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D
Corporate Responsibility
D.4
Ethical excellence inAtos’ sphere of influence
Atos
|
Registration Document 2016
87
D
usefulness in guiding the behaviors of its employees and key
stakeholders.
Atos is continually reviewing its compliance policies to ensure
adherence to laws and regulations, as well as relevance and
Compliance Team reviewed the compliance internal controls to
improve the monitoring of our compliance program in all the
Group Business Units.
In addition, compliance internal controls are put in place and
managed by Internal Control Team. In 2016, the Group Legal
internal audits on specific regions, countries or activity include
compliance checks
Some internal audits are performed on compliance matters, and
with laws and regulations were levied against the Group
[G4-SO8]
. No client or supplier claim related to corruption was
levied against the Group
[G4-SO5]
.
In 2016, 1 significant fine of € 160 thousand for non-compliance
Risk assessment andmapping process
implement adequate remediation actions where necessary as
well to understand how the risks identified are perceived within
the organization.
evaluation by members of the Atos Legal, Compliance and
Contract Management department and relevant non-legal
stakeholders (Human Resources, IT, security) of a series of legal
risks (i.e. risks with a legal cause) that allows Atos entities to
Atos has put in place a legal and compliance risk management
process, which was fully integrated to the Enterprise Risk
Management in 2016. This risk management process consists in
results of the Legal risk management exercise are presented to
the Audit Committee of the Group, with a clear mapping of the
As integrated to the Atos Enterprise risk management, the
legal risks of the Group.
systems for credit, commercial and legal risks, through the
Rainbow Process, which sets out defined steps and escalation
procedures
[G4-SO3]
.
In addition, the review of core compliance issues in assessing
business opportunities is an important part of the overall risk
assessment framework. The compliance review process of
transactions is well established within Atos, similar to the review
[G4-56]
Improvement of compliance awareness
e-learning is mandatory for all employees, regardless of their
job, function, country and hierarchical level.
achieve another step in the improvement of its compliance
program. This specific training on the Code of Ethics’ principles
ensures a better understanding of the Code of Ethics and
promotes fair practices in the daily business activities. This
Regarding training, the launch in September 2013 of specific
e-learning on the Code of Ethics has made it possible for Atos to
In 2016, a new version of the e-learning was elaborated and will
be launched in January 2017.
responsibilities and the risks of non-compliance for Atos and the
managers related to the principles of the Code of Ethics, explains
the main Atos policies and processes to ensure compliance with
these principles, and gives concrete examples of ethical
To complement this e-learning module on the Code of Ethics,
specific classroom training sessions on the Code of Ethics are
organized in some Business Units for top managers: ETO²S
training (“Ethics in Tier One Organization School”) presents the
behaviors of manager in their daily work.
In 2016, 86% of employees completed the e-learning on the
trainings
[G4-SO4]
.
Code of Ethics and 642 managers were trained in classroom