SCH2017_DRF_EN_Livre.indb

2 Sustainable development

Green and responsible growth driving economic performance

enabled them to develop scenarios resembling the reality in the field. Managers are encouraged to use these case studies to facilitate discussions about ethics with their teams at least once per quarter; the goal is to create a space for open and free discussions to address complex issues and to ensure that no employee has to face issues of this type on his/her own. These kits address 2 themes in particular: E the infringement of Human Rights, particularly child labor, hygiene and safety conditions and discrimination issues; E anti-corruption and financial fraud, especially conflicts of interest, the role of intermediaries, and accounting manipulation. These kits are particularly useful for the functions most exposed to these ethical issues, such as the Procurement, Sales and Finance Departments. A professional alert system: the R&ED Line When an employee is a victim of or witness to an event that touches on ethical issues, a professional alert system has been available since 2012 to report information on such events. This system ensures the confidentiality of the exchanges and protects the anonymity of the whistleblower (unless there is legislation to the contrary). In compliance with local legislation, this system is provided by an independent company and proposes alert categories, a questionnaire, and information exchange protocol between the person issuing the alert and the person responsible for investigating it. Each alert is reviewed by the Group’s Fraud Committee, which appoints a 2-person team to take charge of the investigation, consisting of a Compliance Officer and an investigator from the Schneider Electric Bureau of Investigation (see “Dedicated teams and organization”). Based on the findings of the investigation, management take appropriate measures to sanction or exonerate the party or parties involved. Each year a detailed report with statistics (number and type of alerts by region) is presented to the Audit Committee and the Group Executive Committee, which reviews and approves the preventive and corrective actions to be taken.

Unless there are legal provisions to the contrary, the system can be used to send alerts in the following areas in every country in which the Group operates: discrimination, harassment, safety, environmental damage, unfair competition, corruption, conflicts of interest, accounting manipulation, document forgery, insider trading, theft, fraud and embezzlement. In 2017, 259 claims were escalated in the R&ED line system: 46% of them concerned potential breaches of our code of conduct on financial matters; 35% were related to potential discrimination, harassment or unfair treatment cases; the 19% remaining were related to potential violations of other Schneider Electric policies. Not all these claims prove to be established breaches or frauds. Dedicated teams and organization The program requires implementation of an organization including the following: E a Responsibility & Ethics Committee responsible for setting program priorities and the company’s ethical vision; it comprises 3 members of the Executive Committee: Strategy, Human Resources and Legal & Finance as Chairman of the Committee; E a network of Principles of Responsibility Advisors that brings together about 30 employees worldwide whose mission is to advise employees facing ethical dilemmas. More generally, they are in charge of the deployment of the program’s prevention efforts; E a Fraud Committee, whose mission is to collect and investigate alerts received via the R&ED Line; E a network of Compliance Officers attached to the Group’s Legal Department, whose mission is to detect and manage cases of non-compliance with the defined processes, in accordance with local laws and regulations and Our Principles of Responsibility . In particular, the Ethics & Responsibility Committee must ensure coherence with the Group’s strategic goals. It provides information to its members from the Executive Committee on operational trends that could be incorporated into the corporate strategic program, for instance.

Executive Committee

Executive Level

Operational

Strategic

Responsability & Ethics Committee

Fraud Committee

Corporate Level

Define, explain & communicate the rules

Detect & manage non compliance

Principles of Responsability Advisers

Compliance Officers

Zone Level

Awareness Enablers

Investigation Enablers

2017 REGISTRATION DOCUMENT SCHNEIDER ELECTRIC

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