###### 3.1.2 Governing responsibly
Act for Good® is embedded throughout the Group's management, governance structure and departments in all countries in which it operates. The strategy is supported by dedicated tools to track sustainability performance, and managed through the following governance structure:
**STAFF**
**SUPPORT FUNCTIONS** **DEVELOPMENT** **OPERATIONS**
The CSR Department is responsible for defining the Act for Good® strategy and coordinating its implementation across departments and countries. Country managers, Group heads of departments involved, as well as operational teams in the shopping centers (technical and marketing mostly) then manage the implementation of Act for Good®, in line with the local context. Each country determines its annual action plan regarding investment and management for all technical and sustainable development issues, including tailored targets for individual assets in collaboration with the Group Engineering & Sustainable Buildings Department. They are supported by best practices guides that define actions a country can take, based on proven initiatives on the implementation of Act for Good® pillars. The CSR Department meets quarterly with each country's Management Committee to ensure the successful implementation of the strategy and monitoring of progress. The meetings facilitate two-way engagement between country CSR teams and Group-level departments along with the dissemination of best practice and performance reviews.
This governance framework is also supported by a network of approximatively 50 delegates across Klépierre subsidiaries, who carry out local actions and report on best practices. The delegates engage with the head office teams via regular monthly meetings to increase information sharing and build robust cross-functional teams.
Klépierre also embeds the Act for Good® strategy in all company communications to increase engagement amongst employees and promote the implementation of the strategy in daily business operations.
FInally, to demonstrate commitment to the strategy at the highest level, key Act for Good® commitments are incorporated into the performance share allocation criteria for the Group's principal managers."
"An Ethics and Compliance Committee has been set up to oversee the proper implementation of the compliance system and to rule on specific cases. It is composed of the three persons above in addition to the COO and the Group Head of Internal Audit. [...] The Anti-corruption Code of Conduct sets out the Group's expectations regarding the giving and receiving of gifts and invitations, conflicts of interest, facilitation payments, patronage and sponsorship and lobbying activities."
"The climate strategy is supported by an integrated governance structure that serves the Group's ambition and performance: the Executive Board is in charge of strategic planning and of implementing climate commitments, which are themselves reviewed by the Supervisory Board via the Sustainable Development Committee, which meets at least three times a year. [...] The Klépierre Group also reports annually on its progress in a dedicated chapter of the Universal Registration Document, which is fully audited by an independent third party.