Leading by example
The Airbus Ethics and Compliance Programme seeks to ensure that the company's business practices conform to applicable laws, regulations and ethical business principles, as well as contribute to a culture of integrity.
Commitments and standards
Over the years, Airbus has earned the trust of passengers, customers, operators and other stakeholders through the quality and safety of our products. To fully serve our communities and thrive in the future, our commitment to business integrity must be just as robust. This means conducting our business ethically and based on Airbus values, as well as in compliance with all laws and regulations.
Our goal is to be known as a company with "integrity inside" - integrity in its people, partners and suppliers.
As part of this commitment, Airbus supports the principles of the UN Global Compact and IFBEC's Global Principles of Business Ethics, which set a benchmark for high ethical standards globally.
Airbus also is committed to the FX Global Code, a joint initiative between major central banks and private sector participants to enhance integrity of foreign exchange markets.
Join me in focusing on what really matters: rejecting bribery and corruption, preserving our integrity, and embracing our values for the purpose of serving the best interests of our great company, Airbus.
- Guillaume Faury – CEO Airbus
The foundation for integrity at Airbus is our Code of Conduct (CoC). The Code is intended to guide daily behaviour and help employees resolve the most common ethical and compliance issues they may encounter.
The Code of Conduct applies to all employees, officers and directors of Airbus, as well as entities that we control. Third-party stakeholders whom we engage are also expected to adhere to Airbus Code of Conduct in the course of performing work on our behalf.
The Code of Conduct
Programme and risk
While our Code of Conduct provides a useful starting point, they cannot answer all questions, nor are they sufficient to ensure that Airbus complies with the myriad legal requirements applicable to its business. Because of this, we have worked over the past several years to develop an Ethics and Compliance programme that is structured around three key risk areas: business ethics/anti-corruption compliance, export compliance and data protection compliance.
Each of these areas in turn is supported by dedicated compliance policies and a team responsible for their implementation, together with the identification and proposal of new measures to adapt to a constantly evolving regulatory landscape.
Improving our programme is a constant and ongoing process, not only in the area of business ethics/anti-corruption but across the ethics and compliance spectrum more generally.
Airbus rejects corruption of any kind, whether public or private, active or passive. This means that neither we, our employees nor third parties acting on our behalf may offer, promise, give, solicit or receive – directly or indirectly – money or anything of value to or from a government official or someone in the private sector in order to obtain or retain business or secure some other improper advantage.
Airbus' anti-corruption policy summarises our zero tolerance stance. It also refers to some of the specific directives we have adopted to address key anti-corruption risk areas, such as the engagement of third parties, gifts and hospitality exchange, and making sponsorships and donations.
More broadly, business ethics at Airbus also covers other areas such as conflicts of interest, anti-competitive conduct, insider trading, fraud, etc., while also complementing the Airbus corporate responsibility programme - which focuses on managing the social and environmental impacts of Airbus’ operations.
We do not allow personal interests to interfere, or appear to interfere, with our ability to make fair and objective decisions when performing our jobs in the best interest of Airbus.
Airbus has implemented a directive requiring employees facing a situation that represents or may represent a conflict of interest with regards to their activities with or within Airbus should proactively declare it to the Ethics and Compliance team. Examples include, among others, having a financial interest or directorship in a third-party, outside employment or a side business, or having a relative who is a public official with decision-making power that could affect Airbus.
Failing to declare and properly manage a conflict of interest situation may have negative consequences for individuals and for Airbus.
Gifts or hospitality shall not be extended as a way to improperly influence a business decision or gain an undue competitive advantage.
The giving and receiving of any gifts or hospitality are regulated by an internal Airbus policy and are subject to recording and pre-approval into a digital approval tool depending on their value.
Before offering or accepting any gifts or hospitality, we must ensure that (i) it is lawful, (ii) the value is reasonable and (iii) it is allowed under Airbus internal policies and standards.
Extra caution must be taken when interacting with government officials, for which specific compliance pre-approval is required as set forth in the applicable Airbus policy.
Airbus has a sponsorships, donations and corporate memberships directive that applies to all employees. The directive incorporates mandatory recording for all projects irrespective of their values and sign-off requirements by Ethics and Compliance for projects over certain financial values, or where Ethics and Compliance "red flags" are identified.
All sponsorships, donations and corporate memberships entered into by Airbus must:
- Have a legitimate charitable, societal, professional trade or promotional purpose, consistent with Airbus’ global strategy, priorities and values;
- Comply with all applicable laws;
- Be made to reputable organisations or beneficiaries;
- Be properly recorded.
The sponsorships, donations and corporate memberships directive also applies to political contributions.
Airbus has implemented a business development support initiative directive for the approval and monitoring of commercial intermediaries/agents, requiring them to undergo an enhanced Ethics and Compliance due diligence background check and multi-level managerial approval prior to engagement. As part of the process, information gathered directly from the potential intermediary/agent is corroborated by Airbus’ own in-depth research activities, e.g. to confirm/establish the ultimate beneficial ownership of the intermediary. In the event where Airbus identifies red flags or risks that cannot be properly mitigated, in particular questions concerning ultimate beneficial ownership, the company has and will refuse new engagements and terminate existing engagements with the third party.
Commercial intermediaries’ activities are monitored on a regular basis throughout the entire life of the relationship. Payments require approval from different functions including Ethics and Compliance and finance, and are processed only upon reception of satisfactory and detailed activity reports.
Airbus systematically requires inclusion of an anti-corruption clause in its contracts with intermediaries, which includes a termination right for Airbus in case of failure by the latter to adhere to anti-corruption or other standards. Incentive schemes for agents are designed and calculated in such a way to promote ethical behaviours and discourage corrupt practices.
Airbus is committed to ensuring that any lobbying activity is undertaken in compliance with all applicable laws and its anti-corruption programme.
The Airbus Responsible Lobbying Charter provides the principles which any Airbus employee or third party representative retained by the company must adhere to when engaging with public officials in any capacity. The principles are also reinforced by a training module available to all employees.
Complementing the specific processes applicable to commercial intermediaries, lobbyist & special advisors, sponsorships & donations, the Ethics & Compliance team conducts screening on the entire supplier base of the group.
Consequently, all suppliers undergo an automated initial screening and ongoing monitoring through the Airbus Supplier Screening Tool.
The third-party due diligence is managed by the Ethics and Compliance team to ensure a full segregation of duty with the Procurement team, which itself maintains oversight of all supplier relationships.
Airbus has implemented a directive to ensure that corruption risks associated with potential mergers and acquisitions (M&A), joint ventures (JV) and similar transactions are detected, assessed and mitigated.
The directive incorporates a number of milestones, which are reviewed from a compliance perspective at each stage of the transaction. For example, the directive sets out the requirement for Airbus to establish a potential joint venture’s ultimate ownership, understand its track record with regard to anti-corruption initiatives, and scrutinise key individuals’ historical business activities.
In addition, the directive provides for extra requirements such as the right to conduct periodic audits on a joint venture's activities.
The directive also requires that Airbus is able to terminate a joint venture following breaches of anti-corruption representations and warranties in the joint venture agreement.
As part of its mission to support sales campaigns and contract execution in certain countries, Airbus may enter into offset related agreements.
Offset transactions carried out by, or on behalf of Airbus, must comply with the company's policies and all the applicable laws, which include but are not limited to: anti-corruption, export controls and local procurement laws and regulations.
All offset third parties must be reviewed from a compliance perspective prior to entry into any binding agreement or transaction.
The depth of the due diligence will depend on the level of risks implied by the offset agreement (country risk; operational risk; commercial relation type: supplier; joint venture partner; consulting services, etc.)
The company has implemented a dedicated procedure for the compliance review of offset third parties and projects. As for intermediaries and joint ventures, this includes due diligence steps to ensure the legitimate business rationale of investments, checks to confirm/establish the ultimate beneficial ownership of third parties, etc. A central business team in turn has oversight over all approved offset projects and commitments, working closely with the Ethics and Compliance team on proposed new engagements as needed.
Airbus conducts business only with reputable customers, who are involved in legitimate business activities and whose funds are derived from legitimate sources.
To ensure that its customers do not present money laundering/terrorism financing risks, Airbus has implemented a directive to perform risk-based due diligence depending on the level of anti-money laundering/counter-terrorism financing risk induced by its prospective customer. This due diligence is also known as the "know your customer" (KYC) process.
Such due diligence includes identifying and understanding the identities of individual ultimate beneficial owners and the customer's source of wealth or funds.
The KYC due diligence is updated periodically on a risk basis and in case of significant changes in the relationship or activity.
The process incorporates an enhanced level of due diligence to be performed where a prospective customer resides in a Financial Action Task Force-designated high-risk or non-cooperative jurisdiction, or where other red flags are identified. In the event that red flags are unable to be mitigated at the conclusion of the divisional customer due diligence process, there will be an escalation to the Group level for additional consideration and recommendation.
The Ethics and Compliance organisation is charged with oversight and monitoring of the Ethics and Compliance programme to ensure that it is being implemented effectively. Periodic controls on key processes are performed and reports provided to the Airbus Executive Committee and Ethics and Compliance Committee of the Board of Directors, including recommendations to strengthen the Ethics and Compliance programme where necessary.
In addition, the Corporate Audit & Forensic Department conducts periodic (at least annual), independent audits of Airbus compliance processes to assess the effectiveness of internal controls and procedures, and allow Airbus to develop action plans for strengthening such controls.
Each of the countries in which Airbus does business has controls on the export and transfer of its goods and technologies that are considered to be important to national security and foreign policies. As a global enterprise, it is Airbus’ responsibility to respect and comply with each of these controls. Our export compliance directive defines our policies, processes and organisation to ensure compliance with all relevant export control laws and regulations.
Data protection compliance
Airbus is required to handle personal data in accordance with applicable data privacy laws at national, European and international levels. In doing so, Airbus seeks to apply a consistent approach, by setting data security standards for personal data processing in line with global best practices. This is embodied in part by our Binding Corporate Rules, which provide a consistent level of protection for various personal data throughout Airbus.
Airbus suppliers must comply with all applicable laws and regulations of the countries in which operations are managed or services provided. In addition, wherever suppliers are located, all business should be conducted in a manner compatible with the Airbus Supplier Code of Conduct.
Suppliers are also expected to cascade these principles through their own supply chain.
Supplier Code of Conduct
Organisation and culture
Our Ethics and Compliance organisation is part of the Legal Department under the ultimate responsibility of Airbus' General Counsel. The aim is to provide strong governance throughout the company with the global presence of qualified compliance officers who ensure the compliance programme is implemented in the different functional and operational areas.
They do this in close cooperation with our employees and management, who are expected to lead by example with integrity and take responsibility for compliance within their scope of activity.
Our awareness and training
While the "tone at the top" and leading by example are critical for the success of the Ethics and Compliance programme, it is equally important to ensure that employees and Directors receive the right level of training and awareness around the key Directives.
Airbus aims to educate its employees about the standards of conduct that apply to their jobs and the potential consequences, including on anti-corruption.
All Airbus employees receive Ethics and Compliance training including on Anti-Corruption and are required to take at least one Ethics and Compliance e-learning per year. Additionally, depending on the functions, the country and the level of risk implied by their role, some employees may be selected to attend enhanced and tailored face to face Anti-Corruption training.
Airbus is committed to maintaining a "Speak Up" culture by promoting an open and trusting dialogue with employees at all levels.
All employees are encouraged to express their views, defend their opinions, and point out unacceptable behaviour — especially behaviour that violates our Code of Conduct. Employees can raise concerns to their line manager, their human resources business partner, to a Legal and Compliance representative, or through the Airbus "OpenLine" hotline (www.airbusopenline.com).
The OpenLine is a channel through which employees and other stakeholders may submit an alert securely and confidentially/anonymously. Alerts could relate to our Code of Conduct, policies and standards, or to compliance with applicable laws or regulations. The use of the OpenLine is entirely optional and voluntary, and there will be no consequences for employees who do not use the system.
Airbus protects those who Speak Up and raise concerns appropriately and in good faith; we do not retaliate against anyone who raises a concern, or against those who assist in investigations of suspected violations. Retaliation can take many forms, both direct and indirect, including: harassment, exclusion from meetings, sanction, dismissal, or other discriminatory measures, in particular related to compensation, profit-sharing, free share awards, job classification, performance reviews, promotion, training, transfers, contract renewal, etc.
Airbus takes seriously its responsibility to investigate potential instances of misconduct, whether detected in the normal course of business, via the Airbus OpenLine, or from any other source.
Airbus has developed a dedicated investigations procedure to ensure that these investigations are conducted in a consistent and professional manner in accordance with company standards and relevant laws.
Investigations are closely monitored by the investigation team to ensure a timely resolution and documentation of the investigative work performed.
In the event that misconduct is confirmed, Airbus considers not only appropriate disciplinary action for the employees involved, but also engages in a root cause analysis of the misconduct.