Group integrity referential
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 programme, which incorporates best international standards (UK Bribery Act, US Foreign Corrupt Practices Act (FCPA), French Sapin 2 law).
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 consultants policy whose key elements include: an ethical risk analysis (“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.
Gifts 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 in business relations.
Policy on analysis of the ethical risk related to investment projects
The Group has adopted a policy to ensure that all parties involved in its investment projects and major contracts are subject to an ethics due diligence procedure. This policy requires to perform ethics due diligence by specialized providers. These due diligence may range from consultation of open sources to field surveys, based on a risk-based approach and on alerts identified. The Group has its own capacity to carry out these due diligences and to better control the possible use of outsourcing in this area.
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.
Patronage and partnerships policy
The patronage and partnerships policy provides a framework for the support offered 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 and by specifying the terms of ethics due diligence. It also sets up a process for validating projects by the Patronage and Partnership Committees at the Group and within each BU.
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 localised operational production in countries that are non-cooperative in fiscal terms.
Ethics, environment and social responsibility clause
ENGIE’s ethics, environment and social 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.
NB: GDF Suez Ethics & Compliance documents available on www.engie.com apply within the ENGIE group until they are replaced.