APC 2012 Annual Report Download - page 61

2012 REGISTRATION DOCUMENT SCHNEIDER ELECTRIC 59
SUSTAINABLE DEVELOPMENT
2
GREEN AND RESPONSIBLE GROWTH DRIVING ECONOMIC PERFORMANCE
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.
After a measure in 2010 for the deployment of the benchmark,
Our Principles of Responsibility, the 2011 assessment focused on
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 revealed two very important
points :
•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.
Since2012, these lessons are driving us to integrate communication
into the Schneider Electric University training programs and to use
supplementary action for the job posts where the result is weakest.
Personal data protection
Building a global organization requires the pooling of our information
systems (human resources, customer relationship management,
suppliers, etc.) and globally sharing our databases among all
entities. However, personal data protection regulations restrict
cross-border fl ows of personal data by subjecting them to strict
constraints requiring the signing of contractual agreements between
the entities concerned.
Schneider Electric chooses to provide legal certainty for cross-
border fl ows by developing a code of conduct for the protection
of personal data (Binding Corporate Rules), an option proposed to
multinationals by the personal data protection authorities in Europe.
Schneider Electric’s Binding Corporate Rules were approved on
November27, 2012 by the personal data protection authorities in
26Member States of the European Union.
These data protection rules will be applicable to all Schneider
Electric subsidiaries worldwide. The communication plan,
e-learning module and practical guides will be available to allow for
harmonized deployment of the Binding Corporate Rules, which will
be binding on all employees. Their implementation will be subject to
an annual audit, whose report will be available to the personal data
protection authorities.
This code of conduct publicly affi rms Schneider Electric’s
commitment to protect the personal data of its employees but
also of its customers, which is a measure of a digital strategy
that reconciles economic business objectives and respect for the
fundamental right of people to protect their data and their privacy.
Award for excellence 2012
The Group is proud of having been included in The Ethisphere
Institute’s World’s Most Ethical Companies indicator for the second
year in a row.
Schneider Electric is among 100 international companies
recognized for their ethical commitment and behavior. The
performance measure looks at the existence and consistency
of governance, the reputation and infl uence of the Company,
the quality of actions promoting citizenship and social
responsibility, and the culture and actions promoting ethics.
This recognition is reassuring for the Group as it implements the
Responsibility&Ethics Dynamics program.
Outlook for2013
Program rollout will continue in2013 along various axes:
•continuing communication actions and training for employees in
countries most susceptible to breaches of ethics;
•continuation of implementing simple measures to enable
employees to understand ethical dilemmas in an operational
context and to help them place themselves above the risk level
to which they may be exposed; this action, which was decided
in2012, will build up a corpus of training kits in2013 that will
be available to all Group managers. Each kit, for use at team
meetings, includes an ethical dilemma placed in a real-life
context, three examples of typical behaviors and an explanation
of the behavior recommended by the Group ;
•working with the Principles of Responsibility Advisors to forge
closer ties between the principles and the operational procedures
and directives that should be readily available to all Group
employees.