Ethics: a core commitment for GRTgaz
GRTgaz: an independent transport operator
GRTgaz designs, maintains and operates a gas transmission network spanning the various French territories, with interconnections to neighbouring countries. In France, the French Energy Code governs GRTgaz’s activities and sets the obligations for its public service role:
- ensuring the safety of people and property;
- contributing to the energy security of supply and guaranteeing the continuity of gas transmission in France and in Europe;
- playing a strategic role in the energy transition and developing new sectors based on gas uses, renewable gas, and renewable electricity storage;
- establishing trust-based relations with consumers, energy shippers and producers, communities, companies, residents and civil society.
This code, which was updated in 2020, sets out the internal organisational measures that guard against the risk of discriminatory practices relating to third-party access to the natural gas transmission network. It also covers the ethical regulations applicable to staff, the confidentiality of commercially sensitive information (ICS), the transparency of access conditions to the transmission network, and compliance with the 10-year development plan approved by the Energy Regulatory Commission (CRE).
The code of conduct enhances GRTgaz’s legitimacy in respect of other market players. Within the company, code of conduct contact persons ensure that it is made available to all staff. They also manage and review the yearly action plan. In 2022, 98.7% of GRTgaz employees took an e-learning course relating to the code of conduct.
Every year, GRTgaz asks its customers, shippers and industrial partners to complete a satisfaction survey to assess compliance with the code of conduct. In 2022, 99% of shippers and 94% of industrial customers considered GRTgaz to be an independent operator.
The Energy Regulatory Commission (CRE) approves the code of conduct, which is one element of GRTgaz’s certification.
Since 2102, the Energy Regulatory Commission (CRE) has certified that GRTgaz acts as an independent transmission network manager, according to the obligations set out in the French Energy Code.
The CRE is an independent authority that oversees the workings of the natural gas market. Its aim is to guarantee access to gas infrastructures that is transparent, non-discriminatory and fair. The CRE sets public rates for network usage, supervises investments, and checks the quality of service.
GRTgaz implements a comprehensive ethics system
Practical prevention actions
The Board of Directors and the Executive Committee are directly informed about and involved in implementing GRTgaz’s ethics system.The Ethics Committee is made up of one representative from the CODIR of each division. It meets regularly and is run by the compliance officer.
GRTgaz has produced an Ethical Charter that is attached to the internal regulations.
To design its preventative actions programme, GRTgaz has carried out risk analysis linked to different ethical elements, in particular fraud and corruption. Managers and employees who are most exposed receive training in these areas.
Internally, GRTgaz’s ethical system is centred on prevention: facilitating dialogue and upstream and downstream exchanges, and compliance with regulations. This prevention system is implemented via an action programme that will be in place until 2024. The prevention of the main ethical risks, in particular the different types of discrimination and harassment, fraud, corruption and conflict of interest, are all included in this programme.
Externally, GRTgaz has drawn up a “Relations with Suppliers” ethical code. This sets out a mutually applicable ethical framework and obligations for suppliers, service providers and sub-contractors.
GRTgaz’s Ethical Charter aims to protect employees and the company, to make ethics a central component of its strategy, and to enhance the trust of its stakeholders.
This is a key reference document for preventing various ethical risks. Compliance with the ethical values it detailed in the Charter steers employees’ behaviour, example setting by managers, and professional practices.
GRTgaz has updated its Ethical Charter, approved by the Economics and Social Committee (CSE) in 2020, and complies with the requirements of the French “Sapin II” Law 2016-1691 of 9 December 2016 relating to transparency, the fight against corruption, and modernized business practices. The Ethical Charter applies to all GRTgaz employees and shareholders.
Main principles of the Charter
The company’s professional practices and employees’ behaviour comply with four principles:
- act in compliance with laws and regulations;
- strengthen the ethical culture;
- demonstrate good faith, integrity and honesty;
- treat others with respect.
GRTgaz maintains ethical relations with its suppliers
GRTgaz has implemented an Ethical Charter specifically for its suppliers, as well as a due diligence procedure (link to the Suppliers’ responsible and ethical purchases page).
This system aims to strengthen ethical prevention measures with suppliers and partners who are the most “at risk” in the areas of human rights, health and safety, and the environment. In 2020, GRTgaz appointed an external service provider to assess over 30 service providers, compared with 17 in 2019 and 8 in 2018.
>> To find out more, see the page: "You are a supplier"
Corruption and transparency: a prevention priority
As part of the so-called “Sapin II” law, GRTgaz has implemented a special training tool (both face-to-face and remotely) for employees who are most exposed to the risk of corruption.
Anonymity guarantee and protection for whistle-blowers
GRTgaz guarantees anonymity and protection for whistle-blowers to encourage the reporting of incidents and/or ethical dilemmas. When an employee raises an alert, the details that would identify them and the individuals to whom the alert refers are systematically anonymized.
Each employee is asked to share their doubts or questions with their manager and/or the HR department and/or their division’s ethics representative and/or the GRTgaz compliance officer.
"Ethics is a guiding principle for our activities and supports our long-term industrial vision."
GRTgaz Chief Executive Officer