The Ethics & Compliance team develops the Alstom Integrity Programme according to a specific approach made of several steps.
Ethics & Compliance Team
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.
Alstom complies with all laws and regulations, as well as the international standards that apply to the conduct of business in all countries. Some practices that occur in business environments can put Alstom and its employees at risk. They require clearly defined instructions to guide any of the employees in complying with the law and respecting Alstom's values and rules.
Gifts & Hospitality
In some cultures, good business relations may sometimes involve the
exchange of symbolic gifts and hospitality.
Offering gifts and hospitality, especially with a public official, can
appear as bribery. The acceptance or offering of gifts is also related to
the issue of conflicts of interest and can expose Alstom and its employees
to accusations of unfairness, partiality or deceit.
Alstom employees must not offer, accept or authorise a family member or
relative to accept gifts, money, loans, invitations or any other form of
special treatment from anyone involved in business with Alstom, if the
ultimate goal is to influence business decisions.
Employees may accept or offer, on behalf of Alstom, an occasional business
meal invitation or an occasional non-pecuniary symbolic gift of low value
if it can be reciprocated on another occasion. Any employee required to
offer or to accept a gift or invitation of value as a result of protocol,
courtesy or other reasons must first inform his or her Unit manager and the
Political contributions are often subject to national laws and vary from country to country. Even when legally permitted, such contributions can be a source of abuse or otherwise perceived as a questionable practice. Political contributions can be used to disguise an improper advantage in order to obtain or retain a business. In simpler words, a political contribution can be or appear as bribery, direct or indirect.
Alstom's policy is not to make contributions, financial or in kind, to political parties or organisations, or to individual politicians.
Alstom respects the rights of its employees to participate as individuals in their community and civic affairs. This must be done at a personal level, in their own time and at their own expense, consistent with applicable laws.
Employees need to carefully separate their own political activities from Alstom activities and avoid any conflict of interest.
Charitable contributions are commendable ways to be associated with environmental, cultural, educational, welfare or other non-profit making activities.
Charitable contributions can be used to disguise an improper advantage. They can be diverted from the purpose for which they have been made and be used for private gain. This risk is greatest when charitable organisations are controlled by politicians, public agents or their relatives, or when a politician or a public official benefits indirectly from the charitable contribution.
Charitable contributions made in the Alstom’s name or using its financial resources are permitted as long as they comply with applicable laws and regulations. Contributions should have relevance to the community in which Alstom operates and must effectively serve the purpose of the charitable organisation concerned while enhancing Alstom’s reputation as a good citizen. Charitable contributions must not be made without prior written approval and must be properly recorded.
Alstom sponsors cultural and sporting events as well as conferences every year.
Sponsorship allows a company such as Alstom to strengthen its notoriety by associating its image with events that reflect the Alstom's values.
Like charitable contributions, sponsorship can be used to disguise an improper advantage. It can be diverted from the purpose for which it has been made and be used for private gain. This risk is greatest when sponsored events or activities are controlled by politicians, public agents or their relatives, or when a politician or a public official benefits indirectly from the sponsorship.
Sponsorship is part of the marketing and communication strategy. It is authorised in compliance with applicable laws and regulations and solely within the framework of the Alstom's communication policy.
Ethics & Compliance Principles
In addition to our Code of Ethics and to the Instructions that are designed to prevent any situation that could jeopardise the company's integrity, Alstom applies Ethics & Compliance Principles in all its operational procedures and in particular to managing conflicts of interest, dealing with sales partners and dealing with consulting companies, the laws and regulations and solely within the framework of the Alstom's communications policy.
A culture shift by training
Alstom employees reflect the company's commitment to ethics and compliance. When conducting business on Alstom's behalf, they are responsible for ensuring that their conduct and that of those reporting to them fully comply with the Code of Ethics and all applicable Instructions.
Employees can refer at any time to our Code of Ethics, to the Alstom's Instructions and to a number of resources that are made available on Alstom's intranet. Training is central to adopting good practices and developing ethical conduct.
Combining face to face and distance learning
All the employees are made aware of the Alstom's Integrity Programme on their arrival within the company.
The Ethics & Compliance training offer comprises comprehensive compliance sessions regularly held throughout the Alstom by the Ethics & Compliance Department. Face to face training sessions are dedicated to delivering deep knowledge and appropriate conduct to employees potentially exposed to difficult professional situations. Distance learning is based on several modules.
The e-Ethics module aims at ensuring that employees understand the principles of the Code of Ethics. It is based on practical business scenarios. The e-Ethics module is mandatory for Managers and Professionals. The "Sourcing & Procurement Compliance" modules provide background on the risks of non-compliance in the Sourcing and Procurement functions, and further information on Alstom policies and procedures. For all distance learning modules, a Certificate of Completion is awarded to the trainee right after the quiz is correctly answered.
Key resources accessible to all employees
Alstom's intranet site provides key resources and information about E&C. A practical guide to the Code of Ethics is also available to all Alstom employees through the intranet-based e-learning programme e-Ethics.
To ensure that employees are well informed, Alstom regularly feeds the Ethics & Compliance reference section with information on the prevention of corruption as well as a clear summary of the Alstom's commitments.
A complete set of links to a selection of reference materials on its intranet site is updated.
Regarding anti-corruption, Alstom advises its employees to refer to regional and international conventions, to the principle NGOs in the sector, to government authorities and to principle money laundering prevention organisations. Alstom's presence in a number of countries means that the company is exposed to various regulations and cultural practices. So that each employee can easily have access to information that is relevant to the country in which he or she operates, Alstom provides reference sheets that explain anti-corruption issues, international engagements and regulations for countries where Alstom does business.
The diffusion of the culture of ethics and compliance
Because the Code of Ethics must be known and applied by all, in all circumstances, Alstom has developed a global organisation built on two specific internal networks, assuming the diffusion of the culture of ethics and compliance.
A number of years ago, Alstom created the Ethics & Compliance team, a structure that is responsible for promoting and applying the Code of Ethics within all of the Alstom's locations.
The team includes Ethics & Compliance Officers who report directly to the Chief Compliance Officer. A Legal and Compliance Officer is appointed in each Alstom' region.
The Ethics & Compliance team is supported by a community of Ethics & Compliance Ambassadors. The E&C Ambassadors are all volunteers whose role is to disseminate Alstom's culture of integrity within the group through Ethics & Compliance Awareness sessions.
The E&C Ambassadors come mainly from the Legal, Finance and HR functions. They have direct contact with the Ethics & Compliance team that provides them with the support and tools necessary to achieve their mission. They are points of contact for any questions about Ethics & Compliance.
The Ethics & Compliance Ambassadors receive, for example, a monthly newsletter that outlines subjects related to ethics in business and that provides practical case studies along with recommendations on how to manage the ethical questions that were encountered.
Recognised rules and procedures
Alstom ensures that its efforts systematically reflect best practices in terms of compliance and ethics standards and regularly reviews and audits its Integrity Programme.
Maintaining the highest ethics standards
Since 2009, Alstom is engaged in a certification process of its anti-corruption policy. These efforts include a dedicated internal audit plan of E&C processes and outside certifications of our Integrity Programme. In 2017, Alstom has obtained ISO 37001 certification on Anti-bribery Management Systems, an international best practice standard applicable to organisations of all sizes, private or public.
A thorough and rigorous process
The certification has been attributed following a complete and rigorous evaluation of the anti-corruption programme and of its implementation. The company underwent the certification audit conducted by AFNOR on March and May 2017 at seven sites in France and Europe, and has obtained the first AFAQ ISO 37001 certification awarded by AFNOR Certification in June 2017, confirming its commitment to fight corruption.