evaluation mission of the corporate social responsibility of sni …€¦ · responsibility of sni...

Evaluation mission of the corporate social

responsibility of SNI Group entities

Consolidated Report

Tasks carried out by Vigeo during the period April to December 2015 in each of the following SNI Group

entities: 11 ESH (OSICA, Coligny, NLCL, SHAB, SHRA, SHB, LPN, NLP, NLA, NLE, NLM), and the establishments

SNI, Sainte Barbe and AMPERE Gestion.

EFIDISD and SAMO, which have already been assessed for CSR by Vigeo, and ADOMA, are not included in the

scope of the evaluation. AMPERE Gestion was assessed based on an evaluation framework contextualised

according to its sector of activity and thus is excluded from the consolidation for this reason.

April 14th 2016

.

Mission team

This report was compiled by:

Under the supervision of:

Rudy L’Espagnol

CSR Consultant

Tel: +33 1 55 82 32 89

[email protected]

Julien Souriau

CSR Consultant

Tel: +33 1 55 82 32 97

[email protected]

Florence Fouquier

Mission Director

Tel: +33 6 32 71 53 19

[email protected]

The information contained in this document is strictly confidential and cannot be divulged to third parties. All use of texts, images, graphs, methods and databases presented in this document and protected by the provisions of Books I and III of the Intellectual Property Code, without the prior written consent of Vigeo, will incur civil and criminal penalties.

mailto:[email protected]



▌3/24 14/04/2016 – Consolidation of CSR audits conducted at SNI, Sainte-Barbe and 11 ESH in 2015

CONTENTS I. Content and context of the mission ...................................................................................... 4

II. Consolidated results of the SNI Group .................................................................................. 6

III. Consolidated results of the SNI Group detailed for each criterion .......................................... 8

DOMAIN: ENVIRONMENT ........................................................................................................... 10

DOMAIN: RESPONSIBLE BEHAVIOUR TOWARDS CUSTOMERS ........................................................ 12

DOMAIN: FAIR BUSINESS PRACTICES .......................................................................................... 12

DOMAIN: COMMUNITY INVOLVEMENT........................................................................................ 13

DOMAIN: HUMAN RIGHTS .......................................................................................................... 14

DOMAIN: HUMAN RESOURCES ................................................................................................... 15

DOMAIN: CORPORATE GOVERNANCE ......................................................................................... 16

ANNEXES .................................................................................................................................. 17

Consolidated results of the SNI Group – Detailed tables ............................................................. 18

Methodological principles ......................................................................................................... 21


I. Content and context of the mission

This mission is part of the continuous process of assessing social responsibility, taken on

by the SNI Group over the last 4 years.

Assessment by Vigeo of environmental and social performance of SAMO (2011), and then

EFIDIS (2012)

Assessment in 2013 of CSR policies and commitments initiated by the Group

The present process is based on this assessment of the Group's policies in order to identify

the quality and level of their implementation in each entity audited.

Our assessments, carried out between April and December 2015, are based on :

The self-assessment forms completed for each entity, on the basis of a questionnaire

compiled by Vigeo.

The review of more than 1,000 internal documents

Interviews with over 320 people, including 280 employees and managers within entities, and

40 external stakeholders.

Questionnaires compiled by Vigeo, sent to several hundred suppliers and service providers

to SNI Group entities.

- We consider that this information is sufficiently qualified for us to make a diagnosis

with a reasonable level of assurance.

The evaluation framework is in line with Standard ISO 26000. It covers 18 corporate social

responsibility (CSR) drivers contextualised according to the business sector and weighted

according to their importance.

The 18 CSR objectives in the evaluation framework*

Environment

1. Management of the environmental impact in the creation of housing

2. Management of environmental risks in the construction, renovation and maintenance of properties

Responsible behaviour towards customers

3. Respect for interests of applicants for social housing

4. Respect for interests of tenants

5. Management of health risks within housing units

Fair business practices

6. Integration of social and environmental factors in the supply chain

7. Prevention of corruption

Community involvement

8. Contribution to sustainable development of territory and improvement of living conditions

9. Development of social accompaniment for tenants in difficulty

10. Development of physical accessibility and adaptation of housing

Human Rights

11. Non-discrimination and diversity

12. Respect for human rights standards and prevention of violations

Human resources

13. Quality of remuneration systems

14. Career management and promotion of employability

15. Improvement of health and safety conditions

16. Promotion of labour relations and collective bargaining

Corporate Governance

17. Transparency and effectiveness of authorities

18. Dialogue with tenants' representatives

Weighting of each criterion according to importance (see methodological annex)


CSR: first and foremost a managerial process

Our assessment of the level of commitment and of management of risks for each CSR objective results

from an analysis and assessment of the components of the managerial system

The notation scale

Our opinion on the company's performance is assessed for each sustainability driver on a scale of 1 to 4.

Effectiveness of results

Coherence of implementation

Exhaustiveness of policies

Visibility

Exhaustiveness

Ownership

Coverage

Scope

Means allocated

Indicators

Stakeholder opinions

Controversy management

Advanced

Robust

Limited

Weak

Advanced

- Advanced commitment, that is level 3+: solid evidence of mastery of managerial factors dedicated to the

realisation of the sustainability driver.

- Reasonable level of assurance on the management of risks and innovative orientations in the direction of

anticipating emerging risks.

Robust

- -Convincing commitment, significant and consistent evidence of mastery of managerial factors.

- -Reasonable level of assurance on the management of risks.

Limited

- -Commitment to the sustainability driver has been started and/or is incomplete; fragmentary evidence of the

management of managerial risks.

- - Low level of assurance of mastery of risks.

Weak

- -Commitment to sustainability driver cannot be detected; no evidence of management of risks.

- -Low to very low level of assurance on the management of risks.

9 angles of analysis 4 levels of performance


II. Consolidated results of the SNI Group

We have audited the CSR performance of the various SNI Group entities (SNI, Sainte-Barbe, OSICA & 10

ESHP), for all 18 CSR criteria.

We have consolidated these results at SNI Group level, in order to provide a synthesis of the Group's overall CSR performance (see annexes for further details).

Graph 1: Consolidated results of the SNI Group, all entities and all criteria (without any weighting)

Example of graph reading: 0.4% of the criteria audited at the SNI Group were assessed at an “advanced”

level.

Explanation: overall, amongst all the SNI Group entities and criteria audited, there is only 1 criterion rated "4" ("advanced" level) that is, 1 case with a "4" rating amongst 13 entities x 18 criteria less 2 cases (since the corporate governance criterion no. 1 was not rated for either Sainte-Barbe nor SNI), that is

= 1 / (13x(18-2))

= 0.0043 = 0.43% of the criteria assessed for the SNI Group

Advanced Robust Limited Weak


Main conclusions

Group policies contribute to the structuration of the CSR approach

Convincing commitments have been formalised and cover all challenges, except for the

responsible purchases policy, which is still limited.

Strong ownership of the commitments to most objectives, by both management and teams

Visibility of the Group's commitments still variable between the entities

Heterogeneous implementation, according to entities

The robust systems developed by the Group form a framework for implementing the

commitments in the entities (procedures, tools, resources,…)

However, their operational implementation is more heterogeneous

An internal control that is globally robust, while reporting tools would benefit in certain

cases from being more operational in order to strengthen piloting and monitoring, as at

present they are mostly used to report to head office rather than to manage the activity

Overall performance of entities is mostly robust

However, major differences in performance remain visible between entities regarding some

criteria

No major risk identified during the audit

A CSR approach embedded in a progress dynamic

A positive tendency attributed to most criteria being reviewed, all entities combined

Good practices observed in ESH as well as in SNI establishments


III. Consolidated results of the SNI Group detailed for each criterion

The consolidated results of the SNI Group, detailed for each of the 18 CSR criteria audited, are presented below without any weighting.

Graph 2: Consolidated results of SNI Group detailed for each criterion (without any weighting)

Graph 3: Result for each criterion and for each entity (without any weighting)

14/04/2016 – Consolidation of CSR audits conducted at SNI, Sainte-Barbe and 11 ESH in 2015 ▌9/24

Environment

Management of the environmental impact in the creation of housing

Management of environmental risks in the construction, renovation and

maintenance of properties

Responsible behaviour towards customers

Respect for interests of applicants for social housing

Respect for interests of tenants

Management of health risks within housing units

Fair business practices

Integration of social and environmental factors in the supply chain

Prevention of corruption

Community involvement

Contribution to sustainable development of territory and improvement

of living conditions

Development of physical accessibility and adaptation of housing

Development of social accompaniment for tenants in difficulty

Human Rights

Non-discrimination and diversity

Respect for human rights standards and prevention of violations

Human Resources

Quality of remuneration systems

Career management and promotion of employability

Improvement of health and safety conditions

Promotion of labour relations and collective bargaining

Corporate Governance

Transparency and effectiveness of authorities

Dialogue with tenants' representatives

DOMAIN: ENVIRONMENT


Of note: the consolidated result at domain level is compiled after taking account of the weighting of its

various component criteria.

The SNI Group demonstrates a robust management of the environmental impact of its new building constructions and renovation, essentially in terms of energy performance and urban sprawl. Robust procedures are in place, with environmental references for each operation, energy renewal programmes, and circulation of supports for making tenants aware of eco-gestures. The results are also robusts, with a significant improvement in energy performance and several exemplary pilot projects (e.g. eco-district, BEPOS and BEPAS). There is, however, still a need to formalized a policy for the other impacts, to increase the requirements regarding VEFA operations (which represent the majority of new productions) and to improve the monitoring system.


DOMAIN: RESPONSIBLE BEHAVIOUR TOWARDS CUSTOMERS

The house leasing attribution policies have been formalised and are backed by robust processes. The management of tenants' interests is also robust. The Group's quality charter sets specific objectives, reorganisation is in progress to reinforce the entities' proximity services, and an important monitoring system is in place. The results are robust and are improving, despite varying levels of performance and tension on some resources. Finally, management of health risks within housing units remains a challenge for almost all entities, despite compliance with the regulations and the major policy on asbestos introduced by the SNI Group. However, progress remains variable and some risks are still not being monitored.


DOMAIN: FAIR BUSINESS PRACTICES

The SNI Group respects the regulation requirements. However, the entities' current commitments and procedures only allow partial integration of the environmental and social factor into the purchase processes.

In contrast, the internal control and audit procedures in place allow a robust level of performance in terms of prevention of risks of corruption, even if it could be useful to circulate a guide of operational practices to increase the awareness of the employees.


DOMAIN: COMMUNITY INVOLVEMENT

The SNI Group contribution to the development of territory is robust, with strong involvement of the entities and various actions implemented to meet the expectations of the local authorities and to dynamise activities in the neighbourhoods’ communities. The current objectives and monitoring process would benefit from being better formalised. Social assistance to tenants with economical and social difficulties is also robust but is more heterogeneous. The commitments made and the entities' resources are currently being strengthened, but the aims and the monitoring system are insufficiently suited to assess its effectiveness. Finally, the accessibility and adaptation of the housing for person with reduced mobility (PRM) are covered by commitments from the SNI Group and various levels of action are carried out by the entities. Although the procedures are in place, the monitoring of demands and the assessment of needs require improvement.


DOMAIN: HUMAN RIGHTS

The performance of the SNI Group is limited in the Human Rights domain for the 13 entities covered by the audit. The policies initiated by the SNI Group (agreements on diversity, action plan for the prevention of psycho-social risks) contribute to convincingly address the challenges under review. However, the implementation of these commitments is still limited, since dedicated training sessions do not yet cover all the targeted populations and the monitoring systems should be part of the teams' daily activities. The results on diversity show a positive trend in terms of gender equality and regarding the integration of disabled persons, even though this dynamic remains variable between the 13 entities.


DOMAIN: HUMAN RESOURCES

The performance of the 13 entities of the SNI Group in terms of working conditions and relations is robust. Commitments have been formalised for all criteria under review, through business agreements that are relayed internally via several different communication channels. The ownership of these commitments is shared between the Group, the entities' management bodies and the local managers. Regarding implementation, the processes in place are robust for most of the challenges being reviewed, with sufficient dedicated resources and means of control and reporting to ensure monitoring within the Group; even though they would benefit from being implemented at entities level to strengthen proximity piloting. However, reservations have been expressed by stakeholders, especially with regard to remuneration, carrer development and psycho-social risks issue.


DOMAIN: CORPORATE GOVERNANCE

The Corporate Governance has been assessed at a robust level on the perimeter of the 13 entities covered by the audit. The functioning of the Boards of Directors is consistent with CSR standards in the matter. Rooms for improvement include the training of directors and the regular assessment of the Boards. With regard to discussion with tenants, the practices in the entities of the SNI Group are more variable (frequency of committee meetings, dedicated resources …).


APPENDIX

14/04/2016 – Consolidation of CSR audits conducted at SNI, Sainte-Barbe and 11 ESH in 2015

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Consolidated results of the SNI Group – Detailed tables

We have audited the CSR performance of the various entities of the SNI Group (SNI, Sainte-Barbe, OSICA & 10

ESHP), for all 18 CSR criteria.

We have consolidated these results at SNI Group level, in order to provide a synthesis of the Group's overall CSR performance. To do so, we propose two methods of consolidation :

- Consolidation without weighting: the cumulative of the 13 entities audited (see graph 1)

- Consolidation with weighting: the performance of the SNI Group entities is weighted on one hand by

the number of housing units in each entity and on the other hand by the level of importance of each

CSR criterion within the sector evaluation framework (see graph 2).

Graph 1: Consolidated results of the SNI Group, all entities and all criteria included (no weighting)

Example of graph reading: 0.4% of the criteria audited by the SNI Group were assessed at this level:

"advanced"

Explanation: overall, amongst all the SNI Group entities and criteria audited, there is only 1 criterion rated "4" ("advanced" level) that is, 1 case with a "4" rating amongst 13 entities x 18 criteria less 2 cases (see governance criterion no. 1 was not rated for Sainte-Barbe and for SNI), that is

= 1 / (13x(18-2))

= 0.0043 = 0.43% of the criteria assessed for the SNI Group

Limited Weak Robust Advanced


▌19/24

Example of graph reading: 58.2% of entities audited were rated as "convincing".

Graph 2: Consolidated results of the SNI Group, all entities and criteria combined (with weighting according

to the importance assigned to each criterion and the number of housing units in each entity)

Example of graph reading: 1.7% of criteria audited were rated as "advanced".

Explanation: Overall, amongst all the criteria of all the SNI Group entities audited, there is 1 criterion rated "4" ("advanced" level), and this criterion is given a weighting of 3 (because of the importance of this criterion) and of 0.24 (as the entity concerned with our rating represents 24% of the SNI Group's housing stock), of the 13 organisations and 16 CSR criteria assessed, with each rating given a weighting of 1, 2, or 3 depending on the importance of the criterion and the function of the total portion of SNI Group housing that corresponds to each entity:

= 1 x 3 x 0.24% / 43,114

= 1.7% of the notes obtained by the SNI Group.

It emerges that the overall CSR performance, consolidated at SNI Group level, is roughly comparable

whatever the method of consolidation adopted.

We have also consolidated the results of our audits for the 3 categories of entities making up the SNI

Group, in order to define their respective performance levels better:

- Consolidated section: SNI and Sainte Barbe (see graph 3)

- OSICA (see graph 4)

- The 10 ESHP (see graph 5)

-

Robust Weak Limited Advanced


▌20/24

Graph 3: Results of the SNI and Sainte-Barbe, all criteria (with weighting according to importance assigned

to each criterion and number of housing units in each entity)

E

xample of graph reading: 57.3% of criteria audited for SNI and Sainte-Barbe have been assessed as

"convincing".

Graph 4 : Results of OSICA, all criteria (weighted according to importance assigned to each criterion)

Example of graph reading: 7 % of criteria audited for OSICA were rated as "advanced".

Explanation: At OSICA level, there is only 1 criterion given a rating of "4 " ("advanced" level), that is, 1 case given a rating "4" (and a weighting of 3) amongst the 18 CSR criteria each given a weighting of 1, 2, or 3 according to their level of importance (which represents a total weighting of 46)

= 1x3 / 46

= 7% of the rating obtained by OSICA

Weak Limited Advanced Robust

Weak Robust Limited Advanced


▌21/24

Graph 5: Results of the 10 ESHP, all criteria (with weighting according to importance assigned to each criteria

and number of housing units in each entity)

Example of graph reading: 60% of criteria audited for the ESH were rated as "advanced".

Advanced Weak Limited Robust


▌22/24

Methodological principles

CONTEXT: INCREASED PRESSURE FROM STAKEHOLDERS

Under the rising influence of the stakeholders (particularly by international organisations, associations and NGOs), the pressure on the companies is increasing. Whether of conviction or of necessity, they are required to take account of their stakeholders' expectations and report to them.

The quality of this relationship gives rise to new risks and opportunities at social, corporate, environment and management levels. This relation may have a positive or negative effect on the reputation of the company and renders the managers of the company responsible.

THE VIGEO’S EVALUATION FRAMEWORK: IDENTIFICATION OF THE STAKEHOLDERS' LEGITIMATE EXPECTATIONS

The stakeholders' expectations are multiple and sometimes contradictory, leading organisations to question their hierarchy and the arbitration that should be conducted between them.

Simple hearing of the stakeholders will not allow this hierarchy arbitration procedure to be realised. Should all expectations be taken into consideration? How to verify their legitimacy? Should the most strongly expressed expectations be given extra weighting? How can weak signals be taken into account? Etc.

Specifically, our opinion on each of the components (Leadership, Implementation, Results) is itself built using more precise angles of analysis. A transverse reading of the evaluations that follow these angles of analysis is rich in meaning for an organisation as it facilitates answering the following questions:

Are the commitments being followed by the company known internally and by the stakeholders (the

visibility of policies is a condition for the improved company’s reputation)?

Company

Performance risks

Level of commitment

Stakeholders


▌23/24

Are the commitments being taken by the company consistent with the stakeholders' legitimate

expectations (exhaustiveness of policies)?

Are the company managers being effectively mobilised to implement the commitments (ownership of

policies)

Has the company adapted its processes and functions to take into account the requirements of corporate

social responsibility (means)?

Are the human and financial resources dedicated to these aims consistent with the company's ambition

(a transverse reading of the results from this angle provides indications on the efficient use of resources)

Does the company have an efficient reporting system (a necessary condition for effective monitoring of

actions and optimum enhancement of the value of its investment)?

Are the results measured consistent with the ambitions (opinion formulated through available

indicators)?

What is the stakeholders' opinion on the performance of the company (measure gaps between objective

and results indicators)?

when controversy occurs , what is the company's capacity to manage suchsituation?


▌24/24

CSR OBJECTIVES WEIGHTING MATRIX

Fundamental or vital

interests / expectations

Essential interests /

expectations

Minor interests

/expectations

Frequent violations of

stakeholders rights /

controversies

Occasional violations of


controversies

Infrequent violations of


controversies

probable

Less significant interests

/expectations

Reputation

Human capital

cohesion

Operational

efficiency

Legal security

Market

Transparency

EXPOSURE RISKS

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