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.