GECINA - REFERENCE DOCUMENT 2017
06
RISKS Information regarding certain control activities
Anti-fraud and anti-corruption measures The Group’s anti-fraud and anti-corruption arsenal is supervised by the Risks and Compliance function. It is based on the evaluation and analysis of risks of fraud and corruption through annual risk mapping projects. The evaluation helps to define specific prevention measures based on the Group’s ethical charter and on the repository of internal procedures, which include various controls, segregation of tasks and access security measures. Prevention is also based on awareness-raising actions conducted by the Risks and Compliance function, which organizes briefings and training for the Group’s employees. In line with our policy of raising awareness about risks, an awareness-raising session for employees exposed to corruption risk and influence peddling is planned for 2018. A detection system includes the risk of fraud and corruption in the permanent control audit work carried out by the Risk and Compliance function within the reporting and warning systems, as well as via occasional investigations when anomalies are detected or reported. This system is enhanced by updating the ethics charter, on these aspects in particular. The Risk and Compliance function carried out a review of the main provisions of the Sapin II law on the fight against corruption, which came into effect on June 1, 2017, in order to ensure its proper implementation. This work, which includes management’s action plans, was presented to the Audit and Risk Committee. The anti-money laundering and terrorism financing system is incorporated into the ethics charter. A procedure and tools for identifying and managing these risks has been developed for operational departments. An awareness-raising and information session was organized by the Risks and Compliance function for the Management Committee and the employees concerned when the procedure was published to all Group employees. The Risks and Compliance function is integrated in this procedure as an informed entity and consulted by the operational entities. An additional detection system has been established, by incorporating anti-money laundering and terrorism financing risks into the permanent audit control work performed by the Risk and Compliance function. The system will be strengthened in 2018 via the implementation of a new counterparty identity intelligence tool. For an overall description of how risk management is organized, see the description in the chapter “Risks” (6.1.1). Anti-money laundering and terrorism financing
6.2.3
INFORMATION ABOUT THE RISK AND COMPLIANCE FUNCTION
Ethics charter All the regulations, measures and internal procedures were supplemented by the implementation of the Group’s ethics charter. The ethics charter was updated in 2017. It includes specific information related to corruption which is now included in whistle-blowing. The ethics charter was drafted in accordance with Gecina’s fundamental values and ratified by the Board of Directors. It was distributed to all employees and posted on the Group’s website and on the Intranet. In 2017, the charter was updated and distributed to all employees. It focuses on nine key issues: compliance with regulations; ■ Group’s commitments towards its stakeholders; ■ Group corporate social responsibility; ■ community involvement and political neutrality; ■ work conduct; ■ ethical business management; ■ confidentiality; ■ stock exchange compliance; ■ whistle-blowing rights. ■ Each employee is asked to follow and ensure that others follow the charter and act with integrity at all times. A practical guide illustrating the principles listed in the ethics charter has been distributed to all administrative staff. In the event of an additional query regarding a transaction or doubt about a specific situation, employees may report this directly to the Chief Compliance Officer. A whistle-blowing right has been in place since 2012 through a special email address. Depending on the nature and seriousness of the problem, a Whistle-Blowing Committee is then set up to handle the issue as rapidly as possible. Each new employee is given the ethics charter and the practical guide on joining the company. A presentation on the charter is also added to the orientation process for new Group employees and the executive induction seminar. All new employees attended the presentation in 2016 and 2017. This included seven awareness-raising sessions on the topic for new employees in 2017. Taking into account the initial trainings when the charter was issued in 2012 and staff turnover, 98% of Group employees have been familiarized with the ethics charter. The ethics charter has been incorporated into internal regulations since 2016.
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