A process of continuing improvement
The Ethics & Compliance team develops the Alstom Integrity Programme according to a specific approach made of several steps.
First, the Ethics & Compliance Risk assessment is designed to create the most appropriate ethics and compliance programme for Alstom. Regularly updated, it is based on an analysis of Alstom activities and it enables implement all necessary mitigation factors.
Second, the Alstom Integrity Programme implementation refers to all the means put in place to diffuse a culture of integrity within Alstom, which include:
- An independent E&C team;
- An Ethics & Compliance Policy;
- Our Code of Ethics;
- The E&C Alstom Instructions providing guidance and strict rules to employees, especially with regards to Consulting Companies, Joint Venture and Consortium, Suppliers and Contractors;
- The training with face-to-face training sessions and e-learning programmes which are deployed within the company to explain the Ethics & Compliance policy;
- Communication actions to ensure that employees are well informed about ethics and compliance;
- A community of E&C Ambassadors, all volunteers and coming mainly from the Legal, Finance and HR functions have been appointed to disseminate the Alstom Integrity Culture. They run Ethics & Compliance Awareness sessions and are points of contact for any questions about Ethics & Compliance.
Third, the monitoring and continuous improvement is carried out at both internal and external level. Every year, in the framework of the Yearly Integrity Review, Alstom's top managers report on the implementation of the Alstom Integrity Programme. The E&C team also works closely with the Internal Control and the Internal Audit departments to anticipate and detect risks. And the E&C team is engaged in a certification process of its anti-corruption policy.