Airbus // Universal Registration Document 2021

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

1.2.5 Exemplify Business Integrity

I. Introduction The Company’s Ethics &Compliance programme seeks to ensure that the Company’s business practices conform to applicable laws, regulations and ethical business principles, as well as reinforcing a culture of integrity and speak-up. In 2021, Ethics & Compliance continued to be a top priority for the Company, following the completion of the first phase of the ongoing monitorship by the Agence Française Anticorruption within the context of the settlement agreements reached between Airbus and the authorities on 29 January 2020. In its list of priorities for the year, the Company set the objective to Speak Up, Listen Up and act with integrity and respect.

The Company has worked over the past several years to develop an Ethics & Compliance programme that is structured around the following key risk areas: Business Ethics / Anti‑Corruption Compliance, Export Compliance and Data Privacy Compliance. Each of these areas is, in turn, 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 the Ethics & Compliance programme remains a constant and ongoing process, in cooperation with other functions within the Company, in order to sustain and capitalise on our values.

Business Integrity

GRI

SASB

SDGs

Others

205 Anti Corruption Business Ethics

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Highest governance body(ies) involved

Board of Directors / ECSC Executive Committee

Anti Corruption Policy, Responsible Lobbying Charter Directives: see below, section III. Risk Management Code of Conduct, Supplier Code of Conduct

Related Corporate Policies and reference documents

Airbus Commitments to take into account external standards

IFBEC’s Global Principles of Business Ethics, FX Global Code

Key metrics

2021

2020

Number of employees per appointed Ethics & Compliance Representatives

390

372

% of employees (non-Exec) who have completed the E&C training objective

80% 90%

Number of E&C e-learning sessions delivered to employees (Reporting period: from 1 Oct. to 30 Sep.)

309,682

284,774

35,073

9,547

Number of data privacy e-learning sessions delivered to employees (Reporting period: from 1 Oct. to 30 Sep.) (1)

(1) In 2021 the reporting period was changed, from calendar years to Oct-Sept periods, and led to restate past year figures accordingly.

Airbus Ethics & Compliance webpage, including CEO statement , Airbus Values Anti Corruption Policy , Responsible Lobbying Charter , Airbus’ commitment on the protection of Personal Data , Code of Conduct , Supplier Code of Conduct , OpenLine , Compliance at Airbus IFBEC website , Global Foreign Exchange Committee website

Additional resources

II. Governance The Ethics & Compliance organisation is part of the Legal Department under the ultimate responsibility of the Company’s General Counsel. The aim is to provide strong governance throughout the Company with the global presence of qualified Compliance of ficers who ensure the Ethics & Compliance programme is implemented consistently in the different functional and operational areas. The Company’s Chief Ethics & Compliance Officer, who reports to both the General Counsel and the ECSC of the Board of Directors, leads a dedicated team of Compliance professionals who are responsible for supporting and advising across the Company on compliance related topics, supporting the day to day business, performing risk assessments, drafting policies, conducting third party due diligence, investigating compliance allegations, implementing tools and controls and delivering compliance training.

The ECSC also plays a key role in the oversight and continued development of the Company’s Ethics & Compliance programme, organisation and framework for the effective governance of Ethics & Compliance. In addition to the dedicated Compliance professionals, the Company is coordinating a network of part-time ethics & compliance representatives (“ ECRs ”), spanning all Divisions, functions, and regions. The number of ECRs slightly increased in 2021, with a total of 340 ECRs at the end of 2021 (compared to 335 at the end of 2020). Although the ECR network members are not compliance experts, they play an important role in promoting the Ethics & Compliance programme and culture and serve as points of contact for any employee who has questions about the Ethics & Compliance programme or wishes to raise an Ethics & Compliance concern, including but not limited to bribery or corruption. The Ethics & Compliance team is animating the ECRs network, providing continuous training and information of the ECRs.

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Airbus / Registration Document 2021