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Anti-bribery and corruption Primagas, Spain 12/11/2018

Ethics and compliance conference

On the 30th and 31st of October 2018, SHV Ethics & Compliance Officers gathered in the Ethics & Compliance Conference held in Hoofddorp. During the conference, we attended trainings, shared views, and created synergies. The topics discussed were of great interest.

Building a solid compliance program

 As a starting point, all Business Unit Ethics & Compliance (BU E&C) Officers verified the importance of having a solid compliance program. By way of example: looking at the Corruption Perception Index, which is each year published by Transparency International, one can tell that awareness on anti-bribery and corruption is of essence. All BU E&C Officers present in the conference committed to make sure all employees are familiar with the policies and manuals that have been recently updated in this regard. Moreover, together with the Head of Group Internal Audit and the Manager of Risk & Internal Control we agreed our role as BU E&C Officers is to support managers to implement controls, monitor the measures taken, identify improvements, and be aware and alert of what could go wrong.

Collective thinking

 Separately, each of the BU E&C Officers shared an ethics case or dilemma that happened in their work. Having a constructive dialogue and using collective thinking, created many useful insights that participants could bring back to their organizations.

Another important topic was the Third Party Due Diligence tool, which has been recently implemented in SHV Energy. In conjunction with E&Y, we acknowledged the benefits of an efficient and effective diligence framework. These days, it is no longer acceptable to plead ignorance on the basis that the company is unaware of what is going on. Instead, we need to be aware of each link of the chain, if necessary.

SHV Privacy Codes

 Finally yet importantly, we also reviewed the status of the implementation of the SHV Privacy Codes. This project has demanded a truly remarkable organisational effort. For instance, a lot of work has been made in Spain: 12 privacy implementation calls; 68 privacy assessments; and the privacy e-learning completed by all BU employees, are examples that show the magnitude of the project at local level.

A shift in privacy culture

 The implementation of the SHV Privacy Codes is now carried out. However, privacy still requires continuous attention and focus. Among other actions, all SHV Energy BUs will update the agreements subscribed with partners that process data on their behalf. Putting in writing each party’s responsibilities should help reducing the risk of infringements.

At Primagas Spain we have gone one step further. As part of our partners engagement strategy, we offered a training on privacy and security to our key installers during the Annual Security Week with the aim to increase their awareness on privacy and security. It not only prevents complaints and massive fines, but also averts reputational risks, business disruptions and costs for handling requests. In addition, Primagas Spain will share with all partners a video providing specific instructions on how to implement GDPR and the basic security measures that all businesses should implement. We are convinced that these, and other future measures we adopt, will make privacy a success that our stakeholders will notably benefit from.