Airbus // Universal Registration Document 2023
1. Information on the Company’s Activities
1.2 Non-Financial Information
1
Exemplify business integrity
1.2.14 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 2023, Ethics & Compliance continued to be a top priority for the Company. In its list of priorities for the year, the Company treats integrity and compliance as vital for its business. 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 Control Compliance and Privacy. 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. In 2023 the Company closed the Deferred Prosecution Agreements in the United States, the United Kingdom and France, as well as of the Consent Agreement in the United States – See “Notes to the IFRS Consolidated Financial Statements – Note 38: Litigation and Claims” 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 its values.
Business integrity
GRI
SASB
SDGs
Others
205 Anti Corruption Business Ethics
16
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
External standards taken into account
IFBEC’s Global Principles of Business Ethics, FX Global Code
Key metrics
2023
2022
Number of employees per appointed Ethics & Compliance Representatives
360
338
Number of employees per appointed Export Control Point of Contact
236
242
% of employees who completed the E&C training objective (Reporting period: from 1 Jan to 31 Dec)
96% 96%
Number of E&C e-learning sessions taken by employees (Reporting period: from 1 Oct to 30 Sep)
290,178 525,280
Of which Export Control e-learning sessions delivered to employees (Reporting period: from 1 Oct to 30 Sep)
149,426
367,187
Number of privacy e-learning sessions delivered to employees (Reporting period: from 1 Oct to 30 Sep)
3,181
9,255
Airbus Ethics & Compliance webpage, including CEO statement , Airbus Values Airbus’ commitment on the protection of Personal Data , OpenLine , Compliance at Airbus
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 officers 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 Ethics Compliance & Sustainability Committee (“ 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 2023, with a total of 445 ECRs at the end of 2023 (compared to 373 at the end of 2022). Although the ECR network members are not compliance experts, they play an important role in promoting
123 Airbus Annual Report
Universal Registration Document 2023
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