AFD - 2018 Registration document

STATEMENT OF NON-FINANCIAL PERFORMANCE

Fair practices

2.7.3 Checks carried out as part of the foreign public procurement process Foreign public procurement for contracts financed by AFD Group undergo specific checks ensuring that the various stages of the procurement process unfold under the required conditions of integrity, transparency, fairness and efficiency. These checks are published through the issuance of a notice of no objection (NNO) and are carried out ex ante at specific stages of the public procurement process. Over and above these checks, AFD Group imposes exclusion (1) criteria on the Project Owner, in addition to those covered by local legislation, in connection with processing and awarding contracts that AFD is likely to finance. 2.7.4 Counterparty commitments AFD Group’s financing agreements include a certain number of provisions that impose commitments on counterparties in terms of combating corruption, fraud, cartels, money laundering and terrorist financing. These provisions make it possible for AFD Group to suspend payments, cancel the portion of its financing in relation to which improper or non-compliant practices have been detected and demand early repayment of all or part of a loan or repayment of all or part of a subsidy paid. 2.7.5 Information reporting systems There are several information reporting systems within AFD Group. Firstly, Group employees have an operating incident declaration system which collects and centralises all shortcomings identified by employees (including AML/CFT/ corruption and fraud issues). Group employees must also report, through a reporting mechanism following management reporting lines, any suspicion of irregular practices within and outside projects. The handling of these suspicions is managed by the Compliance Department in order to secure an exhaustive overview of instances encountered, and to make sure that there is a consistent response or action plan. AFD Group’s employees also have the right to consult the Director of this department and his/her deputy directly if they believe they have identified a situation where there is a compliance risk.

Alongside these pre-existing channels, AFD Group has set up a whistle-blowing system in accordance with the requirements of the “Sapin II” Act of 9 December 2016. This system came into force on 31 January 2019 and constitutes an ancillary, voluntary and optional warning system when an employee believes that current alert channels have not operated properly, or that there is a serious obstacle preventing their use. 2.7.6 Training of Group employees In accordance with applicable French regulations, AFD Group ensures that all of its employees, including those of its office network, receive regular training and notifications on the risks and procedures to implement in terms of the fight against money laundering, terrorist financing, fraud and corruption. These training courses are provided both in e-learning mode and in classroom mode. P e-learning sessions on AML/CTF: new employees who joined the Group in 2018 (head office and network), i.e. 445 people, were required to follow one or two e-learning modules. The number of modules allocated to each employee depends on the risks identified for the activities performed by said employee. The annual results are as follows: 72% of employees enrolled for module M1 (445 people) and 65% of employees enrolled for module M2 (338 people) validated their training. Those having fully completed their training all validated said training, i.e. 323 employees enrolled for M1 and 216 employees enrolled for M2. For the rest, i.e. those who have not begun or finalised their modules, namely 122 employees enrolled for M1 and 116 employees for M2, a campaign to remind them of the requirement to validate this training is under way in the first quarter of 2019; P face-to-face training provided on the subjects of fraud, corruption, AML/CTF: they supplement the e-learning programme and aim to offer employees access to all the regulatory and legislative knowledge required to perform their activities within AFD Group. 510 employees were trained in 2018 (new hires, catch-up training for certain employees at the head office and in the agency). These training modules are adapted to the learners’ profile, as they take into consideration the assignments of employees as part of the introductory programme for new employees, and with respect to transferred AFD Group employees (training relative to transfers to local offices or to users of the payment tool coming from local offices, for example). The Compliance Department developed two offers: one intended for operational employees, and the other for support employees. Moreover, at a manager’s request, this department will provide AML/CTF training specific to his/her teams.

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(1) See Directives on procurement financed by AFD in foreign countries – April 2015: https://www.afd.fr/sites/afd/files/2017-07/Directives- Passation-Marches-Etats-Etrangers.pdf

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REGISTRATION DOCUMENT 2018