Exclusive Networks // Sustainability Report 2022
Ethics, fair practices, compliance and security Ethics, prevention and anti-corruption
To comply with best practices and the recommendations of the supervisory authorities, in 2022 an internal reorganisation was carried out, aimed at separating the operational functions of the Risks & Compliance department, internal control and internal audit. The Risks & Compliance department is now independent and reports to the Group General Counsel & Group Compliance Officer. At the same time, an Internal Control department was created which reports to the Group Chief Financial Officer. The Internal Audit department reports to the Audit Committee as an independent control body. At local level The Regional Risk Committee brings together the SVP of the region concerned, the Group General Counsel & Group Compliance Officer, the Internal Control Director, the Internal Audit Director, the Risks & Compliance Director, the Regional Finance Director, the Regional HR Director and the Regional Risks & Compliance Manager. It is already in place for the Asia Pacific region and will soon be implemented in the Europe, Middle East and Africa (EMEA) region. The Country Manager is responsible for the implementation and compliance with the programme in the legal entities under his/her responsibility. The Ethics Champions network implements the compliance programme in cooperation with the Risks & Compliance department, and ensures that it is properly taken into account and understood. [GRI 3-3]/SDG 16.5
At corporate level The Group General Counsel & Group Compliance Officer: reports to the Group Chief Executive Officer on these matters; defines and organises the Compliance function and ensures its implementation within the Group; brings the issue before the various governance bodies (Group Executive Committee, Audit Committee, Board of Directors); decides freely, and at its sole discretion, on any internal investigation that it deems appropriate and which will be entrusted to Internal Audit. The Risks & Compliance Director: reports to the Group General Counsel & Group Compliance Officer; designs the compliance program and first of all the one related to the anti-corruption system; manages and controls the implementation and updating of the programme, and leads the Compliance network within the Group; ensures a regulatory watch as well as best practices; organises and runs Compliance training courses within the Group; is the point of contact for the operational departments; contributes, where appropriate, to internal or external investigations relating to the programme, or likely to be initiated in the event of use of the internal whistleblowing system.
6.2
Ethics, prevention and anti-corruption
behaviour in all its relationships and with all its partners. This principle has led the Group to define rules of conduct in terms of ethics, intended for its employees as well as for all its business partners and stakeholders.
A mature compliance programme The Exclusive Networks Group is strongly committed to adopting and promoting honest and ethical
Key dates in the Group’s compliance policy
Creation of the whistleblowing hotline open to all employees and third parties
Creation of the Risks & Compliance Department
Creation of the Ethics Champions network
2013
2014
2015
2017
2021
2022
Publication of the first Code of Conduct
Completion of the first corruption risk map
• Updating of compliance procedures • Set up of a new third-party integrity review tool • Updating of the corruption risk map
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Exclusive Networks
Sustainability Report 2022
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