APC 2014 Annual Report Download - page 66

2SUSTAINABLE DEVELOPMENT
GREEN AND RESPONSIBLE GROWTH DRIVING ECONOMIC PERFORMANCE
Unless there are legal provisions to the contrary, the system can a network of Principles of Responsibility Advisors that brings
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be used to send alerts in the following areas in every country in together about thirty employees worldwide whose mission is to
which the Group operates: discrimination, harassment, safety, advise employees facing ethical dilemmas. More generally, they
environmental harm, unfair competition, corruption, conflicts of are in charge of the deployment of the program’s prevention
interest, accounting manipulation, document forgery, insider efforts;
trading, theft, fraud and embezzlement. a Fraud Committee, whose mission is to collect and investigate
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alerts received via the R&ED Line;
113 ethical alerts have been escalated in the R&ED line system in
2014: 3/4 of them were related to potential financial frauds/conflict a network of Compliance Officers attached to the Group’s Legal
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of interest; the remaining 1/4 were related to allegations of Department whose mission is to detect and manage cases of
discrimination/harassment/unfair treatment of employees. non-compliance with the defined processes, in accordance with
local laws and regulations and Our Principles of Responsibility.
Dedicated teams and organization
Stakeholders and committees exercise their authority within
activities of influence and control.
The program requires implementation of an organization including In particular, the Ethics & Responsibility Committee must ensure
the following: coherence with the Group’s strategic goals. It provides Executive
Committee members with information on trends that, for example,
an annual Ethics & Responsibility Committee responsible for
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integrate the Company strategic program.
setting program priorities and the Company’s ethical vision;
Executive Committee Board
Once a year
Define, explain and communicate the rules Detect and manage non compliance
Awareness Enablers Investigation Enablers
Upon Request
(at least once a month)
Responsibility & Ethics Committee Fraud Committee
Principles of Responsibility Advisers Compliance Officers
Executive Level
Corporate Level
Zone Level
Measuring rollout and effectiveness
The 2014 results show that 80% of the entities have reached a
level of deployment from satisfactory to very good. This score is up
The Responsibility&Ethics Dynamics program is the subject of from the 2013 results (73%).
regular internal communication. The objective is to inform all the
Personal data protection
employees and remind the management teams of the priority
actions that they must drive forward, depending on the risks to Schneider Electric has chosen to implement a code of conduct for
which they are exposed in their countries of operation. the protection of personal data (Binding Corporate Rules), a legal
In addition and since the program was launched in2010, it has framework proposed to international companies by the personal
been the subject of an assessment conducted by Internal Audit. data protection authorities in the European Union.
The results of this assessment are then analyzed by the program To facilitate their application and be effective, these rules must be
support teams to assist entities in need of guidance and to gather visible and understandable by all entities. As a result, a data
best practices from those with the highest scores. This protection policy, training sessions, an e-learning module and fact
assessment was recently updated and will be applied starting from sheets are available on a dedicated collaborative space.
the 2015 campaign. It will now serve as an Ethics indicator in the In addition, for the third year, Schneider Electric’s headquarters at
Planet&Society Barometer 2015-2017: «All our entities pass our Rueil Malmaison celebrated Personal Data Protection Day on
internal Ethics & Responsibility assessment». January28, 2014 by organizing activities to increase employee
awareness of this issue.
64 2014 REGISTRATION DOCUMENT SCHNEIDER ELECTRIC