In January 2020, Airbus SE paid $4 billion to settle global bribery and trade charges with French, UK, and U.S. authorities after an eight-year investigation. How does its anti-corruption policy compare?
1. Tell employees the risks (of policy violations).
Violations of anti-corruption laws carry significant civil and criminal penalties, and put the reputation, hard work and business of Airbus and its employees at risk. Any employee who fails to comply with this Policy and the Directives referenced below will be subject to appropriate disciplinary action.
2. A valuable list.
Anti-corruption laws make it illegal to offer, promise, give, solicit or receive “anything of value”, in exchange for an “improper advantage”. The term “anything of value” is broadly interpreted under the law. In addition of cash or money, which immediately come to mind, a bribe can also take other forms, all of which convey value to the receiver, for example:
• Providing luxurious or overly frequent gifts and hospitality to someone;
• Promising to pay for personal medical, educational or living expenses;
• Making sponsorships or donations to the “pet charity” of a public official;
• Extending employment or an unpaid internship to the relative of a key decision-maker;
• Offering an investment at below market value of a company controlled by a public official who would benefit personally.
3. No facilitation payments. . . unless you’re in danger.
Consistent with most anti-corruption laws, Airbus prohibits facilitation payments. A narrow exception exists if a facilitation payment is made in the context of avoiding or preventing an imminent threat to the health, safety or welfare of an Airbus employee. In such cases, the employee should immediately inform a member of the Legal & Compliance team.
4. Get the board involved.
The Ethics & Compliance Committee of the Board of Directors also plays a key role in the oversight and continued development of Airbus’ Ethics & Compliance programme, organisation and framework for the effective governance of ethics and compliance, including all associated internal policies, procedures and controls.
5. It’s gettin’ better all the time.
When misconduct reveals a gap in compliance policies, procedures or tools, Airbus undertakes revisions to its Ethics & Compliance Programme commensurate with the wrongdoing and in light of lessons learned.
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View more anti-corruption policy benchmarks here.
Here’s the full nine-page anti-corruption policy:Airbus-Ethics-and-Compliance-Anti-Corruption-Policy_fcpablog