APC 2015 Annual Report Download - page 68

2015 REGISTRATION DOCUMENT SCHNEIDER ELECTRIC66
SUSTAINABLE DEVELOPMENT
2GREEN AND RESPONSIBLE GROWTH DRIVING ECONOMIC PERFORMANCE
These kits address two themes in particular:
–the infringement of Human Rights, particularly child labor,
hygiene and safety conditions and discrimination issues;
–anti-corruption and fi nancial fraud, especially confl icts
of interest, the role of intermediaries, and accounting
manipulation.
These kits are now being rolled out, particularly in the functions
that are most exposed to these ethical issues. In 2015, specifi c
training sessions were introduced for the Purchasing and Finance
Departments.
A professional alert system: the R&ED Line
When an employee is a victim of or witness to an event that touches
on ethical issues, a professional alert system has been available
since 2012 to report information on such events. This system
ensures the confi dentiality of the exchanges and protects the
anonymity of the whistleblower (unless there is legislation to the
contrary).
In compliance with local legislation, this system 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. Each alert is reviewed by the Group’s Fraud Committee, which
appoints a two-person team to take charge of the investigation,
consisting of a Compliance Offi cer and an investigator from the
Schneider Electric Bureau of Investigation (see «Dedicated teams
and organization »). Based on the fi ndings of the investigation,
management take appropriate measures to sanction or exonerate
the party or parties involved. Each year a detailed report with
statistics (number and type of alerts by region) is presented to
the Audit committee and the Group Executive Committee, which
reviews and approves the preventive and corrective actions to be
taken.
Unless there are legal provisions to the contrary, the system can
be used to send alerts in the following areas in every country in
which the Group operates: discrimination, harassment, safety,
environmental damage , unfair competition, corruption, confl icts
of interest, accounting manipulation, document forgery, insider
trading, theft, fraud and embezzlement.
242 ethical alerts were escalated in the R&ED line system in 2015:
47% of them were related to potential violations of our code of
conduct in the fi eld of business integrity; 35% were related to
potential discrimination, harassment or unfair treatment cases;
the 18% remaining were related to potential violations of other
Schneider Electric policies.
Dedicated teams and organization
The program requires implementation of an organization including
the following:
•a Responsibility & Ethics Committee responsible for setting
program priorities and the c ompany’s ethical vision;
•a network of Principles of Responsibility Advisors that brings
together about 30 employees worldwide whose mission is to
advise employees facing ethical dilemmas. More generally, they
are in charge of the deployment of the program’s prevention
efforts;
•a Fraud Committee, whose mission is to collect and investigate
alerts received via the R&ED Line;
•a network of Compliance Offi cers attached to the Group’s Legal
Department whose mission is to detect and manage cases of
non-compliance with the defi ned processes, in accordance 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 Ethics & Responsibility Committee must ensure
coherence with the Group’s strategic goals. It provides Executive
Committee members with information on trends that, for example,
integrate the Company strategic program.
Executive Committee
Strategic
Define, explain & communicate the rules Detect & manage non compliance
Awareness Enablers Investigation Enablers
Operational
Responsability & Ethics Committee Fraud Committee
Principles of Responsability Advisers Compliance Officers
Executive Level
Corporate Level
Zone Level