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111

CORPORATE SOCIAL RESPONSIBILITY

6

LISI 2017 FINANCIAL REPORT

More specifically in France, the sites collaborate closely with the

Training Centers of UIMM and with the local ADEFIMs in order

to optimize the financing of the training actions, and with Pôle

Emploi (Job search national organization) to implement Operational

Preparation for Employment processes.

4.3

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SUBCONTRACTORS AND SUPPLIERS

The LISI Group is part of a “win-win” sustainable partnership with its

suppliers and subcontractors to ensure mutual, long-term success.

Aside from economic considerations (quality, competitiveness

and continuous improvement), the Suppliers Charter established

by the Group dictates the terms of partnership in accordance with

the principles of ISO 14001, which are addressed during audits for

selecting new suppliers.

Approval and application of the ten principles of the UN Global

Compact program are also part of this Suppliers Charter.

The Group Purchasing Policy includes ethical, sustainable

development and corporate social responsibility aspects with the

application of the Global Compact principles and the principles of ISO

14001 and OHSAS 18001 standards, that need to be complied with, in

particular by our subcontractors and strategic Suppliers.

5

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ANTI-CORRUPTION

5.1

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GENERAL POLICY ADOPTED BY THE LISI GROUP

TO PREVENT AND FIGHT CORRUPTION

The LISI Group has built its growth on compliance with laws and best

practices. Each division is responsible vis-à-vis the Group’s Senior

Management for the proper performance of its subsidiaries and

employees. The LISI Group is intensifying its policy on the prevention

of and fight against corruption: thus in 2017, its actions were inspired

by its membership of the Global Compact and are also in keeping with

the new French legal framework set out by the Sapin II Law. This is in

keeping with the values that the LISI Group upholds.

5.2

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ACTIONS CARRIED OUT IN 2017 AND ROLL-OUTS

SCHEDULED IN 2018

5.2.1

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Development of the anti-corruption code of conduct:

The LISI Group has deployed a detailed action plan led by the Group

Legal, Human Resources and internal audit teams. One of the main

actions of the LISI Group relates in particular to the development

of a new “anti-corruption and influence peddling” code of conduct.

It underpins the conduct of its business relations. It is intended

for corporate officers, members of Executive and Management

Committees as well as all employees of the LISI Group. It sets forth

the principles that each employee of the Group must apply in the

conduct of their work. It complements the rules, procedures ad

standards defined in each country and to which employees must

continue to refer. Any person acting on behalf of LISI is required to

comply with this code of conduct, regardless of the place and nature

of his/her work. The LISI Group also ensures that its partners share

these values. The LISI Group places a high importance on behaving

in a flawless manner with its stakeholders. This code of conduct will

apply from 2018 after consultation, for the concerned subsidiaries,

with employee representative bodies.

5.2.2

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Method of deployment of the whistleblowing system

The LISI Group is finalizing the development of its alert system

which will also apply from 2018, like its code of conduct. The method

of deployment chosen is a collection of alerts through internal

management: it meets the legal requiremens since it is a secure

system which protects the whistleblower. The management of

alerts will be under the responsibility of the Compliance Committee.

This Committee is made up of three departments: the Group Legal

Director, the Group Human Resources Manager and the Internal Audit

Manager. It is chaired by the Group Deputy CEO, who is also a member

of the Audit Committee. The employment contracts of this team will

be amended to provide for an enhanced confidentiality clause. In

early 2018, the Compliance Committee will follow a training course

on the management of alerts in order to acquire the necessary

expertise: the training will be provided by two members of the NGO

Transparency International (TI), who are expert in the collection of

alerts.

5.2.3

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Work initiated on the identification of the risk level

associated with corruption

In the last quarter of 2017, the LISI Group initiated work identification

of the risk level associated with corruption. This work will continue

in 2018 through the assessment of risks on two levels: firstly,

exposure by country (TI framework) where the LISI Group conducts

business; secondly, the nature of business relations maintained by

the LISI Group.

5.2.4

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Consideration of the training models to roll out

The LISI Group implements its system to fight corruption by giving

information to its employees through a communication kit which will

be distributed as soon as its code of conduct is applied. Employees

most exposed to possible corruption practices will follow training

under e-learning as from 2018. The number of employees concerned

by this training module is estimated at around 800.