2017 is a year in which Alstom became a leading light in the fight against corrupt business practises – and not just for the railway business. A conversation with Pierrick Le Goff, Alstom SVP & General Counsel.
In June, Alstom gained ISO 37001 certification, a new international standard aiming to codify anti-corruption measures within enterprises. The company was the first major industrial to achieve certification. By October, Pierrick Le Goff, Alstom SVP & General Counsel, had been invited to give the keynote address at IFBEC 2017 in Washington D.C., the International Forum on Business Ethical Conduct for the aerospace and defence industries, attended by leaders such as Airbus, Lockheed Martin, Boeing and BAE Systems. Soon after that, Alstom won two trophies at the prestigious Legal Awards 2017 held in Paris: Silver for ‘Best Legal Department’ in the Industrial sector, and Gold, for being ‘Most Innovative Legal Department’ all round.
How did it come about that you gave the keynote address at a forum dedicated to aerospace and defence?
Alstom has unique insight into the process of attaining ISO 37001 certification, a very recent standard. None of the IFBEC participants had the accreditation yet, and in Alstom, though a railway actor, they saw an industrial comparable in terms of size, footprint, logistics, risk factors and so on. They wanted to know more about the challenges and benefits of certification. Alstom works via public tenders, often with state entities, as do companies in aerospace and defence. They were wondering if ISO 37001 could become a prerequisite for public tenders.
In a few words, what were your messages?
I spoke for over 45 minutes… So I’ll try to be brief! On tenders, I can’t predict any better than anyone else, but it was a consideration for Alstom too. Short-term, accreditation could gain a company extra points, especially in ethics and compliance questionnaires. Mid to long-term, I can imagine a snowball effect. In a global fight against corruption, it would be logical. In the meantime, however, there are many practical benefits to be gained from the certification process itself.
Could you give an example?
AFNOR are more well-known as experts in certification rather than in compliance. The agency was a good choice for Alstom thanks to the perspective it gave us. I explained to IFBEC that even with a comprehensive Code of Ethics and an advanced E&C organisation – as does Alstom – gaining ISO 37001 certification is not a “rubberstamp” affair. It requires preparation and structure, a clear E&C mission statement and effective tools to back it up. For example, we quickly learned that we had greater expertise in deployment than in performance. But the point of certification is to measure performance! For that, you need appropriate KPIs. We suggested the number of trained employees, or the number of alerts registered through our systems… But working with AFNOR helped us see that while positive indicators, they really only demonstrated the deployment levels of our anti-corruption measures.
What was AFNOR’s advice?
In this case, we established that it would be more useful to look at the proportion of alerts that were made anonymously, as our system allows. Low anonymity equates to high confidence in the system - a sign that it is performing well, impacting the culture and behaviour of employees. This is the true objective of an Ethics & Compliance framework. There were many such examples that came out in the auditing process.Why did Alstom become an early-adopter of ISO 37001 certification?P.L.G: As a company, Alstom has a principle of continuous improvement. Gaining ISO 37001 was the logical next step in terms of Ethics & Compliance. We saw early on that launching Alstom into certification would be an internal and external expression of commitment and self-discipline. ISO Certification is the beginning of something, not the end. Remember, companies undergo constant auditing to retain the certification. For our part, Alstom intends to expand the certification to all its regions.
Is cross-sector knowledge-sharing, such as your keynote at IFBEC, likely to become more common?
As regards anti-corruption measures, yes I believe so, thanks to the creation of ISO 37001. For now, return-on-experience is scarce as so few companies have been certified. The fight against corruption comes before everything else, and I’m pleased that a new international standard is elevating the subject. I’m proud that Alstom is a global leader on such a critical issue that crosses the boundaries of sector.
Congratulations for the result at the Leaders League Legal Awards 2017. Was ISO 37001 a factor?
Yes, absolutely… We were delighted to receive the Silver award for the second year in a row, and especially to obtain Gold in a category fully aligned with Alstom’s strategic focus on innovation. The key reason cited by the jury for awarding the Gold trophy was Alstom’s pioneering work regarding ISO 37001 certification. This is a great collaborative achievement and I am thankful to all members of our Legal & Compliance teams for the outstanding result!