| ETHICS EMAIL PROGRAM |
Structure
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The impetus behind GDF SUEZ’s ethical commitment comes from the highest level of the Group: the Chairman and Chief Executive Officer, the Board of Directors and the Executive Committee, which have chosen to equip the Group with a structured organization.
The Ethics and Compliance Division
Within the General Secretariat, the role of the Ethics and Compliance Division is to incorporate ethics into the Group’s vision, strategy, management and practices.
- It drafts the core documents, drives their implementation by the operational business lines and functional divisions, and organizes internal reporting.
- It assists the operational business lines and functional divisions, from a risk analysis perspective, in their responses to the concrete ethical dilemmas they encounter.
- It sets up dedicated ethics training courses for management.
The Ethics & Compliance Division heads a network of more than 140 ethics officers who carry out its motivational, implementational and advisory role in the field of ethics within the business lines and divisions.
The Ethics and Compliance Division has also set a proactive Compliance policy under which compliance checks and ethical audits are carried out. The purpose of this policy is to ensure that the compliance systems needed to manage ethical risk are in place and functioning.
The Committees and management structures
Ethical policies are decided by the Executive Committee, and managed by the General Secretary, who is also the Group Ethics Officer.
Ethics and Compliance policy is overseen by the Ethics, Environment and Sustainable Development Committee, a subcommittee of the Board of Directors.
The Compliance Committee, chaired by the Group Ethics Officer, with the heads of the Audit, Legal and Ethics and Compliance Divisions, to monitor Group compliance. This committee is responsible for developing and overseeing the implementation of compliance policy. It can require the Ethics and Compliance Division to take the necessary measures in the event of compliance failures.
