Practicing business ethics first of all requires an awareness of the issue. It is therefore essential to provide employee training. This is why Legrand implements actions to ensure that employees liable to encounter risky situations will be thoroughly familiar with the rules of business ethics, thereby reducing the probability of violation of fair competition law, anti-corruption law, anti-money laundering or export control regulations.
Legrand also intends to tighten its monitoring of the application of the Compliance program, formalised in 2012, and encompassing all the areas that constitute Legrand’s business ethics.
Observing ethical rules requires prior, specific and strong awareness raising on such topics. It is therefore essential to provide ongoing training for employees. The aim of Legrand's training programmes is to ensure that employees likely to encounter risky situations will be thoroughly familiar with the rules of business ethics. This also reduces the probability of breaching fair competition laws, anti-corruption laws, anti-money laundering or export control regulations to combat fraud, in all the subsidiaries and entities of the Group. Any infraction of Legrand's rules of ethics by an employee shall give rise to immediate sanctions.
Business ethics training sessions are regularly organised for Group employees. The purpose is to help them detect and manage potentially sensitive situations relating to ethical problems in their entities.
Webcasts on various topics related to business ethics are also produced regularly for Ethics Officers, Compliance Officers, and various central functions of the Group.
Moreover, staff who are considered to be at risk must take an online training module on corruption prevention, supplemented by local training sessions. Communication tools (practical guides, presentations) have also been made available to ethics officers and compliance officers to facilitate their work in those areas.
The Duty of Care law, enacted in 2017, obliges big companies to monitor their suppliers and subcontractors, making them responsible for their social and environmental policy. Legrand has kept ahead of the law by establishing a care plan in 2014, which concerns not only its own facilities, but also its value chain, on the themes of human rights and basic freedoms, health and safety of persons, and the environment. It includes a risk map, procedures for the evaluation of subsidiaries, subcontractors and suppliers, and alert mechanisms.
An ethics alert system is in operation, which is accessible to all Group stakeholders in the event of problems involving accounting and/or financial matters, corruption, competition law, serious damage to the environment or the safety of people, unethical behaviour (discrimination and harassment), data protection, or a conflict of interest. All employees are sent this generic e-mail address: firstname.lastname@example.org.
As specified in the Group's Charter of Fundamental Principles, Legrand provides the whistle-blower with protection against reprisals. This means that no one can suffer reprisals, or threats of reprisals, because they have reported an ethics or fraud issue in good faith.
Information collected by all recipients of the report and the people concerned remain strictly confidential. The Group ethics and fraud alert system was declared to the French data protection authority, CNIL. Anyone involved in an alert has a right to access and correct data concerning them.
The firm commitment by the General Management with regard to business ethics is underlined by its signing of the Global Compact and its observance of the main universal principles and international reference texts (particularly the Universal Declaration of Human Rights and additional pacts, the Convention and Guiding Principles of the OECD on corruption of foreign officials in international business transactions and OECD guidelines for multinationals, the United Nations Convention on corruption, all national laws on the fight against corruption, European Directives on competition, and all national laws concerning competition).
The whole Group is actively involved in this business ethics initiative. The General Management declares its support for all the Charters setting out the Group's business ethics principles. All of the Function Managers and Managers of subsidiaries sign letters committing to the proper implementation of the compliance programme. And every employee undertakes to adopt ethical behaviour.
Moreover, the central functions are regularly involved in reinforcing the established rules and developing awareness, training or monitoring initiatives. Locally, the Group's subsidiaries put defined rules in place and ensure their effectiveness given local legislation and regulations. And a network of ethics officers and compliance officers is operational in all of the Group's subsidiaries.