24
Non-Financial Indicators Handbook -
2013
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VIVENDI
Societal Indicators
4
Fair Business Practices
Definitions of the policy’s priority actions
to combat corruption
GRI
UNGC
OECD
DMA SO
Corruption aspect
10
II, VII
Corruption issues and risks occur at different levels depending on
the business unit. Therefore, the Group has chosen to formalize the
general rules of ethics contained in its Compliance Program, which
the subsidiaries must then adapt to reflect their business specificities.
Combating corruption is one of the ten principles of the UN Global
Compact, which Vivendi has signed and is committed to upholding.
The subsidiaries manage their own anti-corruption policies based on this
Compliance Program. The priority areas are listed below:
Canal+ Group’s anti-corruption policy is reflected in an ethics charter
that prohibits its employees from acting on the basis of personal
interest while performing their duties, since this would prevent
them from defending the Group’s interests as their primary concern.
In particular, the Group prohibits payments or benefits of any kind,
or any gift of a value not considered reasonable, from any third
party with which the Group is in a business relationship, or from
any employee to any third party in a business relationship with the
Group;
UMG has instituted a number of key policies governing the
professional practices of the entire workforce, particularly in the
area of combating passive and active corruption and the disclosure
of events contrary to business ethics, and has created an anti-trust
guide.
UMG is committed to adopt a “zero tolerance” approach in
relation to fraud and corruption, and to act professionally and with
integrity wherever the company operates, in accordance with local
regulations and the UK Bribery Act of 2010;
GVT has a Code of Conduct which has one section specifically
dedicated to anti-corruption and anti-fraud policies. The purchasing
policy is also aimed at enhancing transparency and avoiding any
situation of this type.
under its Ethics Code, SFR makes the following commitments:
– to comply with and ensure compliance on the part of the
employees with: laws prohibiting active and passive corruption;
and laws relating to the financing of political activities,
– to prohibit payments or benefits of any kind, or any gift with a
value that is more than symbolic from any third party with which
the Group is engaged in a business relationship, or from any
employee to any third party engaged in a business relationship
with the Group; and
– to ensure that the partners agree to comply with such laws and
rights vis-à-vis the Group.
Maroc Telecom has a four-pronged strategy: to combat any kind
of corruption (in 2012, an Ethics Officer was appointed to advise
employees and ensure compliance with the rules); vigilance to avoid
conflicts of interest; fraud prevention and detection; and insider
dealing.
In 2013, in accordance with its policy of preventing and combating
corruption, Maroc Telecom Group carried on with awareness actions
among employees and information campaign, with particular
emphasis on mechanisms for detecting and preventing fraud.
To date, training programs on subjects related to fraud and corruption
have been given to 25% of the employees of Maroc Telecom.
In 2013, the General Control department of Maroc Telecom held
a seminar on the issues involved in evaluation and fraud control
in three of the Group’s subsidiaries: Onatel, Gabon Telecom and
Sotelma (including a presentation of the different forms and types
of fraud, their impact on the company, tools to deter fraud and the
legal and regulatory framework). This seminar was attended by more
than 150 employees working in various business units (including
warehouse employees, purchasers, sales personnel and managers).
For the second time, Vigeo, the European leader in non-financial
ratings, awarded Maroc Telecom the trophy “Top CSR Performers
in 2014”. This distinction recognizes the “objectives of social
responsibility, where the business is rated as a leader on the
Casablanca Exchange”, which include the strategic management of
CSR by the Management Board, the integration of CSR into auditing
and internal control, the quality of CSR reporting and the prevention
of corruption.
■
4.5.2. Measures Taken to Protect Consumers’ Health And Safety
4.5.2.1.
Ensuring Protection of Personal Data
The Data and Content Protection Charter, adopted in 2008, defines
Vivendi’s commitments regarding the collection and management of
customers’ personal data and protection of content. It is implemented
by every subsidiary. The issue of personal data is strategic for the Group.
Indeed, most of the Group’s activities (Canal+ Group, SFR and GVT in
particular) use subscription-based economic models
The Group pays special attention to any trends in discussion about the
proposed EU Regulations on the protection of personal data (please refer
to AR 2013 Section 2.1.2 p. 54).
Personal data protection systems at the level
of the subsidiaries
Existence of a formal commitment to protecting
personal data
GRI
UNGC
OECD
DMA PR Consumer
privacy aspect,
DMA HR MSS
1, 2
VIII.6
