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The anti-corruption program

Program content

In line with its values and current legislation, Rubis is putting into practice its commitment, as outlined in its Code of Ethics, to fight against corruption in all its forms, by introducing an anti-corruption program. It consists of the following notable measures:

  • an anti-corruption guide to complete the Code of Ethics. The purpose of this guide is to help employees understand the various forms that corruption can take and offers practical advice on how to prevent risks. This guide is completed by thematic fact sheets (gifts and invitations, conflicts of interest, sponsorship and patronage, interactions with public officials, etc.);
  • a third-party assessment system to help operating staff to identify third parties liable to present a risk, to perform appropriate due diligence and to deal with third parties on a case-by-case basis;
  • mapping of anti-corruption risks;
  • regular campaigns to raise awareness of ethical and anti-corruption rules among employees;
  • a global ethical whistleblowing system: the Rubis Integrity Line. It enables all Group employees, as well as external and temporary workers to report observations in a secure way, via a website;
  • a set of disciplinary sanctions;
  • a system of accounting controls;
  • the assessment of the implementation of system measures: the internal risk management system incorporates checks on the application of the Group’s ethics and anti-corruption rules. In addition, each subsidiary reports annually to the Group’s Compliance and CSR Officer on progress as regards to program roll-out.

The Group is committed to a continuous improvement approach and supplements its anti-corruption system in line with changes in legislation and best practices.

Governance

The Group and its management bodies have prioritised the prevention of corruption. Since 2015, variable compensation for the General Partners includes an ethics criterion relating to the implementation of the system across all entities.

A specific organisation has been put in place to support the roll out and monitoring of the anti-corruption programme. The 38 Compliance Advisors, appointed in operating entities, ensure that the anti-corruption policy is properly understood and is being applied in the field.

The “Think Compliance” newsletter has been distributed since 2018 to support the dissemination of compliance culture within the Group.