7.0
Governance
At RED, Senior Management is dedicated to overseeing our governance initiatives across all areas. Our leadership is committed to ethical decision-making and business practices that benefit the environment, society, and uphold RED’s responsible governance structures.
All RED entities operate in compliance with ENGIE Group’s principles, setting the tone for our employees, ensuring that they;
Act in accordance with laws and regulations.
Behave honestly and promote a culture of integrity
Are loyal
Respect others
RED entities adhere to the highest national and international standards in all our projects and operations. This includes compliance with major conventions and regulations. The key goals for 2024 included;
Promoting CSR in the value chain (suppliers and business partners)
Improving ethics and anti-corruption standards
Ensuring awareness of human rights standards among management
Preparation for ISO 37001 Anti-Bribery certification in 2025
Training 85% of sensitive positions on ethics and human rights standard
The principles and policies of RED entities are based on the highest national and international standards that we promote in all our projects and operations:
The United Nations Convention against Corruption.
The Convention of the Organisation for Economic Co-operation and Development (OECD) on Combating Bribery of Foreign Public Officials in International Business Transactions.
UK Bribery Act
US Foreign Corrupt Practices Act (FCPA)
French Sapin 2 law
The OECD Guidelines for Multinational Enterprises.
The assurance of a zero-tolerance approach to bribery is fundamental to all the work undertaken as part of RED’s operations. Our Anti-Bribery Management System includes:
Annual corruption risk assessment
Annual anti-bribery action plan
Pre-employment screening process
Mandatory employee Ethics induction and e-learning modules
Financial procedures including delegation of authority, segregation of duties and counter signature procedures.
Internal audit and investigation procedures
Supplier and sub-consultant onboarding process & 3rd party due diligence processes
Gifts, Hospitality and Technical Trip declaration and approval procedures
Whistleblowing procedures
As part of the ENGIE Group, RED adopts the ENGIE Ethics Code of Conduct as the foundation for its Ethics and Compliance Programme.
The ethical standards are based on the following five fundamental ethical principles which every employee in RED must promote and protect, whatever their position in the hierarchy, entity, or geographical location:
Corruption and fraud are strictly prohibited
Human rights must be respected
Environmental protection is a commitment that binds us
Laws and regulations apply to each of us
Integrity and loyalty guide our relationships with third parties
The International Bill of Human Rights, including the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights.
The Conventions of the International Labour Organization (ILO).
Building Regulations
CDM Regulation
GDPR
COP28
Building Safety Act 2023 and Fire Safety Act
CSR Directive
SECR
ESOS
RED recognises that effectively managing risk is important to its long-term success. Management is responsible for day-to-day risk management activities. RED is fully committed to identifying, controlling, and mitigating risks associated with our business activities through our Enterprise Risk Management (ERM), addressing all business areas and enterprise-level risks.
Our risk management program is designed to ensure that management is monitoring and controlling operating and project risks such as business continuity, compliance, reputational, security (people, information, and assets), and others.
All client projects go through a risk assessment process, with checks required based on various different factors such as project location and fee level:
Client and subcontractor/sub-consultant due diligence
Human rights checklist (approval required for all projects in high-risk countries)
Embargo risk assessment (where required)
All new employees are provided with a copy of the Ethics Charter and Practical Guide to Ethics
All employees receive an Ethics induction during onboarding
Mandatory Ethics e-learning modules
Ethics Champions inducted in 2023
Annual webinars in addition to mandatory e-learning for employees in positions considered to be at higher risk of bribery
Company-wide communications and the Legal/Ethics and Data Privacy newsletter sent throughout the year
Launched our revised Approved Supplier process and Supplier Code of Conduct, outlining our expectations of suppliers and sub-consultants
Confidential 24/7 helpline, the ENGIE Whistleblowing Line available for all employees, contractors, and external stakeholders globally
Our onboarding and prequalification process includes a Code of Conduct that outlines our CSR requirements.
“We are committed to maintaining the highest standards of corporate social responsibility in our business activities and behave with honesty and integrity in all our activities and relationships with others. To meet this commitment, we expect suppliers to abide by our standards and Corporate Social Responsibility Policy."
In 2024, significant strides were made in integrating CSR criteria into the supplier onboarding process. This initiative aims to enhance CSR risk management and establish a robust baseline for future assessments.
CSR criteria was added to the supplier onboarding assessment at the beginning of the year. This move not only measures external recognition but also guides the process of improving CSR risk management
Throughout 2024, data has been gathered to establish a baseline for measuring CSR compliance from 2025 onwards.
We currently do not impose any supply chain CSR obligations outside of the prequalification questions; we are using 2024 to gather a baseline of CSR compliance and will decide on any other CSR obligations for suppliers in 2025.
The actions taken this year have laid a strong foundation for CSR compliance and risk management. The integration of CSR criteria into the supplier onboarding process, coupled with data collection and automated assessments, positions RED for a comprehensive and effective CSR strategy moving forward.
Benchmark of prequalification
RED’s approach covers 12 key areas of risk management in the supply chain prequalification process
General information about an organisation.
A check that steps to reduce financial risks are taken.
Business insurance is not only a legal requirement but also covers the business against mistakes, accidents, theft, damage and legal fees.
Questions about corporate and professional standing relating to criminal activity, corruption, terrorism and human trafficking are included.
Assessing that adequate steps have been taken to protect workers, visitors and the public from harm based on the service we will provide.
Environmental questions are included that cover the steps taken to reduce the environmental impact of projects that meet environmental management standards.
Verify details about an organisation's quality management system.
Confirmation that the organisation has taken steps to assess and manage modern slavery and human trafficking risks.
Confirmation that all employees are treated fairly.
How the organisation impacts society are assessed, including questions about the CSR policy & EcoVadis.
How is personal data managed and protected.
Checks that procedures have been implemented to prevent persons within or associated with the organisation from receiving bribes or bribing others.
