Plastic Omnium - 2020 Universal Registration Document

STATEMENT OF NON-FINANCIAL PERFORMANCE The ACT FOR ALL TM program www.plasticomnium.com PLASTIC OMNIUM UNIVERSAL REGISTRATION DOCUMENT 2020 152 A RESPONSIBLE COMPANY 4.6.1 BUSINESS ETHICS AND THE FIGHT 4.6.1.1 AGAINST TAX EVASION Within a large international group such as Compagnie Plastic Omnium SE, ethical risks are significant and cover several areas: risk of fraud, corruption, conflicts of interest, insider trading and anti-competitive practices. The risk mainly arises from a single employee failing to comply with applicable regulations or Plastic Omnium’s policies and procedures. The Group would then be exposed to financial sanctions from the authorities and could see its image tarnished. To prevent the occurrence of isolated acts, the Group trains employees on Internal Rules and the Codes of Conduct. Plastic Omnium has had a formalized Code of Conduct since 2003 and reviews it regularly. In 2020, the HBPO subsidiary adapted the content of its own Code of Conduct to make it consistent with the Group’s Code of Conduct. These Codes of Conduct present the non-negotiable rules of conduct that the Group has set itself in terms of respect for human rights, fundamental freedoms, health and safety, diversity, the environment and preventing discrimination, fraud, corruption and influence peddling. It also sets out the obligations of its employees: protecting Compagnie Plastic Omnium SE’s assets and image, ensuring product quality and safety, and complying with ethics rules and regulations. The Codes of Conduct are translated into the main languages used within the Group, i.e. 22 languages for the Industries Business and eight for HBPO. Plastic Omnium’s commitment to the United Nations Global Compact since 2003 also requires it to comply with the 10 principles relating to respect for human rights and international labor standards, preservation of the environment and the fight against fraud. An annual statement shows the progress made on these principles. The Internal Control and Compliance Committee is comprised of managers from Human Resources, Finance, Compliance, Risks and Internal Audit, the Legal Department, and Business Line Management. It guides the Group’s policies and actions and relies on a network of compliance correspondents around the world. In France, law no. 2016-1691 of December 9, 2016 relating to transparency, the fight against corruption and the modernization of economic life (known as the Sapin 2 law) requires companies to implement eight measures. The Code of Ethics. 1. Employee training and awareness: e-learning training continued 2. throughout 2020. Available in four languages, the module should be translated into additional languages in 2021 to ensure coverage of those countries with the largest number of employees identified at risk. This e-learning must be taken by all new joiners and the populations at risk (Executive Committee, Finance, Human Resources, Quality, Sales, Purchasing, etc.). Participation and completion rates for the module are monitored annually. Three sessions of Compliance Day, a classroom-based training module implemented in 2019, were planned in 2020 and had to be postponed due to the Covid-19 crisis. This year, HBPO has set up its own e-learning module incorporating training videos offered by the United Nations. A three-year plan provides for the gradual enhancement of e-learning as well as the training of all managers and administrative staff over the long term. Corruption risks mapping: this process was completed in 2018 by 3. Clean Energy Systems and Intelligent Exterior Systems and was updated at the end of 2020. Mapping for HBPO was completed in 2019. Procedures for assessing third parties: when approving a third party, 4. in addition to the financial analyses, the Plastic Omnium Group performs sustainability assessments where third parties are asked to sign up to the Suppliers Charter and are subject to assessments and audits. Internal or external accounting audit procedures: to ensure that the 5. books are not hiding corruption, these procedures are regularly audited by internal audit at subsidiary, site or administrative function level. Whistleblowing mechanism: alerts from employees to report behavior 6. or situations which infringe the Code of Conduct are collected by e-mail (corporatesecretary.ethicsalert@plasticomnium.com ) or mail (Compagnie Plastic Omnium, Alerte Éthique, 1, allée Pierre-Burelle, 92300 Levallois-Perret). Alerts are treated anonymously. The process is described in the Code of Conduct, in 22 languages, on the intranet and on the Group’s website. The disciplinary system: the Code of Conduct has the same legal 7. effect as the Internal Rules where legislation allows, so that managers can apply the zero-tolerance policy. Any breach of the Code of Conduct can expose employees to disciplinary sanctions. Where legislation allows, a reference to the Code of Conduct has been added to employment contracts, thus strengthening its legal dimension. Internal control mechanism and assessment of measures 8. implemented: the Audit Department performs an annual audit of its entities and sites to ensure compliance with procedures and the efficiency of the processes to prevent, detect and correct wrongdoing. The audits were carried out according to the program planned for the first quarter of 2020. From March 2020, the Group took the view that the lockdown and remote working increased ethics-related risks and in particular fraud, as the plants were shut down but collection operations continued. An ad hoc control system has been developed and communicated to all plants to reduce the risk of internal fraud. The risk of external fraud was also considered material and the organization of the internal audit team was adapted over the period to increase monitoring. On-site audits were able to resume over the summer and a new organization was put in place in expectation of an uncertain period: audits were performed with a local auditor on site equipped with connected glasses or cameras and the Group’s remote auditors were able to carry out visual checks (for inventory management, for example). These audits also benefited other departments, such as HSE, finance and quality, who are included in the internal audits but were not able to conduct their own audits during the period. The performance indicator, the Ethics Awareness Index, defined in 2019 as a marker for the ACT FOR ALL TM program, combines the proportion of employees who achieved a score greater than 80% in the online training on the Group’s Code of Conduct during the year, as well as the proportion of employees who participated in the Compliance Day among the employees targeted for the year. In 2020, due to the postponement of the Compliance Days, the Index has not been calculated. Thus, the percentage of people successfully trained in the “Code of Conduct” e-learning is 86.1%.