Saint Gobain - Registration document 2016

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4 AN EFFICIENT AND RESPONSIBLE GROUP
1. Reference policies
66 SAINT-GOBAIN - REGISTRATION DOCUMENT 2016
Reference policies 1.
THE COMPLIANCE CULTURE 1.1
The compliance culture that drives the Group is developed
through its values, formalized in 2003 in the Principles of
Conduct and Action (see chapter 1, section 2.2.1).
worldwide.
resulting obligations, in all the Group’s Activities and
program since 2009 which strengthens the effective
application of the Principles of Conduct and Action and the
This compliance culture has been supported by a full
Compliance is an ongoing obligation that applies to all
hierarchical levels, it becomes obvious for committed
managers.
employees. As regularly noted by the Group’s General
Management, the principle of zero tolerance is required. At all
Regularly enriched since its launch, the compliance program
is today focused on into the following main subjects:
audits, availability of practical guides and newsletters but
also dedicated teams for all operational questions on the
Competition Law Plan is composed of various training
measures (online and in-person), the performance of
subject;
compliance with the rules on anti-trust law: the ‹
corruption in relations with public officials and the private
agents, etc.) and is monitored by a network of
correspondents by General Delegation and by Sector that
sector; it is composed of training tools (online and
in-person), internal policies (gifts, conflicts of interest,
answer operating questions on this subject;
based on the management of measures and good
practices already implemented in various subsidiaries to
prevention of corruption: the anti-corruption program is ‹
prevent the risk specifically connected with international
commercial transactions; it targets passive and active
external lawyers.
for which screening tools, training (online and in-person)
and specific policies are also applied, as well as active
compliance with economic sanctions and with embargos ‹
monitoring of changes in close association with specialist
This results in a well-established and well-structured
managers and the compliance network, it is constantly
developing based on topical subjects.
compliance culture. Disseminated by the Group’s General
Management and passed on to all Group levels by the
Teams in charge at all Group levels
The compliance program is monitored by the Board of
Directors of Compagnie de Saint-Gobain. Its implementation
General Secretary and composed of more than 100 functional
operating managers who are members of Compliance
is based on a compliance network, coordinated by the
Committees within the Group and the General Delegations.
THE COMPLIANCE NETWORK
COUNTRIES
AND SECTORS
COMPLIANCE
CORRESPONDENTS
35 PERSONS
GROUP
GROUP
COMPLIANCE
COMMITTEE
9 MEMBERS
DELEGATIONS
COMPLIANCE
COMMITTEE
(1 PER DELEGATION)
65 PERSONS
At operational level, the application of our values and our
compliance culture is supported by:
both internally and externally;
the General Management, which refers to them regularly, ‹
promotes the Principles of Conduct and Action among all
employees;
the Responsible Development Department, which ‹
the Legal Department, which draws up and implements ‹
the programs associated with specific themes;
the managers, who endorse them and implement them; ‹
the Internal Audit and Control Department (see chapter 7, ‹
section 2), which verifies the effective application thereof.