Plastic Omnium - 2018 Registration Document

3 STATEMENT OF NON-FINANCIAL PERFORMANCE CSR integrated in the business lines PLASTIC OMNIUM 2018 REGISTRATION DOCUMENT 97 Furthermore, a specific IT tool for reputational control (including the corruption risk) and the surveillance of external stakeholders is in the process of being introduced. Internal or external auditing of accounts 3.2.1.2.5 The accounts are audited to ensure that the books are not being used to mask corruption. To check the robustness of these checks, independent internal audits are also carried out regularly, both scheduled and unscheduled, at all subsidiaries and sites (plants, Research and Development centers and administrative functions). These procedures will continue to be improved in 2019, particularly in the field of gifts, invitations, corporate philanthropy and sponsorship, in accordance with the action plans produced as a result of the risk mapping. Training procedure 3.2.1.2.6 To ensure that the commitments of the Code of Conduct are properly understood and assimilated, Plastic Omnium has introduced a dedicated, two-faceted training procedure: a face-to-face “Compliance day” for employees who may be exposed to ● the main ethics risks: Executive Committee, finance, Human Resources, quality, sales, buyers, etc. These training days have been designed in partnership with Plastic Omnium’s legal, financial and Human Resources Departments. Half a day is spent on compliance rules within Plastic Omnium and half a day is spent covering the golden rules of internal control. These training sessions also encourage discussion between employees, particularly through case studies. This training has already been delivered in Asia, France and South America, and is being rolled out across all Plastic Omnium regions, with the involvement of lawyers who speak the local languages; an e-learning module dedicated to the Code of Conduct is in the ● process of being adapted to reflect the strengthened Code produced in 2018. Lasting thirty minutes, this module has two parts: a presentation of the Code of Conduct, and an assessment to validate skills. All employees and new recruits with access to the MyLearningPlace in-house e-learning platform must successfully complete it. In 2018, 689 employees were trained to the Code of Conduct and 200 to the Competition Code of Conduct. Disciplinary procedure 3.2.1.2.7 Management has a zero tolerance ethics policy, particularly in the approach to corruption. Management intends to give the Code of Conduct the same legal scope as an internal rule wherever legislation allows. Therefore, the Code of Conduct, which specifies that any failure to abide by these rules of conduct could result in employees facing disciplinary measures including dismissal in the event of serious misconduct, has been submitted to the employee representative bodies and the European Consultation Committee. Finally, where local legislation allows, employment contracts now contain a specific clause on the obligation to comply with the Code of Conduct, a copy of which is provided to all new employees. Control procedure and internal evaluation 3.2.1.2.8 of the measures implemented The control procedure and internal evaluation of the measures implemented has four aims: check the implementation of corruption prevention and detection ● measures and test their effectiveness; identify and understand failures in the implementation of procedures; ● determine recommendations or other corrective measures to improve ● the compliance program; detect corruption where applicable. ● Plastic Omnium has begun overhauling the internal controls and evaluations to improve its procedure and make it more efficient. Therefore, the corruption risk mapping will be updated annually. When implementing the audit program, the Internal Audit Department must ensure that the corruption prevention and detection procedure meets the latest Plastic Omnium requirements, is efficiently implemented and updated to ensure its adoption by all and compliance with the rules. The risk of tax evasion is stated in chapter 1.7.1 Principal risk factors(AFR)/Other risks/Tax risk. DUTY OF VIGILANCE AND RESPONSIBLE 3.2.1.3 PURCHASING The Group’s organization with functions working centrally allows for procedures to be applied consistently across all subsidiaries and all sites. Human Resources, HSE/CSR and Risk Management and Internal Audit implement policies, procedures and actions to ensure that all subsidiaries uphold human rights and fundamental freedoms protect health and safety and the environment. The Purchasing Departments of the two Divisions also play their part in strengthening and implementing the procedures, actions and tools to ensure that suppliers uphold the same values and are bound by the same obligations as the Group. Risk mapping 3.2.1.3.1 Several complementary in-house tools are used to identify risks within the subsidiaries and joint ventures. Two tools are used at Group level: analysis of risk factors; the main ones are outlined in Chapter 1.7 Risk ● factors and control. This analysis, which is updated yearly, identifies the risks facing the Company, whether external (such as natural disasters, failures by suppliers or the obsolescence of a vehicle model) or internal (approaches to innovation, quality, health/safety, corruption, etc.); the materiality and risk analysis, which was conducted in 2017, ● identified the risks facing the Company and its stakeholders. Internal stakeholders categorized the issues into financial risks, business continuity risks, image/reputational risk and regulatory risks, thereby identifying their potential impact on the Company’s performance. External stakeholders identified the impact on their organizations of Plastic Omnium managing the risks, i.e. the risk borne by them as a result of Plastic Omnium.