ETHICS AND COMPLIANCE

Ethics

The Principles of Conduct and Action constitute the Code of Ethics and the foundation of all our policies and commitments. They define the values and rules applicable to all Group entities and employees, regardless of the nature of their employment contract (permanent, fixed-term or temporary), as well as to our subcontractors and suppliers.

Ethical practices with employees

Through our purpose “Making the World a Better Home”, we base our development on strong values embodied in nine Principles of Conduct and Action, which constitute a true code of ethics. Formalized in 2003, translated into 31 languages, and distributed to all employees, these principles constitute an ethical reference applicable in action. They are a condition of belonging to the Group.

To ensure that our employees adhere to our ethical code, the Principles of Conduct and Action, we have set up an e-learning training program:

  • Adhere: training program dedicated to the Principles of Conduct and Action, the Group's code of ethical conduct
  • Comply: training program dedicated to antitrust law
  • Act: training program dedicated to the prevention of corruption
  • Goal: Train 100% of new managers in Adhere, Comply and Act training programs in their first year of employment

TO ENSURE RESPECT FOR HUMAN RIGHTS

Respect for human rights is at the heart of our DNA.

Our Principles of Conduct and Action make explicit reference to the relevant International Labor Organization (ILO) conventions, the Organization for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises, the OECD Anti-Bribery Convention and the International Bill of Human Rights. We have been a signatory to the UN Global Compact since 2003 and are committed to the UN Guiding Principles on Business and Human Rights.

Through the Principles of Conduct and Action, in particular Respect for other, Respect for the Law and Employee rights, we are committed to respecting employees' freedom of association and the right to organize, to working towards diversity and against forced labor, child labor, discrimination, and harassment.

Annually, a questionnaire is sent to all the countries in order to collect information on the local actions to disseminate and explain the Principles of Conduct and Action to all employees. The questionnaire includes information on incidents that are disclosed in the social part of the ESG reporting in the universal registration document.

In order to ensure our progress, a human rights risk map has been drawn up in accordance with the UN guidelines*. The Group is present in 75 countries, some of which are located in areas less favorable to human rights. We used the indices of human development, human development of women in relation to men, perception of corruption and presence of modern slavery to identify the regions in which we were going to evaluate certain elements more precisely via a questionnaire.

*due diligence to identify, prevent, mitigate and account for actual and potential human rights impacts they may be causing, contributing to or directly linked. 

We have identified the possibility of exposure to the risks concerning our employees:

  • by analyzing incidents reported to the alert system: psychosocial risks and the risk of isolated practices undermining freedom of association and the principle of non-discrimination, harassment;
  • the risk of employing migrant workers in situations that could amount to forced labor, the risk of excessive working hours, the risk of paying less than a decent wage, the risk of dangerous work being carried out by children under the age of 18;
  • inability to meet our commitments in terms of freedom of association or non-discrimination in countries at risk (in particular UN Global compact).

A specific questionnaire based on salient risks was sent in 2021 to the identify entities. Risks in terms of working conditions, inclusion and diversity, housing, working with recruitment agencies, use of security forces, impacts on local communities, in addition with potential exposure to the limitation of the freedom of association, forced labor, child labor and personal data protection.

To consolidate the actions plan developed to mitigate risks, some additional recommendations were sent in the form of practical information.

To find out more, consult the Group's human rights policy and our compliance plan.

WITH A DEMANDING COMPLIANCE PROGRAM


Our compliance program is currently based on three main themes:

  • compliance with competition law rules,
  • prevention of corruption,
  • compliance with economic sanctions and embargoes.

Constantly evolving in line with current events, it enables us to achieve best practices and is a permanent obligation for all our employees.

WITH OUR ALERT SYSTEM

Our alert system is open to all: employees of Saint-Gobain, temporary workers, and subcontractors, but also stakeholders such as individuals, suppliers, clients, unions, NGOs or public bodies. This system is operated through a highly secure platform and can be used to report (including anonymously) breaches of our code of ethical conduct (General Principles of Conduct and Action), of the law and of our internal Group policies, procedures, and commitments. For example, alerts could tackle human rights including (in particular and not exhaustively) non-discrimination, forced and child labour, corruption, anti-trust and anti-competitive practices, freedom of association and collective bargaining issues.

Alerts issued in good faith are systematically investigated by a dedicated group of Saint-Gobain employees who have been specially trained in the matter and are bound by enhanced confidentiality obligations.

The Group is committed to protecting issuers who acted in good faith via:

  • No disciplinary action
  • No legal proceedings
  • No retaliation

WITHOUT FORGETTING...


The Saint-Gobain Group complies with the tax laws of the countries in which it operates and has not set up any structure whose purpose is tax evasion. We apply tax laws and regulations with honesty and integrity.
Saint-Gobain is committed to respecting privacy by ensuring the security and confidentiality of the personal data of users of its services. Each processing of personal data must be lawful and fall within one of the authorized cases (consent of the individual, execution of a contract, compliance with a legal obligation or justified by a legitimate interest). An educational guide dealing with the protection of this data has been distributed internally in order to make our partners and employees aware of this subject.

Responsible Purchasing

The objective of the Responsible Purchasing program is to manage and reduce the environmental, social and societal risks associated with our supply chains.  In a context where supply chains are becoming increasingly complex and where collective awareness of the impact of purchasing on stakeholders is growing, this program aims to integrate ethical requirements into the purchasing process, both for suppliers - based on the supplier charter - and for buyers, by applying the buyer charter.

Thus, ethical criteria on human rights, working conditions and compliance with standards, health and safety and the environment are integrated into the purchasing process. The Responsible Purchasing program is implemented with rigor and in compliance with the Group's general purchasing principles, in order to develop long-term relationships with suppliers, based on shared improvement plans.

FIGURES

 

  • 97% of our managers trained in the Principles of Conduct and Action in their first year with the Group in 2023
  • 97,8% of our managers trained in anti-corruption during their first year with the Group in 2023
  • 97% of our managers trained in competition rules in their first year with the Group in 2023