6 Ethical practices, economics and corporate governance 6.1. Ethical practices in business relations In addition, a web-based whistleblowing system was introduced in Latin America. This system is managed by an independent organisation (KPMG in 2017) and provides data to the local-based and Group Ethics Committee. For example, 79 cases were reported through this channel in 2017. As a result of the investigation, five employees were dismissed and 17 received warning letters. In this region, a local Ethics Committee handles cases of Group noncompliance in Argentina, Brazil, Chile and Mexico in close liaison with the Group Ethics Committee. A whistleblowing system is also in place in the United Kingdom, and the Group’s financial subsidiaries (BANQUE PSA FINANCE) have a similar system, in accordance with legislation. There are also two email addresses for harassment and diversity issues, as additional ways of reporting a problem and initiating an internal investigation. In 2016, an additional whistleblowing system, specifically pertaining to competition law infringements, in the form of email, was put in place. It is supplemented by an internal procedure and a practical guide. An AU-004 compliance statement was filed with the CNIL and it was also subject to a consultation with the Central Works Council. Lastly, in accordance with management process set forth in the Global Framework Agreement (see section 3.1.1), these strictly internal cases are supplemented by reports on potential breaches identified with suppliers. Such cases trigger an action from the Purchasing Department to resolve the issue with the relevant suppliers. (See section 4.2.2.4.). In 2017, Groupe PSA, in collaboration with a specialised external partner, aims to complement its whistleblowing system by creating a global whistleblowing system which will be deployed in 2018. It makes it possible to offer all of the Group’s employees, via a website, a fully secured platform to report incidents. The system’s overall architecture is designed to ensure an efficient circuit and processing of these “ethical and compliance” issues, while fully preserving their confidentiality. This system is in line with the law of 9 December 2016 pertaining to transparency, anti-corruption and business practice modernisation (called the Sapin 2 law) as well as with the CNIL decision No. 2017191 of 22 June 2017 amending decision No. 2005-305 of 8 December 2005 regarding the single authorisation of automated processing of personal data implemented as part of work whistleblowing systems (AU-004). It aims to provide the Company with an additional tool for timely alerts, via its employees worldwide, regarding crimes or offences, violations of laws or international commitments, corrupt practices, threats of serious prejudices for the public interest. The identity of reporting employees and individuals targeted by them, and the information collected by the reporting recipients are processed confidentially with encrypted connections and contents. This system is intended to cover all of OPEL/VAUXHALL employees, after receiving the approval of employee representatives. In France, it was communicated to the Central Works Council in June, and discussed in December 2017. Therefore, ethical issues were still processed as follows in 2017: ppemployees confronted by practices or situations that are contrary to the rules of the Code of Ethics have different options in reporting them. All the options ensure that their request for action remains confidential. Anonymous requests are processed even if this is not encouraged; ppthe natural channels for reporting inside the Company are the official channels in case of ethics-related questions or situations. Employees can also refer the matter to their human resources manager, their Chief Ethics Officer, their Fraud Detection manager, their ICRM or the relevant Compliance Officer, or directly to the Ethics Committee; ppany manager who is informed by an employee of a violation of the Code must report this through one of the above channels; ppoffenders of any proven breaches to the ethical guidelines may be fined or even dismissed under this process. BREAKDOWN OF CASES REPORTED TO THE ETHICS COMMITTEE IN 2017 73% Misappropriation of assets 20% Other cases of fraud 4% Conflicts of interest 3% Insider dealing Audit mechanisms Supplier audits For the non-Group scope, audits are made on suppliers. The Purchasing Department performs the supplier CSR audits. Since 2008, the Group has conducted 86 social and environmental audits with tier 1, 2 or 3 suppliers. They systematically involve an audit of anti-corruption practices and policy. In 2015, the Group started using an external platform to evaluate suppliers (EcoVadis), which incorporates the indicators of fair practice and compliance (cf. 4.2). Internal Audits The share of Internal Audits pertaining to ethics and compliance is constantly increasing, including for competition, corruption and export control rules. 240 GROUPE PSA I CORPORATE SOCIAL RESPONSIBILITY REPORT 2017
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