Saint-Gobain // Universal Registration Document 2021

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Risks and control Internal control

Industrial and distribution risk 2.5.5 prevention manual The Group’s policy for prevention of property damage and the resulting operating losses, compiled as part of an internal collection of standards and best practices, is defined by the Risk and Insurance Department. The DRA coordinates the implementation of the policy by the Group’s operational entities in its different businesses. Within the business and regional entities, Prevention Coordinators manage the application of Group policy within the scope of their activities. At site level, those in charge of Prevention Management perform an annual self-assessment of risks at their sites using a risk rating software package. This tool assesses risks as well as the corresponding levels of protection and prevention. This self-assessment is updated annually by the industrial sites, the Research and Development Centers and logistical sites. A special assessment is carried out for the points of sale. Furthermore, regular inspections of the Group’s most important sites are carried out by prevention engineers, who are auditors external to the Group (approximately 350 inspections and 50 remote meetings per year). The sites update their action plans with a view to improving their level of prevention and protection based on recommendations prepared by these prevention engineers. Tools of the Group’s compliance 2.5.6 culture The culture of compliance that drives the Group has developed through its values, which are formally stated in the Principles of Conduct and Action. The ethics and compliance program currently focuses on the following main themes: promoting the Principles of Conduct and Action; preventing corruption and influence peddling; compliance with rules relating to competition law; and compliance with economic sanctions and embargos.

The tools used in implementing the program include: a dedicated intranet, called Compliance, on which key ■ messages are posted and tools made available; online training modules such as Comply (competition ■ law), ACT (preventing corruption) and Saint-Gobain Economic Sanctions and Embargos (rules relating to economic sanctions and embargos); in-person training; ■ distribution of practical and technical guides: ■ the Thread of Competition, ■ 20 best practices in competition law for purchasers, ■ the Lexia video on the alert system; ■ the dissemination and implementation of internal ■ policies such as: the policy on the alert system in place at the ■ Saint-Gobain Group, anti-corruption policy, ■ gifts and invitations policy, ■ conflicts of interest policy, ■ policy on economic sanctions and control of exports, ■ sales agents and intermediaries policy, ■ membership in professional associations policy, ■ the Group policy on management of the corruption ■ risk by Human Resources, acquisition and joint-venture policies, ■ frequent dissemination of messages by the ■ Saint-Gobain Group’s Chairman & Chief Executive Officer, Chief Executive Officer and General Secretary and the Chief Executive Officers of the Group’s regions, countries and activities; a network of locally-present ethics and compliance ■ managers and embargo managers.

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