The Group's human rights approach

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Respect for human rights is at the heart of ENGIE's Ethics Code of Conduct, its policies, in particular its Duty of Vigilance Policy - Human Rights, and its Vigilance Plan. The ENGIE Group also relies on the recommendations of the United Nations Guiding Principles on Business and Human Rights, which it considers to be a useful framework for reference and interpretation.

The Group's human rights approach thus aims to identify, prevent and manage the risks of human rights violations against any person, in particular employees, local communities, users and customers, throughout ENGIE's value chain. It also aims to ensure that any incident relating to human rights is dealt with appropriately.

Risk mapping

The potential major risks of negative impacts on the human rights of any individual related to the Group's activities relate to 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.

In 2022, for example, 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 2024, 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.

Duty of Vigilance Policy - Human rights

The Duty of Vigilance Policy - Human rights, the first version of which was drawn up in 2014, 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 the foundation of the Group's vigilance plan for human rights. 

The Group's human rights commitments

• ENGIE undertakes to respect the human rights of all individuals and groups likely to be affected by its activities and to ensure that its activities are conducted in accordance with the highest standards of protection and at least with the provisions of international texts for the protection and defence of human rights.
• 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 slavery, 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. It is committed to offering a common and adequate minimum level of social protection to all its employees wherever it operates. 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, particularly those surrounding its sites.
• The Group seeks to identify the risks associated with the activities of its suppliers and subcontractors.
• The Groupe ensures that missions aimed at the safety of its employees and its facilities are carried out with respect for human rights.

To ensure compliance with all of its human rights commitments and to meet French and international requirements, the Group also relies on other policies specific to certain issues, particularly the health and safety, security, ESG, procurement Charter and Human resources policies.

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 Duty of Vigilance Policy - Human rights 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 (ERM process) : 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. 
• 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…) are also subject to  ethical due diligence, in accordance with due diligence policies, that explicitly includes human rights. In addition, specific human rights impact assessments can also be carried out in specific situations.
• 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 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

The application of the Group’s Duty of Vigilance Policy - Human rights ensures this risk management. For each risk identified, the entities define and implement specific action plans to manage these risks at operational level. 

Examples of 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 83% of the Group's entities).

The Global Agreement on fundamental 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, and health & safety at work.

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, the Group rolled out guides to reaffirm the principle of zero tolerance in all parts of the world, for example: 

• a guide against all forms of discrimination against LGBTQ+ people ; 
• a guide on combating sexual harassment and sexist acts ;
• a guide “Empower Gender Identity in the Workplace”.

At operational level, when not required by regulations, entities are encouraged to appoint "sexual harassment and gender-based violence" representatives.

In 2022, for the first time, ENGIE adopted a Global policy for Diversity, Equity and Inclusion (DEI). See our Diversity & Inclusion page for more information.

In 2024, ENGIE introduced business travel guidelines for LGBTQ+ employees. These guidelines outline the essential steps to safe and informed travel, including learning about local laws, cultural norms and LGBTQ+ considerations before travelling abroad. They offer practical advice on how to stay safe and find support when travelling on business, as well as advice on how to deal with any issues that may arise. The guidelines also identify destinations with potential risks for LGBTQ+ travellers and suggest strategies for navigating these areas safely, so that all employees can travel with confidence and in safety.

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 such as during the Cuxtal II gas pipeline project in Mexico (see ENGIE’s Stakeholders engagement policy).

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

Employee and site security conditions 

Preventing and managing personal safety risks

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. The Group's requirements include raising awareness among security managers and mandatory training for the staff of security service providers. These service providers are also subject to due diligence checks prior to employment. Contracts with guarding and private security companies systematically include the Group's ethics clause in the general terms and conditions of purchase.

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

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

For several years now, the Group has introduced a specific heightened vigilance action plan to identify and manage these risks for certain product categories. 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 located in China. In 2024, 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 2022. This plan targets certain Group’s customer relation centers located abroad and is aimed at assessing the actual working conditions of workers in consultation with them. In 2023 and 2024, 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.

Awareness tools

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

• A training course on the Group’s human rights approach was developed in 2019. Open to everyone, it is particularly aimed at operational staff and managers who are directly concerned by this topic.
• An e-learning module on human rights for all employees has also been deployed for several years.
• In 2023, the Group adopted a new Code of Ethical Conduct. This document, which replaces ENGIE’s Code of Ethics and Practical Ethics Guide, sets out ENGIE’s ethical commitments. Among these commitments is respect for human rights. The Code of Ethical Conduct, available in 15 languages, is published on the Group’s website at the following address: https://www.engie.com/en/group/ethics-and-compliance/code-ethical-conduct

Employee awareness campaigns are widely relayed in Group entities. 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. 

Monitoring and measuring the performance of the human rights approach

The monitoring of the implementation of the Duty of Vigilance Policy - Human rights  and of the deployment of the required processes is integrated into existing Group’s ethical compliance processes: the annual ethics compliance report and the internal control system.

• 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.
• A control point designed specifically to assess the deployment of the Duty of Vigilance Policy - Human rights 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.

In 2024, 93.4% of the Group’s entities assessed the deployment of the Human Rights Vigilance Policy at their level as effective (level 4, the highest, according to the internal control framework). An individualized action plan may be implemented for all entities whose results were found to be weak.

The Group Ethics, Compliance & Privacy Department (DECP) coordinates the network of Ethics & Compliance Officers and ethics correspondents (in 2024: over 245 people), as well as Data Privacy Managers (in 2024: 130 people) throughout the Group. The Ethics & Compliance Officers are responsible for promoting the Human Rights Vigilance Policy among the entities' personnel and ensuring the proper implementation of the Group’s commitments locally.

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: