Saint-Gobain // Universal Registration Document 2021

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An efficient and responsible Group Demonstrate ethics and responsibility

1.2

Main ethics and compliance policies

Compliance with anti-corruption and influence peddling rules All over the world, corruption undermines trust in public institutions, makes the most vulnerable even weaker and is the breeding ground for violence, slowing the transition to a more sustainable world. The active fight against this scourge is of concern to everyone. Since 2003, Saint-Gobain has expressed its commitment to the fight against corruption by signing the Global Compact of the United Nations, the tenth principle of which calls on companies to take action against corruption. In addition, the Group has since then set up a program to prevent the risks of corruption and influence peddling, including a commitment from directors and strict compliance with the principle of “zero tolerance”. This program is based on: a mapping of the risks of corruption and influence ■ peddling; policies and procedures; ■ training, in particular the digital training called “ACT”, ■ which is followed by all managers when they are onboarded as well as every two years; communication actions; ■ audits conducted internally or by external service ■ providers. In 2020, the Group publicly released the new version of its anti-corruption policy on the fight against corruption and influence peddling. The purpose of this manual is to define and illustrate the various types of behavior to be prohibited, review the Group’s rules and the best practices to adopt, i.e ., the procedures relating to all areas in which corruption and influence peddling risks are likely to materialize, such as gifts and invitations, conflicts of interest, recruitment, mergers and acquisitions, or the management of intermediaries. All Saint-Gobain employees must feel responsible for the fight against corruption. Therefore, the policy is based on concrete and educational examples of what is and is not allowed in the practice of the professional. It recalls the following fundamental principle: the fight against corruption and influence peddling presupposes a principle of “zero tolerance”. The anti-corruption policy is fully committed to by both the Group’s Chief Executive Officer and the Group’s Executive Committee, and was signed by nearly 3,000 senior employees when it was launched. 1.2.1

The management of the anti-corruption policy is the responsibility of the Group’s Senior Management, which delegates design, deployment of programs and the monitoring of its effectiveness to the Ethics and Compliance Department. Compliance with competition law 1.2.2 Saint-Gobain has put in place a competition law compliance program based on: policies and procedures, notably regarding membership ■ of professional associations; training and communication actions: practical guides ■ are made available, in particular “The ins and outs of competition law” available on the Group’s website; an e-learning training course called “Comply” is followed for the first time by all managers when they are onboarding, and then repeated every two years; numerous in-person training sessions are provided by the Ethics and Compliance Department and the Ethics and Compliance Managers; lastly, the theme was covered as part of the Principles of Conduct and Action Day; audits conducted by third parties. ■ Compliance with economic 1.2.3 sanctions and export control regulations Saint-Gobain has implemented a program for compliance with economic sanctions and export controls. It is based on: a Group policy; ■ a network of people in charge of these issues for the ■ Group's activities, deployed at the relevant level of the regional activities, the Business Units, or the country level; tools to monitor the evolution of applicable regulations ■ are available: a screening tool (screening sanctions) of third parties and country files to identify risks and apply the necessary due diligence updated in line with changes in regulations; training and communication actions: e-learning training ■ is followed by managers exposed to these issues; in-person training is provided by members of the dedicated network; the theme was also covered as part of the Principles of Conduct and Action Day; “sanctions and export control” audits, conducted by ■ external service providers on Group entities previously identified by the central team.

SAINT-GOBAIN UNIVERSAL REGISTRATION DOCUMENT 2021 72

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