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7

7

RISKS AND CONTROL

2. Internal control

183

SAINT-GOBAIN

- REGISTRATION DOCUMENT 2016

a technical standard to Secure the Hosting of Internet

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Applications (SHIA);

a technical standard for SaaS systems which defines

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responsibilities and security measures for implementation;

Rules 4 SG, the new version of the 55 Datacenter Rules);

the central and regional datacenters (Datacenter Security

a set of security rules to annually monitor the security of

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by Saint-Gobain partners for publication on the internet.

a technical standard for the security of applications hosted

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Moreover, the ITAC reference guide was published in 2012 as

describes the automated and semi-automated controls used

an addition to the Internal Control Reference Framework. It

Management and Accounting. It covers the Group’s main ERP

for five key processes: Purchasing, Sales, Inventory, Cash

software and includes:

points;

a reference guide for SAP: ITAC4SAP with 143 control

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a reference guide for MOVEX M3: ITAC4M3 with

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96 control points;

85 control points.

a reference guide for EXACT: ITAC4EXACT with

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with the update to the Internal Control Reference Framework

The ITAC4SAP reference guide was updated for consistency

of tasks).

(143 control points, including the controls for the separation

information systems as follows:

The controls are being gradually integrated into the Group’s

systems covering 121 Group companies), including specific

ITAC100 ITAC4SAP for SAP systems (deployed in 22 SAP

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updates for the Building Distribution Sector;

M3 systems covering 17 Group companies);

ITAC96 ITAC4M3 for MOVEX M3 systems (deployed in 4

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EXACT system covering 2 Group companies);

ITAC85 ITAC4EXACT for EXACT systems (deployed in 1

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covering 1 Group company.

ITAC principles deployed in 1 MS Dynamics system

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prevention manual

Industrial and distribution risk

2.4.5

The Group’s policy for prevention of property damage and

policy implementation through the Sectors and Activities with

Risk and Insurance Department (DRA). The DRA coordinates

and Activities, Prevention Coordinators manage the

the support of the General Delegations. Within the Sectors

collection of standards and best practices, is defined by the

the resulting operating losses, compiled as part of an internal

application of Group policy within the scope of their activities.

At the site level, those in charge of Prevention Management

risk rating software package. This tool assesses risks as well

perform an annual self-assessment of risks at their sites via a

special assessment is carried out for the points of sale.

as the corresponding levels of protection and prevention. This

Research and Development Centers and logistical sites. A

self-assessment is updated annually by the industrial sites, the

Furthermore, regular inspections of the Group’s most

are auditors external to the Group (approximately 450

important sites are carried out by prevention engineers, who

a view to improving their level of prevention and protection

inspections per year). The sites update their action plans with

based on recommendations prepared by these prevention

engineers.

Tools of the Group’s culture of

2.4.6

compliance

Principles of Conduct and Action.

developed through its values, which are formally stated in the

The culture of compliance that drives the Group has

main themes: compliance with rules relating to competition

The compliance program currently focuses on the following

sanctions and embargos.

law, preventing corruption, and compliance with economic

The tools used in implementing the program include:

key messages are posted and tools made available;

a dedicated intranet, entitled Conform’Action, on which

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sanctions and embargos);

Sanctions and Embargos (rules relating to economic

ACT (preventing corruption) and Saint-Gobain Economic

online training modules such as Comply (competition law),

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in-person training;

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distribution of technical guides:

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the Thread of Competition,

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20 best practices in competition law for purchasers;

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such as:

the dissemination and implementation of internal policies

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anti-corruption policy,

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gifts and invitations policy,

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conflicts of interest policy,

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economic sanctions and embargos policy,

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sales agents policy,

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policy on membership of professional associations,

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managers.

frequent dissemination of messages from General

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