APC 2015 Annual Report Download - page 69

2015 REGISTRATION DOCUMENT SCHNEIDER ELECTRIC 67
SUSTAINABLE DEVELOPMENT
2
GREEN AND RESPONSIBLE GROWTH DRIVING ECONOMIC PERFORMANCE
Measuring rollout and effectiveness
The Responsibility & Ethics Dynamics program is 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, depending on the risks to
which they are exposed in their countries of operation.
The annual questionnaire concerning the implementation of the
program was also reviewed and audited in 2015. This questionnaire
is a self-assessment of each entity and the results are verifi ed by the
internal control teams (between 5 and 10% of entities). The results
of this assessment are then analyzed by the team responsible for
ethics, which supports entities in need of help and shares the best
practices of those achieving the highest scores. This assessment
is now used as a reference for the Ethics indicator on the Planet &
Society barometer 2015-2017: « All our entities pass our internal
Ethics & Responsibility assessment ». At the end of 2015, 88% of
entities had successfully completed this assessment.
Personal data protection
Schneider Electric has chosen to implement a code of conduct for
the protection of personal data (Binding Corporate Rules), a legal
framework proposed to international companies by the personal
data protection authorities in the European Union.
To facilitate their application and be effective, these rules must
be visible and understandable by all entities. As a result, a data
protection policy, training sessions, an e-learning module and fact
sheets are available on a dedicated collaborative space.
2015 was marked by a step-up in training actions with awareness-
raising sessions for top management and the Marketing,
Purchasing, Human Resources and IT functions.
Schneider Electric believes that the global implementation of a
digital strategy must reconcile economic objectives and respect
for fundamental human rights, including the right to protection of
personal data and privacy. A Data Privacy & Digital Committee,
composed of Directors of the various functions (Purchasing, IT,
Security, Human Resources, Marketing, Legal, Audit, etc.) and
Activities, ensures global governance of personal data and monitors
compliance with this fundamental right in all digital projects. This
governance will be strengthened in 2016 with the creation of a
global dashboard consolidating all the actions undertaken by the
entities to improve protection of personal data across the world
and the creation of a work group on «Privacy by Design » in the
development of products and solutions.
Policies in areas of high political risk
As a global and responsible company, Schneider Electric has
strict policies and practices in areas identifi ed as high-risk and
its operations, in these areas, have been signifi cantly reduced or
eliminated. The Group strictly respects all applicable embargos
and regulations. It prohibits «Dual Use Goods» – products which
potentially could be used for sensitive applications such as the
military. It screens the parties it engages with against applicable
denied parties lists to ensure it does not support or fund activities
unintentionally. It restricts its business to activities that help the
countries improve their electrical distribution infrastructure.
2015 Award for excellence
The Group is proud to have been selected by The Ethisphere
Institute for its 2015 World’s Most Ethical Companies index for the
fi fth year running (and in March2016 for the sixth year).
Schneider Electric is one of just 130 international companies
recognized for their commitment and approach to ethics.
Performance is measured based on the existence and depth of
governance, the company’s reputation and infl uence, the quality of
actions to promote citizenship and societal responsibility, the culture
and actions carried out to promote ethics.
2015 achievements
The program’s implementation has continued through various lines
of action:
•for the second year running, two days dedicated to ethics and
responsibility, the R&ED Days, were organized based on two
main topics: « Ethics in our business » and « Ethics with our
employees ». This event was organized in 35 countries with
the support of Country Presidents , Principles of Responsibility
Advisors and Compliance Offi cers: Albania, Germany, Australia,
Bosnia, Bulgaria, Chile, China, Colombia, South Korea, Croatia,
Egypt, Spain, France, Greece, Hungary, India, Italy, Japan,
Kazakhstan, Kosovo, Macedonia, Malaysia, Mexico, Morocco,
Myanmar, New Zealand, Philippines, Poland, Romania, Russia,
Serbia, Slovenia, Sweden, Taiwan, Thailand, Turkey and Vietnam.
More than 50 workshops were organized over the course of the
two days, on October6 and 7, 2015: discussions on ongoing
ethical challenges within the Group using Educational Kits;
distribution of Our Principles of Responsibility ; introduction to
the R&ED program and the whistleblowing system. Once again,
this event met with great success and strong interest from the
employees;
•the Letter of acknowledgment with Our Principles of Responsibility
signed by managers;
•the new online training module;
•the introduction of the Ethics indicator to the Planet & Society
barometer 2015-2017;
•the continuation of the training program for the most exposed
functions and geographical areas, with a special mention for
employees coming from recently acquired companies;
•the continuation of implementing simple measures to enable
employees to understand ethical dilemmas in an operational
context and to help them to position themselves on the risk level
to which they may be exposed;
•the update or creation of policies or directives, particularly the
Business Agent policy , the Personal Data Management policy,
the Gifts & Hospitality policy, and the Internal Fraud Investigation
directive. This directive refers in particular to the whistleblowing
system and the investigation process, as well as the protection
given to whistleblowers;
•a fi rst step being taken within the implementation of the UN
Guiding Principles on Business and Human Rights (Ruggie): the
formalization of a Human R ights policy.