Ethics, risk, and compliance.
ENGIE Global and ENGIE North America have a zero-tolerance policy for ethics violations, and compliance is always a paramount priority throughout our company. Business ethics are an essential part of our strategy, management style, and individual professional practices. In fact, we believe that ethics help drive business performance.
To achieve our objectives in the realm of business ethics, ENGIE Global and ENGIE North America have implemented ethics policies and ethics procedures based on the highest international standards.
Our values and principles
ENGIE Global has adopted an Ethics Charter that underpins the day-to-day strategic decisions, management, and professional practices of our employees. The charter is based on four specific ethics principles:
- Act in accordance with laws and regulations.
ENGIE Global employees must, in all circumstances, observe international, federal, national, and local laws, as well as the professional codes of practice applicable to their activities.
- Behave honestly and promote a culture of integrity.
Honesty and integrity must govern business and interpersonal relationships, and everyday professional practices. Employees must avoid any conflict between personal interests and the interests of ENGIE Global. Further, an absolute belief in the obligation to respect certain values underpins our approach to management companywide, creating a climate of trust and acting as a shield against corrupt practices. ENGIE encourages business ethics whistleblowing, and no employee may be sanctioned for reporting an ethics incident — selflessly, in good faith and without malice, and in accordance with the conditions set out by the applicable portions of ENGIE’s whistleblowing policy.
- Be loyal.
Employees fulfill their obligations and engagements scrupulously. Whenever they communicate, within the company or externally, they do so in good faith and in a constructive spirit, with a concern for providing genuine, accurate, and complete information.
- Respect others.
This ethics principle particularly applies to the respect for the rights of individuals, for their dignity and their differences, as well as a respect for different cultures. It also applies to tangible and intangible goods that belong to others.
ENGIE Global’s Ethics Charter and the associated ethical principles apply to all employees of ENGIE Global and ENGIE North America, in every circumstance in their daily business activities as well as in their relationships with customers, stakeholders, and the communities in which ENGIE operates.
The Ethics Charter is accompanied by ENGIE Global’s Practical Guide to Ethics, which details and illustrates the terms for applying the company’s business ethics goals.
Our policies and procedures for business ethics compliance
To ensure and measure compliance with the principles laid out in ENGIE Global’s Ethics Charter and Practical Guide to Ethics, and in accordance with the requirements of several legislative and regulatory regimes, ENGIE Global provides the following tools and procedures:
Integrity Referential
As part of the Integrity Referential, ENGIE Global adopted ethical due diligence policies, which involve investigating our third-party business partners (our suppliers and subcontractors, commercial consultants, investment partners, beneficiaries of sponsorship, etc.) to ensure that they do not represent any major risks for ENGIE and that they are not in violation with any rules governing human rights, health and safety, and/or the environment.
ENGIE Global also implemented a gifts-and-hospitality policy, as well as a conflict-of-interests policy, both of which aim to prevent any type of corruption or influence peddling and to ensure transparency through prior authorization and registration.
These policies are also part of the ENGIE anti-corruption program, which complies with the U.K. Bribery Act, U.S. Foreign Corrupt Practices Act, and French Sapin II law.
Vigilance Plan and human rights commitments
In accordance with the French Duty of Vigilance Law, ENGIE Global developed a Vigilance Plan that aims to identify and prevent the risks of negative impacts on people and the environment related to ENGIE Global’s activities around human rights, health and safety, and purchasing.
As part of the implementation of the Vigilance Plan and other international requirements, ENGIE Global has committed to respecting internationally recognized human rights in all our activities and wherever the business operates. To ensure the respect of our human rights commitments, we conduct an annual risk analysis, which enables us to efficiently develop corrective-action plans. In addition, each new activity and project is subject to a preliminary human risk analysis. The Health and Safety policy, CSR (corporate social responsibility) policy, and Purchasing policies cover the risks that fall within their particular scope.
For example, ENGIE North America signed the Solar Energy Industries Association’s (SEIA’s) Forced Labor Prevention Pledge, joining more than 150 organizations in opposing forced labor within the solar industry supply chain.
For more information, please refer to ENGIE Global’s Vigilance Plan.
Compliance Referential
The Compliance Referential provides a framework for implementing the principle of “acting in accordance with laws and regulations”. It gathers the ENGIE Global procedures and tools to ensure the effective implementation of ethics policies. This notably includes:
- The annual ethics compliance procedure, which ensures that all legal and regulatory requirements, as well as all voluntary commitments taken by ENGIE Global, ENGIE North America, and other ENGIE entities regarding ethics and compliance are respected. All ethics and compliance officers must produce an annual report of progress of their entity and a compliance letter from the entity director certifying its responsibility and commitment to applying the ethics program throughout the organization under his/her responsibility.
- The managerial reporting system for ethics incidents which includes an obligation for entities, businesses, and functional lines of ENGIE Global and ENGIE North America to report into the tool named “My Ethics Incidents”, any suspected ethics incidents as soon as they come to their knowledge. The “My Ethics Incidents” tool allows the tracking of the treatment of each incident until it is closed. Thorough knowledge of ethical incidents and their treatment helps to prevent ethics risks and implement corrective measures.
Codes of Conduct
In addition, ENGIE Global has developed codes of conduct, in order to apply the commitments outlined in our Ethics Charter to each of our activities and professional practices:
Risk management
ENGIE Global defines risk broadly as a deviation from expected outcomes. To manage risk, we have established an internal control environment, as well as specific leadership committees that monitor key aspects of the company’s risk exposures.
Our senior management team engage annually in a robust enterprise risk management (ERM) assessment, which includes evaluations of a broad array of risks. One of those is the risk of engaging, directly or indirectly, in human rights violations. Another is the risk of ethical breaches, which includes identifying controls to avoid and detect business ethics risks, as well as corrective action plans for any identified areas of exposure that are not optimally controlled.
The ENGIE Global risk committees meet regularly to address specific areas of risk:
- Commodity Risk Committee: This committee documents commodity risk limits to which each ENGIE business is held accountable and monitors commodity positions for compliance with those limits. The Commodity Risk Committee discusses hedging strategies and results of previous hedging activity to inform ongoing portfolio management. This committee reports to ENGIE North America’s leadership committee and includes representatives from ENGIE Global’s commodity risk control team, enabling sharing of best practices from across the global organization.
- Credit Committee: This committee establishes credit limits and monitors receivables exposures to the company’s customer base. Similar to the Commodity Risk Committee, the Credit Committee has a scope covering all of ENGIE North America’s businesses and includes representatives of ENGIE Global.
- Project Implementation Steering Committee: This committee monitors the progress of construction projects against health and safety targets, budgeted construction costs, and delivery deadlines. It also catalogs specific construction-related risks unique to each project. The company maintains separate Project Implementation Steering Committees for our renewables and services businesses.
Whistleblowing
ENGIE Global and ENGIE North America have established confidential and anonymous whistleblower systems for the receipt, retention, and treatment of complaints.
Whistleblowing reports can be made by ENGIE employees or any external stakeholders, including suppliers, subcontractors and their respective employees, members of the community, etc.
Reports can address concerns around any issue related to corruption, human rights violations, fraud, breach of personal data privacy rules, violations of international sanctions and embargoes, health and safety risks, environmental damage, or — more broadly — violations of applicable law or regulations regarding conduct subject to criminal punishment, as well as any violations of ENGIE’s Ethics Charter or Practical Guide to Ethics.
Please note that our systems protect whistleblower confidentiality. Reports are managed by a third-party provider that ensures anonymization (if requested). Messages are then routed to members of the ENGIE North America management team, or to ENGIE Global’s Ethics and Compliance Department for review, investigation, and response.
To report an incident, please use one of the following methods:
- Click here to access an internet-based message Interface that will deliver a message to the ENGIE North America Whistleblowing System.
- Email Ethics@engie.com to send a message to the ENGIE Whistleblowing System.
- Call our toll-free hotline at 1-866-553-4733 to leave a voice message on the ENGIE North America Whistleblowing System. All voicemail messages will be electronically altered or disguised to keep the caller’s identity confidential.
- Or call a fixed line to France: (011) 331 45 51 03 67 to contact the ENGIE Global Whistleblowing System.
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