Unibail-Rodamco-Westfield
ESRS disclosure: ESRS G1 \ DR G1-3
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- Provide a detailed description of the procedures currently implemented to prevent, detect, and address any allegations or incidents of corruption and bribery, as required under Disclosure Requirement G1-3.
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Question Id: G1-3_01
The Group has implemented robust internal mechanisms to anticipate, monitor and counter any risks of engaging in practices that could amount to corruption or bribery, such as the ACP, the Anti-Money Laundering Programme, and the Group Code of Ethics. Additionally, all employees are trained to identify and distinguish situations that could be associated with corruption, with a clear communication of the Group’s zero tolerance principle for any violation.
Report Date: 4Q2023Relevance: 85%
- Does the undertaking currently lack procedures to prevent, detect, and address allegations or incidents of corruption or bribery? If so, disclose this fact and provide details of any plans to implement such procedures.
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Question Id: G1-3_04
The Group has implemented robust internal mechanisms to anticipate, monitor and counter any risks of engaging in practices that could amount to corruption or bribery, such as the ACP, the Anti-Money Laundering Programme, and the Group Code of Ethics.
Report Date: 4Q2023Relevance: 75%
- Provide detailed information regarding the nature, scope, and depth of the anti-corruption and anti-bribery training programs that are either offered or mandated by your organization, as stipulated under Disclosure Requirement G1-3 for the prevention and detection of corruption and bribery.
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Question Id: G1-3_06
To raise awareness and entrench the compliance culture within the Group, employees are required to participate in an annual and mandatory e-training, covering ethics and compliance topics such as the prevention of corruption and influence peddling (the ACP). As of December 31, 2023, 80% of URW staff have completed the online training. In addition to the online training, the most exposed departments identified in the URW corruption risk mapping (investment, development, public affairs, and procurement) are required to attend classroom training. Several training sessions were held throughout the Group, hosted by the Local Compliance Correspondents (LCC) in local languages. Finally, an ACP training session was attended by all Supervisory Board, Management Board and Executive Committee members. The objective was to present actions implemented to comply with the Sapin II Law.
Report Date: 4Q2023Relevance: 95%
- Provide detailed information regarding the extent of anti-corruption and anti-bribery training administered to members of the administrative, management, and supervisory bodies, as stipulated under Disclosure Requirement G1-3 for the prevention and detection of corruption and bribery.
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Question Id: G1-3_08
An ACP training session was attended by all Supervisory Board, Management Board and Executive Committee members. The objective was to present actions implemented to comply with the Sapin II Law.
Report Date: 4Q2023Relevance: 65%