AFD // 2021 Universal Registration Document

STATEMENT OF NON-FINANCIAL PERFORMANCE Fair practices

2.7.5 Information escalation systems There are several reporting mechanisms within the AFD group to report reprehensible practices. 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 or outside projects. The processing of these reports is managed by the “Investigations” function of the Compliance Department in order to have an exhaustive overview of the cases encountered, and to ensure a consistent response. The 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. Since January ɸ 2019, the AFD Group has provided its employees with a whistleblowing system, in accordance with the requirements of the so-called “Sapin ɸ II” law of 9 ɸ December 2016. This system 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. Lastly, since September ɸ 2021, a reporting system has been open to the Group’s stakeholders on the AFD institutional website (2) . 2.7.6 Training of Group employees In accordance with applicable French regulations, the 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. Due to the health crisis, this training was again delivered both in e-learning format and through a webinar. (i) AML/CFT training provided in e-learning format: all Group employees and representatives (head office and network, whether newcomers or existing employees) were asked to take one or two e-learning training modules. The number of modules assigned to each employee takes into account the risks identified with regard to the activities carried out by the employee. In 2021, 83% of the Group’s employees subject to the obligation to follow module ɸ 1 validated their training (2,478 ɸ employees out of 2,979 ɸ employees subject to completing this module, a group comprising employees on permanent and fixed-term contracts, as well as international volunteers and civil servants seconded to AFD) and 62% of Group employees subject to the obligation to follow module ɸ 2 validated their training (1,145 employees out of 1,838). Among this staff, 83% of AFD employees validated module ɸ 1

2.7.3 Checks carried out as part of the foreign public procurement process Public procurement for contracts financed in foreign States by the 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. In some cases, and after AFD’s approval, an ex-post control may also be exercised for some procurement processes. In addition to these controls, AFD imposes exclusion criteria for project management, in addition to those existing in local legislation. Thus, a contract cannot be financed by AFD if the successful tenderer is in one of the cases of exclusion or ineligibility specified in the Directives for the award of contracts financed by AFD in foreign States (1) . Already in preparation before the health crisis, a comprehensive e-learning training course on the award of contracts, primarily for project managers, was launched in June ɸ 2020. In response to the Covid-19 crisis, this tool made it possible to offer an alternative while the crisis prevented the training missions planned for project managers. Internally, training was also adapted so it could be delivered remotely. In 2021, this digitisation also made it easier for employees in local offices to participate, thus transforming the initial constraint into an opportunity for other sectors (see below, section on “Skills development, employability, training”). 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 clauses require counterparties to inform AFD of any allegations of prohibited practices or proven reprehensible practices, and to take remedial measures to comply with the Group’s expectations. In the absence of remediation, the Group reserves the right to trigger an event of breach. The Group can 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 grant paid. The Group may also decide to take the matter to the French courts or to the local courts where the project is being carried out.

2

(1) See Guidelines for the award of contracts financed by AFD in foreign States – October ࣢ 2019: https://www.afd.fr/fr/ressources/directives-pour-la passation-des-marches-finances-par-l-afd-dans-les-etats-etrangers (2) https://www.afd.fr/en/form/signaler-un-abus

63

2021 UNIVERSAL REGISTRATION DOCUMENT

Made with FlippingBook - Online catalogs