Aéroports de Paris - 2019 Universal registration document
SOCIAL, ENVIRONMENTAL AND SOCIETAL RESPONSIBILITY INFORMATION 15 OPERATING IN AN EXEMPLARY WAY
DEFINITION AND DIFFUSION OF POLICIES, RULES AND METHODS Included in the internal rules of procedure, Aéroports de Paris’ Code of Ethics was distributed, via the intranet and internet sites, in the form of a communication document entitled “Group Ethics and Compliance Code of Conduct”. It includes best practices, areas of vigilance and prohibitions as well as examples of tangible cases. In March 2019, it was distributed individually to Aéroports de Paris employees. The French subsidiaries have their own code of conduct. For the international scope, a code of conduct translated into seven languages was distributed within the subsidiaries. In 2020, a single, multilingual code will be rolled out. At group level, a reminder of the Gifts and Invitations and Conflicts of Interest procedures deployed in 2018 must be made by management at least once a year. They have also been rolled out for the international scope. They are supported by registers enabling annual reporting to the Ethics Division. The procedures are enhanced as required and diffused within the group in the relevant languages. Committed to basing its development on principles which reflect its ethical commitment, Groupe ADP formalised its ethics rules at the end of 2016 in a Responsible Lobbying Charter, available on its website. Since 2017, it is also registered in the list of interest representatives held by the High Authority for Transparency in Public Life ( Haute Autorité pour la transparence de la vie publique ) in accordance with the Sapin 2 law. As part of the approach steered by the group Ethics Division, Aéroports de Paris’ Purchasing Division has defined a methodology to assess risks of corruption in the area of purchasing both prior to the contract signing and during the contract execution, in accordance with the law. The level of exposure to corruption is assessed based on the analysis of five risk factors: sector of activity, type of transaction (procedure and contract signing), business opportunity (quality and level of commercial relations), country risk, status and reputation of contacts and stakeholders. Based on this analysis, a mapping of suppliers at risk in terms of ethics and corruption was prepared. 100% of suppliers already under contract with Aéroports de Paris were analysed in 2018. In 2019, the approach continued by focusing on new suppliers. From 2020, a tool will be rolled out across the group. WHISTLE-BLOWING MECHANISM Accessible since 1 October 2018 to group and supplier employees, the whistle-blowing platform (https://report.whistleb.com/fr/adp) meets the requirements of the Potier law (duty of vigilance) and Sapin 2 law (fight against corruption). Integrated into the platform, a charter manages the admissibility criteria for alerts and defines the protection for whistle blowers. It was subject to an audit by Transparency International. The whistle-blowing mechanism project was presented to the Works Committee in July 2018. The platform’s accessibility and the protection of whistle blowers were promoted by a group communication in France and to the TAV, AIG, ADP Ingénierie and Hub One subsidiaries. A new communication campaign will be rolled out in 2020. TRAINING AND AWARENESS-RAISING An intranet site and website (https://www.parisaeroport.fr/groupe/rse/ ethique-et-compliance) dedicated to the Ethics and Compliance action plan were launched in December 2018. Nearly 500 managers have been trained in face to face training, along with an e-learning system progressively rolled out across the scope since May 2019. The first module, designed for all employees, concerned the issues of ethics and compliance, the fight against corruption, conflicts of interest, and gifts and invitations. Around 9,000 group employees were trained in 2019. Other specific modules will be gradually rolled out to the most exposed populations.
◆ the inclusion of prevention measures in the contract documents for the contracts in question: adjustment of CSR rating grids and specifications used for their selection. These CSR grids, which are specific to each purchasing segment, are used to measure the level of maturity of candidates and allocate a rating for this item (of between 5% and 10% of the score); ◆ the reinforcement of the internal CSR-environment purchasing procedure and the pooling of tools and documents between the Environment, CSR and Regions Division, the Purchasing Logistics Services Division and the SME reference contacts to ensure the proper management of the inclusion of environmental specifications in contracts. WHISTLE-BLOWING MECHANISM EXTENDED TO SUPPLIER EMPLOYEES The Ethics and Compliance whistle-blowing platform (see chapter on the Ethics and Compliance programme: the seven action plan pillars) has been made accessible to employees of suppliers in accordance with the Potier law (duty of vigilance). Human rights As a member of the UN Global Compact since 2003, and with Advanced Level status since 2015, Aéroports de Paris undertakes to comply notably with the Universal Declaration of Human Rights in all its activities. In its sustainable development goals, it has selected SDG 4: “ensure inclusive and equitable quality education and promote lifelong learning opportunities for all” and SDG 5: “achieve gender equality and empower all women and girls”. In 2015, Aéroports de Paris also signed the Mobilisation Charter to fight for equality against racism, supported by the Human Rights Defender. Internationally, our TAV Airports subsidy has been a member of the UN Global Compact since 2015 with the Active level. The Ethics and Compliance programme Groupe ADP has rolled out its Ethics and Compliance programme across seven pillars to fight against corruption. MANAGEMENT SETTING AN EXAMPLE In 2019, all Executive Committee members (including ADP International) took part in an awareness-raising session on the issue of corruption. Face to face awareness-raising sessions were also organised in the international subsidiaries for top management and exposed populations. The Chairman and CEO, Executive CEO, Group General Secretary and CEOs of subsidiaries supported the launch and rollout of e-learning (videos, messages, etc.). CORRUPTION RISK MAPPING A corruption risk mapping was prepared in 2019 for the France and International scopes based on 10 pre-identified risks and the preparation of scenarios. DEDICATED GOVERNANCE The Ethics Division was created in 2018. Its Director reports to the Chairman and CEO, thus guaranteeing the Division’s independence in processing alerts. The Ethics Division defines and steers the Ethics and Compliance action plan with the Legal and Insurance Division. To extend the plan to the group’s subsidiaries, these divisions are supported by the Ethics & Compliance contacts in ADP International, ADP Ingénierie, TAV Airports, AIG and Hub One, as well as the Ethics and Compliance relays appointed in Aéroports de Paris’ divisions. The programme is monitored in the group’s different bodies: Executive Committee, Social and Economic Committee, Board of Directors (and its Audit and Risk Committee). In 2020, the appointment of Ethics and Compliance relays is planned at TAV Airports and its subsidiaries.
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AÉROPORTS DE PARIS ® UNIVERSAL REGISTRATION DOCUMENT 2019
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