Ethics & Compliance @ Tractebel
A high level group commitment
- Complete commitment to ethical rules
- Exemplary management
- Zero Tolerance
Our ethics principles are the foundations of our business and a key driver for our future growth. All Tractebel staff must be committed to fully respect and promote these ethics principles in an exemplary way. To be compliant with Ethics is a basic rule that should be integrated in all our business activities. We are all accountable for it, at all levels and, as already clearly stated before, a zero-tolerance policy will be applied towards any instances of non-compliance. Doing business with Ethics is a condition number one.
Our 4 commitments
Tractebel bases its ethics and compliance policy on four simple and specific action principles:
- To act in accordance with laws and regulations
Our employees must in all circumstances observe international, federal, national and local laws and the professional codes of practice applicable to their activities.
- To establish a culture of integrity
Integrity is about avoiding any conflict between personal interests and the company’s interests. It underpins an absolute belief in our obligation to respect certain values. It thereby creates a climate of trust and acts as a shield against corrupt practices.
- To behave fairly and honestly
Employees fulfil their undertakings and engagements scrupulously. Whenever they communicate, within the company or externally, they do so in good faith and in a constructive spirit, with a concern for providing genuine, accurate and complete information.
- To respect others
This principle particularly applies to the respect for the rights of individuals, for their dignity and their differences, as well as respect for different cultures. It also applies to tangible and intangible goods that belong to others.
Tractebel Ethics & Compliance Program
Tractebel, as a leading global player in energy, water and infrastructure engineering, aims to build a trustworthy and reliable relationship with all its stakeholders adopting a culture of integrity and zero tolerance towards fraud, corruption and violations of human rights. In line with ENGIE Group’s values and commitments, Tractebel seeks to act in all circumstances in accordance with the laws and regulations in force in the countries where it operates. To consolidate such principles, Tractebel has implemented an Ethics & Compliance Program that underpins everyday strategic decisions, management, and professional practices for all Tractebel Staff.
Our values, requirements, and ethical ambitions
For Tractebel, ethics are an essential part of our strategy, management style, and individual professional practices. Ethics is crucial to drive performance.
Tractebel Ethics & Compliance Policy
The Tractebel Ethics & Compliance Policy which establishes the culture of integrity and zero tolerance towards any illegal or unethical actions and adopts the ENGIE Group Ethics Charter, and other policies and procedures, as the foundation for its Ethics & Compliance Program.
The Group Ethics Charter and Practical Guide to Ethics
The Group Ethics charter and Practical Guide to Ethics, which set out the general framework within which each employee’s professional behavior must fit and to which all Tractebel contractual counterparties shall be committed, presents the Group four fundamental ethics principles and describes the Group’s ethics and compliance organization, and the Practical guide to ethics, which supports the implementation of ethics in everyday life by presenting concrete examples by theme. The four fundamental ethics principles are:
- Act in accordance with laws and regulations
- Behave honestly and promote a culture of integrity
- Be loyal
- Respect others
The referentials unify the policies and procedures used by Tractebel for the concrete implementation and development of ethical culture within the Group: the Integrity Referential, the Human Rights Referential and the Compliance Referential.
The Integrity Referential
The Integrity Referential provides Tractebel’s Anti-Bribery Management System, a framework for behaving honestly and promoting a culture of integrity based on the UK Bribery Act, the US Foreign Corrupt Practices Act (FCPA) and the French Sapin 2 law. The Integrity Referential includes the following policies and procedures:
Due diligence policy
The Group has adopted several ethical due diligence policies, which consist in investigating our counterparties, namely our suppliers and subcontractors, our commercial consultants, our partners in the context of projects, beneficiaries of sponsorship, etc., before the beginning of any business relationship or partnership. This ensures that these parties do not represent any major ethics risks and that they are not in violation of any rules governing human rights, health and safety, and/or the environment).
Due diligence policy on partners related to investment projects:
This policy covers the due diligence required for future counterparties for projects.
Due diligence policy in the context of patronage and sponsorships:
This policy covers the due diligence required for future recipients of corporate sponsorship and patronage.
Due diligence policy level 1 – Suppliers and subcontractors:
This policy covers the due diligence required for future suppliers and direct sub-contractors.
Business Consultants policy:
To prevent any ethical risks that may arise over the course of a project, from the contract negotiation phase to its implementation, the Group has built a business consultant policy whose key elements include: an ethical due diligence of all business consultants, the analysis of the business rationale of their missions, a framework governing compensation, traceability of selection decisions and services provided.
Gift, hospitality and technical trips policy
The gifts, hospitality and technical trip policy aims to prevent any type of corruption, conflict of interests or influence peddling. It outlines the general principles to respect in matters of gifts and hospitality, in particular for technical and study travel, relations with public authorities and invitations to events. It provides a framework for the transparency of the practice by requiring information, declaration or prior authorization depending on the amount of the gift, invitation for technical trip or study. It is supported by a dedicated Group tool (My Gift & Hospitality Register).
Policy for the prevention of conflicts of interests
The policy for the prevention of conflict of interests aims to eliminate any doubts concerning the impartiality of a decision taken by a Group employee or his or her potential lack of loyalty in taking a decision, and to find adequate solutions in case of a conflict of interests, such as the possibility for employees to abstain without having to disclose the nature of their conflict of interests, in order to preserve employees’ right to respect for their private life. This policy informs employees and guides them if facing such situation: it gives them examples of situations, and specifies the process for management and traceability in this matter.
Operating rules for Patronage and sponsorship
In addition to the due diligence policy for beneficiaries of sponsorship, these Operating Rules are intended to provide a framework for the support provided by the Group through its patronage and sponsorship efforts, in accordance with the law, particularly regarding fight against corruption and the Group integrity requirements. It ensures transparent practices by establishing rules for selecting projects, partners and activities. It also sets up a process for validating projects by the Patronage and Partnership Committees at the Group and within each entity.
Ethics, health & safety, social & environmental responsibility clause
The Ethical, health & safety, social & environmental responsibility clause must be inserted into all contracts with every supplier, service provider, subcontractor and partner, regardless of the entity with which they are working. This clause includes the prohibition of all forms of corruption, compliance with competition and embargo rules and compliance with human rights standards and regulations. It directs the contracting party to review the Group’s ethical documents, requires it to follow the ethical rules outlined in these documents throughout the duration of the contract, and to ensure same respect of these rules by its own subcontractors if any. It also informs it of the contractual consequences in case of non-compliance with these rules.
The Human Rights Referential
The human rights referential provides a framework for implementing our principle of respect others and brings together all of the Group’s commitments in the area of human rights.
The Vigilance Plan
As part of ENGIE Group, Tractebel adopts ENGIE’s vigilance plan which is taken in accordance with the French law on the duty of vigilance of parent companies and ordering companies. It targets serious violations of human rights and fundamental freedoms, human health and safety, and the environment.
The Modern Slavery Statement
Tractebel’s human rights commitments, as part of ENGIE Group, are based on the applicable international standards and on the national laws that apply to its activities, such as the French vigilance law and the UK Modern Slavery Act. The Group has put various measures into place to ensure that its operations and those of its supply chain do not involve modern slavery (including: slavery, forced work, and human trafficking).
The Compliance Referential
The ethical compliance system provides a framework for implementing the principle of acting in accordance with laws and regulations. It outlines how the Group is organized to help implement all of the Group’s ethics procedures and tools for monitoring compliance.
Group Codes of Conduct
The Group has developed various Codes of Conduct in order to apply the commitments outlined in Group’s Ethics Charter to each of its activities and professional practices.
The Code of Conduct on Suppliers Relation
The Code of Conduct on Lobbying and interest representatives
ISO 37001 certification granted to Tractebel
Tractebel is certified under the ISO 37001:2016 standard by Speeki Europe, certification body accredited by ANSI-ASQ National American Board (ANAB). This standard specifies the requirements and provides guidance for establishing, implementing, maintaining, reviewing and improving an anti-bribery management system.
Of particular significance, the certified system is deployed by Tractebel across its entire worldwide presence. The benefits of such certification include raising visibility of our anti-corruption commitments, increasing quality and continuous improvement of our anti-corruption program, and lowering our exposure to legal and financial risks.
“This certification, combined with ENGIE S.A. Group Certification, demonstrates our strong commitment to the excellence of our Ethics & Compliance Program,” said Sabien Vermeulen, Tractebel’s Chief Legal, Ethics & Compliance Officer.
Access the certification here.
The validity of our certificate can be confirmed by request through this contact form to the auditor.
This System supplements existing channels and strengthens the Group’s Ethics and Compliance efforts. It is open to anyone and is easy to use, confidential, and anonymous if need.
The whistleblower reports an incident, anonymously or not. The whistleblower can alert in French, English, Spanish, or Portuguese. Messages written in other languages will be translated.
- By mail to the Tractebel BU Chief Ethics & Compliance Officer who will handle your alert in a confidential way at email address : email@example.com
- By mail at the external service provider who receives the alerts at ENGIE level at email address : firstname.lastname@example.org
- By a Toll-free number: + 800 2348 2348 (see the concerned countries on the ENGIE website)
- By the Call-charge number: + 33 1 45 51 03 67
You will find more information on ENGIE website.