Is su
e 3 Business ethics
Combating corruption and avoiding conflicts of interest, promoting fair competition between business partners. Includes the General Data Protection Regulation.
R is
ks
Fraud | Breaches of probity | Conflicts of interest
This concerns risks related to irregularities (in the broad sense), fraud, conflicts of interest or breaches of probity and, more generally, risks related to changes in the conditions of competition, the legality of work, and the payment or collection of funds. This risk is amplified by the level of visibility of the project and its industry, especially since the public profile of Société du Grand Paris requires exemplary conduct. The definitions of the three concepts should nevertheless be clearly differentiated in everyday use and situations:
The risk of fraud corresponds to any deliberately dishonest act carried out with the intention of deceiving by contravening the law or regulations (e.g. producing false invoices, CEO fraud, misappropriation of funds, etc.); The risk of a conflict of interest situation is any situation in which there is interference between a public interest and public or private interests which is likely to influence or appear to influence the independent, impartial and objective exercise of a function. This type of situation may impair a staff member s ability to discern when making a decision, thus running counter to the interests of the project; The breach of probity risk includes the risks of corruption (offering an undue advantage to carry out an action for the benefit of a third party), influence peddling, favouritism (intentional non-compliance with public procurement rules), unlawful taking of interest, bribery, and misappropriation of funds.
A ct
io n
P la
ns
Actions to combat fraud Insurance policy and system for reporting fraud in place Introduction of new secure rooms for contract reviews by project managers Regular audits to ensure that tool accreditations are in line with confidentiality commitments Awareness raising among parties involved in the expenditure chain by the Accounting Services Division Actions to strengthen the measures to combat internal fraud: control of delegated signing authority, internal accounting control
Securing critical anti-corruption and conflict of interest factors Awareness raising among all Société du Grand Paris employees by the Legal Affairs and Risk, Audit and Compliance Divisions Implementation of a conflict of interest and corruption prevention plan Implementation of a monitoring and support plan for employees in a potential or proven conflict of interest situation
IDENTITY
RISKS AND CHALLENGES
Risks
CSR APPROACH
2020 ACTIVITY