Fight against Corruption
The fight against corruption is achieved at three levels:
- The internal level
- The external level
- The collective level
The first two levels concern each company individually and the final level concerns all companies collectively.
Internally the anti-corruption program is based on four pillars:
Evaluate:
- Develop risk profiles based on criteria related to "geography", governments, projects (size, type and nature of counterparties), intermediaries involved, and finally distributors and suppliers of the company.
Prevent:
- Formalize the anti-corruption strategy
- Define the anti-corruption procedures and refine specific procedures for high-risk issues (accounting, gifts, exposed personnel...)
- Write or update the Code of Ethics (Business Conduct guidelines)
- Implement an internal and external communication program
- Educate and train the staff
Detect:
- Implementation of a « risk management system »
- Definitions of thresholds and control programs
- Ensure the coordination with the scope and the actions of internal control,
- Implement the alerting ability (Whistle blowing)
- Adapt the control programs of Internal Audit
Treat:
- Define the regulations of the company when it finds breaches (sanctions)
- Develop a revealed business process workflow
- Ensure that bad experiences are well assimilated and correction procedures properly applied.
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Externally the anti-corruption program is based on four pillars:
- Internal Report / Reference Document / Sustainability Report
- Highlighting good practices during external interventions (conferences, shows ...)
- Space dedicated on the website of the company;
- Press releases and meetings with journalists.