T A B L E O F I N D I C A T O R S
ACTION 9 Apply a prevention policy for corruption, fraud, and conflicts of interest.
Société du Grand Paris is committed to strict compliance with all applicable legal and
regulatory provisions, particularly those on preventing the risks of corruption, conflicts of
interest and the protection of information. It has a zero tolerance policy for unethical
behaviour of any kind, towards either its employees or its service providers.
Corruption prevention policy
Société du Grand Paris’s corruption prevention policy forms the basis for all its efforts to prevent
the risk of corruption. It lays out the scope of the policy and the procedures for monitoring
and assessing it, defines the governance bodies set up to oversee compliance with its provisions,
and clearly states how it applies to employees and to the third-parties with which the company
has business relations. Société du Grand Paris has signed an agreement with the French
anti-corruption agency. Under the agreement, it receives support for the process of achieving
compliance with the provisions of the Sapin II Act of 9 December 2016 on transparency,
anti-corruption efforts, and modernisation of the economy. The anti-corruption programme
steering committee is the decision-making body that determines the actions to be taken and
monitors them.
Personal data management and privacy protection
Société du Grand Paris applies the provisions of the General Data Protection Regulation (GDPR).
It has a personal data protection policy and in February 2019 appointed a data protection officer,
informing the French National Commission for Data Protection and Liberties (CNIL) of this
appointment. Standard GDPR clauses are also included in contracts with all its suppliers.
Employees are trained in all aspects of data privacy as part of the ethics and information security
sessions that are mandatory for all new starters.
F O C U S 4
IN 2020
Appointment of an ethics
advisor An ethics advisor took up his post at Société
du Grand Paris in July 2020. His letter of
engagement was signed by the Chairman of
the Management Board, to whom he reports
directly. Any employee can contact him for
advice. He is bound by an obligation
of strict confidentiality and by the rules of
professional secrecy and discretion.
Talk on preventing corruption On International Anti-Corruption Day,
9 December 2020, Société du Grand Paris
organised a talk that was filmed and
broadcast live. The talk entitled “Preventing
corruption: transparency and vigilance – a
cross-section of views” was given by a
representative from the French Anti-
Corruption Agency and the ethics advisor
from one of our service providers.
Privacy protection Société du Grand Paris has updated its
information protection policy. It will come
into force by the end of the first half
of 2021, after consultation with employee
representatives. It will be appended to
the company’s code of conduct.
RISKS AND CHALLENGES
2020 ACTIVITY
CSR APPROACH
Actions
IDENTITY
