LISI GROUP - 2018 Financial report

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10.4 IManagement of the Alert System
ComplianceCommittee: the committee is chaired by theGroup’sDeputy
CEOandiscomprisedofrepresentativesofthreedepartments:theGroup
Legal Director, the Group Human Resources Manager and the Group
Internal Audit Manager. The purpose of the Committee is to manage the
alerts raised by the system in place. The employment contracts of this
team have been amended to provide for an enhanced confidentiality
clause. In accordance with the commitments announced in 2017, in
March2018,theComplianceCommitteecompletedanewtrainingmodule
dedicated to the management of alerts and organized by two members
of the NGO Transparency International (TI), experts in alert collection.
The alert system (Ethic Line) was put in place on April 1, 2018 on the
LISI Group’s website in a dedicated section called “Ethics”. This system,
which is open to all of the Group’s internal and external partners, is
available in nine different languages. The alerts which may be raised by
this systemmay arise fromproblems linked to anti-corruptionbut also to
the duty of care. To facilitate its use, an alert collection procedure has
been created. An effectiveness test was performed, without warning, as
part of the IATF certification (Automotive activity): it was found that it
complied with the requirements. This system, which is completely
managed internally, meets the legal requirements since it is a secure
systemwhich protects the whistleblower.
10.5 IIdentification Of The Risk Level Linked
To Corruption
The risk linked to corruption was assessed in 2018 according to two
priorities:
■■On the one hand, the exposure per country in which LISI pursues its
activity:thisfocusisbasedonthestandardwhichclasses180countries
by the degree of exposure to corruption risk according to the NGO
Transparency International;
■■On the other hand, the nature of the business relationshipsmaintained
by LISI: identification of the nature of transactions that could involve
LISI as part of its activities.
Through the values defended by the Group, LISI is committed to
presenting the importance of this theme in particular at all levels of its
organization:
■■By demystifying the nature of this risk so that it is considered in the
same manner as all other risks;
■■Creating a group dynamic to fuel the debate;
■■By evaluating the corruption risk in completely transparent manner so
that, if such a risk exists, it can beminimized or even eliminated;
■■By relying on the experience of the local teams to identify the nature of
the relationships exposed to corruption.
The sensitive nature of this issue led LISI to conduct a review at Group
level with the operational teams: the process took the form of
brainstorming sessions. The aim was to determine the most relevant
methodology for evaluating the corruption risk. The focuswas initially on
those countries which were more at risk: with the teams from Izmir
(LISI AEROSPACE), Morocco (LISI AEROSPACE and LISI AUTOMOTIVE),
India (LISI AEROSPACE), China (LISI AUTOMOTIVE), Poland
(LISI AEROSPACE) and Mexico (LISI AEROSPACE and LISI AUTOMOTIVE).
Uptothreebrainstormingsessionsperentitywererequiredtodetermine
the risk zones. Each brainstorming session brought together
representativefromseveralDepartments,inparticularthePlantManager,
PurchasingManager,HumanResourcesManagerandFinancialController.
A number of ideas were collected together in a standardized dashboard:
each issue was dealt with in order to evaluate the existing risk in the
industrial environment in the country in question. Then, in accordance
withtheproceduresandcontrols inplace,theriskwasevaluatedagainto
determine the level of risk to which LISI is exposed.
The initial results showed that LISI was relatively exposed due to the
natureof itsactivitybutalso thankstocontrolmeasures,theprocedures
in place and the policy followed by its employees.
10.6 IThird-Party Evaluation Procedures
In 2018, a reviewwas conducted among the Group’s HR, HSE and Internal
AuditteamstodefineacommonbasisdedicatedtoCSRissues:thiswould
then be included in the supplier evaluation questionnaires which are
already in place and used in the three divisions. This action was slowed
down so that it couldbe incorporated into theoverall approachdefined in
the CSR strategy which LISI wishes to develop. As a result, at the end of
2018, the process had the same status.
10.7 IControl Procedures
The documents that bind the LISI Group and its stakeholders, internal or
external, were updated in coordination with the measures described
above. The Supplier Charter (external stakeholders) and the Supplier
Policy(internalstakeholders)werethusupdatedtobeofficiallydistributed
atthestartof2019toallstakeholders.Theywerethentranslatedintonine
languages.Asaresultofthisupdating,theGeneralPurchasingConditions
wereupdated.Finally,theGeneralConditionsofSalealso includeananti-
corruption and duty of care section.
10.8 ITraining Plan
LISI wished to develop its anti-corruption system by ensuring that
employees were informed by means of a communication kit distributed
at the same time as the code of conduct is applied. The employees of
LISI S.A., LISI AEROSPACE and LISI MEDICAL received an e-learning
moduletocomplete.Thistrainingmodule,basedone-learningdeveloped
bytheOECD(OrganisationforEconomicCo-operationandDevelopment),
isintendedforemployeeswhoaremost likelytobeexposedtocorruption.
In2018,atotalof300employeeswereassignedtofollowthistraining.The
LISIAUTOMOTIVEemployeeswillundertakethismoduleforasecondtime
as a module specifically tailored to the division was deployed on issues
covering their own code of conduct which is more extensive than that of
anti-corruption only. The module will also be followed by each new
management-level employee.
10.9 IOutlook for 2019
The implementation of a SAPIN II LAWprogram forms part of amedium-
term project. In order to do this, in 2019 the Group will continue the work
already undertaken up to now.