Ethics and Compliance

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ENGIE Code of Ethical Conduct 

The ENGIE Code of Ethical Conduct applies to all Group employees worldwide, as well as to any person seconded by a third-party company to a Group entity. It defines the ethical principles that all Group employees and entities must apply in their professional practices and behaviour.

A code of conduct for zero tolerance

Because ethics and compliance are an absolute priority at ENGIE and no deviation in this area can be tolerated, a code of ethical conduct has been drawn up for everyone, regardless of hierarchical level, function or location. 

It is based on 5 founding principles.

  1. Corruption and fraud are absolutely prohibited

  2. Human rights must be respected

  3. Protecting the environment is a commitment that binds us

  4. Laws and regulations apply to everyone

  5. Integrity and loyalty chair our relations with third parties

 

Consult the code of ethics on the ENGIE website

Policies and procedures

Guidelines have been put in place to unify policies and procedures for the practical implementation and development of an ethical culture within the Group:

Integrity repository

The Integrity Guidelines provide a framework for implementing the principle of "behaving with honesty and promoting a culture of integrity" and include the following policies, several of which are part of ENGIE's anti-corruption programme and incorporate the best international standards (UK Bribery Act, US Foreign Corrupt Practices Act (FCPA), French Sapin 2 law). 

 

Sales consultants policy

In order to prevent any ethical risks that may arise during the course of a project, from the contract negotiation phase to the contract execution phase, ENGIE has developed a commercial consultants policy, the main thrusts of which are ethical due diligence of all commercial consultants, analysis of the merits of their assignments, control of remuneration, and traceability of selection decisions and services provided.

Gifts, invitations and technical travel policy

The purpose of the Gifts, Invitations & Technical Travel policy is to prevent any situation of corruption, conflict of interest or influence peddling. It defines the general principles to be respected in terms of gifts, invitations and technical travel, in particular the principles of technical and study trips, relations with public officials and invitations linked to events. It provides a framework for the transparency of the practice by requiring information, prior authorisation and registration, all depending on the value of the gift or invitation.

Ethical, environmental and social clause

ENGIE's ethics, health and safety, social and environmental responsibility clause must be included in contracts with all Group suppliers, service providers, subcontractors and partners, regardless of the entity for which they work.

This clause includes a ban on all forms of corruption, compliance with competition rules and embargoes, and compliance with human rights standards and regulations.

It obliges the co-contractor to familiarise themselves with the Group's ethics and compliance documents, to comply with the ethical rules set out in these documents for the duration of the contract, to ensure that their sub-contractors comply with these rules where applicable, and to inform them of the contractual consequences if these rules are not complied with.

Due diligence policy

The Group has a number of ethical due diligence policies, which involve investigating our third parties, i.e. our suppliers and subcontractors, our business consultants, our partners in investment projects, the beneficiaries of sponsorship, etc.

This is done prior to any commercial relationship or partnership, in order to ensure that they do not present major ethical risks for ENGIE or that they do not infringe the rules relating to human rights, health and safety and/or the environment.

Policy to prevent conflicts of interest

The aim of the policy to prevent conflicts of interest is to avoid any doubt as to the impartiality of a Group employee's decision or as to his or her possible lack of loyalty in the context of a decision, and to propose appropriate solutions in the event of a conflict of interest, including the possibility for employees to abstain without having to disclose the nature of their conflict of interest, in order to preserve employees' right to privacy.

This policy informs and assists employees in the event of a potential conflict of interest situation: it gives them examples of such situations, and specifies the management and traceability process in this area.

Compliance framework

The Ethical Compliance Guidelines serve as a framework for implementing the principle of "acting in compliance with laws and regulations" and specify the way in which the Group is organised to support the implementation of all the Group's ethical systems and the measurement of compliance.

More information on the ENGIE website

Compliance and human rights

The vigilance plan 

As a member of the ENGIE group, the entities of ENGIE Belgium adopt the ENGIE vigilance plan, which was drawn up in application of the French law on the duty of vigilance of parent companies and contractors. It targets serious violations of human rights and fundamental freedoms, the health and safety of individuals and the environment.

More information about the Vigilance Plan on the ENGIE website.

The Human Rights framework

It provides a framework for implementing the principle of "respect for others" and brings together all of ENGIE's commitments in the field of human rights. 

More information on the Human Rights framework on the ENGIE website.

ENGIE alert system

As part of the Group's ongoing desire to strengthen its ethical commitments and to offer tools that are easily accessible to everyone, enabling them to report a situation that is inappropriate or does not comply with our principles or with applicable laws and regulations, ENGIE is making a whistleblowing system available to its employees and to all its stakeholders (suppliers, subcontractors, trade unions, communities, NGOs, etc.). It offers any person an easy, confidential and anonymous means of reporting a problem.

 It is possible to send an alert in 4 languages (French, English, Spanish or Portuguese) to an external service provider. Messages in other languages will be translated.

  • By post to the external service provider who receives the alerts at ENGIE level at the following email address: ethics@engie.com
  • By toll-free number: + 33 1 45 51 03 67
  • By a free group telephone line: 00 800 2348 2348

 More information on the ENGIE website.

It is also possible to make an anonymous report via the local alert system.