ETHICS & COMPLIANCE

The Group's human rights approach

Back to the main page of ENGIE's vigilance plan

 

Respect for others is one of the 4 principles on which ENGIE's ethics and compliance policies are based. The Group’s Human Rights referential provides a framework for implementing the principle of "respecting others" and brings together all of ENGIE's commitments in the area of human rights.

 

Preventing and managing human rights risks

It constitutes the foundation on which the pillars of the Group's overall approach are based, a foundation that includes the United Nations' guiding principles on business and human rights (UN, 2011) and recalls the Group's various policies, all of which contribute to respecting its human rights commitments.
 

ENGIE is committed to conducting its business in a manner that respects internationally recognised human rights wherever the Group operates, including in all its dealings with public authorities. The Group's commitments are based on the risks of human rights violations potentially caused by the Group's activities (either direct activities or through its business relationships).
 

The Group's commitments are based on the mapping of human rights issues updated as part of the Group's vigilance plan.

 

Risk mapping

The major risks of negative impacts on the human rights of any individual related to the Group's activities concern the fundamental rights of workers. They address the following risks: 

visuel URD

Progress

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In 2021, entities in two major regions, South America (SOUTHAM) and Asia - Middle East - Africa (AMEA), as well as Global Energy Management & Sales and Tractebel have seen their level of risk change in terms of human rights, due to the countries concerned by some of their activities or the sector of activity. The risks identified are the subject of specific responses at the operational level.

For example, in 2020, due to the Covid-19 pandemic, ENGIE faced a large increase in the migrant worker population in Singapore. The Philippines, Myanmar and Indonesia are the other countries most exposed in terms of human rights. The main risks in these countries are related to subcontracting and activities requiring a large and low-skilled workforce (including migrants). Due to the outbreak of Covid-19 among the migrant worker population, for example, local authorities have not allowed them to leave their dormitories except to work. With the approval of local authorities, our local entity has been housing migrant workers in private residential premises (condominiums). The aim is to improve their living conditions and to guarantee the principle of free movement. 

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 to assess the 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 with the European Works Council and the Ethics, Environment and Sustainable Development Committee.

Progress

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In 2021, 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 risk factors specific to the planned activity.
In this way, partners, suppliers and subcontractors of business development projects are subject to prior investigation. For example, this allows to identify for hydrogen production installation projects, the risks related to water or land needs. Risks are assessed according to the country, the activity, the presence of vulnerable populations, the products/services used, or the type of commercial relations. Depending on the identified risks, partners and suppliers are also subject to ethical due diligence that explicitly includes human rights.

All files presented to the investment committee are subject to a level 1 and 2 analysis. Each level of analysis addresses the risks related to the human rights practices of business partners, subcontractors and suppliers involved in the project. The results of this analysis are included in an ethics note highlighting the main risks identified and the associated mitigation measures to be implemented.
  
In addition, specific human rights impact assessments can also be carried out in specific situations. For example, for projects that have impacts on local communities, we can request the service of a third party outside the Group who carries out not only the consultation of local stakeholders, even when the consultation has been carried out upstream by the public authorities in the context of a call for tenders, but also the impact assessment of the project with regard to human rights with, if necessary, an action plan to be deployed by our teams locally (for example a sea water desalination project with a fully renewable energy solution in the Dakhla region). In addition, if the assessments reveal a risk of too significant impact of a project on local communities or other, we do not hesitate to renounce or stop the project (ENGIE, for example, has ceased all contractual relations with a mining company for human rights reasons).

Human rights policy

The Group human rights policy, the first version of which was drawn up in 2014 under the name “Human Rights Referential”, 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 now the foundation of the Group's vigilance plan for human rights.
 

The Group's human rights commitments

  • 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 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.
  • 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 surrounding its sites, and that assignments related to the security of its employees and assets are conducted with respect for human rights.

 

To ensure compliance with all of its human rights commitments and to meet French and international requirements, the Group relies on different cross-functional policies and policies specific to certain issues, particularly the human rights policy. The health and safety, CSR, and purchasing policies complement the human rights policy, covering specific commitments that fall within their particular scope.
 
Today, the Group vigilance plan, adopted in 2018 as required by the French law on the duty of vigilance of parent companies and ordering companies, aims to identify and avoid serious harm to people and the environment.

 

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.

 

Methodologie for risk identification

 

The human rights policy calls for vigilance processes at the Group level and at the operational level to ensure that human rights risks are managed as part of all activities, in particular:

  • Annual risk analysis: the risk of human rights violations is seen as a major risk for ENGIE. As a result, all operational entities must ensure that the Group's commitments are being respected: human rights violation risks (related to forced labor, human trafficking, child labor, freedom of association, right to collective bargaining, equal remuneration, discrimination, security forces, harassment & violence in the workplace, working conditions, housing conditions of workers, etc.) must be evaluated annually, and corrective action plans must be established for any identified risks.
  • Risk assessment for any new activities: any new project, any new business relationship that arises from the development of a new activity or from starting business in a new country, must be subject to a preliminary human rights risk analysis.
  • Due diligence on partners and suppliers: human rights risks that are part of business relationships are fully covered by ethical due diligence.
  • Creation of grievance mechanisms at the operational and/or Group level, so that anyone who believes they have been impacted by the Group's activities can freely submit their questions, comments, or requests.
  • The Group’s internal ethics incident managerial reporting system (My Ethics Incident) as well as the Group’s whistleblowing system (also open to all external stakeholders) explicitly include incidents relating to human rights.

Progress on the operational implementation of the human rights approach

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Actions to mitigate risks and prevent serious harm

Prevent the risks of forced labor practices in the Group's supply chains located in China.

  • ENGIE does not source from Chinese manufacturers who do not provide proof that they do not use forced labor. Therefore, ENGIE implemented, end of 2020, early 2021, a specific in-depth vigilance action plan to identify and manage the risks of forced labor practices in the Group's supply chains located in China. ENGIE is committed to ensuring respect for international rights and actively ensuring that there is no use of forced labor throughout its supply chain.
    The main measures put in place include in-depth due diligence on suppliers, documentary evidence requested from suppliers as to their supply chain, written commitments from suppliers not to use forced labor, sending questionnaires by which suppliers must justify that they prohibit forced labor, if necessary the possibility of carrying out thorough investigations and breaches of contract in the event of violation of their obligations. These measures are also part of the Group's vigilance plan.
    ENGIE is also involved in working groups created by organizations in the solar sector and dedicated to these issues, such as Solar Power Europe, with whom we work together with other actors of this sector on the development of a responsible, transparent and sustainable supply chain.
     

  • The NORTHAM region, for example, has strengthened due diligence on its solar supply chain and is working with other large renewable energy companies established in North America to improve supply chain traceability and exchange on good practices in terms of managing the risk of forced labor. ENGIE NORTHAM has signed the Solar Energy Industries Association’s (SEIA) pledge against forced labor.

 

Prevent the risks associated with modern slavery 

  • ENGIE's human rights commitments are based on the best international standards as well as on national laws relevant to its activities, such as the French law on duty of vigilance and the British law on modern slavery. ENGIE shares the objectives of the UK Modern Slavery Act and takes several measures to ensure that in its operations and those of its supply chain, there are no modern slavery practices (including in particular: slavery, forced labor and human trafficking). Go to the ENGIE Statement on Modern Slavery Act at the bottom of the page.

 

  • The UK's Modern Slavery Act imposes criminal penalties on companies and individuals in the UK who are found guilty of modern slavery offences. In 2018, the UK entities set up a modern slavery working group (consisting of staff from the HR, Legal, Procurement and CSR departments) to coordinate the activities in this area. The working group produced an action plan on modern slavery in early 2019, and this plan was developed in 2020. The plan outlines measures to be implemented to mitigate the risks associated with modern slavery. Here are some of the measures implemented in 2020;
    • A revised and improved statement on modern slavery has been published, as required by the Modern Slavery Act 2015 ;
    • Due diligence investigations were conducted on the top 50 suppliers to the UK entities (by annual expenditure) ;
    • The modern slavery training module for frontline staff has been revised so that staff are better equipped to spot the signs of modern slavery ;
    • The regeneration business has taken steps to become a signatory to the Gangmasters and Labour Abuse Agencies construction protocol, which focuses on the prevention of modern slavery. The GLAA is a public body under the control of the UK Home Office.

    Group employees are constantly reminded of the need to remain vigilant to the risk of modern slavery in an article entitled 'Modern slavery - don't ignore your suspicions', which was published in the UK ethics bulletin in July 2020. It was also produced a short film which was made available to staff (it was distributed by email and is available on the company app and on the UK Ethics intranet page).

 

Prevent the risk of disproportionate use of force 

  • In certain situations, the intervention of government security forces or private security companies may be necessary to protect the employees and facilities of Group entities. In order to prevent the risk of disproportionate use of force, the Group's requirements include the compulsory training of employees and security personnel.
     
  • In Brazil, for example, the use of a private security company to guarantee the security of a site, located in a region exposed to recurring security problems but isolated from the public forces was accompanied by a dedicated action plan: documentation requirements for security guards and in the contract, specific clauses, trainings against excessive use of force or violence and other contractual requirements to mitigate the use of force and its consequences.


 
Update on ENGIE's activity in Myanmar:

During the first half of 2021, Engie was questioned by international trade unions on the Group's activity in Myanmar in view of the takeover by the army and in view of alleged human rights violations. In response, ENGIE answered that our activities in Myanmar were limited to providing access to energy for electrification purposes in non-electrified areas. In September 2021, ENGIE sold its entire stake in Myanmar and sold all its shares in the local Joint Venture company.

 

Awareness tools and other risk mitigation actions
 

Tools have been deployed to raise employee awareness on human rights issues :

  • In 2019, a face-to-face training course on the Group's human rights approach was developed for the entire Group and as of today is fully rolled. It is mandatory in certain entities ;
  • A new e-learning module on human rights for all employees has also been rolled out since 2019 ;
  • At the end of 2021, 634 employees were trained in human rights (face-to-face), including 64% in operational functions, half of them from high-risk entities, and 21,178 employees trained in e-learning.
  • Regarding the prevention and fight against harassment, against all forms of discrimination not only within the Group but also for the benefit of the personnel of the subcontractors, the following actions have been launched in 2020 ;
    • A guide against all forms of discrimination against LGBTQ+ people was implemented in 2021. The primary objective is to provide recommendations, in particular to entities that do not have such a policy, in order to encourage them to adopt one. It reaffirms the principle of zero tolerance towards any discrimination by ENGIE.
    • Similarly, a guide on the fight against sexual harassment and sexist behavior was prepared in 2021 and rolled out in 2022.

 

In the entities

More and more entities are appointing "sexual harassment and gender-based violence" representatives.
At BtoC FRANCE, the CEO and the Ethics & Compliance officer provided a reminder of the fundamentals of the policy on moral harassment / discrimination. In addition, during a webinar with a large audience, human rights issues were addressed by the CEO.
GBS has also rolled out a 'Preventing sexual harassment and sexism in the workplace' training course for all levels of management.
In 2021, the NORTHAM Region continued its Diversity and Inclusion (“D&I”) journey which began in 2020 following the death of George Floyd and the movement of Black Lives Matter which highlighted the persistence of racial inequalities in the U.S. The highlights in this area for 2021 are the following:

  • A regional D&I Committee was launched including a diverse team of employees from throughout the Region. The committee meets regularly to oversee actions conducted, to discuss objectives, challenges, opportunities and support needed, as well as celebrate progress. 
     
  • The NORTHAM Region was assessed by the Human Rights Campaign Foundation and revised a Corporate Equality Index Score of 90/100. The assessment covers four central pillars: 1) non-discrimination policies; 2) equitable benefits for LGBTQ workers and their families; 3) supporting an inclusive culture; 4) corporate social responsibility.
     
  • With regard to hiring, the NORTHAM Region has also taken D&I actions such as the commitment to providing a diverse candidate slate for job openings facilitated by Human Resources. In addition, the Region is expanding university graduate recruitment efforts at Historically Black Colleges and Universities and other minority-serving institutions, as well as providing sponsor paid internship programs for individuals from economically disadvantaged communities.

 

Awareness actions

Employee awareness campaigns are widely relayed at operational level.
For example, France renewables again stepped up in 2021 the ethics training and awareness-raising initiatives it has been running for several years for all employees.
Some entities have also, for example, made training on the Group's human rights approach mandatory for all employees or are also implementing a training program covering the entire vigilance plan.
At AMEA region level, the risk relating to human rights is challenging as it relates to the regional legal context where local regulations provide some restrictions on workers’ rights (recognized by international organizations). The region promotes and implement alternative measures to enable employees to meet and discuss work related issues freely and independently such the Harassment Prevention Policy and the training sessions for new joiners including vigilance plan awareness. The region also implement a training program focusing on Vigilance plan for 2021 and requests all employees to attend the human rights modules. The duty of vigilance has been inserted into the training sessions with a focus on the Group Human Rights Questionnaire to be filled in by the Business Developers. .
Also for instance, in Belgium, awareness of human rights issues among the executive committee and management teams has increased considerably thanks to the local ethics training courses for these people.

 

Ethical due diligence on business partners and customers

Ethical due diligence on business partners and customers is carried out before any business relationship with partners in most entities as part of investment projects. In 2021, for example, within the framework of the Group's investment committees, all (100%) of files related to partners were subject to due diligence with human rights risk. 

For instance, when due diligence is carried out on a business partner in application of the Group's policy by the ethics team or by a professional external service provider, the analysis includes a verification of the partner's reputation in terms of human rights (respect for labour law, controversies with local communities in other projects, allegations by local NGOs, etc.).


 
Inclusion of the Group's ethics clause in contracts

The inclusion in the contractual documentation of the ENGIE Group's standard ethics clause containing, in particular, the requirements related to the duty of vigilance and human rights is also a requirement that is widely implemented in the entities (approximately 82% of the Group's entities) . 

Monitoring the human rights approach

The monitoring of the human rights policy and of the deployment of the required processes are integrated into existing ethical compliance processes: the annual ethics compliance report (« My Ethics Report » process) and the internal control system (« INCOME COR4 » process).

Progress

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To ensure the proper application of the Human rights policy, its monitoring has been integrated into the Group's ethical compliance processes:

  • Quantitative and qualitative indicators on the implementation of the required operational processes are included in the Group's ethical compliance procedure. Each entity reports annually on the progress made in applying the policy (with a letter of compliance from the entity's director certifying its responsibility and commitment to its application).
  • Control reviews related to operational risk analyses have been integrated into the ethics section of the Group's internal control system.

These monitoring processes allow ENGIE SA to ensure the effective application of the human rights vigilance plan and to define, if necessary, additional control actions such as internal or external audits.
In 2021, 88,3% of the entities that evaluated the deployment of the human rights policy considered that the deployment is effective (level 4 maximum). In the same year, the monitoring of the quality of the self-assessments (INCOME COR 4) carried out by the entities was reinforced. In particular, it was decided to set up an individual action plan for all entities with weak results.
The Ethics, Compliance & Privacy Department (DECP) relies on a network of Ethics and Compliance officers (232 worldwide by the end of 2021) responsible for promoting the human rights policy to employees of the entities and ensuring that the Group's commitments are properly implemented locally.
In 2021 again, we note a strengthening of the entities' operational responses linked to the deployment of the human rights policy.