Infrastructure for energy storage and distribution

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:

  • a guide to applying the anti-corruption policy that supplements the Code of Ethics. This guide aims to help the senior Managers and employees who are most exposed to identify at-risk situations and to adopt practical preventive measures. It is supplemented by thematic practical information sheets (gifts and invitations, conflicts of interest, sponsoring and sponsorship, 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 prioritized the prevention of corruption. Since 2016, variable compensation for the Management includes an ethics criterion relating to the implementation of the system across all entities.

A specific organization has been put in place to support the roll out and monitoring of the anti-corruption program. The 37 Compliance Officers, appointed in operating entities, ensure that the anti-corruption policy is properly understood and is being applied in the field.

The “Think Compliance” newsletter was created in late 2018 to support the dissemination of compliance culture within the Group.