Ethics, Risk & Compliance

In keeping with its values and commitments, ENGIE seeks in all circumstances to act in accordance with the laws and regulations in force in the countries where it operates. We have a zero tolerance for ethics violations, and compliance is always a paramount priority. For us, ethics are an essential part of our strategy, management style, and individual professional practices. Ethics help to drive performance.

To achieve our ethical ambitions, ENGIE has implemented across the Group ethics policies and procedures based on the highest international standards.

Our values and principles

ENGIE has adopted an Ethics Charter that underpins the day-to-day strategic decisions, management and professional practices of the Group, and which is based on four specific principles:

  1. Act in accordance with laws and regulations
    Group employees must, in all circumstances, observe international, federal, national and local laws and the professional codes of practice applicable to their activities.
  1. Behave honestly and promote a culture of integrity
    Honestly and integrity must govern both business and interpersonal relationships, and everyday professional practices.  Employees must avoid any conflict between personal interests and the Group’s interests.  It underpins an absolute belief in the obligation to respect certain values, and thereby creates a climate of trust and acts as a shield against corrupt practices.  ENGIE encourages reporting of ethical incidents, and no employee may be sanctioned for reporting an incident, selflessly, in good faith and without malice, and in accordance with the conditions set out by the applicable and ENGIE’s whistleblowing policy.
  1. Be loyal
    Employees fulfill their undertakings and engagements scrupulously whenever they communicate, within the company or externally, they do so in good faith and in a constructive spirit, with a concern for providing genuine, accurate and complete information.
  1. Respect others
    This principle particularly applies to the respect for the rights of individuals, for their dignity and their differences, as well as a respect for different cultures. It also applies to tangible and intangible goods that belong to others.

ENGIE’s Ethics Charter and its ethical principles apply to all Group employees worldwide in every circumstance in their daily business activities as well as in their relationships with customers, stakeholders and more broadly, with the communities in which Group operates.

This Ethics Charter is sided by a Practical Guide to Ethics, which details and illustrates the terms for applying the commitments taken by the Group.

Ethics Charter
Practical Guide To Ethics

The commitments outlined in ENGIE’s Ethics Charter and the Practical Guide to Ethics are detailed for the Group’s activities and professional practices in four Codes of Conduct: the Code of Conduct for Business Relations, the Code of Conduct in Supplier Relations, the Code of Conduct for Group Financial Officers, and the Code of conduct on Lobbying.

Our policies and procedures

Ethics can be defined as a practical application of morally acceptable —or value-based—practices in a given situation. Compliance refers to the set of systems put into practice in order to conform to the required standard of ethical behavior.  In other words, ethics and compliance are two sides of the same reality, a reality that applies to all ENGIE employees.

To ensure and measure compliance with the principles laid out in the Ethics Charter and the Practical Guide to Ethics, and in accordance with the requirements of several legislations, the Group has provided tools and procedures:

Engie Ethics Charter Practical Guide To Ethics

Our Integrity Referential

As part of the integrity referential, the Group has adopted ethical Due Diligence policies, which consist in investigating our third parties (our suppliers and subcontractors, commercial consultants, investment partners, beneficiaries of sponsorship, etc.) to ensure they do not represent any major risks for ENGIE and that they are not in violation with any rules governing human rights, health and safety, and/or the environment.  We also have a Gifts and Hospitality policy as well as a Conflict of Interests that aim to prevent any type of corruption, conflict or interests of influence peddling and ensure transparency through prior authorization and registration.

Those policies are also part of the ENGIE anti-corruption program (UK Bribery Act, US Foreign Corrupt Practices Act, French Sapin 2 law).

Our Human Rights Referential

ENGIE is committed to respecting internationally recognized human rights in all its activities and wherever the Group operates.  To ensure the respect of our human rights commitments and to meet French and international requirements, we conduct an annual risk analysis to allow for efficient corrective action plans, and each new activity and project are subject to a preliminary human risk analysis.  The Health and Safety policy, CSR policy, and purchasing policies, cover the risks that fall within their particular scope.

For example, ENGIE North America has signed the Solar Energy Industries Association’s (SEIA) Forced Labor Prevention Pledge  – joining more than 150 organizations forced labor within the solar supply chain.

The Vigilance plan

In accordance with French law on the duty of vigilance of parent and ordering companies, ENGIE S.A. has developed a Vigilance Plan that aims to identify and prevent the risks of negative impacts on people and the environment related to the Group’s activities with regards in particular to human rights, health and safety and purchasing.

ENGIE Vigilance Plan is based on the Group’s various risk identification and management approaches which have already been in place for several years and described above, and benefits from its dedicated reporting and governance system.

For more information on the Vigilance Plan and access all supporting documentation, please refer to the Group’s Vigilance Plan.

Risk management

ENGIE defines risk broadly as a deviation from expected outcomes and has established an internal control environment as well as specific leadership committees to monitor key aspects of the Company’s risk exposures.

ENGIE’s top management engages annually in a robust enterprise risk management assessment which includes assessments of a broad array of risks including the risk of engaging directly or indirectly in human rights violations and the risk of ethical breaches.  This includes identifying controls to avoid and detect such risks as well as corrective action plans for any identified areas of risk exposures not optimally controlled.

In addition, ENGIE risk committees regularly meet to address specific areas of risk:

  • The Commodity Risk Committee – This committee documents commodity risk limits to which each of its businesses are held accountable and monitors commodity positions for compliance with those limits.  The Committee discusses hedging strategies and results of previous hedging activity to inform its ongoing portfolio management.  This committee reports to ENGIE NorAm’s executive committee and includes representatives from the Group’s commodity risk control team, which enables sharing of best practices from across the Group.
  • The Credit Committee – This committee establishes credit limits and monitors receivable exposures to the company’s customer base.  Similar to the Commodity Risk Committee, the Credit Committee’s scope covers all of ENGIE NorAm’s businesses and includes Group representatives.
  • The Project Implementation Steering Committee – This committee monitors the progress of construction projects against health and safety targets, budgeted construction costs, and delivery deadlines and catalogues specific construction related risks unique to each project.  The company maintains separate PISCs for its renewables and services businesses.


ENGIE S.A. (ENGIE) and ENGIE North America Inc. (ENA) have established confidential and anonymous whistleblower systems for the receipt, retention and treatment of complaints.

Whistleblowing reports can be made either by ENGIE employees or any external stakeholders, including suppliers, subcontractors and their respective employees, member of the community, etc.

Reports can be made on any issue related to corruption, human rights violations, fraud, breach of personal data privacy rules, violations of international sanctions and embargoes, health and safety and environmental damage, and more broadly, violations of applicable law or regulations regarding conduct subject to criminal punishment, and violations of ENGIE’s Ethics Charter and Practical Guide to Ethics.

Please note that confidentiality is protected. Reports are managed by a third-party provider who ensure anonymization (if requested). Messages are then routed to members of the ENGIE North American management or to ENGIE Group’s Ethics and Compliance Department for review, investigation and treatment.

If you wish to report an incident, please use one of the following methods:

Secure Web Form
  • Click here to access an internet-based message Interface that will deliver a message to the ENGIE North America Whistleblowing System.
  • Email to send a message to the ENGIE Whistleblowing System.
  • Call 1-866-553-4733 to leave a voice message on the ENGIE North America Whistleblowing System.  All voicemail messages will be electronically altered / disguised to keep the caller’s identity confidential.
  • Call + (011) 33 1 45 51 03 67 to contact the ENGIE Whistleblowing System.

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