APC 2011 Annual Report Download - page 60

REGISTRATION DOCUMENT 2011 SCHNEIDER ELECTRIC58
SUSTAINABLE DEVELOPMENT
2GREEN AND RESPONSIBLE GROWTH DRIVING ECONOMIC PERFORMANCE
•an online e-learning module. The aim is that, at the end of the
session, the trainee is familiar with Our Principles of Responsibility
and more comfortable using them in his or her job. At the end of
2011, more than 21,000employees participated in the module:
94% rated the module as good or excellent.
A professional alert system
To allow each employee to exercise their right to report a problem,
aprofessional alert system is currently being deployed.
In compliance with local legislations, this market solution 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. The main players in this process are the Compliance Offi cers (see
“Dedicated teams and organisation”).
The system is currently in place on the American continent and
implementation is planned for the whole Group, accompanied by an
internal communication plan that identifi es the persons responsible
for investigating alerts received.
Dedicated teams and organisation
The program requires implementation of an organisation including
the following:
•a Governance Committee and a network of Principles of
Responsibility Advisors.
They are responsible for the implementation and roll out the
Responsibility & Ethics Dynamics program.
•a Compliance Committee and a network of Compliance Offi cers.
They are responsible for detecting and managing cases of non-
compliance with the processes defi ned, in line with local laws and
regulations and Our Principles of Responsibility.
Stakeholders and committees exercise their authority within
activities of infl uence and control.
In particular, the Governance Committee must ensure coherence
with the Group’s strategic plans. It provides Executive Committee
members with information on trends that, for example, implement
the company change program.
Governance
Committee
Compliance
Committee
Executive
Committee
One a year Twice a year Upon Request
Dene, Explain
& Spread the Rules
Detect & Manage
Non Compliance
PoR Advisers
(1 per Entity)
Compliance
Ocers
(1 per geograph. area)
Measuring rollout and effectiveness
The Responsibility & Ethics Dynamics program is primarily the
subject of regular internal communication. The objective is to inform
all the employees and remind the management teams of the priority
actions that they must drive forward, dependent on the risks to
which they are exposed in their countries of operation.
Two particular actions were undertaken in 2011:
•one for the Country Presidents during the year to reemphasize
the importance of their role as sponsor for their countries, the
expectations at the end of 2011 and to respond to their questions;
•and another addressed to the 500 main Group managers to
inform them of the developments brought by the program
and to raise their awareness once more on the importance of
communication within their teams.
In addition and since the program was launched in 2010, it has
been the subject of an assessment conducted by Internal Audit.
Our Principles of Responsibility were rolled out in all the Group’s
entities in 2010. The results of the Internal Audit, including the
fi ndings of a survey of 10,000employees and an audit that includes
Argentina, China, the United Arab Emirates, the United States,
France, India, Indonesia, Italy, and Russia were:
•73% of employees questioned said they were familiar with Our
Principles of Responsibility;
•84% of survey participants stated that the information given was
useful and comprehensive.
In 2011, the assessment of the Responsibility & Ethics Dynamics
program as a whole, with a particular focus on the 19 most exposed
countries in which the Group works, according to the corruption
perception index of Transparency International.
The audit shows the level of knowledge of Our Principles of
Responsibility stands at 75% (83% if a recently acquired entity is
excluded). Beyond the fi gures, the audit makes two very important
points clear to us:
•on the one hand, regarding the means of communication judged
the most effective;
•and on the other, on the level of perception of Our Principles of
Responsibility by position within the company.
For 2012, these lessons are driving us to integrate communication
into the Schneider Electric University programs and to use
supplementary action for the job posts where the result is weakest.