AIRBUS - 2020 Universal Registration Document

1. Information on the Company’s Activities / 1.2 Non-Financial Information

IV. Initiatives Awareness and Training

Policies and Procedures In 2020, the Company updated its anti-bribery and corruption policies related to Sales Intermediaries (Business Partners) and Mergers & Acquisitions, Joint Ventures, and Partnerships, in particular to extend the scope of coverage to teaming and cooperation agreements, and other forms of non-monetary partnership. The Company also issued new ethical guidelines related to (i) competitive intelligence gathering and (ii) resisting solicitation and extortion. All policies and guidelines are made available to employees on the Intranet, and classroom training is delivered to employees who are particularly exposed to the underlying risks as described above. On the Expor t Control side, the Company restructured its programme and issued the following new directives: (i) Requirements for Export Control Sanctions, Embargoes and Screening; ( i i ) Requi rements for Expor t Control Framework; (iii) Requirements for Export Control Escalation and Voluntary Disclosure; (iv) Requirements for Export Control Brokering; (v) Requirements for Export Control Classification; (vi) Requirements for Export Control Licences and Agreements and (vii) Requirements for ITAR Part 130 Reporting. Under the terms of the Consent Agreement with the US DoS made public on 31 January 2020, the DoS has agreed to settle all civil violations of the ITAR outlined in the Company’s voluntary disclosures identified in the Consent Agreement, and the Company has agreed to retain an independent export control compliance officer, who will monitor the effectiveness of the Company’s export control systems and its compliance with the ITAR for a duration of three years. See “– Information on the Company’s Activities – 1.1.7 Legal and Arbitration Proceedings” (Investigation by the UK, France’s PNF, US Departments of State and Justice and Related Commercial Litigation). V. Future Outlook An effective Ethics & Compliance programme is one that, by definition, continuously adapts to changes and improves over time. Going forward, the Company will continue to assess its risks and monitor and test the implementation of mitigation measures at all levels: corporate level, Divisions, regions and local entities. When misconduct reveals a gap in compliance policies, procedures or tools, the Company undertakes revisions to its Ethics & Compliance programme commensurate with the wrongdoing and in light of lessons learned. While compliance at the Company will therefore always be a work in progress, the Company is committed to this endeavour, as it aims to make its Ethics & Compliance programme sustainable over time.

All Company employees are required to undergo a minimum amount of compliance training via e-learning. Additionally, depending on the function, the country and the level of risk implied by their role, certain employees are selected to attend live classroom training as well. Attendance in such cases is mandatory, and managers have a responsibility to ensure that their team members do so. From 1 October 2019 to 30 September 2020, the Company’s employees followed 309,682 Ethics & Compliance e-learning sessions, including on bribery, corruption and export control. Furthermore, 3,501 employees attended live classroom training on different E&C topics in 2020, the majority of which were delivered in virtual classroom settings due to the pandemic. Likewise the Company also del ivered anti-br ibery and corruption training towards higher risk third parties, including sales intermediaries, lobbyists and special advisors. In 2020, 80% higher risk third parties were trained on E&C requirements and expectations. The Company continued the roll out of the data protection e-learning as part of the E&C compulsory training catalogue. Approximately 30,000 employees completed this training in 2020. Speak-Up Channel: OpenLine The Company recognises that the Code of Conduct cannot address every challenging situation that may arise, and therefore encourages its employees to speak-up through various channels, including through OpenLine (available at https://w‌ ww.‌airbusopenline.com ). The OpenLine enables users to submit an alert securely and confidentially, and also to ask questions related to Ethics & Compliance. In 2020, Inclusion & Diversity was expressly added to the definition of the “Human Resources” topic. Product Safety, previously covered by a broader “Procurement and Product Security” topic, is now displayed as a separate category as well. In addition, the dataprotection@airbus.com mai lbox is systematically published in the Company’s data protection policies and information notices specific to the various apps, for the purpose of exercising data subject’s rights and/or lodging complaints. The Company protects those who speak up and raise concerns appropriately and in good faith. The Company does not retaliate against anyone who raises a concern, or against those who assist in investigations of suspected violations.

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Airbus / Registration Document 2020