Airbus 2015 Annual Report Download - page 161

AIRBUS GROUP REGISTRATION DOCUMENT 2015 l 129 l
Corporate Governance
Registration Document 2015
4.
4.1 Management and Control
4.1.4 Ethics and Compliance Organisation
In June 2013, the CEO described the importance of the
Company’s dedication towards Ethics and Compliance
(“E&C”) in the following way: “Within the AirbusGroup, it’s not
just our results that matter – it’s the way we achieve them”.
The AirbusGroup Ethics and Compliance Programme (“the
AirbusGroup E&C Programme”) seeks to ensure that the
Group’s business practices conform to applicable laws and
regulations as well as to ethical business principles and thus
establish a culture of integrity. The Company is convinced
that such a culture helps to sustain the Group’s global
competitiveness.
There are two foundation documents in the Group E&C
Programme: the “Standards of Business Conduct” which were
revised in 2013 and “Our Integrity Principles” which summarises
the Group’s 6 key Ethics and Compliance commitments and
which was rolled out group-wide to each individual employee
in 2013 by his/ her manager.
Those foundation documents are complemented by policies
addressing specific topics and providing the necessary
framework for AirbusGroup to operate. In light of regulatory
investigations and commercial disputes, the Group has
determined to enhance certain of its policies, procedures and
practices, including Ethics and Compliance. The Group is
accordingly in the process of revising and implementing improved
procedures, including those with respect to its engagement
of consultants and other third parties, in particular in respect
of sales support activities, and is conducting enhanced due
diligence as a pre-condition for future or continued engagement
and corresponding payment. The Group believes that these
enhancements to its controls and practices best position it for
the future, particularly in light of advancements in regulatory
standards. The Group cannot exclude that these changes lead
to additional commercial disputes or other consequences in
the future.
In terms of organisation, in 2015 the decision was made to
merge the Ethics & Compliance Organisation with the Legal
department under the ultimate responsibility of the Group
General Counsel. The Group General Counsel reports to
the CEO and is now a Group Executive Committee Member
and reports to the Board. In order to maintain the necessary
independence, the SVP Group Ethics and Compliance Officer
(“ECO”), reports to the Group General Counsel and has access
to the Audit Committee of the Board of Directors.
This integration at Group level was then replicated at Division
level. As a result, the Divisions’ Ethics and Compliance Officers
now report to their respective Division General Counsel who
themselves report to the Group General Counsel. The Divisions’
Ethics & Compliance Officers also have a dotted line to the
Group ECO.
To further ensure its independence, the decision was also made
to fully integrate the new Legal and Compliance function, such
that the Division General Counsels report only to the Group
General Counsel.
The Ethics and Compliance organisation is made of 5 pillars:
 the E&C Programme sets the rules and policies and deals
with the allegations and investigations;
 the International Compliance Office addresses corruption
and bribery risks;
 the Export Compliance Office ensures that the activities of
the Group comply with all relevant export control rules and
with the internal “sensitive countries” policy;
 the Procurement Compliance Officer supervises compliance
in the supply chain; while
 the Data Protection Compliance Officer is in charge of data
privacy risk.
Under the responsibility of the Group General Counsel, each
Division has a Divisional E&C Organisation that is embedded
within the business through a network of E&C representatives.
In recent years, we have enlarged our footprint of E&C
representatives and they are now present in all functions and
locations of the Business.
Furthermore, in 2015 we maintained five E&C Country Managers
in the following zones: Brazil, India, Russia, Middle East and
Africa, China. The E&C Country Managers report to the Group
Ethics & Compliance organisation.
Like previous years, E&C was a top priority for the Group in 2015
and the E&C Organisation had a set of objectives. Similarly, each
of our Executives had E&C objectives to meet.
Financial Statements 2015
11 22 33 44 55
QRegistration Document 2015
Annual Report 2015 Financial Statements 2015
Q