The Group's human rights approach

Back to the main page of ENGIE's vigilance plan

ENGIE's Ethics, Compliance & Privacy Department, attached to the Legal, Ethics and Compliance Department, itself under the authority of the Corporate Secretariat, is in charge of the human rights approach of the vigilance plan. It relies on its network of Ethics and Compliance Officers and ethical correspondents located all over the world and on the other departments concerned by the human rights.

Respect for human rights  is one of the 5 principles on which ENGIE's ethics and compliance policies are based. The Group’s Human Rights referential provides a framework for implementing the principle of respecting human rights and brings together all of ENGIE's commitments in the area of human rights.

Preventing and managing human rights risks

The referential constitutes the foundation on which the pillars of the Group's overall approach are based, a foundation that includes the United Nations' guiding principles on business and human rights (UN, 2011) and recalls the Group's various policies, all of which contribute to respecting its human rights commitments.

ENGIE is committed to conducting its business in a manner that respects internationally recognised human rights wherever the Group operates, including in all its dealings with public authorities. The Group's commitments are based on the risks of human rights violations potentially caused by the Group's activities (either direct activities or through its business relationships).

The Group's commitments are based on the mapping of human rights issues updated as part of the Group's vigilance plan.

Risk mapping

The major risks of negative impacts on the human rights of any individual related to the Group's activities concern the fundamental rights of workers. More broadly, the Group's human rights challenges are as follows:

The risks identified are the subject of specific responses at the operational level, some of which are described below in the section on risk management and prevention of serious harm.

For example, in 2020, due to the Covid-19 pandemic, ENGIE faced a large increase in the migrant worker population in Singapore. The Philippines, Myanmar and Indonesia are the other countries most exposed in terms of human rights. The main risks in these countries are related to subcontracting and activities requiring a large and low-skilled workforce (including migrants). Due to the outbreak of Covid-19 among the migrant worker population, for example, local authorities have not allowed them to leave their dormitories except to work. With the approval of local authorities, our local entity has been housing migrant workers in private residential premises (condominiums). The aim is to improve their living conditions and to guarantee the principle of free movement.

In 2022, following several press articles reporting a high rate of child labor in Quebec, the NORTHAM region targeted Quebec suppliers, and sent them letters reminding them of the mandatory compliance with ENGIE's human rights commitments, including the prohibition of child labor.

Assessment of subsidiaries

Self-assessment and risk analysis tools are deployed annually for all entities. The entities participate in INCOME COR4 (human rights internal control) and ERM analyses (My Ethics Risks) to assess the human rights risks.

In particular, all entities must annually assess their activities with regard to their impact on human rights using a dedicated self-diagnostic grid as part of the overall risk management policy (ERM process). These assessments make it possible in particular to identify the risks specific to each of the Group's entities: (1) the risk factors intrinsic to the entity's specific activities and (2) the strengths and weaknesses in the consideration of human rights within the entities' processes/policies/practices, and (3) consequently, the action plans to be put in place in light of the elements identified. This tool covers all the Group's human rights commitments.

The risk assessment is updated at least once a year and the entity’s risk prevention plan is updated accordingly. These elements are also discussed at the Global Forum (the monitoring body for ENGIE's Global agreement), at  the European Works Council and with the Ethics, Environment and Sustainable Development Committee of ENGIE.

In 2023, the dedicated self-diagnosis grid allowing entities to assess their activities annually with regard to their potential impacts on human rights covered 95% of the entities.

Entities must also assess any new business activity using a dedicated grid aimed at identifying the human rights risk factors specific to the planned activity.

Human rights policy

The Group human rights policy, the first version of which was drawn up in 2014 under the name “Human Rights Referential”, aims to define the means necessary to ensure compliance with the Group's commitments in all its activities by implementing a global vigilance approach. It is now the foundation of the Group's vigilance plan for human rights. The Group's vigilance plan adopted in 2018 as required by French law on the duty of vigilance of parent and ordering companies aims to identify and prevent serious harm to people and the environment.

The Group's human rights commitments

• The Group makes sure that the fundamental rights of its employees are respected, in accordance with the fundamental conventions of the International Labor Organization: it rejects all forms of forced or compulsory labor, of child labor, of human trafficking, of discrimination and recognizes freedom of association and the right to collective bargaining. The Group pays particular attention to guarantee the highest standards of health and safety in the workplace, working hours and holidays in accordance with international standards and equal remunerations.
• ENGIE rejects all forms of harassment and violence in the workplace and makes sure that its employees are provided with a working environment that is respectful of their individual freedoms and privacy.
• The Group ensures that its activities do not infringe the rights of local communities surrounding its sites, and that assignments related to the security of its employees and assets are conducted with respect for human rights.

To ensure compliance with all of its human rights commitments and to meet French and international requirements, the Group relies on different cross-functional policies and policies specific to certain issues, particularly the human rights policy. The health and safety, security, ESG, procurement Charter and Human resources policies complement the human rights policy, covering specific commitments that fall within their particular scope.

Human rights risk management

The Group exercises vigilance by identifying and managing any risks to people that arise from its activities. The vigilance approach is guided by the UN Guiding Principles and French law on the duty of vigilance of parent companies and ordering companies.

The human rights policy calls for vigilance processes at the Group level and at the operational level to ensure that human rights risks are managed as part of all activities, in particular:

• Annual risk analysis (My Ethics Risks via ERM process) : the risk of human rights violations is seen as a major risk for ENGIE. As a result, all operational entities must ensure that the Group's commitments are being respected: human rights violation risks (related to forced labor, human trafficking, child labor, freedom of association, right to collective bargaining, equal remuneration, discrimination, security forces, harassment & violence in the workplace, working conditions, housing conditions of workers, the presence of vulnerable people such as migrant workers or indigenous populations etc.) must be evaluated annually, and corrective action plans must be established for any identified risks. Risks are assessed considering the country, the presence of subcontracting, the type of activity, characteristics relating to workers, the presence of populations where risk is heightened if they are vulnerable, the products / services used, use of armed security forces, and the type of business partners. 
• Risk assessment for any new activities: any new project, any new business relationship that arises from the development of a new activity or from starting business in a new country, must also be subject to a preliminary human rights risk analysis using a dedicated grid aimed at identifying the human rights risk factors specific to the planned activity. Third parties (partners, suppliers and subcontractors…) of business development projects are also subject to prior ethical due diligence that explicitly includes human rights such as the practices of business partners, subcontractors and suppliers involved in the project. The results of this analysis are included in an ethics note highlighting the main potential risks identified and the associated mitigation measures to be implemented. In addition, specific human rights impact assessments can also be carried out in specific situations.
• Due diligence on partners and suppliers: human rights risks that are part of business relationships are fully covered by ethical due diligence done prior to any commercial relationship.
• Creation of grievance mechanisms at the operational and/or Group level, so that anyone who believes they have been impacted by the Group's activities can freely submit their questions, comments, or requests.
• The Group’s internal ethics incident managerial reporting system (My Ethics Incident) as well as the Group’s whistleblowing system (also open to all external stakeholders) explicitly include incidents relating to human rights.

Actions to manage risks and prevent serious harm

Entities in two major regions, South America (SOUTHAM) and Asia - Middle East - Africa (AMEA), as well as Global Energy Management & Sales (GEMS) and Tractebel have seen their level of risk change in terms of human rights, due to the countries concerned by some of their activities or the sector of activity (gross risk). For each risk identified, the entities define and implement specific action plans to manage these risks at operational level.

In addition to these risk management measures defined and implemented locally by the Group’s entities are more global actions. The application of the Group’s human rights policy ensures this risk management for all the Group’s human rights issues. Examples of these risk management measures illustrating the main categories of human rights issues identified for the Group are presented below.

The inclusion in the contractual documentation of the ENGIE Group's standard Ethics clause containing, in particular, the requirements related to the duty of vigilance and human rights is also a requirement that is widely implemented in the entities (approximately 82% of the Group's entities). 

The Global Agreement on fundamental social rights and social responsibility signed in 2022 by ENGIE and the Group’s social partners also contributes to the management of risks related, for example, to the fundamental rights of workers, health & safety at work and to suppliers and subcontractors.

Fundamental rights of workers

Prevent the risk of harassment and discrimination

The prevention and combating of harassment and all forms of discrimination is applied both within the Group and for the benefit of the subcontractors’ employees. For example, in 2021 and 2022, the Group rolled out guides to reaffirm the principle of zero tolerance in all parts of the world: 

• a guide against all forms of discrimination against LGBTQ+ people; 
• a guide on combating sexual harassment and sexist acts.

In 2022, for the first time, ENGIE adopted a Global policy for Diversity, Equity and Inclusion (DEI). This policy has a dual objective of helping the Group progress in terms of the representation of the diversity of populations and in making all work environments inclusive. There is no place for either discrimination or harassment in any form.

The priority subjects defined for 2022 and 2023 are:

• gender equality (notably with the Fifty-Fifty program);
• the question of LGBTQ+ (Lesbian, Gay, Bisexual, Transgender / Transsexual plus);
• origins (including nationalities, ethical origins, skin color, religion, social background, education and non-standard career paths);
• generations (the integration of young people and the employability of seniors);
• and the issue of disability.

See our Diversity & Inclusion page for more information.

At operational level, entities are encouraged to appoint "sexual harassment and gender-based violence" representatives.

Prevent the risks related to modern slavery

ENGIE's human rights commitments are based on the best international standards as well as on national laws relevant to its activities, such as the French law on duty of vigilance and the British law on modern slavery. ENGIE shares the objectives of the UK Modern Slavery Act and takes several measures to ensure that in its operations and those of its supply chain, there are no modern slavery practices (including in particular: slavery, forced labor and human trafficking).

Go to the ENGIE Statement on Modern Slavery Act at the bottom of the page.

Other risk management measures relating to fundamental workers' rights are set out in ENGIE's global agreement, as well as in its occupational health and safety and personal security policies.

Rights of local communities

Prevent the risks of violation of the rights of local communities

The Group is particularly attentive to the impact of its activities on local communities. It specifically takes into account the situations of vulnerable people (such as indigenous communities). To do this, the Group assesses the potential impact of its activity on communities and ensures that their expectations are taken into account through dialog and consultation (see ENGIE’s Stakeholders engagement policy).

Within the framework of the Group's investment committees, all of files related to partners were subject to due diligence with human rights risk. When due diligence is carried out on a business partner in application of the Group's policy by the ethics team or by a professional external service provider, the analysis includes a verification of the partner's reputation in terms of human rights (respect for labour law, controversies with local communities in other projects, allegations by local NGOs, etc.).

In addition, specific human rights impact assessments can also be carried out in specific situations.

Employee and site security conditions 

Prevent the risk of disproportionate use of force

In certain situations, the intervention of government security forces or private security companies may be necessary to protect the employees and facilities of Group entities. In order to prevent the risk of disproportionate use of force, the Group's requirements include the compulsory training of employees and security provider’s workers.

Other health, safety and security risk management measures are set out in ENGIE's Global agreement, as well as in its occupational health and safety and security policies.

Subcontracting, suppliers, partners

Prevent the risk of forced labor practices in the Group’s supply chains located in China

The Group does not source from Chinese manufacturers that are unable to provide proof that they have not used forced labor. As of 2020, the Group introduced a specific heightened vigilance action plan to identify and manage these risks. The Group has agreed to ensure compliance with international laws and actively monitors the situation to ensure that no forced labor is used anywhere along its supply chain. In 2023, the Group continued its enhanced vigilance measures.

The main measures implemented include: 

• in-depth due diligence on suppliers carried out by independent experts; 
• supply chain evidence requested from suppliers; 
• written commitment from suppliers not to use forced labor; 
• sending out questionnaires in which suppliers have to provide evidence that they ban forced labor; 
• enhanced contractual clauses (general audit clause, breach of contract in case of failure by suppliers to meet their obligations, supplier’s guarantee to comply with local and international regulations governing forced labor, from the procurement of commodities through to the delivery of a product); 
• participation in several sector initiatives in solar (for instance, Solar Power Europe, with whom we work together with other actors of this sector on the development of a responsible, transparent and sustainable supply chain) and wind (for instance, wind Europe) to share and help improve risk management practices.

Prevent the risk of violation of the fundamental rights of workers in ENGIE’s customer relations centers located abroad

The Group began to roll out an action plan in one of its entities in 2022. This plan targets the Group’s customer relation centers located abroad and is aimed at assessing the actual working conditions of workers in consultation with them. In 2023, for example, controls to ensure the implementation of the requirements were conducted directly on site in certain customer relations centers.

Other risk management measures related to business partners are elaborated on in the ENGIE Global Agreement and in application of policies relating to occupational health and safety, personal security, energy supply risk management, non-energy procurement risk management and third-party assessment.

Update on ENGIE's activity in Myanmar

During the first half of 2021, Engie was questioned by international trade unions on the Group's activity in Myanmar in view of the takeover by the army and in view of alleged human rights violations. In response, ENGIE answered that our activities in Myanmar were limited to providing access to energy for electrification purposes in non-electrified areas. In September 2021, ENGIE sold its entire stake in Myanmar and sold all its shares in the local Joint Venture company.

Situation related to Russia and Ukraine

ENGIE has no industrial activity in Russia and no investment projects are underway in the Russian territory. Furthermore, ENGIE does not operate in Crimea, Donbass or Luhansk Oblast.

Awareness tools

Tools have been deployed to raise employee awareness on human rights and duty of vigilance issues :

• In 2019, a face-to-face training course on the Group's human rights approach, including the duty of vigilance, was developed for the entire Group and as of today is fully rolled. Open to all, it particularly targets operational staff and managers directly concerned by this topic. Since 2022, the people performing functions that are particularly exposed to human rights risks are identified and a training plan specifically dedicated to them is deployed. This training is also mandatory by some entities.
• An e-learning module on human rights for all employees has also been rolled out since several years ;
• At the end of 2023, 2 228 employees were trained in human rights (face-to-face), including around 57% of operational functions, around half of them from high-risk entities, and 16, 520 employees trained in e-learning .
• Regarding the prevention and fight against harassment, against all forms of discrimination not only within the Group but also for the benefit of the personnel of the subcontractors, the following actions have been launched in 2020 ;
  • A guide against all forms of discrimination against LGBTQ+ people was implemented in 2021. The primary objective is to provide recommendations, in particular to entities that do not have such a policy, in order to encourage them to adopt one. It reaffirms the principle of zero tolerance towards any discrimination by ENGIE.
  • Similarly, a guide on the fight against sexual harassment and sexist behavior was prepared in 2021 and rolled out in 2022.

Employee awareness campaigns are widely relayed at operational level.

For example, France Renewables again stepped up in 2022 the ethics training and awareness-raising initiatives it has been running for several years for all employees.

Some entities have also, for example, made training on the Group's human rights approach mandatory for all employees or are also implementing a training program covering the entire vigilance plan. Also for instance, in Belgium, awareness of human rights issues among the executive committee and management teams has increased considerably thanks to the local ethics training courses for these people.

Monitoring and measuring the performance of the human rights approach

The monitoring of the implementation of the human rights policy and of the deployment of the required processes is integrated into existing Group’s ethical compliance processes: the annual ethics compliance report (« My Ethics Report » process) and the internal control system (« INCOME COR4 » process).

• “My Ethics Report” process : quantitative and qualitative indicators on the implementation of the required operational processes are included in the Group's ethical compliance procedure. Each entity reports annually on the progress made in applying the policy (with a letter of compliance from the entity's director certifying its responsibility and commitment to its application).
• “INCOME COR4” process : a control point designed specifically to assess the deployment of the human rights policy by the entity is deployed by the Group's internal control system. It includes, for example, control points linked to the annual human rights risk analyses carried out by the entities. 
  These monitoring processes allow ENGIE SA to ensure the effective application of the human rights vigilance plan and to define, if necessary, additional control actions such as internal or external audits.

In 2023, 97,5% of the entities that evaluated the deployment of the human rights policy considered that the deployment is effective (level 4 maximum). In the same year, the monitoring of the quality of the self-assessments (INCOME COR 4) carried out by the entities was reinforced. As each year,  it can be, for example, decided to set up an individual action plan for all entities with weak results.

The Ethics, Compliance & Privacy Department (DECP) relies on a network of Ethics and Compliance officers (more than 245 worldwide by the end of 2023) responsible for promoting the human rights policy to employees of the entities and ensuring that the Group's commitments are properly implemented locally.
In 2023 again, we note a strengthening of the entities' operational responses linked to the deployment of the human rights policy.

In 2022, ENGIE signed a new global agreement on fundamental social rights and social responsibility. The agreement also provides for a monitoring of the commitments: