FINAL ASSESSMENT AIRBUS GROUP The following pages contain the detailed scoring for your company based on public information. The following table represents a summary of your scores: Topic Number % score based of on public questions information Leadership, Governance and 10 75% Organisation Risk Management 7 71.4% Company Policy and Codes 12 66.7% Training 5 60% Personnel and Helplines 7 57.1% Total 41 67.1% AIRBUS GROUP 18/11/14 WWW.AIRBUS-GROUP.COM A1: Does the company publish a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company? Score: 2 Comments: Based on public information, there is evidence that CEO Tom Enders has made several strong statements in the past two years, which promote the company’s anti-corruption and ethics agenda. They can be found in the two principle ethics documents, the Standards of Business Conduct and Our Integrity Principles, as well as the company website. References: Public: Company website: Board of Directors Denis Ranque, Chairman of the Board of Directors of Airbus Group N.V. Thomas Enders, Chief Executive Officer of Airbus Group N.V. http://www.airbusgroup.com/int/en/group-vision/governance/board-of- directors.htmlBoard members Company website: Ethics & Compliance ‘Tone From The Top "At Airbus Group, it’s not just our results that matter – it’s the way we achieve them. Today, we have an Ethics & Compliance programme created in-house, brick by brick, supporting all employees. We will continue to grow and pursue excellence, not just in terms of our products and services but in terms of how we do business and achieve our results". Thomas Enders, Chief Executive Officer of Airbus Group’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Standards of Business Conduct (January 2014), p.3: Message from CEO Tom Enders ‘Dear Colleagues, AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM While we work for different Group companies and in different locations around the world, we share one common roof -- Airbus Group, and one common foundation -- Integrity. Airbus Group inherited from its founding companies their long-existing dedication to integrity, quality, trust and innovation. Our commitment today to upholding those core values is what secures our success for tomorrow. No matter which business we are in or what job responsibilities we have, it is not only what we do – but how we do it – that wins the trust of our colleagues and stakeholders. However, “doing the right thing” isn’t always obvious, particularly in the complex and highly regulated global businesses we are in. These Standards provide valuable guidance on the most common ethics and compliance issues and set forth the mutual rights and obligations of our employees and the Airbus Group. We should all take the time to read them and understand them. Thank you for your part in upholding our tradition of integrity and making Airbus Group and our family of companies great places to work and a source of pride for all of us.’ http://www.airbusgroup.com/dam/assets/airbusgroup/int/en/group-vision/ethics- compliance/documents/Standards_Airbusgroup_EN.pdf Annual Review 2013, p.11: Letter from the Chairman ‘Throughout all our activities, we will continue to support and promote ethical working practices. Over the long-term, good citizenship and irreproachable behaviour are an essential basis for Company performance. On this point, too, I can assure you, that we intend to act in the best interests of all our stakeholders.’ http://www.airbusgroup.com/dam/assets/airbusgroup/int/en/group-vision/business- suppliers/Airbus_Group_Annual_Review_2013.pdf Our Integrity Principles (February 2014), p.1: Message from CEO Tom Enders ‘While we conduct our day-to-day business in different Group companies, we share one common roof - Airbus Group, and one common foundation – Integrity. A crack in the roof or foundation anywhere presents risks to Airbus Group everywhere. Global aerospace companies like ours conduct business in an ever-changing regulatory and legal environment. This requires continuous awareness-building for ethics and compliance risks. Acceptance of ethics and compliance as integral to our successful business operations needs to be the same across all Airbus Group companies. The Group’s Executive Committee and leadership team is fully committed to the application of Our Integrity Principles and to the more detailed Standards of Business Conduct. These documents articulate our core commitment to act with integrity with each other and with our business partners and communities. Please read and discuss Our Integrity Principles, and the Standards, and if you have ethics or compliance concerns, do not hesitate to ask questions. Speaking up will help improve our performance, maintain a positive, healthy working environment, and preserve our reputation. AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM Our reputation – the cornerstone of Airbus Group’s success – was built up over many years. It is our responsibility to preserve this valuable asset.’ http://www.airbusgroup.com/dam/assets/airbusgroup/int/en/group-vision/ethics- compliance/documents/Brochure_Code_of_Ethics_Airbusgroup_EN--2- /Brochure_Code_of_Ethics_Airbusgroup_EN%20%282%29.pdf AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM A2: Does the company’s Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company? Score: 1 Comments: Based on public information, there is no readily available evidence that the company’s CEO or Chairman demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company. However, TI notes that Chief Compliance Officer Pedro Montoya has served as the Chair of IFBEC since 2013. The company therefore scores 1. To score higher the company would need to provide evidence of external facing engagement from CEO or Chairman in the last two years. References: Public: Youtube website: Entrevista con Pedro Montoya, Chieff Compliance Officer de Eads ‘Pedro Montoya, responsable de Compliance de Eads a nivel mundial, explica como se ha implantado este sistema de prevención en este grupo de defensa mundial de carácter mundial. Este programa contiene un Código Etico e implica a todos los empleados de la firma’ In Spanish and from 2011. http://www.youtube.com/watch?v=9yn6iMPYvVc Company website: Ethics & Compliance ‘Airbus Group has been part of the IFBEC steering committee since its creation. The Airbus Group Chief Compliance Officer was the first vice-chairman and has served as chairman since 2013.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Pedro Montoya IFBEC Bio (2013) ‘He represents EADS in international groups leading Compliance initiatives, such as the ICC Anti-Corruption Working Group. He has actively contributed to the drafting and AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM implementation of the ASD Common Industry Standards (“CIS”) and the AIA/ASD Global Principles of Business Ethics for the Aerospace and Defense Industry.’ http://ifbec.info/wp-content/uploads/2013/07/PedroMontoya-bio.pdf UN Global Compact website: Call to Action – Anti-Corruption and the Global Development Agenda ’12. Airbus’. https://www.unglobalcompact.org/docs/issues_doc/Anti- Corruption/Call_to_Action_Global_Development_Agenda_Signatories.pdf AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM A3: Does the company’s Chief Executive Officer demonstrate a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure? Score: 0 Comments: Based on public information, there is no readily available evidence that the CEO demonstrates a strong personal, internal-facing commitment to the ethics and anti- corruption agenda of the company. This engagement could take the form of leading an anti- corruption workshop or chairing a review of the anti-corruption agenda. References: Public: NA AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM A4: Does the company publish a statement of values or principles representing high standards of business conduct, including honesty, trust, transparency, openness, integrity and accountability? Score: 2 Comments: Based on public information, there is evidence that the company publishes a statement of values representing high standards of ethical business conduct, including integrity, trust and honesty. The Standards of Business Conduct clearly explain why these values matter to the organisation and how they are implemented in practice. In particular, a range of documents suggest that the company highly values integrity. References: Public: Company website: Ethics & Compliance ‘The Airbus Group Ethics & Compliance Programme seeks to ensure that the Group’s business practices conform to applicable laws, regulations and ethical business principles, as well as developing a culture of integrity. The company is convinced that such a culture helps to sustain the Group’s global competitiveness.’ ‘Our Culture – Integrity at Airbus Group With people’s lives in its hands and the huge impact on the communities it serves, Airbus Group is committed to Ethics & Compliance at all times. The Airbus Group has earned the trust of billions of customers, passengers, operators and stakeholders worldwide thanks to the quality and safety of its products. Product integrity is as important as business integrity. We want to be known as a company with ‘integrity inside’: integrity in its people, its partners and its suppliers.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Standards of Business Conduct (January 2014), pp.4-5: ‘Our Integrity Principles Commitment to Our People. Our Company believes that a workplace should be based on AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM respect, honesty, and fairness. We encourage innovation and employee engagement and are committed to maintaining high standards of quality, health and safety. Commitment to Our Company. Our employees are committed to avoiding any conflicts that might put their personal interests ahead of what is best for the Company.