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A
Corporate and social responsibility report
Annex III -
Being an ethical and fair good player in business
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Worldline
2016 Registration Document
compliance matters processed by the Group Operational
Group’s compliance approach, by rolling out and monitoring
Steering Committees (bottom-up).
compliance related reporting to the Group Compliance
Compliance Committee (top down) and by improving
Team:
initiated and implemented by the Group Legal Compliance
governance framework by way of several concrete measures
Additionally, Atos recently enhanced the compliance
of the Group Compliance Team;
local leadership of compliance matters under the guidance
the General Counsels of Atos, aiming to strengthening the
Creation of a Global Legal Compliance Board involving all
●
reporting to the Group Compliance Steering Committee,
programs within the GBU Compliance Committees;
and the monitoring of the effectiveness of the compliance
composed of compliance KPIs, aiming to improve the
Development of country compliance dashboards,
●
clarification of the ambit of responsibilities and duties;
Improve the role of the compliance function including the
●
key compliance topics;
program through presentations and trainings on a variety of
compliance culture by greater visibility of the compliance
Enhance compliance leadership and the overall Group
●
Committee.
to the Group Compliance Program to the Group Executive
Communication on the milestones and realizations related
●
Compliancemonitoring
A.4.1.1.2
will launch the Non-Compliance Response process [GRI 102-33].
the Head of Internal Audit (both within Worldline and Atos), who
to be reported to the Head of Legal and Compliance and/or to
Any suspected non-compliance detected within the Company is
actions in a measureable and consistent manner, in case of
investigate report and take decisions, such as remediation
the applicable laws and regulations. This process defines how to
non-compliance behaviors.
event of breaches of the Code of Ethics, and/or infringements of
(defined in the Group’s anti-fraud policy) to be followed in the
The Non-Compliance Response process is an internal process
Response Process and confirmed as a critical concern. All
case investigated at Group level through the Non-Compliance
Officer, who will report to the Group Executive Committee any
Response Team is reported to the Group Chief Compliance
Any case which is investigated by the Non-Compliance
governance matters as far as compliance is concerned are
Document.
described in Chapter
4.5 Risk management in this Registration
through this process [GRI 102-34].
In 2016, no cases deemed critical were reported at global level
[GRI 102-17]
Policies to prevent compliance risks
A.4.1.1.3
export control laws, and fraud in general.
bribery, corruption, and violations of competition laws and
and as an affiliate of the Atos group, Worldline has implemented
As a signatory of the United Nations Global Compact since 2010,
several internal policies to prevent compliance risks such as
approval by the Finance department.
Management department, which recommends or not the
specific piece of software, the Business Partner Tool): their
before the beginning of any business relationship (using a
Worldline in developing/retaining its business are screened
Any intermediaries, consortium partners or consultants assisting
is screened by the Legal, Compliance and Contract
disproportion regarding the compensation, the business partner
are verified beforehand. In case of risk of corruption/insolvency/
behavior and knowledge of ethics are essential criteria which
To protect Worldline from any disproportionate gift or benefit
provider or recipient. Management can carry out checks in case
gifts, invitations and other benefits of which Worldline is a
gifts and benefits was implemented in 2013, aiming to screen
given or received by a Worldline employee, a policy concerning
of identified risk.
faith to line management or, if applicable, to the competent
measure against workers who report illegal practices in good
prohibits Worldline from any discriminatory or disciplinary
the management and support function in preventing fraud, and
Worldline’s General Counsel is responsible for internal
Group Compliance Team of Atos in coordination with
raised by an employee or assumed by an internal control, the
public authorities. If an allegation of fraud/non-compliance is
investigations.
Atos group’s policy), which defines roles and responsibilities of
Worldline has also rolled out an anti-fraud policy (as part of the
competitors.
to be adhered to by meetings with potential and known
A roundtable policy, stipulates the main rules of fair competition
clear processes to mitigate risks. Thanks to these measures, the
prohibitions related to Export Control Regulations, and providing
An Export Control policy, explaining the main principles and
suppliers related to corruption.
regulations in 2016. It received no complaints from clients or
non-monetary sanctions for non-compliance with laws and
Group was not subject to any penalties or any major