This information is collected for purpose of Communication on Progress in line with our UN Global Compact report.

Preventing corruption

In early 2011, an ambitious program of prevention of corruption has been launched:

• The Anti-Corruption Compliance Directive and its associated procedures were adopted. This specific guidance provides our employees with clear rules of conduct if they are exposed to corruption risks. It lays down rules in compliance with the most restrictive laws in relation to the choice of an intermediary dealing with public officials, in business partnerships, acquisitions, procurement, as well as donations, gifts, entertainment, travel, contributions to social development, corporate philanthropy and sponsorship ;
• A network of over 300 compliance officers at branches, subsidiaries and entities level has been established ;
• Training seminars for compliance officers has been organized ;
• An e-learning anti-corruption has been developed in 11 languages to increase knowledge of corruption risks and prevention procedures. It is based on practical business situations and is available to all Group employees . As of to date, it has been taken by 45,000 certificates.

The RESIST (Resisting Extortion and Solicitation in International Sales and Transactions) anti-corruption tool, which was developed by the International Chamber of Commerce (ICC), the Global Compact, Transparency International (TI) and the Partnering Against Corruption Initiative (PACI) and published in 2009 was incorporated, among others, into the e-learning anti-corruption. Total participated together with other companies in its realization. This is a learning tool that uses case studies to assess a company’s possible responses in high-risk situations.

Total also joined international initiatives which contribute to the fight against corruption and participates in the dissemination of good practices and the promotion of dialogue between companies and civil society. Indeed, as a member of the Global Compact Anti-Corruption Working Group, Total took part in the writing of “Fighting Corruption in the Supply Chain: A Guide for Customers and Suppliers” in 2010.

Fighting fraud

In 2011, our program to fight against fraud has been also strengthened.

The Integrity Policy and Program were adopted in early 2011. The Policy reaffirmes the principle of zero tolerance of fraud, completes and clarifies cross-business ethical behavioral rules and defines and structures roles and responsibilities within the organization. It also reinforces awareness and training to help employees better prevent, detect and manage fraud and corruption risks. It provides incident analysis and feedback to make our ongoing protection more effective.

This program is particularly supported by a network of Fraud Risk Coordinators at C orporate, branches and subsidiaries/entities levels. Their role is to recommend measures to prevent, detect and handle fraud and corruption and implement those measures in their business or field of activity.

The Group Directive Guidelines to be followed in case of fraud incidents, adopted in May 2011, provides what to do at the local, branch and corporate level if irregular practices are identified.