Case study: How the Prysmian Group combats corruption
With sales in excess of Euro 11.5 billion, approximately 29,000 employees and 106 plants in more than 50 countries worldwide, the Prysmian Group is a world leader in the supply of power and telecom cables, committed to a business management model based on the most stringent standards of business ethics and integrity – especially with regard to the measures adopted to prevent both active and passive corruption.
This case study is based on the 2019 Sustainability Report by the Prysmian Group published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ ESG/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.
Abstract
The Prysmian Group implements a series of actions aimed at managing corruption issues on a preventive basis Tweet This!, including the adoption of an Anti-Corruption Policy. In order to combat corruption the Prysmian Group took action to:
- implement the “Third Party Program”
- provide anti-corruption training
- launch an Anti-Bribery Compliance Programme
- review compliance policies
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With this case study you will see:
- Which are the most important impacts (material issues) the Prysmian Group has identified;
- How the Prysmian Group proceeded with stakeholder engagement, and
- What actions were taken by the Prysmian Group to combat corruption
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What are the material issues the company has identified?
In its 2019 Sustainability Report the Prysmian Group identified a range of material issues, such as respect for human rights and workers’ rights, solutions for sustainable applications, energy efficiency and combating climate change, technological development and eco-design innovation, occupational health and safety. Among these, combatting corruption stands out as a key material issue for the Prysmian Group.
Stakeholder engagement in accordance with the GRI Standards
The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:
Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.
Key stakeholder groups the Prysmian Group engages with:
| Stakeholder Group |
| Employees |
| Customers and Business Partners |
| Institutions and Governments |
| Universities and Research Centres |
| Suppliers and sub-contractors |
| Shareholders and Financial institutions |
| Society and Communities |
How stakeholder engagement was made to identify material issues
To identify and prioritise material topics the Prysmian Group engaged with its stakeholders through a multi-stakeholder event involving stakeholders from all over Europe, attended by approximately 70 stakeholders, and also carried out a survey of key external stakeholders (customers, suppliers, universities and research centres, investors and trade unions) in order to reach a larger number and obtain additional feedback.
What actions were taken by the Prysmian Group to combat corruption?
In its 2019 Sustainability Report the Prysmian Group reports that it took the following actions for combatting corruption:
- Implementing the “Third Party Program”
- Prysmian Group’s “Third Party Program” is intended to prevent and manage the risk of corruption deriving from relations with third parties (such as agents, distributors and certain categories of supplier). In particular, before establishing business relations with any third party, it is necessary to carry out due diligence in relation to that party using a dedicated on-line platform. As a result of the above activity, a level of risk (high, medium, low) is assigned to each third party that, consequently, is subjected to an approval procedure responsive to the identified risks. Additionally, the due diligence work must be repeated every 1, 3 or 5 years, depending on the level of risk identified. Further, the Code of Ethics adopted by the Group (which includes the anti-corruption clause) is accepted and signed by all contractors, suppliers and agents and, with the introduction of the new Third Party Program, all new agents, distributors and 15 categories of suppliers must also sign the anti-corruption certificate.
- Providing anti-corruption training
- In 2019, the Prysmian Group trained around 100 white-collar employees in compliance and anti-corruption matters through on-line courses, while 1,024 were trained in classroom sessions (classroom sessions include both Anti-Corruption and Anti-Trust modules). Training in how to use the new platform to carry out due diligence work on third parties was also carried out by the Prysmian Group, with 1,463 white-collar employees trained in classroom sessions and conference calls during 2019.
- Launching an Anti-Bribery Compliance Programme
- In 2017, the Prysmian Group, in line with the objectives set in 2016, decided to further strengthen the monitoring and central focus on compliance issues by launching an Anti-Bribery Compliance Programme inspired by the guidelines set by the ISO 37001: 2016 “Anti-bribery management systems”. This programme, in addition to giving greater control over the management of the risk of corruption, is also aimed at minimising the risk of being subject to sanctions following the commission of corruptive offences by employees or third parties. In the three-year period 2017-2019, there were no cases of corruption within the Prysmian Group.
- Reviewing compliance policies
- The compliance policies of Prysmian and General Cable were reviewed, updated and merged in 2019, in order to create documentation valid for the entire Group. With specific reference to the anti-corruption programme, the relevant policy was revised together with that covering gifts and entertainment expenses. The anti-corruption policy now provides further clarification about the requirements to be met with regard to high-risk transactions, such as donations, sponsorships, governmental interactions/projects, business relations with high-risk third parties (e.g. agents, consultants), gifts and entertaining expenses related to the Public Administration. In addition, a new conflicts of interest policy was issued in 2019, consistent with the Group’s constant commitment to making sure that the financial and personal interests of employees and consultants do not conflict with their ability to perform their duties with professionalism, ethics and transparency. The new policy, approved by the Board of Directors on 12 November 2019, requires all employees and consultants to disclose all potential conflicts of interest, which will then be appropriately analysed and assessed in order to agree any corrective actions needed to mitigate or eliminate the conflict. The new policies (Code of Ethics, Global Compliance, Helpline, Anti-Corruption, Gifts & Entertainment, Third-Party Program, Antitrust, Antitrust EU, Conflicts of Interest, Export Control) have been published on the corporate intranet and are available in the official languages of the Prysmian Group.
Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?
The GRI Standards addressed in this case are:
1) Disclosure 205-2 Communication and training about anti-corruption policies and procedures
2) Disclosure 205-3 Confirmed incidents of corruption and actions taken
Disclosure 205-2 Communication and training about anti-corruption policies and procedures corresponds to:
- Sustainable Development Goal (SDG) 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels
- Business theme: Anti-corruption
Disclosure 205-3 Confirmed incidents of corruption and actions taken corresponds to:
- Sustainable Development Goal (SDG) 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels
- Business theme: Anti-corruption
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References:
1) This case study is based on published information by the Prysmian Group, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:
http://database.globalreporting.org/
2) https://www.globalreporting.org/standards/gri-standards-download-center/
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