2) the strengths and weaknesses in the consideration of human rights within the entities’ processes/policies/practices, and (3) consequently, the action plans to be put in place in light of the elements identified. This tool covers all the Group’s human rights commitments.

The risk assessment is updated at least once a year and the entity’s risk prevention plan is updated accordingly. These elements are also discussed at the Global Forum (the monitoring body for ENGIE’s Global agreement), at  the European Works Council and with the Ethics, Environment and Sustainable Development Committee of ENGIE.

In 2024, the dedicated self-diagnosis grid allowing entities to assess their activities annually with regard to their potential impacts on human rights covered 95% of the entities.

Entities must also assess any new business activity using a dedicated grid aimed at identifying the human rights risk factors specific to the planned activity.

Duty of Vigilance Policy – Human rights

The Duty of Vigilance Policy – Human rights, the first version of which was drawn up in 2014, aims to define the means necessary to ensure compliance with the Group’s commitments in all its activities by implementing a global vigilance approach. It is the foundation of the Group’s vigilance plan for human rights.

The Group’s human rights commitments

  • ENGIE undertakes to respect the human rights of all individuals and groups likely to be affected by its activities and to ensure that its activities are conducted in accordance with the highest standards of protection and at least with the provisions of international texts for the protection and defence of human rights.
  • The Group makes sure that the fundamental rights of its employees are respected, in accordance with the fundamental conventions of the International Labor Organization: it rejects all forms of slavery, forced or compulsory labor, of child labor, of human trafficking, of discrimination and recognizes freedom of association and the right to collective bargaining. The Group pays particular attention to guarantee the highest standards of health and safety in the workplace, working hours and holidays in accordance with international standards and equal remunerations. It is committed to offering a common and adequate minimum level of social protection to all its employees wherever it operates. ENGIE rejects all forms of harassment and violence in the workplace and makes sure that its employees are provided with a working environment that is respectful of their individual freedoms and privacy.
  • The Group ensures that its activities do not infringe the rights of local communities, particularly those surrounding its sites.
  • The Group seeks to identify the risks associated with the activities of its suppliers and subcontractors.
  • The Groupe ensures that missions aimed at the safety of its employees and its facilities are carried out with respect for human rights.

To ensure compliance with all of its human rights commitments and to meet French and international requirements, the Group also relies on other policies specific to certain issues, particularly the health and safety, security, ESG, procurement Charter and Human resources policies.

Human rights risk management

The Group exercises vigilance by identifying and managing any risks to people that arise from its activities. The vigilance approach is guided by the UN Guiding Principles and French law on the duty of vigilance of parent companies and ordering companies.

Infographic presenting ENGIE’s methodology for identifying, assessing, and managing human rights risks through risk factors and operational assessment processes.
This infographic outlines ENGIE’s methodology for identifying human rights risk factors and implementing operational assessment and mitigation actions across its activities and business relationships.