A process of continuing improvement
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 Legal department.
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 and communication
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. Communication, awareness and training of the managers and employees are essential to adopting good practices and developing ethical conduct.
Combining face to face and distance learning
All employees are made aware of the Alstom's Integrity Programme upon their arrival within the company.
The Ethics & Compliance training offer comprises comprehensive compliance sessions regularly held by the Ethics & Compliance Department. Face to face training sessions (three hour class) 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 and targets managers, engineers and professionals for whom it is compulsory when they join Alstom. As part of our continuous improvement approach, an annual micro-learning (10 minutes interactive e-learning refresher) is developed and implemented for each fiscal year with a specific focus (Alstom Alert Procedure in 2018/2019 ; Conflicts of interest in 2019/2020). The target population is the same as for the e-Ethics, meaning all managers, engineers and professionals. In addition to the objective of raising awareness, the Executive Committee decided to make this E&C exercise part of the bonus scheme and, as a result, a group objective for the company.
Key resources accessible to all employees
A number of communication tools are available to all Alstom employees in order to increase the visibility of the compliance activities such as regular news on Alstom’s internal communications channels (Intranet, internal social networks, TEAMS magazine).
Spreading 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.
A dedicated training course of one and a half days was implemented to strengthen their knowledge of the ethics and compliance subjects and various tools available to the employees of the Company such as the Alstom Alert Procedure.
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 audit focused on the adequacy of Alstom’s anti-bribery system according to the standard ISO 37001, in particular its Ethics & Compliance policy, the Code of Ethics, and the various instructions relating to existing anti-corruption procedures and numerous associated training tools.
Each year, the company is audited of several sites in order to confirm the ISO 37001 certification.