Translations

GDF SUEZ is developing the resources to meet the highest ethical standards

1. Organizational Governance

Strategy and organization

Sector Energy / Water

Year 2012

Country France

Transmitter

Context

GDF SUEZ, which employs over 217,550 staff on five continents (70 countries), understands the need for inviolable ethics rules. The Group has established an ethics organization and developed references that will be distributed to all employees: the Ethics Charter and “Ethical Practices” guide are being translated into approximately twenty languages, with the aim of shaping governance and providing strong oversight mechanisms in compliance management.

Objectives

- Provide a consistent ethics compliance mechanism to meet increasingly strict and complex national and international regulations.
- Ensure that every employee and business unit of the Group throughout the world knows and follows the ethics rules that govern its activity.
- Strengthen the Group against risks that could adversely impact its performance or integrity.

APPROACH

Well established principles
The Group has developed a set of documents explaining the rules and frameworks to which all routine practices of the Group must adhere: an ethics policy, Charter, an ethical practices guide, supplier relationships guide, integrity benchmarking adopted in 2010 along with an associated action plan, compliance management benchmark, guide to commercial relationships (being updated), policy for selecting business consultants, environmental charter, guidelines for handling sensitive information and protecting confidentiality, codes of conduct, Convention on fundamental rights.
The Ethics and Compliance Department, which comes under the General Secretary’s Office, is spearheading the ethics rules development process for GDF SUEZ and overseeing the incorporation of these rules into Group strategy, management and practices. Each business line and business unit has its own Ethics Officer. The Group has a total of 170 ethics officers and ethics correspondents within the operational teams.
The Compliance Committee, led by the ethics officer, includes the heads of the Audit, Legal, and Ethics and Compliance departments, featuring a Secretary General and Deputy Secretary General. It ensures that the Group follows its own ethics rules throughout the world and that it is capable of detecting any deviation from them.

Developing an ethics-based culture company-wide
Reference documents are published on the Group's Intranet and widely disseminated to employees throughout the world. Several online training modules offered in five languages raise managers' awareness of ethics issues and provide them with the keys to promoting ethical behavior in their business dealings.
Ethics awareness is a mandatory module for all Group senior executives, focusing on corruption risk prevention and building greater respect for the rules of competition; it was introduced at the end of 2011 and now completes the current executive training program: an "Ethics in Business" course hosted by the Ethics and Compliance Unit, along with a "Responsible Performance" course offered by GDF SUEZ University to all new managers.
Feedback on ethics compliance incidents is provided through a reporting tool being rolled out Group-wide. An Annual Compliance Procedure is overseen by the Group's Secretary General, as the Group's Ethics Counselor. Business lines and business units submit a Compliance letter from their director each year along with a report indicating the state of progress on ethics policy implementation. The Group’s annual compliance report is based of a compilation of these letters and reports for presentation to the Board of Directors' Ethics Committee.

A best practice showcased by World Forum Lille in 2010 and updated in 2012 to reflect changes.