Ethics

Integrity and transparency

Integrity and transparency are the cornerstones of the Group’s ethical approach. They govern behaviors and actions of all employees.

A dedicated program

To convey our principles

Wherever we operate, our subsidiaries respect local cultures and traditions while also conveying the Group’s values through their actions and local commitment. 

In line with our Principles of action, we adhere to the highest standards in conducting business and are particularly committed to respecting human and labor rights and to protecting the environment.

We are committed to complying with all applicable laws and regulations, in particular regarding fair trade and we do not tolerate corruption in any form. Our behavior and actions are driven by the principles of integrity and transparency.

The Group’s ethics program aims to help employees develop their activities with integrity and transparency in compliance with our rules of conduct. It is based on a specific organization, the Group Code of Conduct and a whistleblowing system available for all.

A specific organization

To support the Ethics program monitoring

  • The Ethics & Compliance Committee, gathering some of Air Liquide’s global functions (Human Resources, Legal, Group Control & Compliance, Sustainable Development) and Operations representatives, validates the program’s main guidelines and priority actions. It may, if necessary, make post-deviation sanction recommendations
  • The Group Control and Compliance Department, responsible for Ethics, reports directly to one of the Group’s Executive Vice Presidents
  • The Group Ethics Officer is responsible for providing guidance and support to entities in the implementation of the ethics program and in the treatment of fraud and deviations. He also suggests improvements to the ethics program, combining and building on strategic challenges, best practices, regulatory developments and annual action plans. He relies on a network of more than 50 Ethics correspondents present in each of the Group’s geographic regions and business lines.

Group Code of conduct

A renewed Code and a common framework for all

The Group Code of conduct was updated in 2021. For instance, it now includes the Group's Anti-Corruption principles. The Code is deployed worldwide in 2022 and is available in 25 languages. It is supplemented by specific guides on the following topics:

An e-learning module regarding employee Code of Conduct sets out the Group’s ethics approach and presents its key concepts through case scenarios. This module, renewed annually,  is mandatory and must be followed by all employees each year. On this occasion, individual commitment to adhering with the Code is required from employees.

Whistleblowing system

Available for all employees and stakeholders

EthiCall is the whistleblowing system of the Group whereby any person who has direct knowledge of inappropriate behavior regarding a variety of ethics, integrity and compliance issues (fraud, corruption, conflict of interest, harassment, discrimination, breach of competition law, protection of personal data, health and safety or environmental issues, etc.) can confidentially raise an alert.

Alerts can be raised in accordance with the December 9, 2016 “Sapin II” law, relating to transparency, the fight against corruption and the modernization of economic life, and the March 27, 2017 “duty of care” law relating to the duty of care of parent companies. 

A worldwide system

EthiCall is available 24/7, in nearly all countries where Air Liquide operates and in all Group spoken languages.

Alerts can be raised through the online platform or by phone (see numbers list on the platform). It is important that the information contained in reports received be as detailed as possible so that it can be processed and investigated (names or description of the persons involved, circumstantial elements - date, time, place, etc.).

The system, managed by an external service provider, is secure and access rights are limited to personnel authorized to receive or process alerts.

Employees may also share any concern and report any suspected breach to their manager, Human Resources manager, Ethics correspondent or the Group Ethics Officer.

Alerts treatment

All alerts are handled confidentially

Provided this is allowed under local laws , whistleblowers can remain anonymous and maintain the dialogue with the Company (secured communication platform). 

Air Liquide takes all necessary measures so that reports are managed with integrity, confidentiality and in compliance with applicable laws and regulations, consistent with the needs of the investigation. In general, all alerts are handled within a maximum of two months..

Any person who has in good faith reported a potential violation will not be subject to any disciplinary measures or retaliation of any kind related to the reporting.

A Group’s commitment

This whistleblowing system allows our internal and external stakeholders to help us maintain the highest ethical standards within the Group.

In 2021, EthiCall received around 200 reports, over 50% of which were related to Human Resources issues. 30% of reports were  considered substantiated and gave rise to corrective actions or sanctions.