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Corporate and social responsibility report
Annex III -
Being an ethical and fair good player in business
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Worldline
2016 Registration Document
lists, it is rejected by the BPT.
business partner is on any of the main international sanction
international laws, regulations and sanctions and in the event a
business partners. In addition, Worldline closely complies with
the Group CFO and Group General Counsel, for high-risk
low-risk business partners, to complex approval processes by
ranging from a simple approval process by the Head of Sales for
across the entire Atos group. BPT uses a series of questions and
automated tool, the Business Partner Tool (BPT), applicable
paper-based review and validation process was replaced by an
diligence and validation process. In 2015, the former
assessment will identify the appropriate validation process,
perform the required validation process. The level of risk
to perform a risk assessment on business partners, as well as to
documents to gather the different items of information needed
developing and retaining its business are subject to a due
consortium partners and consultants assisting Worldline in
Worldline’s business partners, including agents, intermediaries,
practice in the area of business partner management.
the Group’s Compliance department were revised to reflect best
In 2015, the business partner contract templates developed by
seek approval from management.
similar contribution. When in doubt, an employee is required to
disproportionate gift, invitation, hospitality package or any other
prevents Worldline employees from accepting or offering any
the compliance efforts relating to corruption. The policy
In addition, the Worldline contribution policy further enhances
rules and procedures to be followed in the event of inspection
Worldline also has a “Dawn raids” policy which provides a list of
by local authorities.
and the Code of Ethics is a key Group priority. As detailed above,
non-compliance alerts.
management process and the action to be taken in response to
the Non-Compliance Response Procedure sets out the
Prevention of fraud and non-compliance with Worldline values
several key actions:
framework more generally, Atos group Compliance will focus on
To support this objective, and enhance the compliance
manage legal and compliance risks throughout the chain of
Redesign Worldline legal risk mapping to better identify and
●
global operations;
particular by implementing the Global Legal Compliance
operations by improving the governance framework, and in
Reinforce the compliance culture throughout global
●
Board;
compliance dashboards and compliance KPIs, permitting
each country through the deployment of the country
Greater visibility on the strength of the compliance culture in
●
compliance culture of the Group;
targeted enhancements and trainings to improve the overall
in late 2016.
Management Systems is expected to be completed by ISO
standard related to Anti Bribery and Corruption
Benchmarking Worldline compliance with the ISO 37001
●
[GRI 205-2]
Improving awareness
[GRI 102-16] and
A.4.1.1.8
respect to Company policies through appropriate dissemination
Worldline aims to promote awareness of employees with
part of Worldline’s compliance program.
of these policies, including through training program, which is
In the first instance, Worldline has implemented a thorough
personnel representative bodies, which makes the policies’
benefits need to be presented to local management and
policies, such as the policy on gifts, entertainment and other
deployment plan for its compliance policies: all compliance
policies.
communication to the employees of the new compliance
deployment plan is the launch of mandatory global and local
content enforceable within the Group. The next step of this
community, called “Legal Compliance Organization”. The
communication channel with employees, who can join a specific
application of policies.
employees to ask questions about compliance and the
well as applicable internal rules and policies and to enable
objective is to circulate information on compliance matters, as
In addition, Worldline’s social network, blueKiwi, is a direct
program.
Worldline to achieve another step in improving its compliance
of specific online training on the Code of Ethics has enabled
Concerning awareness, the launch in late 2013 and during 2014
adoption of fair practices on a daily basis. This e-learning training
ensures a better understanding of the Code and promotes the
This specific training on the principles of the Code of Ethics
employees completed it [GRI 205-2].
country and hierarchical level and in 2016, 79% of Worldline
is mandatory for all employees, regardless of their job, function,
To complement this e-learning module on the Code of Ethics,
professional activities relate to the content of the Code.
persons considered as “core target” or whose day-to-day
specific webinars were organized for top managers and all
103-2 Customer Privacy]
Data protection
[GRI 102-13] and [GRI
A.4.1.2
Worldline’s comprehensive data
A.4.1.2.1
protection approach.
value of personal data used in day to day business is now
account or on behalf of its customers. The importance and
Every day, Worldline processes personal data for its own
employees is managed with a particular attention.
obvious. Personal data from both Worldline’s customers and