Vilmorin & Cie - Annual report 2017-2018

ANNUAL REPORT Vilmorin & Cie 118 2017-2018 Social, environmental and societal INFORMATION 4 It includes seven commitments to internal and external stakeholders: respect for shareholders, respect for employees, preservation of the environment, loyal behavior towards competitors, customer and consumer satisfaction, long-term, balanced relationships with suppliers and partners, responsible conduct with respect to the regions in which it operates. It is currently available in eleven languages: French, English, Spanish, Portuguese, Chinese, Dutch, Italian, Ukrainian, Japanese, Hebrew and Turkish. In order to facilitate its appropriation and use, it is accompanied by a complete communication kit including a dedicated e-learning module, the pedagogy of which is based on the principle of a role-playing game. Each player is put in a situation based on four operational scenarios (gifts, safety, data confidentiality and antitrust) and must solve these ethical cases by using a questioning reflex to act with common sense and discernment. As previously explained, on June 30, 2015, 100% of top executives had already been trained in the Code of Conduct , using operational scenarios. On June 30, 2018, 2,387 permanent employees from Vilmorin & Cie had fully completed the e-learning module and the knowledge check quiz, i.e. 36% of the employees. This result is a long way from achieving the results fixed when the e-learning was launched. However, it should be noted that because of updating the courses to make them compliant with the Sapin II law in France (cf.§ 4.3.2.2, p 118), no effort to promote this training was made over the course of the fiscal year. The next version, available at the beginning of 2019, will provide improvements that deal with certain issues identified as preventing the efficient use of the training as it stands today, particularly with regard to connection to the platform, with developing awareness with non-connected employees and with reporting. 4.3.2.2 Fighting corruption The Group strives to enforce the statutory and legal provisions in fighting corruption and money laundering (notably the OECD convention of 1997), and, in the conduct of its commercial and financial relations, to take account of the significant recommendations of national and international organizations such as OFAC concerning economic sanctions. Vilmorin & Cie’s compliance with the Sapin II law was a major project for fiscal year 2017-2018 and will be pursued in 2018-2019. This project, called “BE&AB” for Business Ethics & Anti-Bribery, is being carried out by Vilmorin & Cie’s reference shareholder, Limagrain, and goes beyond compliance with the Sapin II law by also addressing the issues of insider trading and interest representatives. The BE&AB project is co-led by the Governance Risks and Compliance department (GRC) and the CSR department, with the Group’s VP for International Affairs and CSR as sponsors. The various topics listed in the Sapin II law were either continued or launched during fiscal year 2017-2018 on the basis of projects already available or work previously undertaken. Risk mapping was carried out with the methodological and operational support of an external consultancy. Interviews and online surveys identified the main corruption risks facing the Group. The presentation of the risk map to the Executive Committee was an opportunity for the latter to affirm its determination to fight all forms of corruption that the Group and its subsidiaries could face in their daily activities, wherever they may be in the world. The Code of Conduct was updated during the fiscal year to take into account the required regulatory changes. Its content will cover in greater depth topics such as conflicts of interest, gifts and hospitality and the alert system. In addition, it will naturally address the risks identified in the corruption risk map. Its new version will be presented, by the end of 2018, to all existing staff representative bodies. Discerning unethical acts and avoiding mistakes are concerns that go in the direction of excellence. For Vilmorin & Cie, present in many countries with very different cultures and legislations, marking its identity with clear benchmarks is a sine qua non condition to insure its reputation and legitimacy. At the same time, the e-learning is being modified to take into account the evolution of the Code of Conduct . Additional modules will deal with the new features of the Code of Conduct , without calling into question the existing version. In addition to this e-learning, which targets all Vilmorin & Cie employees, training courses dedicated to populations exposed to corruption risks will be scheduled. Identification of these populations (buyers, salespersons, financial and legal staff, etc.) is the first step that needs to be taken. However, sessions have already been scheduled for Vilmorin & Cie’s Board Members and top executives In terms of third-party evaluation, the process has been initiated. This project is complex to implement given Vilmorin & Cie's organizational specificities: facilities in 48 countries, sales in nearly 150 countries, ten Business Units that, in conjunction with the holding companies, coordinate more than 90 companies, a strong operational delegation that does not require the sharing of such data. The first stage is to analyze available data on customers and suppliers in order to consider a first procedural approach that meets the requirements of the law. Vilmorin & Cie already has extensive accounting controls in place. They will be reviewed in terms of anti-corruption in the light of the changes adopted in other projects linked to the Sapin II law . The alert system was determined during the fiscal year. Although HR managers and company or Business Unit managers are to be the privileged contacts for an employee who identifies an action that is contrary to the Code of Conduct , the Group also provides them 4.3. Conducting activities in an ethical, sustainable and effective manner