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2 SUSTAINABLE DEVELOPMENT GREEN AND RESPONSIBLE GROWTH DRIVING ECONOMIC PERFORMANCE 58 • an online e-learning module. The aim is that, at the end of the session, the trainee is familiar with Our Principles of Responsibility and more comfortable using them in his or her job. At the end of 2011, more than 21,000 employees participated in the module: 94% rated the module as good or excellent. A professional alert system To allow each employee to exercise their right to report a problem, a professional alert system is currently being deployed. In compliance with local legislations, this market solution is provided by an independent company and proposes alert categories, a questionnaire, and information exchange protocol between the person issuing the alert and the person responsible for investigating it. The main players in this process are the Compliance Offi cers (see “Dedicated teams and organisation”). The system is currently in place on the American continent and implementation is planned for the whole Group, accompanied by an internal communication plan that identifi es the persons responsible for investigating alerts received. Dedicated teams and organisation The program requires implementation of an organisation including the following: • a Governance Committee and a network of Principles of Responsibility Advisors. They are responsible for the implementation and roll out the Responsibility & Ethics Dynamics program. • a Compliance Committee and a network of Compliance Offi cers. They are responsible for detecting and managing cases of noncompliance with the processes defi ned, in line with local laws and regulations and Our Principles of Responsibility. Stakeholders and committees exercise their authority within activities of infl uence and control. In particular, the Governance Committee must ensure coherence with the Group’s strategic plans. It provides Executive Committee members with information on trends that, for example, implement the company change program. One a year Twice a year Upon Request Executive Committee Governance Committee Define, Explain & Spread the Rules PoR Advisers (1 per Entity) REGISTRATION DOCUMENT 2011 SCHNEIDER ELECTRIC Compliance Committee Detect & Manage Non Compliance Compliance Officers (1 per geograph. area) Measuring rollout and effectiveness The Responsibility & Ethics Dynamics program is primarily the subject of regular internal communication. The objective is to inform all the employees and remind the management teams of the priority actions that they must drive forward, dependent on the risks to which they are exposed in their countries of operation. Two particular actions were undertaken in 2011: • one for the Country Presidents during the year to reemphasize the importance of their role as sponsor for their countries, the expectations at the end of 2011 and to respond to their questions; • and another addressed to the 500 main Group managers to inform them of the developments brought by the program and to raise their awareness once more on the importance of communication within their teams. In addition and since the program was launched in 2010, it has been the subject of an assessment conducted by Internal Audit. Our Principles of Responsibility were rolled out in all the Group’s entities in 2010. The results of the Internal Audit, including the fi ndings of a survey of 10,000 employees and an audit that includes Argentina, China, the United Arab Emirates, the United States, France, India, Indonesia, Italy, and Russia were: • 73% of employees questioned said they were familiar with Our Principles of Responsibility; • 84% of survey participants stated that the information given was useful and comprehensive. In 2011, the assessment of the Responsibility & Ethics Dynamics program as a whole, with a particular focus on the 19 most exposed countries in which the Group works, according to the corruption perception index of Transparency International. The audit shows the level of knowledge of Our Principles of Responsibility stands at 75% (83% if a recently acquired entity is excluded). Beyond the fi gures, the audit makes two very important points clear to us: • on the one hand, regarding the means of communication judged the most effective; • and on the other, on the level of perception of Our Principles of Responsibility by position within the company. For 2012, these lessons are driving us to integrate communication into the Schneider Electric University programs and to use supplementary action for the job posts where the result is weakest.
Award for excellence 2011 The Group is also proud of having been included once again in The Ethisphere Institute’s World’s Most Ethical Companies indicator. Schneider Electric is among 100 international companies recognised for their ethical commitment and behaviour. The performance measures looks at the existence and consistency of governance, the reputation and infl uence of the company, the quality of actions promoting citizenship and social responsibility, and the culture and actions promoting ethics. This recognition is reassuring for the Group as it implements the Responsibility & Ethics Dynamics program. 2.5 Fight against corruption Approach and action plans Schneider Electric must complete surveys, controlled by rating agencies and investors on sustainable development practices, which often include questions on very specifi c subjects such as our anti-corruption policies. The Group makes an effort to respond to all questions with full transparency. The Governance Committee, presided over by the Executive Vice President for Strategy & Innovation, applies a seven-point progress plan based on the Responsibility & Ethics Dynamics program: 1. identify high level employees to monitor the rollout of the Responsibility & Ethics Dynamics program; 2. defi ne best practices to prevent illegal actions, strengthen management’s major role and promote use of the professional alert system; 3. ensure that all policies comply with Our Principles of Responsibility; 4. inform employees of standards and procedures; 5. implement monitoring, audit, and reporting systems; 6. establish a discipline for the practical implementation of standards and procedures; 7. in the event of a breach of the ethics principles, take the corrective measures necessary, including the consolidation of procedures. SUSTAINABLE DEVELOPMENT GREEN AND RESPONSIBLE GROWTH DRIVING ECONOMIC PERFORMANCE Outlook for 2012 Program rollout will continue in 2012 along various axes: • implementation of the recommendations given during the internal audit in late 2011, primarily continuing communication actions and training for employees in countries most susceptible to breaches of ethics; • continuation of implementing simple measures to enable employees to understand ethical dilemmas in an operational context and to help them place themselves above the risk level to which they may be exposed; • working with the Principles of Responsibility Advisors to forge closer ties between the principles and the operational procedures and directives that should be readily available to all Group employees. Examples In full coordination with the Responsibility & Ethics Dynamics program, the awareness-raising actions, linking the Sustainable Development, Legal, Security and Internal Audit functions have been led by the line managers in 2011. Various other anti-corruption initiatives have been implemented, at the national or regional level: • in France, Schneider Electric is involved in defi ning ethical standards as part of the Business Ethics Commission of the GIMELEC, a grouping of electrical equipment manufacturers; • in Russia, Schneider Electric signed an ethics charter with the Association of European Businesses; • Schneider Electric Egypt obtained specifi c anti-corruption certifi cation for its work with the National Electricity Corporation in Sudan. REGISTRATION DOCUMENT 2011 SCHNEIDER ELECTRIC 59 2
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274 PERSONS RESPONSIBLE FOR THE REG
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Schneider Electric SA Headquarters:
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