Airbus // Universal Registration Document 2023

1. Information on the Company’s Activities

1.2 Non-Financial Information

1

Speak-up channel: OpenLine The Company recognises that the Code of Conduct cannot prevent every situation that may arise, and therefore encourages employees and third parties – including but not limited to contractors, subcontractors, direct or indirect suppliers, and local communities around our and our suppliers’ sites – to speak-up about concerns related to the Company. Concerns may be raised through various channels, including through OpenLine (available at https://www.airbusopenline.com ). The OpenLine enables people to submit an alert securely and confidentially. Employees may also report concerns to managers, HRBPs, Ethics & Compliance Representatives, Privacy Focal Points, or Export Control Points of Contact. The Company commits to protect those who speak up and raise concerns, and commits not to retaliate against anyone who raises a concern in good faith, against those who assist in investigations, or against other legally protected classes in the jurisdictions where it operates. The Company has a specific method regarding principles of non-retaliation and encouraging a “Speak Up” culture. The speak up channels and the non retaliation principles are both included into various team talks, e-learnings, anti-bribery and corruption trainings, and otherwise communicated frequently. In 2023, the Company received a total of 1,200 alerts or allegations of which 764 were HR related (1) . Cases requiring investigation are managed by dedicated members of the Ethics & Compliance team in accordance with an internal method on how to conduct investigations. The Ethics & Compliance team provides regular updates to the pool of internal investigators on internal policies, recent developments in the regulatory framework and investigation best practices to ensure the consistent deployment of compliance investigations across the entire Company.

In addition, the Corporate Audit & Forensic Department conducts periodic, independent audits of the Company’s compliance processes to assess the effectiveness of internal controls and procedures and allow the Company to develop action plans for strengthening such controls.

IV. Implementation / activities Awareness and training

As part of their annual goals and objectives, all Company employees are required to undergo a minimum amount of ethics and 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, including on Anti Bribery & Corruption and Export Control. Attendance in such cases is mandatory, and managers have a responsibility to ensure that their team members do so. Exposed employees are also required to complete regular training refreshers. From 1 October 2022 to 30 September 2023, the Company’s employees followed 525,280 Ethics & Compliance e-learning sessions, including on bribery, corruption and export control. Furthermore, 9,964 employees attended live classroom training on different Ethics & Compliance topics over the period. In 2023, sessions were delivered both virtually and in person. Likewise, the Company also delivered anti-bribery and corruption training towards higher risk third parties, including sales intermediaries, lobbyists and special advisors. In 2023, 100% of higher risk third parties were trained on Ethics & Compliance requirements and expectations. The Company continued the roll out of the privacy e-learning as part of the Ethics & Compliance compulsory training catalogue. A total of 9,255 privacy training sessions were performed in 2023 (reporting period from 1 October 2022 to 30 September 2023).

1,200 investigative requests received in 2023

Compliance-related investigative requests

436

764

HR-related investigative requests

In some instances, the Company may engage outside legal counsel for support, depending on the nature of the investigation.

The Ethics, Compliance & Sustainability Committee and other relevant stakeholders (including relevant authorities, if applicable, and Company’s local management teams) are briefed regarding the progress and outcome of key internal investigations on a regular basis.

(1) Covering harassment and bullying, discrimination and other breaches of HR policies or processes.

125 Airbus Annual Report

Universal Registration Document 2023