Foster integrity We recognize corruption and fraud are ever-present risks for global companies such as Technip Energies. We have a zero tolerance for corruption, we believe in fair competition, and we encourage our employees to speak up. To foster awareness and encourage transparent discussions, we train our management and our high-risk populations on anti-corruption and bribery. We abide by the laws but our concept of compliance goes beyond the strict adherence to the laws and our policies and procedures, as our Values guide our decisions.
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TECHNIP ENERGIES CODE OF BUSINESS CONDUCT
Technip Energies’ aim of building a better tomorrow is intrinsically linked to the respect of our Values. Our Code of Business Conduct serves as a fundamental guide that must be read and followed by our directors, officers, and employees. We aspire to develop business relationships with like-minded clients, subcontractors, suppliers, and business partners who are guided by a similar set of principles of business conduct. Our Compliance program is designed to prevent, detect and remediate violations of our Code of Business Conduct whenever they arise. We are committed to continuously improving and enhancing our Compliance program, through relevant risks assessments, data analysis, policies and procedures, and cooperation amongst key stakeholders. Our Code of Business Conduct is available on our website here.
GOVERNANCE
We do not compromise on integrity. Our Code of Business Conduct helps us recognize and address the ethical dimensions to our everyday decisions. The Compliance organization is part of the Legal Department, under the responsibility of the Chief Legal Officer. The Company’s Chief Compliance Officer leads a dedicated team of legal and compliance professionals that provide support, advice and risk management services relating, in particular, to anti-bribery and corruption, internal investigations, trade sanctions,
13% reduction
of non-mandatory commercial
intermediaries
92.5% of gatekeeper employees completed anti-bribery
and corruption (ABC) training
payments, kickbacks, and self-dealing) and influence peddling. We do not make or accept improper payments to obtain or retain business with those in government or the private sector, or as a reward for awarding subcontractor or supplier contracts. We are committed to complying with all international and national legislation against illegal payments, including prohibitions on facilitation payments (to expedite routine and administrative government action) except in extraordinary circumstances where the safety or security of an employee is in immediate danger. Dedicated standards, policies, and procedures are designed to supplement the Code of Business Conduct by providing
a clear and comprehensive operational framework. Such standards, policies, and procedures address in more detail the applicable bribery and corruption risks exposures, and include: An Anti-Bribery and Corruption Standard,
which sets out our principles for strict compliance with applicable anti-bribery and corruption laws;
A Third-Party Intermediaries and Business Partner Standard, which clarifies the requirements for the due diligence and monitoring of Third-Party Intermediaries and joint ventures/consortia partners. This Standard is designed to enable us to assess and manage bribery and corruption risks as part of our global business activities;
A Gifts, Hospitality, and Travel Standard, which sets forth our rules related to the receipt or provision of gifts, hospitality, or travel, and establishes procedures for the approval, reporting, and accounting of such. The Gifts, Hospitality, and Travel Standard assists employees in ensuring that gifts and hospitality, whether given or received as part of a usual courtesy of business, are not and cannot be considered as bribes;
A Social Donations, Sponsorships, and Charitable Contributions Standard which sets forth our rules related to the making of contributions to our communities to ensure contributions are not misused for improper purposes, such as to disguise illegal payments to government officials;
export controls, conflicts of interests, human rights, and data privacy. Dedicated subject matter experts and compliance counsels serving geographic roles and covering company projects ensure that the Compliance program is implemented consistently across the different businesses and geographies of the organization. The Chief Compliance Officer reports to the Chief Legal Officer, and to the ESG Committee of the Board of Directors. The ESG Committee plays a key role in the oversight and continued development of our Compliance program to ensure that the Company operates in compliance with principles of ethical conduct and good governance. The Chief Legal Officer reports to the Chief Executive Officer and presents to the Audit Committee all legal and compliance matters that may have a material impact on the Company.
ANTI-CORRUPTION AND ANTI- BRIBERY COMPLIANCE CONTROLS
The Company is required to comply with numerous laws and regulations, in jurisdictions around the world where we conduct business, including countries perceived as having an increased risk of corruption. Technip Energies is, in particular, subject to the U.S. Foreign Corrupt Practices Act and French law No. 2016- 1691 dated December 9, 2016 (also more commonly known as “Sapin II”). Regardless of where we operate, Technip Energies does not accept any form of corruption and prohibits all acts of corruption (including bribes, facilitation
2022 key figures
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30-34 Rue du Chemin Vert 75011 Paris +33 (0)1 85 56 97 00 www.carrenoir.com
Ce fichier est un document d’exécution créé sur Illustrator version 2020.
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64 . ESG Roadmap and Performance
Visit of Technip Energies Executive Team at NFE project construction site in Qatar
Technip Energies Sustainability Report 2022 . 65
