The risks that Steria’s activities in IT services pose to the environment are modest compared to those of other economic activities. Nevertheless, Steria strives to limit them .
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Marketplace
Î 3.5 Marketplace
3.5.1 The Power of Sharing: Engaging dialogue with our stakeholders
Since its creation in 1969, Steria has emphasized the need to develop its business activity while following the strictest ethical guidelines and engaging with stakeholders, which means:
z making sure we clearly identify our key stakeholders;
z engaging with them as effectively as possible to understand any concerns and respond appropriately.
The Group believes that its current key stakeholders are its employees, employee representative organizations, clients, partners and suppliers (including subcontractors), shareholders, bankers, government agencies (national and territorial), NGOs and charities, rating agencies and Corporate Responsibility indexes.
Steria engages dialogue with its stakeholders whenever possible through website, meetings, presentations, surveys, agreements, and has made a breakthrough in 2013 enhancing use of social media internally as well as externally.
Steria Group also publishes a report on Corporate Responsibility that is available on its website (www.steria.com), and every year it undertakes to communicate its progress and key indicators (following Global reporting Initiatives – GRI recommendations) in the areas concerning Corporate Responsibility (Workplace, Marketplace, Environmental and Community).
3.5.2 Responsibility in the Marketplace
How Steria do business – and how all our actions have an impact in the marketplace – is an important consideration in our commitment to being an ethical business. We aim to provide benefits to society through everything we do and always bear in mind the potential ethical dimension of every service or solution we offer.
Steria signed the UN Global Compact in 2004, bringing companies together to advance universal principles in the areas of human rights, labour standards, the environment and anti-corruption and thus comply to:
z t he Universal Declaration of Human Rights,
z t he International Labour Organization’s Declaration on Fundamental Principles and Rights at Work,
z t he Rio Declaration on Environment and Development,
z t he United Nations Convention Against Corruption.
Compliant with UN Global Compact, Steria commits itself to respect the following principles:
Human Rights
z Businesses should support and respect the protection of internationally proclaimed human rights; and
z make sure that they are not complicit in human rights abuses.
Labour
z Businesses should uphold:
− the freedom of association and the effective recognition of the right to collective bargaining,
− the elimination of all forms of forced and compulsory labour,
− the effective abolition of child labour ,
− the elimination, of discrimination in respect of employment and occupation .
Environment
z Businesses should support a precautionary approach to environmental challenges;
z U ndertake initiatives to promote greater environmental responsibility;
and
z E ncourage the development and diffusion of environmentally friendly technologies.
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Anti-Corruption
Businesses should work against corruption in all its forms, including extortion and bribery.
Key priorities Key achievements in 2013 Medium-term goals Indicators (KPIs)
Re engage with our key stakeholders and extend the scope of our ethics programme to take account of new and emerging risks.
Interactive ethics eLearning module
launched on 9,764 employee PCs. Elaborate training of the bid and sales teams, focussed on ethics, anti-bribery and corruption, prioritising
‘at-risk’ geographies
% of employees attending ethics training sessions and completing compliance confirmation
Reinforce our engagement with suppliers and business partners to increase assurance that they are acting ethically in the marketplace .
Ethics training rolled out to new
employees Extend surveys of our top suppliers beyond sustainability to ethics and workplace compliance .
% of new suppliers contracted evaluated against Steria’s Corporate Responsibility selection criteria Procurement Charter extended
to 100% of the procurement population to affirm their compliance
Further develop the CR criteria
within the supplier selection process . Number of existing suppliers assessed against Corporate Responsibility criteria (focussed on top suppliers)
Extend the scope of internal audits to include CR related control objectives; notably supplier selection and contract renewals
% of procurement employees attending ethical sourcing training sessions
% of customer satisfaction surveys completed, including rating of our corporate responsibility performance KPIs have been identified in the table above to track our progress into 2014 and beyond.
3.5.3 Relations with our stakeholders
3.5.3.1 Employees
The Steria values of trust, openness and respect are captured in our compact Code of Ethics. With new and emerging risks, notably data privacy and growth in the India domestic market, Steria aims to continuously refresh our Code of Ethics as well as the awareness programme This programme is sponsored by the Group and Area Executive Committees.
The Code is published on our intranet in 3 different languages, as well as being available to our investors and partners on www.steria.com. This document defines Steria’s commitments with respect to human rights and diversity, labour standards, fighting fraud and corruption, conflicts of interest, protection of intellectual property, insider information, anti-competitive practices and environmental preservation. The Steria Corporate Responsibility Report (www.steria.com) provides more detail on our achievements, objectives and key indicators.
At the end of 2012 and beginning of 2013 we launched an interactive version of our Code of Ethics, uploaded to all Steria employees’ computers.
Our top 400 managers sign an ethics compliance confirmation each year. In 2013, all India staffhave formally signed the Code of Ethics and
awareness training programs for new employees have been launched in the UK, Scandinavia and Belux. In all over 30% of Steria employees have attended ethics awareness classroom training and/or completed compliance confirmations. To ensure that all managers and employees live out our values, as well as those initiatives cited, we have taken numerous steps to improve ethics and compliance awareness throughout the organisation. Increased awareness is supported by a practical Book of Internal Control, which includes a number of control rules related to ethics, as well as group and country specific policies. Compliance is monitored through annual confirmations as well as cyclical audits performed by the internal audit department
Our lean structure and corporate governance framework encourages a listening management culture. Multiple channels are open to employees, depending on countries and local legislations to report any misconduct, whether through their managers, HR or employee works councils. Referenced within all ethics training and documentation is an Ethics Mailbox. Any ethical concerns or issues can therefore be sent to the Steria Group Director of Internal Audit for investigation (including formalised fraud procedures if required), escalation and resolution.
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As part of its ethics program, Steria reports conflicts of interest for members of the Executive Committee, CEOs and CFOs of our subsidiaries.
These statements are submitted by the Group CFO to the Group Legal Director. They are then reviewed by the Group Audit Committee. Refer to section 2.6.2 of this document for more information.
3.5.3.2 Clients
Working in collaboration with its partners, Steria continues to develop innovative solutions in response to rapid changes in the industry. Steria’s thought leadership and publications can be found on www.steria.com. Additionally, Steria led numerous surveys with industry leaders in 2013, providing additional insight to our clients across a number of geographical areas (published at a local level). Steria organises a wide range of meetings and seminars with clients, notably within the “innovation board” framework to integrate new technological possibilities and respond to new challenges. Steria regularly conducts satisfaction surveys in its different local entities. These surveys enable continuous improvement in the quality of our services and include client’s perceptions on the way we do business.
In terms of corruption risk, 11 of the 12 countries where we have local customer contracts (France, UK, Germany, Austria, Belgium, Luxembourg, Norway, Sweden, Denmark, Switzerland and Singapore) are ranked in the top 15% of countries in terms of the corruption index (transparency international ranking). India is ranked 94 out of 177 globally, however the value of the contracts signed with Indian organisations, all in the public sector, represented less that 0.1% of the Steria revenue in 2013.
The Group also operates in Poland and Morocco through our Shared Services Centers, and do not have any client contracts locally. Therefore we do not consider the corruption risk across the Steria Group to be significant.
Furthermore, with a growth in local contracts forecasted in India, we will be running an awareness programme for bid management staff in India in 2014, focussing on corruption prevention and anti-competitive practices. Our Code of Ethics includes guidance on anti-competitive practices. It focuses on employees’ behaviour and dialogue with competitors in compliance with principles of competition and exchange of business information.
Working in collaboration with our clients, we manage security centres of expertise at various European locations, notably our Shared Security Services Centre in Toulouse. We harness this expertise to ensure our customer’s information is safeguarded. This includes a regular refresh of Steria Group IT security policies and standards, as well as security awareness training for our staff across the organisation. In 2013 we contributed significantly to European wide discussions on Big Data, Cyber Security, Biometrics and data confidentiality.
Regarding offers and services offered to customers, reference is made in the preceding paragraphs about the offers available for sustainable development and in favor of greater support vis-à-vis climate change.
3.5.3.3 Partners and Suppliers
We fully acknowledge our responsibility to source and allocate our resources accountably with suppliers, partners and subcontractors.
To ensure a responsible supply chain, we launched a Procurement Charter which has been signed by all employees working for the Steria procurement departments. We provide to suppliers seeking to work with Steria, a locally tailored Procurement Charter which clearly sets out Steria business principles when engaging and working with our suppliers.
The Procurement Charter addresses the following topics:
z corruption, gifts and donations;
z managing conflicts of interest;
z respect for principles of integrity and transparency in the pre-selection of suppliers participating in tendering, pre-selection among the suppliers used and negotiation of the signature of contracts and business relationships with suppliers.
We place emphasis on selecting suppliers embracing and demonstrating recognised sustainable environmental, ethical and other Corporate Responsibility standards (as set out in our procurement charter).
Corporate Responsibility commitments are now incorporated into new supplier contracts and in larger geographies a separate confirmation is required prior to Steria engaging with a supplier (this process is not yet uniform in all geographic areas).
The new procurement system currently being implemented across Steria has built in a supplier selection template including sreening questions and subsequent scoring on Corporate Responsibility criteria, where applicable. Furthermore the system’s supplier performance functionality will allow us to assess more regularly and effectively performance against many criteria including Corporate Responsibility. We continue to screen our supply chain for risks related to corruption, child labour, unacceptable working conditions and labour union rights. Therefore we are continuously improving our ability to check compliance our CR procurement policy, beyond environmental topics.
In the specific case of anti-corruption, in addition to code of ethics training, the following measures have been taken:
z in the UK, an anti-corruption policy has been issued to reflect the requirements of the 2010 UK Bribery Act. This policy applies to all those doing business within the UK and to overseas activities associated with the UK business (notably India);
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z Steria clearly prohibits the giving or receiving of bribes or kickbacks, with practical guidance provided on gifts of any value.
3.5.3.4 Shareholders
Steria Group SCA is a listed company. Steria Group SCA strives to apply the best corporate governance and transparency practices. Group corporate governance is described in part 2 of this Document.
With regard to Governance, the Steria Group applies the AFEP/MEDEF Corporate Governance Code and informs its shareholders every year in section 2 of the Registration Document of the way in which it applies the recommendations of this Code.
In addition to the report in section 3 of this Registration Document that contains the social, environmental and corporate information required
by the French Code of Commerce, Steria Group publishes a report on Corporate Responsibility that is available on its website (www.steria.
com), and every year it undertakes to communicate its progress and key indicators in the areas concerning Corporate Responsibility (social, environmental and corporate).
3.5.3.5 Territorial, economic and social impact of the company activity
In several countries where Steria is present, most employees work in the capital or in a city or near the big cities. However, Steria contributes to the development of the “territories”, as shown in the table below, which summarizes some of the “local hires made in France in 2013 (non-exhaustive list):
City where Steria is present (country) Number of hires in 2013
(under 25) Number of hires in 2013 (over 25)
Aix-en-Provence (France) 8 23
Colomiers (France) 43 77
Mérignac (France) 1 5
Orléans (France) 6 5
Rennes (France) 15 29
Roanne (France) 16 37
Saint-Herblain (France) 31 81
Valbonne (France) 4 36
Steria also contributes at the local level by cooperating with NGOs, associations and charitable organizations: see paragraph 3.6 of this document, GRI Report and our websites: www.steria.com, www.fondationsteria.org/, www.institut-de-france.fr and http://www.steriaindiafoundation.com/.
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Community
Î 3.6 Community
3.6.1. Support to local communities through volunteer programs for the empowerment of the disadvantaged
Steria believes that local communities are an important stakeholder in its environment. Education is the main factor of wealth creation of a society and a genuine agent of social mobility. Mastery of IT skills is the key to social and professional integration. Steria has therefore chosen primarily to help people to help themselves by giving them access to education, information technology and employment opportunities. Steria supports skills training programs that empower individuals and can lead to employment.
Steria’s collaborators, most of whom are volunteers, participate in community programs in countries where the Group operates. The aim is to encourage their initiative and to help them find opportunities for personal and professional development that will complement their professional growth.
This gesture of solidarity is based on two major Group volunteer programs (described below) and many local initiatives (some of which are detailed in the present document).