Vigilance plan

与集团业务相关

环境al 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
人权and fundamental freedoms	歧视*
	Labor law
Health and Safety of individuals	个人健康和安全*
环境	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.

与供应商有关

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.

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
操作转向 操作转向 可持续发展部 采购部 HR Department HSE Department Business Line Department Cluster Department Legal Department	Four meetings per year	Ensure regulatory compliance 实施运营推广 提出需要改进的地方 Monitors indicators
环境与社会委员会	Three meetings per year	向董事会代表团提供企业社会责任方面的专业知识

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.

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“安全”,“Ethics”and“Human Rights”)强调这些是集团所有业务都要考虑的先决条件。）

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. 作为气候目标的一部分而实施的措施在气候目标页. 减轻职业健康安全风险，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: Oversight of change management and transformation Continuous improvement Respect for the personal life of all employees and the facilitation of well-being at work Encouraging autonomy and accountability in the workplace Encouraging healthy relationships in the workplace 建立倾听和反馈的文化 鼓励包容和多样性 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

蓝皮书中的两个程序涉及可持续采购和供应商关系。后者于2019年更新。

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.

为降低风险，防止供应商严重侵犯人权和基本权利、个人健康和安全以及环境，液化空气集团定期向集团所有供应商发送供应商行为准则，以促进和执行与人权、道德、环境和安全相关的实践。这个代码有13种语言在液化空气公司的网站上.

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.

该集团还对某些供应商进行了现场可持续发展审计，这些供应商在评估不满意后被认为在这方面特别有风险。它们是根据公认的外部基准进行的，通常由专门的外聘审计员进行。在这些审计之后，制定了纠正行动计划。在某些情况下，业务关系可能会暂停，而供应商使其做法合规。

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

以下类别的EcoVadis领导力奖：最佳价值链参与度。该奖项旨在表彰供应商参与可持续采购计划的卓越表现

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

上述信息如下图所示，图中强调了各级供应商均需采取风险缓解措施：

Suppliers	行为准则和培训	RSE Clause	Evaluation by EcoVadis or internal questionnaire	行动计划的实施和现场审计
液化空气供应商	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

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.

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	每个评估领域的供应商得分	Overall supplier score
		≥ 45	之间 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.
橙色：每三年对供应商进行一次重新评估，并定期监控纠正措施计划。
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.}

对评估和行动计划的全面审查由采购经理委员会确认。

无声的相关监控措施leblowing 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.

Ethicall报告的详细信息：

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%