Schneider Electric's Trust Charter Flipbook
Schneider Electric's Code of Conduct | 2021 | 37 pages
Trust Charter SchneiderElectric’s Codeof Conduct
Trust Charter, SchneiderElectric’s CodeofConduct Wewanttrusttopowerallourinteractionswithstakeholdersandallour relationships with customers, shareholders, employees and the communities weserve,inameaningful,inclusiveandpositiveway. SchneiderElectric’s purpose is to empower all to make the most of our energy and resources, bridging progressandsustainability for all. At Schneider, we call this “Life is On”. Webelievethattrust is a foundational value. First, trust is earned, both by individuals and by organizations. Second,trustservesasacompass,showingthetruenorthinanevermorecomplexworld.Third,trustis core to our Environment, Sustainability and Governance commitments. Wewanttrusttopowerallourinteractionswithstakeholdersandallourrelationshipswith customers, shareholders, employees and the communities we serve, in a meaningful, inclusive and positive way. HencewecreatedthisTrust ChartertoactasourCodeofConductanddemonstrateourcommitmentto ethics, safety, sustainability, quality and cybersecurity, underpinning every aspect of our business and our willingness to behave and respond respectfully and in good faith to all our stakeholders. It is both our individual and collective responsibility to comply and respect laws and regulations, to apply our Schneider Policies and to uphold strong ethical principles to earn trust at all times. Astrust fuels empowerment, each section of the charter states clear do’s and don’ts and provides clear references to relevant policies and procedures (which are adapted to meet local legal requirements when necessary). OurCodeofConductappliestoeveryoneworkingatSchneideroranyofoursubsidiaries.Hence,wetrain ouremployeesyearlyontheTrust Charterandregularlyaskthattheyconfirmtheiracceptanceofitscontent. Whatyoucandoifindoubtorneedtoraise aconcern Weareencouragedtouseourjudgmenttodeterminethebestcourseofaction,buttheremaybetimes whenwefaceethicaldilemmasorareunsureandneedguidancetobetterunderstandhowtoact.Insuch cases, our network of Ethics Delegates is available for advice and support. Ouralert system Trust Line allows our employees and our external stakeholders to raise any concerns. When an alert is raised, it is subject to a thorough and confidential investigation, protecting all individuals involved. The findings of such investigations are then submitted to the relevant governing committees, who decide on the appropriate action to be taken. For more details, please refer to our whistleblowing policy.
Tableof Contents Trusted Teams 4 1. Exemplify Our Leadership Expectations 5 2. Create Equal Opportunities 6 3. Harness the Power of All Generations 7 4. Champion Well-Being and New Ways of Working 8 5. Be S.A.F.E. First 9 TrustwithCustomersandPartners 10 1. Strive for High Quality 11 2. Strive for Resiliency 12 3. Reach the Highest Standards for Cybersecurity, Data Privacy and Protection 13 4. Prohibit any Form of Corruption 16 5. Require Third-Party Integrity 17 6. Avoid Conflicts of Interest 18 7. Uphold Fair Competition 19 8. Abide by Export Controls and Sanctions 20 9. Select and Manage Suppliers Responsibly 21 TrustwithInvestors 22 1. Prevent Insider Trading 23 2. Deliver Accurate Financial Statements, Records and Tax Information 24 3. Deliver Solutions in Compliance with Financial and Risk Management Standards 25 4. Preserve our Information Technology and Related Intellectual Property Assets 26 5. Preserve our Reputation 27 6. Make objective decisions using trusted data 28 TrustwithCommunities 29 1. Act for a Climate Positive World 30 2. Be Efficient with Resources 31 3. Uphold Responsible Lobbying and Political Activity 32 4. EmpowerLocalCommunities 33 5. Do not use ‘Conflict Minerals’ 34 6. Act as Good Corporate Citizens 35
TRUSTEDTEAMS
Exemplify Our LeadershipExpectations 01 S M A TE D TE S U TR Leadershipis recognition of experience and expertise, but also aresponsibility. Ourleaderssetthetoneandexemplifyourculture.Beyondourcorevalues,leadersthroughoutourorganizationmust live up to, and actively demonstrate, our leadership expectations. In today’s next normal, leaders share a common commitmenttodrivethecompany’sfuture,bydeliveringmeaningfulbusinessimpact,leadinginclusivelybuilding humanconnectionsinadigital world with trust, empowerment, accountability, and care. • Innovate for the future with visionary, disruptive and • Sacrifice long-term success for short-term results digital mindset • Lack trust in our teams and colleagues • Removecomplexity wherever possible and move with • Create an environment with NO psychological safety simplicity and speed • Overlook compliance on safety, ethics or • Ask for and give coaching and feedback on a regular basis harassmentviolations • Lead with care for well-being and work/life management • Collaborate across the organization with openness and trust • Empowertheteamwithoutmicromanaging • Are decisive and clear even in ambiguous situations
CreateEqual 02 Opportunities S M A TE D TE S U TR OurDiversity, Equity and Inclusion ambition aims to offer equal opportunities to everyone, everywhere. Wewantouremployees–nomatterwhotheyare,orwheretheyliveintheworld–tofeeluniquelyvaluedandsafeto contribute their best, free from harassment, victimization and discrimination. A diverse, equitable and inclusive workforce yields stronger innovation and performance. Equal opportunities are strengthened through transparent and equitable accesstoinformation and tools that support growth and development. • Foster an open and safe work environment so that everyone • Make assumptions about people or their intentions can share their perspective and authentically be themselves • Let biases drive decisions • Encourage employees to take ownership of their careers • Accept or allow intimidation, discrimination, or disrespect and take advantage of different platforms and programs • Tolerate degrading comments on race, sex, ethnic and to grow national origin, religion, political opinion, age, medical • Ensure equal pay for equal work and implement fair and status, marital status, disability, pregnancy, sexual equitable pay practices orientation, gender, or gender identity • Demonstrate inclusive behavior by identifying and addressing our own biases • Build and support a culture of respect and speak up when weseediscrimination or harassment of any kind
HarnessthePower of All Generations 03 S M A TE D TE S U TR Weseektocreateanopenandsupportiveworkplacewhereallemployees are‘talent’ and empowered to grow to their full potential, developing new skills and building their careers for today and tomorrow. Wewanttoinspireandattractthenextgenerationof talentbybuildingstrongrelationships withuniversities, campuses andunderprivileged communities. Our more experienced talents can also lead, learn, coach and share their knowledge. Byleveragingthepowerof allgenerations, wecancreateaworkforcewithunrivaledskillsandexperience. • Foster learning, upskilling and development for all, whatever • Withhold(organizational) information that may hinder career stage employees are at effective collaboration and business continuity, such as • Drive employees’ development through career conversations support with succession plans andplatforms, such as the Open Talent Market • Limit career progression or learning opportunities based on • Facilitate open discussions by dedicating time to late-career assumptions and/or stereotypes conversations • Invest in mutual mentoring relationships, knowledge transfer and training to bridge knowledge and skill gaps • Committoinvesting in and hiring ‘next generation’ talented recent graduates, interns and apprentices • Support digital upskilling for all and across generations, in response to business and market needs
ChampionWell-Being andNewWaysofWorking S M A TE D TE S U TR 04 In today’s global, digital and ever-changing environment; agile, inclusive, efficient, trusted, and empowered interactions between colleagues, partners andcustomersaremorevitalthanever. Theemotional, physical, social and mental well-being of our people is important and can be sustained by purposefully building a more resilient organization in which people can set boundaries and perform at their best. As a company, we are embracingnew–moredigital,agileandsmarter–waysof workingthatdrivehigherperformance,improvewell-beingand offer a more equitable and inclusive work environment. • Implement Flexibility@Work practices to better manage our • Judge people’s flexibility needs, whatever their situation time at work, or when away from it • Ignore signs of distress, stress or burn-out • Adopt a digital-first mindset, implementing new ways of • Underestimate the value of rest and recovery working to connect with customers, partners and teams • Strive to enhance well-being, physical and mental health and develop smarter ways of working to free up people’s time and save energy • Focus on results and outcomes instead of placing more value on time connected at work
BeS.A.F.EFirst S M A TE D TE S U TR 05 Weallhavearoletoplay,thereforeweareallempoweredtolookafterour ownsafetyandthesafetyof others. Safety is a value of our brand, that we never compromised. Our ‘S.A.F.E. First’ principle remind us to pause and assess on ourownsafetybeforebeginninganytask(Self, Activity, Facility, and Environmental checks). We strive to work safely at all levels of the organization, at anytime, anywhere. • Identify, assess, and systematically control risks • Blamepeopleforsafetyissues,orif someone speaks up • Only carry out tasks that we are qualified to perform • Interfere with or bypass safety control measures • Follow the Safety Golden Rules for the Top 5 Hazards: • Dobusinesswithoutaclearvisionof safety hazards machine, electrical, road, powered industrial trucks and falls and controls • Stop work when risks are not controlled or when a situation • Become complacent about unsafe decisions and situations becomesunsafe to be performed • Report all opportunities and events to continuously improve our health and safety systems, and share solutions so others can learn • Lookoutfor the safety of our colleagues, contractors, and customers. Truly caring for each other
TRUSTWITHCUSTOMERSANDPARTNERS
Strive for HighQuality 01 S ER N T PAR D AN RS E M O T CUS H T WI T S U TR Our priority is to delight our customers with an outstanding end-to-end experience. Quality is every customer’s right and every employee’sresponsibility. Experienceisthemostimportantdriverforcustomers,definingthebusinessrelationshipstheysustainwithsuppliers and partners. Our customers place trust in our resilient, highly personalized, multi-channel experience, and the superior quality of our products. To ensure this, we act with agility, discipline, and good business sense throughout the offer life cycle from creation to supply, manufacturing, delivery, when in operation and when being serviced. • Empowerourpeople to put customers first, by prioritizing • Delay removing internal barriers to resolve quality issues their interests, anticipating their needs, reacting quickly and • Layblame if an employee speaks up about a customer always going the extra mile through a consistent experience issue at every touchpoint • Ensure our products’ reliability, safety and cybersecurity to secure customers’ business continuity and protect their people, assets and data • Guarantee that our digitized end-to-end value chain drives resiliency at each touchpoint when customers seek to “get quotations, place and follow orders, get delivered, or get technical support” • Makesureouranalytics, processes and people make the difference, to deliver the ultimate customer experience • Listen carefully and continuously, turning insights into value via end-to-end improvement • Respect our promises to customers by not compromising on quality at any point in the lifecycle of our offers
Strive for Resiliency 02 S ER N T PAR D AN RS E M O T CUS H T WI T S U TR Resiliency is the capacity to quickly recover from difficulty. We use a risk- centric framework to reduce our exposure to technological, environmental, process, geo-political. and health risks that disrupt our business. Wehavestandardizedissue-escalation processes in place, as well as risk assessment and business impact analysis. Wearepreparedtomanageanycrisiswithdisasterrecoveryandbusinesscontinuityplans,if needed.Ourlocalleaders are empoweredtoassessrisks,increasetheirpreparednessandhandlealltypesof criseswitharapidandeffective response, thanks to processes and tools in place to support them. • Respond to emergencies by focusing on protecting lives, • Assume that resiliency planning is somebody else’s minimizing damage to assets and any impact on both the responsibility immediate area and the wider environment • Focus on keeping and/or getting our critical operations running in times of crisis, with tools, processes, roles and responsibilities for immediate and effective response • Strive to continuously improve our response and recovery management, learning from simulations and real events
ReachtheHighestStandard for Cybersecurity, Data Privacy andProtection a) Excel at Cybersecurity S ER N T PAR D AN RS E M O T CUS H T WI T S U TR 03a Cybersecurity is an essential business imperative for us, our ecosystem and the industry at large. Ourstrategy encompassespeople,processes,andtechnologyacrosstheoperationallifecycle. Wealignwith the NISTCybersecurity Framework, follow globally recognized standards1 and comply with certified ‘secure by design’ developmentprocesses,tosafeguardourdigital ecosystemanddeliversecureoffers, systems, solutions and services. • Complywith international regulations and coordinate with • Consider that cyber risks are purely technical issues or lawenforcement,whenrequired separate them from other enterprise risks • Assessandcontinuously seek to improve our cybersecurity • Assume that our suppliers, partners or external posture (and the cybersecurity posture of our ecosystem) organizations will manage cyber risks for us • Help our customers to improve their cybersecurity posture enabling them to strengthen security protection and evaluate risks stemming from suppliers by applying defined standards and frameworks • Promote cybersecurity through trusted and transparent information sharing; provide support against cyber threats and attacks • Collaborate with cross-industry organizations2 to secure value chains and strengthen digital trust • Provide clear communication and public statements on Schneider and its ecosystem’s cybersecurity posture, if required
b) HonorDataPrivacyandProtection S ER N T PAR D AN RS E M O T CUS H T WI T S U TR 03b Werecognizetherighttoprivacyandprotectionof personalinformationasa fundamentalhumanright.Weconsiderfairness,transparency,dataintegrity, quality, security, and trust as core principles of how we handle data and use it in the products, systems and services we deliver. By promoting a data protection culture, we are committed to spreading these principles throughout our organization, in our R&D processes and to continuously improve our products and customers’ experience. We are set up to ensure resilient data handling and storage processes and comply with relevant regulations. We make it a point to responsibly source, process and share data. • Process personal information fairly and transparently with • Allow unauthorized access, unrestricted sharing, unlawful or appropriate security safeguards unsecured use of personal information • Adopt a ‘privacy by design’ approach in our R&D processes • Violate human rights and civil liberties by misusing our • Workwith suppliers or vendors that comply with data- knowledge protection requirements • Protect personal information and respect individuals’ rights • Runcompliance controls and implementation programs
c) UseAIandDataScienceresponsibly S ER N T PAR D AN RS E M O T CUS H T WI T S U TR 03c Webelieve digital resources must be used for the good of humanity and are convinced that Artificial Intelligence (AI), data science and digital innovation cangenerally bring substantial benefits to society. Weleveragedigital technologies to benefit our customers and employees for a sustainable future, based on human- centered design with a ‘do no harm’ oversight. • Promote the use of AI and technology, while taking • Implement or use algorithms that impair unbiased well-being, dignity, integrity, transparency, ethics and decision-making sustainability into account • Ensure fairness and accountability in the use of AI to anticipate potential bias and avoid discrimination • Implement privacy and security safeguards when leveraging AI and other digitally innovative systems • Implement appropriate governance and raise awareness on the possible impact of AI • Develop algorithmic transparency and other automated decision-supporting digital technologies • Act fairly when making decisions based on AI algorithms, addressing potential bias, aiming for equal treatment and respecting individuals’ legal rights
Prohibit any FormofCorruption 04 S ER N T PAR D AN RS E M O T CUS H T WI T S U TR Weupholdazero-tolerancepolicyforcorruptionandbribery, incompliance withall laws, such as but not limited to the FrenchSapin2Law,theUSForeignCorruptPracticesActandtheUKAnti-BriberyAct. Clear boundaries and efficient processes ensure that risks are managed effectively and that all employees are empoweredtoacttoavoidanyformof corruption.Anycompromiseonsuchprinciplescanbeharmfultoemployees, to Schneider and the communities it serves. • Highlight our zero-tolerance for corruption and money • Give or accept bribes, whatever their form, monetary or in- laundering, internally and when dealing with third parties kind, such as monetary gifts or payment of travel • Ensure that all given or received gifts, invitations, donations, • Facilitate payments to secure or speed up routine legal or hospitality packages and sponsoring activities are lawful, government-related actions, such as issuing permits or transparent, appropriate, approved as per our policies, and releasing goods held in customs properly documented in our records • Grant unlawful benefits to any third party to speed up a • Immediately inform our manager when aware of any action process or gain favor contrary to policies • Invite public officials without approval, as per our policies • Organize our marketing events and manage customer and procedures invitations in line with our policies, with a clear • Engage in or cover up corrupt practices or suspicious/illegal business purpose financial transactions, including those potentially perceived • Apply our commercial policy with acceptable and asmoneylaundering transparent rebates and discounts, justified by the • Approveanypaymentwithoutrelevantauthorization workdelivered according to our Chart of Approval and without checking • Follow all accounting, recordkeeping and financial the recipient reporting requirements applicable to payments, • Accept any undue solicitation from third-parties particularly in compliance with legal and/or regulatory anti-corruption provisions
RequireThird-Party Integrity 05 S ER N T PAR D AN RS E M O T CUS H T WI T S U TR Ourrelationships with third parties, such as customers, business partners, distributors, suppliers, subcontractors, or business agents are built on integrity and trust. Weexpectthirdparties to manage ethics and compliance risks according to their level of exposure, abiding with anti-corruption and export control laws and regulations, and in respect of international human and labor rights, such as eliminating forced labor, child labor and discrimination. We ensure that our business is not used to launder money from criminal activities. • Only approve third parties following internal ethics and • Enter into a third-party relationship without defining the compliance due diligence according to our Chart of scope of work Approval and the appropriate monitoring of the related risks • Allow third parties to give bribes or make questionable through training, audits or certification paymentsonourbehalf • Ensure third-party contractual provisions are adapted to any • Useorpaybusinessagents unless approved as per the identified risks Business Agents policy • Enforce our Supplier’s Code of Conduct • Payathird-party without following the contractual payment • Ensure third-parties’ scope of work is contractually defined, terms, an invoice or prior approval according to our Chart their performance effective, and payment proportionate to of Approval industry and local standards • Ensure that payments to third parties, especially business agents, are accurate and auditable • Ensurethat our activities are not used for money laundering • Closely monitor our third party relationships and business requirements, with specific metrics
AvoidConflicts of Interests S ER N T PAR D AN RS E M O T CUS H T WI T S SU MTR A TE D TE S U 06 TR AConflict of Interest situation occurs when an employee’s personal interest potentially competes with –or is in opposition to –the interests of Schneider. Situations of conflict of interest can unconsciously influence a person’s judgment and challenge their integrity. We recognize and respect that employees may take part in legitimate financial, business and other activities beyond their jobs at Schneider. However, these activities cannot conflict with their responsibilities to Schneider. • Disclose potential, apparent or actual conflicts of interest • Hide information on any conflict of interests and comply with related mitigation actions • Debate or participate in internal decision-making processes, • Disclose involvement with, or financial stakes in any should a conflict of interest arise organization related to our competitors, customers or • Allow decisions or actions to be influenced by favoritism, suppliers, and explain how this allows us to influence nepotism or preferential treatment decisions in its favor • Help or work for our competitors • Participate to the yearly Conflict of Interest Disclosure • Engage in or have direct or indirect interests in any other Campaign when requested so activity, business or employment that interferes in any way • ConsultwithourEthicsDelegatesorHRBusinessPartners with our responsibilities and availability to Schneider in case of doubt
UpholdFairCompetition S ER N T PAR D AN RS E M O T CUS H T WI T S U TR 07 Whencompaniescompeteinanequalandfairmanner,trustisguaranteed. This ensures more innovation in markets, enabling companies to meet consumers’ needs with better prices and to drive sustainable growth. As an ethical company, we refrain from any conduct which violates, or can be perceived as violating, competition laws or regulations. • Set our commercial policy, prices and discounts • Shareanyconfidential information with competitors independently from competitors, manufacturers • Split up and share business opportunities, territories or and distributors marketswithcompetitors • Act fairly with our partners • Consult and agree with competitors on margins or the timing • Act promptly when we receive confidential information from of price or margin increases or about our competitors, ceasing all communication and • Intentionally communicate using language that could be reporting any incidents to our legal teams considered misleading from a legal standpoint • Asknewhirestoshareconfidential information about competitors for whom they used to work • Requestconfidential information from former Schneider employers who currently work for competitors • Encourage customers or suppliers to breach contracts with competitors
AbidebyExport Controls and Sanctions S ER N T PAR D AN RS E M O T CUS H T WI T S U TR 08 Export Control involves the transfer of goods, services and technology within acountry, betweencountriesornationals. Asaglobalbusiness,withoperations andbusinessactivities conducted across many countries, it is important to comply with applicable export control laws and sanction regulations, as well as enhancing supply chain security. • Conduct business with respect to export control and • Evadeanyapplicable laws and regulations relating sanction laws and regulations to Export controls and sanctions, including licensing • Adhere to reporting and recordkeeping, in compliance with requirements the applicable laws and guidelines • Conduct business activities before undertaking due • Contribute and comply to Schneider Electric export control diligence and clearance procedures program and its requirements • Get involved in projects with domestic or cross-border transactions which may expose Schneider to infringing export control regulations
Select and Manage Suppliers Responsibly S ER N T PAR D AN RS E M O T CUS H T WI T S U TR 09 Wevalueourrelationshipswithsuppliers, beyond the purchase and delivery of goods and services. We deal with them in a mutually supportive and open, fair, objective way. To achieve our vision for sustainable procurement, we require our suppliers’ full support and collaboration. We conduct our businesstogether ethically, focusing on human rights and social impact at all levels and the preservation of ecosystems andresourceswithcirculareconomiesforaninclusiveandcarbon-neutralworld. Weexpectoursupplierstocommittoandimplementbusinesspracticeswithfullrespecttotheenvironment,human rights, health, safety, decent work conditions, and fair business standards. • Extend our values and commitments to the whole value • Impose abusive conditions on suppliers, such as chain and not only to our employees unattainable deadlines or unfair payment conditions, etc. • Require future and existing suppliers to comply with • Select or award suppliers who do not meet our values and Schneider’s Suppliers Code of Conduct expectations • Award suppliers fairly based on open, competitive bidding andwithout favoritism • Support suppliers in understanding our terms and conditions and in meeting our expectations, in line with industry standards • Expect our buyers, and other Schneider stakeholders in contact with our suppliers, to apply fair and ethical business practices
TRUSTWITHINVESTORS
Prevent Insider Trading 01 S OR T S E V IN H T WI T S U TR Insider trading occurs when a person trades in a company’s securities wheninpossession of material nonpublic or price-sensitive information aboutthatcompany. Asemployees,wemustbemindfulof ourresponsibilitytorespectinsiderdealinglawsandregulationsaswemayhave accesstoinsideinformation about Schneider Electric and its listed subsidiary companies. Employeesarenotrestrictedfrommakingpersonalinvestments,butitisprohibitedtotradeinanySchneiderorlisted subsidiary companies’ shares while aware of nonpublic information that can significantly affect the market value of theseshares. Examplesof insider trading include buying or selling shares before announcing financial results, acquisitions, divestments, winning or losing major contracts, or ongoing litigation, etc. which may cause the company’s share price to rise or fall. • Only disclose inside information, on a strictly need-to-know • Buy or sell shares in Schneider or its listed subsidiary basis and with the authorization of the Board of Directors’ companiesif wehaveinsideinformation at that time Secretary • Disclose inside information to anyone, inside or outside • Avoid chain mails and conversations in public spaces the company, without the Board of Directors’ Secretary • Consult the Board of Directors’ Secretary, if in doubt, before authorization buying or selling Schneider shares or its listed subsidiary companies’ shares
Deliver Accurate Financial Statements, Records andTaxInformation 02 S OR T S E V IN H T WI T S U TR All our financial records must be accurate, properly maintained and transparent to accurately present Schneider’s performance in accordance with International Financial Reporting Standards (IFRS) and to regularly provide transparent and trustworthy information to shareholders. • Enforce internal controls and processes to ensure that our • Makeanyexceptionstoourfinancial processes financial and business records, including financial and non- • Sell, transfer or dispose any of Schneider’s assets without financial reporting, are always accurate proper authorization and documentation • Continuously review and improve our processes to attain the • Accept cash transactions unless no alternative is possible best standards in the market and only then subject to the authorized legal amount, • Follow all recordkeeping guidelines to maintain records expressly authorized and properly recorded securely • Conceal payments via third parties • Cooperate with our internal and external auditors • Knowingly evade tax obligations
Deliver Solutions in Compliance withFinancial and Risk ManagementStandards S OR T S E V IN H T WI T S U TR 03 Oursolutions are designed, manufactured, and delivered to meet customer specifications, ranging from simple engineered-to-order solutions to complex integrated solutions. Fromtheearliest stage of each project, we involve experts to identify and manage potential risks related to financial, legal andimplementation matters. We comply with contractual terms and financial reporting standards to protect our assets. • Consult legal expertise to check liability exposure before • Get involved in bids and contracts without expert analysis approving contracts and approvals per our Chart of Approval • Allocate people to each project with appropriate skills • Getinvolved in the integration of legal entities or other and competencies arrangements which intend to share profits and/or losses • Implement a sequential business opportunities review andliabilities without Group CFO approval and approval methodology, in compliance with our Charts • Provide parent company guarantees without Group of Authority CFOapproval • Runcomprehensiveexpertassessmentssoapprovers • Raise customer expectations that don’t coincide with our makeinformed decisions by evaluating risks, benefits and Chart of Authority’s approved mandate propose mitigating actions • Knowingly misrepresent a projects’ financial performance • Identify project performance obligations per the Recognize Revenuepolicy, in accordance with International Financial Reporting Standards (IFRS) • Conduct regular project reviews to update forecasts, control risks, identify opportunities, and monitor customer satisfaction • Secure cash and margins for projects in compliance with all applicable laws, regulations and standards through accurate and timely reporting
PreserveourInformation TechnologyandRelated Intellectual Property Assets 04 S OR T S E V IN H T WI T S U TR OurIT(InformationTechnology) and IP (IntellectualProperty) assets enable us to effectively achieve our business and sustainability goals and become a more digital organization. It is our collective responsibility to source, implement, manage, and retire our IT and IP assets correctly. Moreover, it is essential to reduce any existing and new risks that may arise from how we use these assets. • Understand how to properly handle company assets and • Usecompanyassetsforourownpersonalneedsorinways apply security guidelines that interfere with our professional responsibilities • Give the same level of care to those company assets we use • Useassets belonging to third parties, such as photos or aswewouldtoourownassets videos, etc., without ensuring that we have the right to • Apply sustainable thinking when working with or returning usethem our company assets • Acquire, sell, transfer, or dispose of any IT or IP assets • Apply our Source Code Governance policy when creating without following Schneider’s process softwareIP
Preserveour Reputation S OR T S E V IN H T WI T S U TR 05 Weareallcustodiansof ourbrandanditsreputation.Asrepresentativesof Schneider, we mustchooseourwordswiselyandactresponsiblyinboth formal and informal meetings and discussions. Information is valuable, and the unauthorized disclosure of internal information can be detrimental to the Schneider brand image. As well, we make our best effort to honor the commitments we take in financial and extra-financial matters and we communicateonaregularbasisontheachievementof thesecommitments. • Demonstrate ethical and professional behavior • Interact with the press or speak publicly without prior externally and protect Schneider’s reputation, use official approval communication materials and follow brand guidelines • Share any confidential or proprietary company information • Act with caution when posting on social media related to R&D, pre-launches, mergers, acquisitions, • Avoid discussing confidential topics externally, in public disposals, financial performance, intellectual property, places internal documents or customer and employee information, • Respect confidential information by signing Non-Disclosure etc. Agreements(NDA) • Commenton financial performance or announcements • Take the right care in elaborating our commitments for future • Get involved in activities that could reflect negatively on financial and extra-financial performance, and make our Schneider best effort to deliver • Involve Schneider in our personal convictions and beliefs • Express our personal opinions about Schneider through official communication channels, such as social media • Disparage Schneider or our colleagues on online forums
Makeobjectivedecisions 06 usingtrusteddata S OR T S E V IN H T WI T S U TR Dataiseveryone’s business, because we all produce and consume data everydaytoinformSchneiderElectric’skeydecisions. WebelievethatDataGovernanceisanacceleratorof scalabilityandan enabler of trust. By implementing standards, controls and best practices, datagovernanceenablesasecuredatasupplychain,fosteringdata reliability, integrity and velocity. TheDataChartersetsouttheprinciplesandfoundationof datagovernance,detailing4datagoldenrules: • Goldenrule#0–DataProtection&Complianceframework, • Goldenrule #1 - Governed Authoritative source, • Goldenrule#2–GovernedGroupReferentials, • Goldenrule#3–GovernedGroupDataPlatform. SchneiderElectric and all subsidiaries must adequately comply to data golden rules from data creation to data consumptionacrossprocesses.The charteralsoseekstoensurethatauthorizedindividualsandentities withinSchneider Electric are compliant with the relevant regulations and legislation from privacy to ethical usage of data. • Apply the 4 Data Golden Rules to drive trust and scalability • Handle data without a clear understanding of its sensitivity – Apply the Data Protection & Compliance framework and without applying relevant data protection mechanisms – Useauthoritative data sources • Keepdata or records without checking data retention policy – Categorize data using Company Referentials • Usedatafor key decisions without considering traceability – Distribute data to approved SE data platforms only • Jeopardize accuracy and integrity of data by manipulating • Ensure that Performance Management is relying upon data sourced from Schneider Electric Data Platforms objective data • Think data is a topic for experts: data is everyone’s business • Skill up on Data Competencies, leveraging the Data & • Addressdatagovernanceonceasystem isalreadydeployed AI Academy • Develop Algorithms without consideration for Ethics and Privacy,
TRUSTWITHCOMMUNITIES
Actfora ClimatePositive World S E I T UNI M M CO H T WI T S U TR 01 Wetakeourclimatepledgeveryseriously,andwehelpourcustomersdrive their business growth while reducing their carbon emissions. We share our carbon-neutrality responsibility and ambitions with our employees, customers andotherstakeholders. • Increase our customers’ energy efficiency, enable the • Consider the environment secondary to our growth of renewable energy and reduce CO emissions business priorities 2 • Consider climate impact as part of our corporate and • Merely comply with laws and regulations; on the contrary industrial strategy westrive to set and achieve ever more ambitious goals • Advise customers on improving their energy management and reducing their carbon footprint • Act with suppliers to reduce emissions throughout our supply chain, from production to transport to waste management • Disclose detailed information on the environmental life cycle footprint of our products • ReducetheCO emissionsinoursitesandfacilities with our 2 technologies and by using renewable energy sources • Encourage our employees, partners and customers to reduce their carbon footprint
BeEfficient withResources 02 S E I T UNI M M CO H T WI T S U TR In respect of our planet, its nature and biodiversity, we have pledged to continuously minimize our environmental impact and take care to use fewer resourcesandmoregreenmaterialsinourproducts.Wehavedeveloped circular-use systems to incorporate reuse, repair and recycling, and welcome innovative service models which extend the life of our products. • Innovate with circular offers enabling increased life cycle • Practice the planned obsolescence of our products services and efficient maintenance • Seekexemption from substance regulations • Include recycled materials in our products without • Intentionally disregard our indirect impact on biodiversity compromising on safety and quality • Reducewasteintensity • Comply with high environmental standards and regulations • Disclose environmental information about our products • Prevent and limit pollution and emissions • Report environmental abuses for investigation and remediation • Savewaterandimplementresponsible sewagemanagement • Endorse initiatives to protect nature and wildlife
UpholdResponsibleLobbying andPolitical Activity S E I T UNI M M CO H T WI T S U TR 03 Asaglobalcompany,weplayaroleinthepublicdebate,clearly stating our position on issues, defending our interests and participating in technical discussions. Assuch,wemustactwithintegrityinall public decision-making processes and interactions with public officials when lobbying. We communicatepubliclyandtransparently onourpositionsharedthroughofficial meetings orpositionpapers with public decision-makers. • Take part in lobbying and representation activities only when • Participate in activities that could be considered as taking a authorized partisan position on behalf of Schneider • Report our lobbying activities where requested • Makecontributions (either monetary or in-kind) to political • Strictly adhere to laws governing lobbying and interaction bodies directly or through third parties with public officials, and expect the same from third-parties • Getinvolved in political activity or representation on behalf who act on our behalf of Schneider • Interact with public officials or participate in activities that could be considered as taking a partisan position or which maycomprise Schneider’s reputation
Empower S E I T LocalCommunities UNI M M CO H T WI T S U TR 04 Ourglobalpresenceallowsustohelpless-privilegedcommunitiesthrough specific initiatives, such as the Schneider Electric Foundation, Access to Energy program or other local and employee-led programs. Through charitable contributions and donations, by teaching, and volunteering our personal time, we support and stimulate communities, providing training to empowergrassrootsdevelopmentandinvestment. • Support communities with reliable, long-term commitments • Force any employees or third-parties to participate in, or • Maintain flexible work policies that encourage employees to donate to good causes devote work time to volunteering • Getinvolved in initiatives that are not in line with our ethical • Provide opportunities to devote time to volunteering, principles or community work community service and social causes
Donotuse ‘Conflict Minerals’ S E I T UNI M M CO H T WI T S U TR 05 Wedonotuseanyproductsorrawmaterialswhicheitherdirectlyorindirectly finance armed groups involved in the mining and trading of ‘conflict materials’ andassociatedhumanrightsabuses.Inlinewiththiscommitment,weensure our products and the substances used in our products are compliant with applicable laws, throughout our supply chain. • Source minerals and metals from trusted and socially and • Workwith suppliers who source from or are related to environmentally responsible suppliers organizations violating human rights • Influence suppliers towards more responsible sourcing with aConflict Minerals Compliance program • Adhere to internationally recognized standards for Conflict Minerals
ActasGood CorporateCitizens a) Protect the VulnerablefromAbusive WorkingConditions S E I T UNI M M CO H T WI T S U TR 06a Webelieveindignity, respect, fairness and protecting the most vulnerable from abusive working conditions, including child, forced or other improper labor. We monitor and evaluate our supply chain to ensure that everyone involved has safe working conditions, decent working hours and can earn a minimumlivingwage.Weexpectoursuppliers,subsidiariesandcustomers to act similarly for the respect of all Human Rights. • Operate a value chain free from labor abuses of any kind • Tolerate human rights infringements • Treat our suppliers and subsidiaries’ workers as we treat our • Delay in responding to any potential labor abuse or ownemployees violations • Conduct due diligence with suppliers, contractors and other stakeholders • Continuously improve our entire supply chain through dialogue, information sharing and training • WorkwithNGOs,businessassociationsandother companies to collectively improve working conditions
b) Respecttherightsof Association, RepresentationandSocialDialogue S E I T UNI M M CO H T WI T S U TR 06b Weupholdouremployees’righttosetupassociationsandrecognizetheir right to collective bargaining. In accordance with local regulations, our employeesarefreetojoin,takepartinorleavelabororganizationsthat maintainanddefendtheirinterests. We follow all the requirements to build andsustainfruitful and mutually beneficial relationships between labor organizations and management. • Respect the right of workers to set up and join • Implement internal measures which limit employee access representation groups and unions to labor organizations • Foster and encourage constructive dialogue • Interfere with the work of employee representative groups • Provide workers with the means to run these activities and unions • Discriminate or intimidate employee representative bodies or their members
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