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GDF SUEZ Group Integrity Referential
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Presentation summary
Context
Integrity is one of the four fundamental principles guiding ethics within the GDF SUEZ Group. These ethical principles must underpin the behaviour of each and every one of us. However, the Group operates in an environment that is increasingly susceptible to the risk of fraud and corruption. The global crisis and competitive pressure in the energy, services and water markets are bringing new pressures to bear, which can be felt in all sectors of business and at every level of responsibility.
Objective
In a bid to address this major challenge and within the context of the Group's Ethics Policy, the
In line with the GDF SUEZ Group's Ethics Policy as adopted by Executive Committee on
Target
The Integrity Referential is aimed primarily at managers. They will make themselves familiar with it and will ensure that conditions for meeting it within their teams are met. On a broader scale, the Integrity Referential concerns every Group employee whose individual conduct contributes to the overall expression of integrity as promoted by
Part 1: fraud and corruption - The main threats to integrity
I- Behave with integrity
Integrity is an excellent tool for enhancing performance and a sense of pride in being part of a team and for promoting cohesion. However, it can also pose a significant risk if staff in any part of the Group fail to behave with integrity.
II- Fraud and corruption, a serious issue
Four areas are highlighted, providing a better understanding of the scope of fraud and corruption.
- The 5th Global Economic Crime Survey conducted by PricewaterhouseCoopers (PWC) is unequivocal: the economic crisis is driving up the risk of fraud.
- Corruption: a global phenomenon in a globalised economy
- Fraud and corruption represent what are often significant and varying risks for companies: strategic risks, risks to image and reputation, economic and financial risks, risks to internal cohesion.
- Case law highlights the penalties imposed for corruption and fraud.
III- Detect fraud and corruption: knowing the definition, type and characteristics of fraud and corruption is essential to be able to detect and prevent it.
IV- Rules and regulations presents the two international documents that provide a framework for combating corruption, their transposition into French law and amendments that move towards stronger legal constraints, increased criminal and civil liability of business leaders, and tougher sentencing for fraud in general.
- The 1997 OECD Convention on combating bribery of foreign public officials in international business transactions, ratified by France and transposed into French law
in 2000 . - The Council of Europe's Civil Law and Criminal Law Conventions on Corruption (1999) and the UN Convention
of 2003 . - The French law of November 13, 2007 on combating corruption provides for modifying the French penal mechanism in line with the various international instruments ratified by France.
- American legislation (FCPA, Dodd Frank Act) and UK legislation (Bribery Act)
Part 2: managing the risk of fraud and corruption within GDF SUEZ
No company can claim faultless integrity in its practices. It is a company's responsibility to put measures in place to prevent the systemic organisation of fraudulent practices.
The system proposed for GDF SUEZ has six risk management approaches.
I- Identify fields and situations in which fraud and corruption may occur
Respect for integrity will be encouraged by monitoring sensitive areas, especially local rules and regulations. We focus on the need to systematically check the framework for using intermediaries and the relevant guidelines put forth.
II- Use the Group's existing monitoring processes as a baseline via the INCOME program, the ERM approach and the audit program.
III- Consult the appropriate experts to refine our knowledge of the scope of fraud and corruption. The studies and tools provided by think tanks or initiatives to which the Group is a member are important documentary sources that can be supplemented by ad hoc studies.
IV- Deal with cases of fraud and corruption: dealing with cases requires familiarity with the contact people (managers, ethics officers, etc.), appropriate detection methods, analysis, resolution and reporting, as well as a fair understanding of the penalties to impose. Two fundamental principles must be observed in order to achieve zero-tolerance in stages: any instance of fraud uncovered must be dealt with and no proven instance of fraud must go unpenalised.
V- The appropriate awareness and training are implemented within the Group to enable everyone to have the required skills in line with their level of responsibility. Several modules are presented in the Integrity Referential.
VI- Evaluation benchmarks
Many external stakeholders judge companies on their ability to manage risks associated with fraud and corruption, including extra-financial ratings agencies, certification organisations and anti- corruption organisations.
To flag up procedures and good practices in this field, the Integrity Referential presents the evaluation criteria used by several organisations.
