Airbus Group

Based on public information, there is evidence that CEO Tom Enders has made several strong statements in the past two years, which promote the company’s anti-corruption and ethics agenda. They can be found in the two principle ethics documents, the Standards of Business Conduct and Our Integrity Principles, as well as the company website.

Based on public information, there is no readily available evidence that the company’s CEO or Chairman demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company. However, TI notes that Chief Compliance Officer Pedro Montoya has served as the Chair of IFBEC since 2013. The company therefore scores 1. To score higher the company would need to provide evidence of external facing engagement from CEO or Chairman in the last two years.

Based on public information, there is no readily available evidence that the CEO demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company. This engagement could take the form of leading an anti-corruption workshop or chairing a review of the anti-corruption agenda.

Based on public information, there is evidence that the company publishes a statement of values representing high standards of ethical business conduct, including integrity, trust and honesty. The Standards of Business Conduct clearly explain why these values matter to the organisation and how they are implemented in practice. In particular, a range of documents suggest that the company highly values integrity.

Based on public information, there is evidence that the company is a signatory to the United Nations Global Compact and the ASD Common Industry Standards, and is a member of the International Forum on Business Ethical Conduct.

Based on public information, there is limited evidence that the Audit Committee has overall corporate responsibility for the company’s ethics and anti-corruption agenda. The company therefore scores 1. To score higher the company would need to provide details of what this responsibility entails, ideally through terms of reference.

Based on public information, there is evidence that the company has given Chief Compliance Officer Pedro Montoya, responsibility for implementing the company’s ethics and anti-corruption agenda. Mr Montoya reports to the CEO and the Audit Committee.

Based on public information, there is evidence that the company commissioned an external review of its anti-corruption agenda in 2013. ETHIC Intelligence completed a review of the company’s anti-corruption system, with 24 audits carried out and all company divisions having received certification.

Based on public information, there is some evidence of a plan that guides the review of the ethics and anti-corruption agenda by the Board or senior management. The Audit Committee receives quarterly programme progress reports and semi-annual compliance allegations reports. The Corporate Responsibility and Sustainability Report 2013 contains evidence of monitoring indicators, such as training uptake, as well as the steps of the ethics and compliance cycle. The company therefore scores 1. To score higher there must be evidence of a written plan that clearly guides how the review of the anti-corruption agenda should be undertaken, as well as evidence of improvement plans being implemented.

Based on public information, there is evidence that the company’s Ethics and Compliance Officer reports to the Audit Committee on compliance allegations twice a year. If corrective action is required it will be decided by the appropriate level of management. Furthermore, TI notes that prompted by the allegations surrounding the GPT subsidary, the company conducted internal audits and commissioned an external investigation.

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure. The Enterprise Risk Management (ERM) system is designed for operational risk and opportunity management, and internal control management. The system mitigates a range of risks including compliance risks. The four areas of focus in compliance are corruption, export, procurement and personal data protection. Compliance risk officers issue standards aplicable throughout the company, test effectiveness and control adherence. These officers manage a network of over 100 risk specialists that are embedded in the company’s divisions. Specifically for corruption risks, the company has an anti-corruption programme and organisation under the leadership of the Group International Compliance Officer.

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions. Before working in certain sensitive countries the company’s top management performs an anti-corruption risk assessment, and prior to any mergers or acquisitions the company performs anti-bribery due diligence. In particular detailed information is given on the assessment of potential business partners and mergers and acquisitions.

Based on public information, there is evidence that the company conducts due diligence that minimises corruption risk when selecting agents. A capacity due diligence is implemented with the information business partners provide in the Compliance Pack. TI notes that the ETHIC Intelligence review of the company’s anti-corruption system highlighted the quality of the business partner vetting process. The company therefore scores 1. To score higher on this question the company would need to provide evidence that the due diligence process is refreshed at least every 3 years and / or when there is a significant change in the business relationship.

Based on public information, there is some evidence that the company has contractual rights and processes for the behaviour, monitoring, control and audit of agents. Business partners are provided with a copy of the Airbus Group Business Ethics Main Principles. If a business partner fails to provide the company with regular and documented reporting, the company is entitled to terminate the contract; this reporting may be periodically audited. The company therefore scores 1. To score higher on this question the company would need to provide further information of the monitoring and auditing process and provide evidence of contractual rights to deal with unethical behaviour.

Based on public information, there is evidence that suppliers must commit to the company’s Supplier Code of Conduct, which includes a zero-tolerance policy of bribery and corruption. There is also evidence of contractual rights for disciplinary action, with the company able to terminate a supplier’s contract if they fail to adhere to the ‘EADS Corporate Social Responsibility in Sourcing document’.

Based on public information, there is evidence that the company addresses the corruption risks of offset contracting at a general level. In the Airbus Group Business Ethics Policy Processes and Guidelines Main Principles document, a company that assists with offset arrangements is defined as a business partner. Therefore, policies that ensure that business partners abide by all anti-corruption legislations also apply to those working for the company on offset contracts. The company therefore scores 1. To score higher the corruption risk from offset contracting must be explicitly addressed in the company’s offset policies, procedures and contractual terms.

Based on public information, there is evidence that the company conducts due diligence that minimises corruption risk when selecting its offset partners and offset brokers. The Airbus Group Business Ethics Policy Processes and Guidelines Main Principles document defines a company that assists with offset arrangements as a business partner, and clearly states that a capacity due diligence is carried out on the information provided by a business partner. TI notes that the ETHIC Intelligence review of the Company’s anti-corruption system highlighted the quality of the business partner vetting process. The company therefore scores 1. To score higher the company would need to provide evidence that it refreshes the due diligence at least every 3 years and/or when there is a significant change in the business relationship.

Based on public information, there is evidence that the company has an anti-corruption policy, which prohibits all forms of corruption in all operations of the company. This includes bribery, facilitation payments and kickbacks.

Based on public information, there is evidence that the company has an explicit zero tolerance policy of corruption, specifically in regard to bribery.

Based on public information, there is evidence that the company’s anti-corruption policy is easily accessible to Board members and employees. The Standards of Business Conduct are available online and on the company’s intranet portal in six different languages.

Based on public information, there is evidence that the company’s anti-corruption policy is understandable and clear to Board members and employees. The anti-corruption section of the Standards of Business Conduct is written in simple language and provides definitions of the key forms of corruption.

Based on public information, there is evidence that the anti-corruption policy explicitly applies to all employees and Board members.

Based on public information, there is evidence that the company has a minimal policy on potential conflicts of interest. It states that employees must avoid both actual and apparent conflicts of interest at all times, and includes a definition and example. However, the rules of the policy are unclear, which might make it hard for employees to implement. The company therefore scores 1. To score higher the company would need to provide evidence of further examples to help employees understand and implement the policy. TI notes the Directors’ Charter details a similar policy for Directors.

Based on public information, there is evidence that the company has a policy for the giving and receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. However, tt is minimal in description, though employees are encouraged to record all gifts received. The company therefore scores 1. To score higher the company would need to provide evidence that it sets upper limits for gift exchange or has a requirement for senior management authorisation if a certain threshold is exceeded.

Based on public information, there is evidence that the company has a policy for the giving and receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. However, it is minimal in description, though employees are encouraged to record all hospitality received. The company therefore scores 1. To score higher the company would need to provide evidence that it sets upper limits for hospitality exchange or has a requirement for senior management authorisation if a certain threshold is exceeded.

Based on public information, there is evidence that the company has a policy that explicitly prohibits facilitation payments. Although the company provides minimal supplementary information on how the policy is to be implemented in practice, a detailed definition of facilitation payments is provided and examples of the circumstances under which employees might be asked to engage in them are outlined.

Based on public information, there is evidence that the company’s political contributions are regulated. However, there is a lack of information explaining the policy, as only one short sentence in the Standards of Business Conduct document states that the company has such regulations. The company therefore scores 1. To score higher the company would need to provide information on the application of the regulations and publically declare the recipients of contributions.

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities.

Based on public information, there is some evidence that the company regulates charitable contributions. The company’s Corporate Responsibility and Sustainability Report 2013 states that the Airbus Group operates three charitable foundations, including the Airbus Group Corporate Foundation. TI assumes that as part of the foundations’ mandates there are controls in place to prevent undue influence or other corrupt intent. However, as these controls, in addition to the recipients of the contributions, are not made clear the company is unable to score on this question.

Based on public information, there is no readily available evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda. The section on ethics and anti-corruption in the Standards of Business Conduct is short, but provides definitions of the key forms of corruption. The Our Integrity Principles document only lists the ethical principles of the company. To score higher the company would need to provide written guidance that contains scenarios to ensure that any areas of uncertainty are fully explained.

Based on public information, there is evidence that the company has an explicit anti-corruption module as part of its ethics and compliance training programme. In 2013, 9,447 anti-corruption training sessions were carried out.

Based on public information, there is evidence that ethics and compliance training is provided in all countries where the company operates.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board.

Based on public information, there is evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions. This includes specific departments such as Procurement and Marketing, and the training is conducted by compliance specialists in their areas.

Based on public information, there is no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest. The Standards of Business Conduct document only states that employees should make it known to a supervisor if they cannot avoid a conflict of interest. To score on this question the company would need to provide evidence, that employees are instructed to declare conflicts of interest to a manager in writing or to an independent department.

Based on public information, there is no readily available evidence that the company has an explicit commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities.

Based on public information, there is evidence that employees can report concerns or instances of suspected corrupt activity using multiple, well-publicised channels. Employees are encouraged to report any issues or concerns using normal business channels, such as a manager, a Human Resources Business Partner (HRBP) or an Ethics and Compliance representative. The company also provides the OpenLine alert system. The OpenLine is operated by an external provider and employees must declare their indentity on the understanding it will be kept confidential by the external operator. The contact details of all Chief Compliance Officers in Airbus Group and the OpenLine are provided in the Our Integrity Principles document.

Based on public information, there is evidence that whistleblowing channels are available to all employees, in all geographies. Employees are encouraged to report any issues or concerns using the normal business channels such as a Human Resources Business Partner (HRBP) or an Ethics and Complaince representative. The Ethics and Compliance respresentatives network is worldwide. Employees are also able to report issues or concerns to the OpenLine. However, TI notes that the current availability of the OpenLine is unclear. In some documents the company claims it is available to all Airbus Group employees, but in others it states that it is continuously being expanded to new countries, with China, Mexico and Saudi Arabia set to receive the system in 2014.

Based on public information, there is some evidence that the company has mechanisms to assure itself that whistleblowing by employees is not deterred and that whistleblowers are treated supportively. The company encourages employees to raise questions and concerns via communication campaigns, and managers receive training on the benefits of ethical and compliant behaviours. The company therefore scores 1. To score higher the company would need to provide evidence of detailed analysis of whistleblowing data, such as whistleblowing channel usage statistics, or independent employee surveys.

Based on public information, there is evidence that the company has well-publicised resources available to all employees, where help and advice can be sought on corruption-related issues. This includes trained managers, a worldwide network of Ethics and Compliance representatives and the OpenLine alert system. The contact details of all Chief Compliance Officers in Airbus Group and the OpenLine are provided in the Our Integrity Principles document.

Based on public information, there is evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption. However, there is no evidence that disciplinary measures are applied to employees who breach this policy. The company therefore scores 1.