Ethics e-mail system
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Do you have an ethical question? Need advice on compliance? It is not always easy to discuss ethical problems with colleagues or line managers. Although not a replacement for the other alternatives, the Ethics e-mail program can be used by any employee, as a final resort, to raise a problem that may affect their work or seriously compromise their position.
(Document dated From December 16, 2010)
Information on the Ethics Email System
This email system is reserved for persons employed by the GDF SUEZ Group, whatever their employment status. Its use is strictly voluntary and cannot be made mandatory.
This email system has been set up by the GDF SUEZ Group to enable its employees to give notice of problems that could seriously affect their work or their responsibilities. It is not a substitute for other existing reporting channels (with the hierarchy, personnel representatives, the auditors, a public authority, etc.) but supplements them. The specific electronic address directs factual information obtained towards specially trained persons. The latter will then, within a strictly confidential framework, arrange for verification of the facts obtained and enable the employer to decide, in full knowledge of the matter, on the steps to be taken to remedy a noted malfunction. The facts obtained will be verified in accordance with the local laws and regulations, especially as regards the protection of personal data.
The Group Ethics Officer, assisted by the Vice President, Group Business Ethics and Compliance, is responsible for the email system.
Any misuse of the system may be the subject of disciplinary measures while, conversely there is no risk of prosecution for any employee who uses it in good faith.
The identity of the person who reports an issue will be treated as confidential, subject to sanctions should confidentiality be breached.
The program will not allow anonymous inputs.
Processing of Information Collected by the Email system
Data obtained through the system may be processed by the person responsible for the system.
Only the following types of data are processed:
- identity, functions and contact details of the sender of the data;
- identity, functions and contact details of the person about whom the data is being submitted;
- identity, functions and contact details of persons involved in collecting information/data or processing it;
- facts reported;
- information/data collected in order to verify the facts reported;
- report on verification operations;
- follow-up on the report.
The person responsible for the system will ensure that the facts reported are accurate, demonstrable and fall directly within the scope of the system before proceeding to any further action.
The person responsible for the system will process data collected in this way as specified in the amended French Data Protection Law of January 6, 1978. He or she will take all necessary precautions to ensure that the data remains secure, both when collected and when communicated or filed.
Data collected through this system may be communicated to another Group company. This can be done only if the same confidentiality requirements are observed and if necessary to verify the report, or if communication is necessary due to the Group organization. It will depend specifically on “the nature and seriousness” of the facts reported. This might be the case, for example, if the facts reported affect an employee of another Group company, an employee at senior level or a member of the management of the company concerned. It will also apply if the facts reported are so serious that, if substantiated, they could have consequences for GDF SUEZ, other Group companies or even the Group as a whole (financial scandal, etc.).
The facts collected through the system may also be forwarded to employees of one or more Group companies as an organizational requirement. Indeed, GDF SUEZ has set up a dedicated groupwide network of ethics officers dedicated to Business Ethics issues, comprising individuals from different Group entities appointed for their respective areas of expertise. Details may therefore be forwarded to these officers as part of their duties, to ensure that data are handled under the appropriate legal procedures, in particular with all necessary measures being taken to ensure that the data is kept confidential and secure.
Scope of the Ethics Email System
The scope of the email system covers facts relating to serious risks to the company in the fields of accounting, finance, the fight against corruption and respect of competition rules.
Examples of such risks include:
- accounting and auditing anomalies,
- forgery,
- tax fraud,
- fictitious employment of personnel,
- corruption of public officers, etc.
According to the statement of the CNIL adopted October 14, 2010 amending the Single Authorization AU-004, it will only be possible for facts relating to serious risks for the enterprise in the fields of accounting, finance, the prevention of corruption and respect of competition rules, to be reported; these may possibly be the subject of computerized processing of the data gathered.
The organization in charge of the system will destroy or file the collected data without delay when it does not lead to disciplinary or legal proceedings.
In other cases (collected data outside the scope of the system), the person sending the email may simply be advised and directed to make contact with conventional routes (supervisor, information to Union Representatives, Human Resources Division or competent service). Data concerning such reports will be immediately destroyed or filed.
When disciplinary or legal proceedings are instituted against the person accused or against a person responsible for misuse of the system, information is kept by the organization in charge of the system until the end of the procedure.
Data that is retained is filed in a separate information system with restricted access, for a period not exceeding that of any dispute proceedings..
Observance of access and correction rights
In accordance with articles 39 and 40 of the French act of 6 January 1978, as amended, any person identified within the email system is entitled to have access to data and to seek their correction or deletion if they are incorrect, incomplete, ambiguous or outdated.
In certain objectively justified cases, a response to a request for access rights may be deferred for the period strictly necessary to safeguard evidence, to ensure that exercise of these rights does not jeopardise the efficiency of verification operations undertaken.
The party subject of the report is, in conformity with articles 6 and 32 of the Act of 6 January 1978, informed of the registration, electronically or otherwise, of data concerning him or her, in order to allow him or her to contest the handling of the data. Where protective measures are required, to prevent the destruction of evidence concerning the collected data in particular, this party will only be informed after any such measures have been taken.
A person referred to in the data submitted report may in no circumstances obtain information on the basis of his access rights regarding the identity of the person sending the warning from the person responsible for processing it.
(In the event of conflicting interpretations, only the French text will be considered as authentic).
Contact ethics e-mail : ethics@gdfsuez.com
