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Vigilance plan

In accordance with article L. 225-102-4 of the French Commercial Code, the aim of the Vigilance Plan is to identify risks and prevent serious violations with respect to Human Rights and fundamental freedoms, to the health and safety of persons and to the environment, which may result from the activities of the Group, its subcontractors, or suppliers with whom Air Liquide has an established business relationship.

Reminder of the law

The plan therefore applies to all Group subsidiaries, as well as to subcontractors and suppliers with whom Air Liquide has an established business relationship; it is based on the following:

  1. Risk mapping to identify, analyze and rank these risks;
  2. Regular assessment procedures of the position of subsidiaries, subcontractors, or suppliers with whom the Group has an established business relationship, in terms of risk mapping;
  3. Risk mitigation measures and the prevention of serious harm;
  4. A whistleblowing mechanism and compilation of reports on the existence or occurrence of risks, established in cooperation with the unions representing said company;
  5. A monitoring system of measures implemented and the assessment of their efficiency.

Please find the integrity of the vigilance plan published in the reference document at this link.

1

Risk mapping for the vigilance plan

Relating to Group businesses

Environmental and societal risks are included in the Group’s risk protocol. They are also subject to specific mapping covering areas targeted by law and set out in the table below:

Topics covered by the duty of vigilance Associated risks
Human rights and fundamental freedoms Discrimination*
Labor law
Health and Safety of individuals Health and Safety of individuals*
Environment Greenhouse gas emissions*
Resource management
Discharges into air and water


* Material risk factors within the meaning of the Prospectus 3 regulation

All “environmental and societal risks” are assessed by groups of countries (clusters) according to their impact and probability of occurrence. Specific mapping of net risk is established at the Group level and is based on the summary of this assessment.

Relating to suppliers

A level 1 suppliers’ risk map is drawn up each year based on the methodology developed by the Group Procurement Department. This methodology allows subsidiaries to rate the criticality of their suppliers according to seven criteria including the CSR(a) criterion. This criterion is itself based on four elements (the supplier’s business, country risk, Air Liquide’s rate of dependency on the supplier, the amount spent by the Group with this supplier). Deviation from just one of these elements is sufficient to class a supplier as “critical” in terms of CSR.

2

Assessment procedures of the position of subsidiaries, subcontractors and suppliers

Risk analysis by subsidiaries

Each year, risks are assessed locally by groups of countries (clusters) under the responsibility of their General Managers, in terms of impact (financial and reputational) and probability. A matrix dedicated to the Duty of Vigilance is drawn up at the Group level.

Method components (for example the analysis matrix) are provided by the Sustainable Development Department which supervises the process. The assessment is then reviewed by the risk Committee and the Environment and Society Committee.

This assessment allows the Group to rapidly implement corrective measures.

Steering Commitee Frequency Role

Governance

Executive Management
Risk Department
Finance Department
HSE Department
Legal Department
Communication Department

Two meetings per year

Validates guidelines
Analyses decision-making
Ensures follow-up measures

Operational steering

Operational steering
Sustainable Development Department
Procurement Department
HR Department
HSE Department
Business Line Department
Cluster Department
Legal Department

Four meetings per year

Ensure regulatory compliance
Implements operational roll-out
Suggests areas for improvement
Monitors indicators

Environment and Society Commitee Three meetings per year

Contributes its expertise on CSR subjects, to a delegation by the Board of Directors

Assessment of suppliers by the Procurement Department and by subsidiaries

For suppliers recognized as critical in terms of CSR, the Group assesses, with the support of EcoVadis, their performance in the following fields: the environment, social, business ethics and the supply chain. This assessment is based on the combined references of EcoVadis and the Procurement Department.

The EcoVadis questionnaire is regularly updated to take into account the results from previous campaigns. For example, a criterion relating to water consumption was added this year. To monitor the CSR performance of smaller suppliers while adapting to their structure, Air Liquide also developed a more suitable internal questionnaire in 2019.

In 2019, 944 suppliers were identified as presenting a critical CSR risk and are part of the long-term assessment program. Cumulatively over the 2017-2019 period, 914 assessments of suppliers’ CSR performance (including 325 in 2019) were carried out by EcoVadis and by using Air Liquide’s internal questionnaire.

These indicators are monitored under the Group’s Vigilance Plan.

Assessment of subsidiaries by independent auditors

All Group subsidiaries are subject each year to social, safety and environmental reporting. Data are collected, analyzed, consolidated and published in the Universal Registration Document (Chapter 5). Moreover, it is audited by an independent verifier (for around 20% of the Group’s environmental data and 30% of its Human Resources data).

The conclusions of the independent verifiers are published on page 319 of the universal registration document. Moreover, these are used to draw up action plans when non-compliance with Group protocols is identified.

3

Risk mitigation measures and the prevention of serious harm

Within the Group:

Air Liquide has formalized, in the BLUEBOOK, its values, Codes of Conduct, policies and internal procedures, in order to manage and mitigate environmental and societal risks. In terms of safety and the environment, the IMS provides a framework for operations. The Group’s commitment in terms of safety, ethics and Human Rights and fundamental freedoms (see “Safety”, “Ethics” and “Human Rights”) highlights that these are prerequisites that are taken into account in all of the Group’s businesses.)

Following a risk assessment, any anomalies detected must be subject to a local action plan. Assessments are reviewed at the Group level by the risk Committee to ensure the implementation of action plans.

Mitigation measures implemented in 2019

To mitigate environmental risks: climate roadmaps have been drawn up for all operations. They have been drafted based on the Group’s Climate Objectives. An internal “Climate Champions” network has been created to ensure the correct reporting of environmental data and to identify anomalies. Specific training courses have also been designed and are currently being rolled out within the Group.

Measures implemented as part of the Climate Objectives are described on the climate objective page.

To mitigate occupational health and safety risks, and in particular the risk relating to the psychological health of employees, seven principles of prevention were drawn up in partnership with Air Liquide’s European Works Council. These principles outline appropriate working and cooperation conditions to prevent psycho-social risks:

  1. Oversight of change management and transformation
  2. Continuous improvement
  3. Respect for the personal life of all employees and the facilitation of well-being at work
  4. Encouraging autonomy and accountability in the workplace
  5. Encouraging healthy relationships in the workplace
  6. Building a culture of listening and feedback
  7. Encouraging inclusion and diversity


Moreover, the Group is developing the MyVoice program to measure employees’ commitment (see page 69). A pilot phase was completed in 2019 and the program will be rolled out in 2020.

Measures relating to inclusion and diversity (gender, age, nationality and disability) are described in Chapter 5, page 299.

Suppliers’ sites

Two procedures in the BLUEBOOK relate to sustainable procurement and suppliers’ relations. The latter was updated in 2019.

Checks are carried out during tender offers. These checks relate in particular to the interrogation of public databases on subjects including sanctions and anti-corruption.

To reduce risks and prevent the grave abuse of Human Rights and fundamental rights, the health and safety of individuals, and the environment by suppliers, Air Liquide routinely sends the Supplier’s Code of Conduct to all Group suppliers in order to promote and enforce practices relating to Human Rights, ethics, the environment and safety. This Code can be found in 13 languages on Air Liquide’s website.

Moreover, a Sustainable Development clause is included in the Group’s new contracts and framework agreements with its suppliers. This clause covers the option for Air Liquide to assess the supplier’s sustainable development performance, as well as the obligation to implement adequate corrective measures. It also includes a compulsory reporting element for the suppliers in question, in particular on safety, energy and water consumption and atmospheric emissions, as well as Human Resources.

The Group also conducts on-site Sustainable Development audits for certain suppliers that are considered to be particularly at risk in this area, following unsatisfactory assessments. They are conducted according to recognized external benchmarks, often by a specialized external auditor. Following these audits, corrective action plans are drawn up. In certain cases, the business relationship may be suspended while the supplier brings its practices into compliance.

In addition to these measures, the Group also has Procurement procedures and provides training. Several training courses exist according to the degree of risk: e-learning or on-site training. Suppliers are provided with the same amount of information as Group employees.

Mitigation measures implemented in 2019
  • Change in critical supplier classification which allows at-risk suppliers to be identified more quickly and efficiently.
  • New criteria have been added to the supplier assessment process such as, for example, criteria relating to water consumption.

Air Liquide's measures relating to its suppliers awarded?

EcoVadis Leadership awards in the following category: Best Value Chain Engagement. This award acknowledges excellence in engaging suppliers in Sustainable Procurement programs

Sustainable Purchasing Leadershop Council (SPLC) in the following category: Leadership Award for Overall Sustainable Purchasing Program

Handeco Award (largest sustainable sourcing structure in France) in the Best Sustainable Sourcing Buyer Category

The above information is presented in the diagram below which highlights that all levels of suppliers are subject to risk mitigation measures:

Suppliers Code of conduct and training RSE Clause Evaluation by EcoVadis or internal questionnaire Implementation of an action plan and on-site audit
Air Liquide suppliers YES N/A N/A N/A
Suppliers with contract YES YES N/A N/A
Critical suppliers YES YES YES N/A
Non-compliant suppliers YES YES YES YES

4

Whistleblowing mechanism and compilation of reports

The current whistleblowing tool, Ethicall, allows employees and external collaborators to report deviations from the Code of Conduct, including on subjects relating to Human Rights and fundamental freedoms, health and safety in the workplace as well as environmental protection.

5

Monitoring system of measures implemented and the assessment of their efficiency

The Vigilance Plan is drafted and monitored by the Sustainable Development, Procurement and Legal Departments. It is overseen by operational teams which have a dedicated procedure in place on this subject. The Board of Directors’ Environment and Society Committee is regularly informed (at least once a year) of the monitoring and implementation of the Vigilance Plan

Monitoring of supplier-related measures

Critical CSR suppliers are assessed using EcoVadis and Air Liquide questionnaires. These questionnaires have four categories: environment, social, ethics and value chain. The monitoring system for these critical CSR suppliers is presented in the table below:

Assessment of critical CSR supplier (Based on EcoVadis + Air Liquide criteria) Score out of 100 Supplier score for each area of assessment Overall supplier score
≥?45

between
25?and 45

<?25
If one criterion obtains a score of > 20 ? ? ?
If one criterion obtains a score of < 20 ? ? ?

Green : Reassessment of a supplier every three or five years according to the duration and specific characteristics of the contract.?
Orange : Reassessment of a supplier every three years with regular monitoring of corrective action plan.
Red : One month to draw up a corrective action plan and then implementation of this plan within the following 12 months. A review is carried out each quarter by the procurement steering Committee.?

The overall review of assessments and action plans is validated by the Procurement Managers Committee.

Monitoring of measures relating to the whistleblowing mechanism

The Group whistleblowing monitoring system is supervised by the Ethics Officer. Each year, it communicates the type of reports received and implements dedicated action plans.

Detail of Ethicall reports?:?

Number of Ethicall reports in 2019 298
Including alerts relating to Human Resources 77%
Including alerts relating to suspected fraud or conflicts of interests 17%
Alerts requiring corrective action 27%

?

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