Saint Gobain - Registration document 2016

AN EFFICIENT AND RESPONSIBLE GROUP

1. Reference policies

SAINT-GOBAIN

- REGISTRATION DOCUMENT 2016

The tools used to implement the program are as follows:

Group employees;

a dedicated Intranet, known as Conform’Action, where key

messages are passed on and tools are made available to all

training, including various e-learning modules;

dissemination and implementation of internal policies;

internal and external audits;

the compliance alerts system, allowing employees to

report any non-compliance with the applicable laws, the

Group’s internal rules and procedures and the Principles of

necessary, investigated. When they are found to be

justified, appropriate measures are taken.

Conduct and Action. All reports are examined and, if

conducted such as:

Correspondents of the General Delegations and Activities in

October 2016 and targeted awareness measures were

build teams around the subject and identify the main action

plans, a seminar brought together all the Compliance

Supporting the compliance culture within the Group involves

calling upon many participants both centrally and locally. To

the publication of a guide dedicated to purchasers on the

20 good practices in competition law in April 2016;

the publication of a guide intended for all employees

containing measures concerning competition law (the Fil

Concurrence [“Competition Line”]) in July 2016;

Anti-Corruption Day held on December 9, 2016.

the notice from the General Management on

anti-corruption measures during the International

objectives on compliance program. As well as for the

online training program ACT on preventing bribery during the

first year of presence.

Principles of Conduct and Action, and the anti-trust rules, all

manager joining Saint-Gobain will have to also achieve the

The Group also added the anti-bribery training to its

presence, as an objective for 2018 (see chapter 5, section 2.1).

Action and Conduct), Comply (competition laws) and Act

(anti-corruption prevention) during their first year of

So, Saint-Gobain esthablished that 100% of the new managers

will have passed the e-learning courses Adhere (Principles of

Reference points

The General Secretary, the Legal Department and the

network of Compliance Correspondents work to

understanding of the rules by all employees and checking

the correct application of the rules:

disseminate the compliance culture within the Group,

ensuring the communication of messages, a good

training program “Comply” on competition law and the

online training program “Act” on preventing corruption;

Group managers are required to follow the online

compliance;

in-person training is organized by the General

Delegations and the Sectors on the subject of

Compliance Committees aiming to review the subjects

are organized several times a year for the Group’s

General Management and the General Delegations;

Activities are adapted and implemented;

associations, gifts, conflicts of interest, commercial

agents, etc.) are disseminated in the countries and

policies on every sensitive subject (professional

audits are organized every year, including compliance

topics.

RESPECT FOR HUMAN RIGHTS

1.2

The first two principles of the Global Compact, which

Saint-Gobain joined in 2003 (see chapter 1, section 2.2), invite

influence” (principle 1) and to “make sure that their own

companies are not complicit in human rights abuses”

businesses to “promote and respect the protection of

internationally proclaimed human rights within their sphere of

(principle 2).

In 2008, Pierre-André de Chalendar, Chairman and CEO of

Saint-Gobain, signed the statement of support for human

Rights. Saint-Gobain’s values, formalized by the Principles of

Conduct and Action, are an essential means of mobilization

rights by company leaders on the occasion of the

anniversary of the Universal Declaration of Human

Rights and the applicable conventions of the International

Labour Organization.

for human rights owing to their reference to international

conventions, particularly the International Charter for Human

contract of employment.

(Respect for employees’ rights) state that “the Group

Companies […] must refrain from any form of recourse to

More specifically, the Principles of Conduct and Action

latter are working on a Group site”, such concepts having to

be taken within the meaning of the applicable Conventions of

forced labor, to compulsory labour or to child labour, either

directly or indirectly or through subcontractors when the

recruitment, during execution or on termination of their

the International Labour Organization. They shall not apply

any discrimination whatsoever vis-à-vis their employees, on

by performing additional verifications, as needed, in

cooperation with the local authority.

The Group companies shall verify the age of their employees

any way, particularly through dialog with the personnel

representation entities, in an effort to detect any violations.

Similarly, for child labor, the Group companies shall ensure

that they are not involved in forced or compulsory labor in

Since 2014, the Group has increased the collection of

information on discrimination. The systems for collecting

complaints have been improved to favor employee concerns.

The clarification of internal definitions has made it possible to