Universal Registration Document 2019

104 LISI 2019 UNIVERSAL REGISTRATION DOCUMENT Corporate Social Responsibility 4 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. The alert system (Ethic Line) was put in place on April 1, 2018, on the LISI Group 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 alertswhichmay be raised by this systemmay arise from problems linked to anti-corruption but 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 (LISI AUTOMOTIVE division): 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 system which protects the whistleblower. Identification Of The Risk Level Linked To Corruption The risk linked to corruption was assessed in 2018 based on two priorities: ■ The exposure per country in which LISI conducts business: this focus is based on the standardwhich ranks 180 countries by degree of exposure to corruption risk according to the NGO Transparency International, ■ The nature of the business relationships maintained by LISI: identification of the nature of transactions that could involve LISI as part of its activities. LISI is committed to addressing the importance of this subject 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 be minimized 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 retreats. The aim was to determine the most relevant methodology for evaluating the corruption risk. The focus was initially on those countries which were more at risk: with the teams from Turkey (LISI AEROSPACE), Morocco (LISI AEROSPACE and LISI AUTOMOT I VE ), India (LISI AEROSPACE), China (LISI AUTOMOTIVE), Poland (LISI AEROSPACE) and Mexico (LISI AEROSPACE and LISI AUTOMOTIVE). Up to three meetings per entity were required to determine the risk areas. Each retreat brought together several departmental managers in particular the Plant Manager, Purchasing Manager, Human Resources Manager and Financial Controller. 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. In accordance with the procedures and controls in place, the risk was evaluated again to determine the level of risk to which LISI is exposed. The initial results showed that LISI was relatively exposed due to the nature of its activity but also thanks to control measures, the procedures in place and the policy followed by its employees. This work continued in 2019 and confirmed this relative exposure level. Third-Party Evaluation Procedures This procedure is now an integral part of the CSR policy. Control 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 (internal stakeholders) were thus updated to be officially distributed at the start of 2019 to all stakeholders. They were then translated into nine languages. As a result of this updating, theGeneral Purchasing Conditions were updated. Finally, the General Conditions of Sale also include an anti-corruption and duty of care section. Training 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 module to complete. This training module, based on e-learning developed by the OECD (Organisation for Economic Co-operation and Development), is intended for employees who are most likely to be exposed to corruption. In 2018, a total of 300 employees were assigned to follow this training. The LISI AUTOMOTIVE employees will undertake this module for a second time 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 assigned to all new hires whose roles may expose them to this risk. Outlook for 2020 The implementation of a Sapin II Law program forms part of a medium-term project. In order to do this, in 2020, the Group will continue thework already undertaken up to now. Themain priorities of the work will be: ■ Finalizing the corruption level risk at Group level then include this risk assessment in the annual mapping. ■ Continue the process to develop evaluation procedures for third parties in line with the CSR strategy to be deployed. ■ Finalize the training process by means of e-learning. ■ Confirm the organization of the Compliance committee by formalizing this by means of an operating procedure.