The Airbus Ethics & Compliance Programme seeks to ensure that the Group’s business practices conform to applicable laws, regulations and ethical business principles, as well as developing a culture of integrity. The Company is convinced that such a culture helps to sustain the Group’s global competitiveness.
Integrity at Airbus
With people’s lives in its hands and the huge impact on the communities it serves, Airbus is committed to Ethics & Compliance at all times.
The Airbus has earned the trust of billions of customers, passengers, operators and stakeholders worldwide thanks to the quality and safety of its products. Product integrity is as important as business integrity. We want to be known as a company with ‘integrity inside’: integrity in its people, its partners and its suppliers.
Tone from the top
At Airbus, it’s not just our results that matter – it’s the way we achieve them. Today, we have an Ethics & Compliance programme created in-house, brick by brick, supporting all employees. We will continue to grow and pursue excellence, not just in terms of our products and services but in terms of how we do business and achieve our results
Fostering a culture of integrity and transparency
We want to develop an Ethics & Compliance culture that permeates throughout the organisation, from top to bottom, to all of our businesses, everywhere we operate. We can leverage the strong commitment we have from our highest-ranking executives. We reach out to all our employees in our communication and training campaigns. We encourage them to speak up and offer continuous support through various channels, such as the OpenLine.
Setting industry standards
Looking beyond its own 4 walls, Airbus is contributing to establishing global standards for the aerospace and defence industry. We are an active participant in a number of forums, such as the United Nations Global Compact and International Forum on Business Ethical Conduct for the Aerospace and Defence Industry, of which Airbus is a co-chair. These efforts have led to the adoption in 2009 of the ‘Global Principles of Business Ethics’ by European and US industry associations.
Communication and training
training on Ethics & Compliance matters were delivered to Airbus employees in 2015
Airbus employees' support in bringing the Standards of Business Conduct to life is vital. That is why communication and training activities are critical components. We implement our own communication and training strategy concerning Ethics & Compliance. Surveys enable us to assess our achievement in this area.
Airbus acknowledges that the Standards of Business Conduct cannot address every challenging situation that may arise. To create a strong ‘speak up’ culture, the company encourages employees, through communication campaigns, to raise questions and concerns, helping them to identify the appropriate experts to consult and to make the right decisions. E-learning modules have also been developed at corporate level to raise employees’ awareness of the Standards of Business Conduct.
Specific departments, e.g. Mergers & Acquisitions, Marketing & Sales, Finance & Controlling, Procurement, Airbus programmes and Human Resources receive periodic and specific training courses conducted by the compliance specialists in these areas. These include experts for export compliance, business international compliance, procurement compliance and data protection compliance.
Focus on management
Empowerment of Airbus managers in the promotion of Ethics & Compliance is critical to the success of such a programme. Furthermore, the relationship of trust between Airbus's employees and managers is the cornerstone of a successful ‘speak up’ culture. This is why, as part of our internal management development programmes, Airbus aims at raising all managers’ awareness on the benefits of ethical and compliant behaviours. In addition, they have Ethics & Compliance annual objectives that cover training needs and communication requirements to their teams.
Support and OpenLine
Thanks to the Airbus OpenLine and a strong network, we support our employees when dealing with Ethics and Compliance matters. We strive to support all our employees in the many countries we operate, which is why a worldwide network of Ethics and Compliance representatives and officers has been set up throughout Airbus.
Ethics and Compliance representatives are employees trained by the Compliance Office, who spend a part of their work time on Ethics and Compliance matters. Employees can ask them for advice and support, while the representatives convey important information and guidelines about Ethics and Compliance risks for their Division.
OpenLine alert system
The OpenLine alert system is available at all times to Airbus employees. The OpenLine enables employees to confidentially raise their concerns via the internet or by phone. Airbus does not tolerate retaliation against employees making reports in good faith and/or assisting in investigations of suspected violations of the Standards of Business Conduct.
Actively contributing to international standards for ethics and good governance within our industry is a top priority for Airbus. To ensure a fair and level playing field, and to succeed in our business globally, Airbus is a strong promoter of international cooperation between private and public partners. Our interest, shared by our industrial partners, is to generate synergies and share best practices in compliance. This is not only in the interest of our company, but of all competitors to protect our industry and promote its reputation worldwide.
Consequently, Airbus is part of numerous initiatives, uniting companies from around the world with the same objective: to promote a fair and equal environment for our industry and our clients. These include:
- UN Global Compact
- ASD Common Industry Standards
- International Forum on Business Ethical Conduct (IFBEC)
United Nations Global Compact
Airbus is a long-time signatory of the Global Compact (since October 2003), a United Nations policy initiative for businesses that are committed to aligning their operations and strategies with 10 universally accepted principles in the areas of human rights, labour, environment and anti-corruption. The Airbus Corporate Responsibility & Sustainability Report provides details on practical actions to uphold these principles within daily business. To further support UN anti-corruption initiatives, Airbus has also signed the CEO Letter, calling for a more robust and effective implementation of the UN Convention against Corruption.
Common industry standards
Airbus instigated the creation of a committee with other companies within the AeroSpace and Defence Industries Association of Europe (ASD), which was in charge of developing ethical standards for acceptance and adoption by all European companies in the sector. This declaration, called Common Industry Standards (CIS), was approved in June 2007 by the board of the ASD and was sent out to all European trade associations and unions in the aerospace industry.
Building on the effective implementation of these standards within the leading European aerospace and defence companies, a dialogue was established with the leading North American companies with the cooperation of the Aerospace Industry Association (AIA). As a result, AIA and ASD founded with their members the International Forum of Business Ethical Conduct (IFBEC). Airbus played a key role during the establishment of this dialogue and contributed in all aspects of its foundation.
International Forum on Business Ethical Conduct at a glance
The International Forum on Business Ethical Conduct (IFBEC) was created in 2010 by member countries of the ASD and its American counterpart, the Aerospace Industry Association (AIA). It provides a platform for aerospace and defence competitors to meet and discuss best practices in business ethics, promote transparent business and face challenges that could impact our industry.
IFBEC is governed by a chair and vice-chairperson, a steering committee and sub-committees that contribute to the workflow and bring key topics for our industry to the table. Airbus has been part of the IFBEC steering committee since its creation. The Airbus Chief Compliance Officer was the first vice-chairman and has served as chairman since 2013.
Members that commit to IFBEC’s Global Principles guarantee ethical behaviour regarding employees, competitors, suppliers and customers, and embrace high compliance standards in international markets. The Global Principles include common statements on:
- Implementation of integrity programmes
- Zero tolerance of corruption (including promotion of anti-bribery practices to avoid “improper advantages”)
- Correct use of advisors
- Management of conflict of interest
- Respect for proprietary information
IFBEC mission and principles
To help establish consistent global standards for business ethics and compliance, Airbus is a co-founder of IFBEC. The International Forum on Business Ethical Conduct (IFBEC) is the international organisation for the aerospace and defence industry, maintaining its Global Principles of business ethics. The Airbus Chief Compliance Officer currently chairs the steering committee that governs the IFBEC.
The purpose of IFBEC is to:
- Promote and foster through the Global Principles the development of global, industry-wide ethical standards for the companies that are active in the aerospace and defence sectors.
- Organise opportunities for industry and relevant stakeholders to exchange information and best practices concerning ethical business challenges, practices and opportunities worldwide.
The Global Principles
The Global Principles are a common set of standards for ethical conduct, adopted in October 2009 by the AeroSpace and Defence Industries Association of Europe (ASD) and the Aerospace Industries Association (AIA), its US counterpart. All companies willing to join IFBEC must provide a written declaration in which they commit to respect and follow these principles. Companies must also demonstrate that they have the internal mechanisms needed to apply the Global Principles.
They address business conduct as it relates to:
1. Zero tolerance of corruption
It is also outlined that any facilitation payment is strictly forbidden, even in countries where these practices are not prohibited by law.
2. Use of advisors
IFBEC promotes our industry among organisations and individuals that share our integrity values. Airbus follows procedures to track risk factors and warning alarms when advisors intervene in our business.
3. Management of conflicts of interest
Both our Standards of Business Conduct and IFBEC dictate that all kinds of conflict of interest must be avoided, in particular with regards hiring public officials.
4. Respect for proprietary information
Our company is proud of upholding high ethical standards regarding all stakeholders. IFBEC members are committed to respect and provide good use of third-party information and to refuse to receive any unauthorised information coming from third parties, whether it relates to competitors, suppliers or any other stakeholder.
IFBEC Annual Conference
The IFBEC Annual Conference is an important, interactive dialogue, gathering around 100 participants each year to promote and enhance global, industry-wide ethical standards towards companies outside of Europe and the US, such as China and Brazil. Around the same table, major international aerospace and defence companies and public officials from national and international organisations focus on sharing perspectives on emerging trends, risks and opportunities in the area of ethical business conduct. Thanks to this interaction, IFBEC’s members published the first Annual Public Accountability Report in 2012.
There have been 4 IFBEC Annual Conferences to date, in which Airbus has been an active participant:
- Berlin 2010
- Washington, DC 2011
- Madrid 2012
- Washington, DC 2013
In 2014, Brussels, the capital of Europe and the headquarters of important international institutions such NATO, will host the IFBEC Annual Conference. For more information, please visit IFBEC’s website.
International Forum on Business Ethical Conduct
IFBEC promotes the development of global, industry-wide ethical standards for aerospace and defence industries.Go to website
Standards of business conduct
In this section, you will find details on our Ethics & Compliance organisation and standards (foundations documents, policies and guidelines).
The Airbus Ethics & Compliance organisation balances proximity to day-to-day business activities with a degree of necessary independence. Consequently, the Group’s Ethics & Compliance Officer (ECO), who is appointed by the Board of Directors, reports both to the Group’s Chief Executive Officer and the Audit Committee of the Company’s Board of Directors, while the Divisions’ Ethics & Compliance Officers report both to their Division CEO and the Group ECO. Each Division Ethics & Compliance Officer runs a Divisional Ethics & Compliance Organisation that is embedded in the business through a network of Ethics & Compliance representatives.
- In 2013, the Company enlarged the footprint of Ethics & Compliance representatives and they are now present in all functions and locations of our business. They are the voice and face of the Ethics & Compliance Programme.
- In 2013, the Company also extended the breadth of the Airbus Ethics & Compliance Programme by appointing Ethics & Compliance managers in four key countries: Brazil, Russia, India and Saudi Arabia.
- In 2014, China was also added to this list. The various country Ethics & Compliance Managers report to the ECO.
Our Ethics and Compliance Standards
There are 2 foundation documents in the Airbus Ethics & Compliance Programme: the ‘Standards of Business Conduct’, which was revised in 2013, and ‘Our Integrity Principles’, a leaflet summarising the Group’s 6 key Ethics & Compliance commitments, rolled out group-wide to each individual employee in 2013 by his/her manager.
Policies and guidelines
Airbus's Standards of Business Conduct are the statement of how the company does business and describe our Integrity Principles in action. The following internal policies and guidelines support the implementation of our Standards of Business Conduct and are available to all employees via the Airbus intranet. The policies are the key Group-wide applicable compliance-related policies. They are updated regularly to take into consideration the most recent legislative changes and any other relevant circumstances.
Airbus Anti-Corruption Policy
Airbus considers it its duty to combat all forms of corruption, public or private. This policy governs all contractual arrangements entered into by the.airbusgroup.companies, in relation to any business or project partners or any associated third parties (download Airbus Anti-Corruption Policy - PDF ; 537MB)
Airbus M&A Anti-bribery Compliance Guidelines
The guidelines follow the logic of a typical mergers and acquisitions transaction whereby the Airbus would acquire control of a target company and move into the post-deal integration stage. Anti-bribery compliance risks and key steps necessary to address them are presented through the successive stages as a transaction moves forward.
Group Export Compliance Directive
Each of the nations in which the Airbus does business has controls on the export and transfer of its goods and its technologies that are considered to be important to its national security and its foreign policies. As a global enterprise, it is Airbus's responsibility, as well as in its business interest, to respect and to comply with each of those controls. This Export Compliance Directive defines the policies, processes and organisations of the Airbus to ensure compliance with the relevant export control laws and regulations.
Sensitive Country Process
The Sensitive Country Process is an end-to-end business process control applying to all business activities from the first step of an operation. It allows the Airbus top management to perform a prior assessment on any potential risk for the Group in doing business with certain sensitive countries. The process applies to all companies under the control of any entity of Airbus irrespective of whether it is for military, dual-use or civil hardware, software, technology and services.
Supplier Code of Conduct
Growing together: determined to ensure the highest standards of responsibility throughout its supply base, Airbus requires that suppliers commit to its Supplier Code of Conduct and cascade these principles to their employees and through their own supply chain.
Binding Corporate Rules
The Airbus Binding Corporate Rules (BCR) provide a consistent level of protection for Airbus employees’ personal data within the group. The BCR’s reflect the standards contained in European data privacy laws and have been approved by data privacy regulators in Europe (the European Economic Area and Switzerland).
Having BCR’s means that all our group entities that sign up to our BCR have to comply with the same internal rules. It also means that your rights stay the same no matter where your data are processed.
For a full copy of our BCR please click on the link below:
Insider Trading Rules
Airbus encourages its employees to hold Airbus securities. The guiding principle is that employees should freely transact in Airbus securities provided that they act in accordance with all applicable insider trading laws and regulations and the provisions of these Airbus Insider Trading Rules.
Gifts and Hospitality Principles
It is appropriate, in instances such as product demonstrations or promotional events, to give and receive reasonable and proportionate gifts and/or hospitality. However, these gifts or hospitality must always meet three conditions – compliance with law, business purpose and social acceptability. Airbus has adapted principles on gifts and hospitality in order to ensure that the giving or receiving of gifts and hospitality is managed ethically and consistently throughout the Airbus.
Sponsoring and Donations Guidelines
At Airbus, all sponsoring and donation projects must strictly comply with the Airbus Standards of Business Conduct, as well as with all applicable national laws and regulations. The guidelines help to reach a coherent and transparent approach for sponsoring and donation activities throughout the Airbus.
Conflicts of Interest Guideline
Airbus's Conflicts of Interest Guideline stipulates that any employees acting on the company’s behalf must be free from conflict of interest or personal interests that could adversely influence their judgment, objectivity or loyalty to the company in conducting Airbus business activities and assignments.
Policy and Process for Compliance Allegation Investigation Hide
The policy and process address the key principles and the mandatory steps that will be followed during an investigation to collect, allocate, evaluate, investigate and remediate compliance allegations. All corporate compliance allegations will be transferred to the Airbus Corporate Compliance Office and the Airbus Core Team for investigation. The Airbus Core Team will then allocate the investigation to the relevant organisation.
Airbus is committed to developing a Speak Up culture. Airbus makes available to its employees a secured and confidential channel to express concerns called OpenLine. The objective of this OpenLine policy is to explain how the Airbus OpenLine works, to define the scope of the system and the safeguards that have been put in place to protect users of the system, and the personal data contained within it.
Strategy & Mission
Airbus innovates every day to enhance product performance, create new customer benefits and reduce costs.Explore our Mission
Ethics & Compliance in action
Airbus's Ethics & Compliance Programme follows a risk-based approach with the aim of preventing, detecting and responding to Ethics & Compliance risks. A strong team focuses on four key areas to support our employees in living by our Standard of Business Conduct and our Integrity Principles.
At Group level, dedicated Compliance Risk Officers are empowered to issue standards applicable throughout the Group, test effectiveness and control adherence. These Compliance Risk Officers manage a network of more than 100 risk specialists that are embedded in the Divisions within the business structure.
4 main focal points
Following a risk assessment carried out by Airbus, 4 compliance areas were identified as of primary importance and relevant structures and staffing were set up to respond to those risks:
International Compliance: zero tolerance to corruption
At Airbus, we prohibit all forms of corruption, public or private. As such, a dedicated anti-corruption programme and organisation were put in place at an early stage under the leadership of the Group International Compliance Officer. Its mission is to reinforce a culture of anti-bribery and to protect the Group against any legal, financial or reputational risk. This is carried out while selecting business partners and conducting M&A operations or investment projects. Notably, the Group International Compliance Office develops and implements the Airbus Business Ethics Policy and Rules.
Export Compliance: global export for business continuity
Many components integrated in products and services we buy and sell are subject to export control regulations, requiring various licenses. The Export Compliance Organisation provides beginning-to-end business process control. With its worldwide team of 110 export compliance professionals, it ensures full compliance with national and international export laws and regulations and implements the Group Export Compliance Policies and procedures.
Procurement Compliance: growing together
Suppliers deliver a high proportion of the value of our products, and thus play an important role in customer satisfaction. At Airbus, we believe we must strive to promote ethical and mutually beneficial relationships with these partners. The Group Procurement Compliance Officer mitigates risks arising from exposure to liability in procurement operations and from suppliers’ activities. In order to meet the highest standards of responsibility throughout our supply base, we request that our suppliers commit to our Suppliers Code of Conduct, Growing Together and cascade these principles to their employees and through their own supply chain.
Personal Data Protection Compliance: global standard for personal data processing
The Group Data Protection Compliance Office manages the risks and business impacts of European, national and international data protection legislations. It ensures a consistent and globally valid data protection approach and sets data security standards for personal data processing, based on globally accepted principles. It also oversees all ongoing activities related to the development and the implementation of the Airbus Data Protection Policies, as well as the Binding Corporate Rules (BCR).
Anti-corruption programme: organisation and employee support
Airbus has organised a risk-based, centralised network of experts in anti-corruption headed up by the Group International Compliance officer. Employees of the Group have direct access to them and may ask questions or request the assistance of those experts either in the.airbusgroup.company where they belong or at Division/Group level. The main points of contacts for anti-corruption issues are given in Our Integrity Principles.
Our anti-corruption policy: 'zero tolerance' to corruption
Airbus has established and regularly updated since 2001 an anti-corruption policy prohibiting all forms of corruption, whether public or private. The policy applies to all operations of Airbus, at any stage of the negotiation or execution of any kind of agreements or contract: e.g. commercial contracts, joint-venture partnership agreement related to any field of activity (e.g. product sales, offset arrangements, mergers & acquisitions projects, etc.).
This policy applies wherever the Group carries out national and international business transactions, to all employees, Directors and Officers of the.airbusgroup.companies. Risk based Processes have to be implemented for the assessment and validation of third parties dealing with the Group.
In 2013 and 2014 Ethic Intelligence awarded the Airbus and its Divisions certificates stating that “The anticorruption policy is properly designed in a coherent manner, corresponding to international best practices, with regard to the risk of corruption of Airbus” and that “the Policy is consistently implemented throughout the Division”. Guidelines have also been edited to support the assessment of corruption risks linked to third parties in general and more particularly in the framework of specific operations such as Mergers & Acquisition or transactions with business partners
Introduction to the guidelines for assessing Airbus partners
The guidelines identify certain situations which an Airbus Company (hereafter "the Company") should consider before entering into any kind of agreement or contract with a Partner and where it would be necessary (1) to carry out additional investigations – the outcome of which would need to be positive and (2) to take the necessary measures to allow proper implementation of the contractual relationship with the Partner.
The situations one could be faced with may not correspond to what it described in these Guidelines. In any case, the following parameters should always be taken into account in the assessment of these situations and the responses provided thereto:
- the level of risk of corruption in the country/countries concerned (using the Transparency International corruption perceptions index);
- the business sector in which the planned transaction is to take place (certain sectors have commonly been identified as presenting a higher risk than others);
- the amounts at stake in the planned transaction or assignment and the remuneration, structure and amount to be paid to the Partner.
After having checked that the.airbusgroup.company has the right to enter into an agreement with a Partner, the Partner has to be selected according to certain criteria, based on risk analysis. Then will come the definition of the contract which is intended to be entered into.
The process then goes through the validation phase as described in the Business Ethics Policy, Processes & Guidelines or in other Airbus processes (M&A, supply chain etc.). Once this validation is done, the.airbusgroup.company will then be in the position to sign the agreement and implement it.
Hence, these Guidelines are organized around the following main chapters:
- Section 1. Know your partner
- Section 2. Define the relationship
- Section 3. Go through the adequate validation process
- Section 4. Implement the contract with the partner
In each section, the document indicates:
- The check(s) to be performed
- The element of alerts which must be analyzed further before entering into the agreement with the selected Partner
- Elements to be obtained in case further investigation is required and which may allow the mitigation of identified risks
- Principles of line of conduct in front of certain situationS
The check-lists which are provided for are not exhaustive and in any case, the International Compliance Officer of the company is there to help appraising the situation the.airbusgroup.company may be faced with when detecting an element of alert.
Introduction to compliance guidelines M&A
When conducting M&A projects, Airbus faces the risk that a target may potentially have ethics and compliance standards lower than Airbus and, in some instances, practices which would not comply with Airbus standards and applicable laws and regulations.
The consequences of such a situation may have significant effects on the potential transaction analysis and economics. For example:
- If the target was obtaining business by using practices which would need to be discontinued or significantly adjusted by Airbus after the acquisition, key performance indicators of the target may suffer material changes (decreases in revenues, decreases in margins, decreases in the success rate of tender bids etc.). This would obviously change the analysis of the transaction price and, potentially, Airbus interest in the transaction;
- If the target’s practices and procedures will require significant remediation efforts to adjust them to Airbus ethics and compliance standards, it would be important to know the potential cost of this remediation and to include it in the transaction suitability analysis.
It is also important to understand that once the transaction is concluded, the acquirer may inherit liabilities related to the practices non-compliant with applicable laws, even if the instances of non-compliance occurred prior to the acquisition date.
To illustrate the impacts of inheriting these liabilities, some consequences can be listed as follows:
- Debarment from government contracts;
- Criminal, civil and financial proceedings against the company, its directors, employees and partners;
- Expensive settlement agreements (many recent cases have settled for hundreds of millions of Euros including fines and disgorgement of profits);
- Triggering of liabilities under other laws e.g. money-laundering, books and records violations etc.;
- Adverse media attention;
- Appointment of court / independent monitors;
- Director disqualifications;
- Employee de-motivation;
- Significant professional fees;
- Substantial occupation of management time…
Those risks are rising rapidly through improved anti-corruption awareness and activism, greater incentives and encouragement for whistle-blowing, improved enforcement tools and more frequent and extensive cooperation between authorities in different countries.
In this respect, when considering a transaction, Airbus takes specific steps to protect from potential reputational and legal risks from the early stages of the potential M&A transaction thought out the conduct of the deal : Anti-bribery due diligence are conducted to identify risks and find responses which should be proportional to those risks.
To that end adequate information is collected and analyzed on a timely basis to allow Airbus to take an appropriate decision related to the potential transactions and the steps required to safeguard its interests. This includes the involvement of the Anti-corruption Department in the review of the agreements to be agreed upon with the potential sellers or buyers.
The guidelines are designed to assist Airbus entities personnel involved in M&A activities in collecting and analyzing information necessary to consider anti-bribery compliance risks that may be encountered and which need to be addressed as part of these activities.
In particular, these guidelines should be used by officers in charge of anti-corruption to improve their understanding of M&A activities and the anti-bribery compliance risks that arise in this context. Other functions may also find it useful to familiarize themselves further with anti-bribery compliance issues that may arise from M&A transactions they are working on and improve their understanding of challenges that the International Compliance function may face in this respect.