PDF CODE OF ETHICS English version - MBDA

MESSAGE FROM THECHIEF EXECUTIVE OFFICERAt the heart of MBDA’s strategy to become a global player in the missile and missilesystems market, is the commitment to develop our business, in an ever increasingbreadth of relationships outside of our domestic countries.This growth entails new challenges and responsibilities, which requires MBDA tooperate at the highest standards in how we conduct our business worldwide.A collective behaviour of honesty, integrity and fairness starts with the individualconduct of each of us.2The Code of Ethics sets out the ethical principles I expect all of us to follow, regardlessof location or role. These principles are not new, but are a more comprehensiveversion of the statements previously set out in the MBDA Operational Framework.The Code of Ethics is implemented through policies and procedures, both at Groupand National level.The Code should help us all determine how to act if we are ever in doubt. Itcannot describe every situation and what action to take. However, we are allresponsible for our actions.Consequently, I do invite you to read this document carefully and use it as a guidein your daily work.If you do come across anything which you are not sure about because it seemswrong or you need advice, do not hesitate to speak up without fear of reprisal.Our reputation and future business success depend on each of us conducting ourbusiness and actions in a responsible way.The Code of Ethics is a tool to meet this goal and sets forth the behavioursexpected of each of us. I rely on you to use it.Antoine Bouvier

GENERALPRINCIPLESCompliance with Laws and RegulationsOur reputation is based on integrity and the respect oflaws and regulations – both in our domestic countriesand in export countries where we operate. It is ourpersonal responsibility to know the laws, regulations andrequirements relating to our job.Any breach of these laws may lead to civil and criminalprosecution.Activities which could involve the company in unlawfulpractices are prohibited.Commitment to Integrity3The Code of Ethics is the foundation stone of the MBDA IntegrityProgramme. Its purpose is to define principles helping each of usto uphold our commitment to integrity in our daily work.Many of our activities are not governed by laws or regulations, inwhich case the principle of integrity must govern our conduct. It isour personal responsibility to apply this principle at all times.No performance objectives should be imposed or accepted if they canonly be achieved by compromising our ethical standards.Seeking guidance and reporting concernsThe Code of Ethics cannot cover every situation that we may face within oureveryday role.We may find ourselves faced with a dilemma that we are not sure how toresolve.There are a number of ways that we can seek advice and support.We can contact our immediate manager, someone else in our managementstructure, our Human Resources department, our Legal department orCompliance Officers.We must not let any concerns go unresolved.No reprisal will be tolerated against employees making such a report in good faith.

BUSINESS RELATIONSHIPS4CustomersWe are committed to treating all our customers honestly and fairly, whatever thesize of their business and honouring our contractual commitments all the time.We must provide our customers with high-quality and safe products and servicesthat meet their expectations.Quality and safety are core values for MBDA and we must comply with all controlstandards, including applicable laws and regulations as well as internal controlprocedures ensuring safe and high-quality products are delivered to our customers.SuppliersSuppliers deliver an important part of the value of our products and play animportant role in customer satisfaction. We must promote ethical relationshipswith our suppliers and make sure that they are treated fairly and equally.In the selection of goods and services account must be taken of price, quality,performance, delivery and suitability.Fair competitionBusiness advisorsWe must never hire someone elseto do anything that we cannotethically or legally do ourselves.Engaging a third-party to indirectlymake an improper payment violatesanti-corruption laws.The selection of business advisors isguided by strict internal procedures.We must always behave ethically when competing for customers’ business andwhen placing business with suppliers. Honesty and integrity clearly apply toour dealings with both customers and suppliers.This is especially true in the development phase of new business and in thenegotiation phase of contracts.We must always comply with competition, antitrust and anti-corruption laws.We strictly adhere to the principles of the OECD Convention on CombatingBribery of Foreign Public Officials in International Business Transactions aswell as the United Nations Convention Against Corruption.It is our collective and individual responsibility to never engage MBDA in anyform of corruption, whether public or private.As a member of the AeroSpace and Defence Industries Association ofEurope (ASD), MBDA recognises that the “Common Industry Standards”issued by the ASD reflect good industry practice and adhere to their terms.

Gifts and hospitalityConflicts of interestMBDA aims to ensure that any businessdecision made by us, our customers, suppliersor other business partners is solely based onrelevant criteria, such as competitiveness,performance and quality of products and servicesoffered. Business courtesies, such as gifts andhospitality, given to or received from customers,suppliers or other business partners must reflect anormal courtesy of business and may not influence,or give the appearance of influencing, any businessdecision.Gifts and hospitality must not be given or received witha corrupt purpose anywhere in the world.Reasonable behaviour, common sense and prudenceshould always guide us in these situations and it is ourduty to always comply with our internal procedures as wellas with the laws and regulations of our domestic countriesand those of other countries where we do business.Gifts in cash or any lavish hospitality are never permitted.Money launderingAll of us as employees are required to avoid conflicts of interest between our obligations toMBDA and our personal affairs.Any relationship or activity which could or would influence, or appear to influence, performanceof our duties to MBDA must be disclosed to our manager.SponsorshipSponsorship is part of the marketing and communication strategy.It is authorised in compliance with applicable laws and regulations.Decisions to engage the company in any sponsorship is subject to prior approval of MBDA andmust be properly recorded.Export ControlWe must comply with all applicable laws and regulations when importing and exportingproducts, services and information.If we fail to observe export control laws, the company (and individuals) may face fines,criminal prosecution and loss of authorisation to export.We must be familiar with MBDA’s policies and procedures for handling goods, technologyand data or providing services which may come into or go outside our country.5Money laundering is the faking of the origin of money comingfrom criminal activities.In compliance with all laws related to this matter, MBDA iscommitted to conducting business with reputable partners.All of us must be cautious with the way payments are made todetect any irregularities with partners who demonstrate suspiciousbehaviours in their operations.Facilitation paymentsFacilitation payments are small unofficial payments to low-level publicofficials to speed up or obtain routine administrative processes.MBDA prohibits such facilitation payments in any country where weoperate.

OUR PEOPLEHealth and SafetyEqual opportunity and diversity6MBDA is committed to pursuing the highest health and safety standards in the workplace.MBDA endeavours to implement the necessary programmes, training and internalcontrols to consistently promote safe work practices.We must familiarise ourselves with, and follow, health and safety policies andprocedures set up within MBDA.Security of employeesMBDA does its utmost to protect its employees, wherever they are working.MBDA informs people of risks and sets out internal procedures to be followed, suchas in the event of unstable political situations, criminal acts or health matters.We must be aware of updated information delivered by MBDA, particularly withregards to business travel.Treating each other with respectOur responsibility is to treat others with respect.MBDA aims to create an environment where employees feel comfortable to voicetheir opinions in a professional and constructive way.MBDA does not tolerate any form of humiliation, harassment - sexual, physical orpsychological –, coercion, bullying or other offensive conduct.All of us are required to comply with all laws and regulations forbidding anydiscrimination.MBDA believes that diversity strengthens the companyand seeks to recognise and value the differencesbetween employees by building teams that reflect themarkets and communities in which it operates.The recruitment process is exclusively based on theapplicant’s experience, qualifications and skills, withremuneration solely determined on the basis of thecontribution to the company.Career managementMBDA aims to promote personal development.One of the key tools to facilitate development is regularface-to-face interviews with our manager.These interviews help focus on required skills, achievements,development plan and career paths according to individual needsand aspirations, as well as business requirements.Training and collaborative ways of working also contribute to thisprocess.

Social relationsMBDA respects the right of all of us to form and jointrade unions and workers’ organisations to organise andbargain collectively.MBDA respects the role and responsibilities of the socialpartners and commits to communicating and negotiatingopenly to address issues of collective interest.Data privacyAccess to personal data shall be limited to those whosefunction and responsibility necessitates the handling of personaldata.MBDA does not communicate personal information to thirdparties, except to the extent necessary and allowed by applicablelaws and regulations.7

PROTECTING ASSETSAND INFORMATIONProtecting MBDA’s and third-party assetsWe should do our utmost to protect the company’s assets. MBDA’s assets must notbe used for illegal purposes or for purposes not related to the company’s activities.We should not appropriate any company’s assets for our own use or make themavailable to others for non-MBDA use.In the course of doing business with MBDA, our customers, suppliers and otherpartners may entrust the company with confidential and proprietary information.To be a trustworthy business partner, we must handle third-party information withthe same care as we take with company information, and cannot disclose it to anyunauthorised persons.8Classified informationDue to the nature of its products and services, MBDA creates and handlesgovernment security classified information and we must know and followapplicable MBDA policies and the established laws and regulations that governour handling of such information.It is important to remember that these laws and regulations are generallyconsiderably stricter than those governing dealings with non governmentsecurity classified information.Access to government security classified information requires specific clearances,relative to the level of sensitivity.Any exchange or transmission of government security classified information ormaterial must comply strictly with the relevant security process.Intellectual propertyIntellectual property rights, which include patents, know-how, trade secrets,trademarks, domain names, industrial designs and copyrights, are one of MBDA’smost valuable assets and must be protected by law, whenever possible.All of us have a duty to safeguard these assets.We must also respect the intellectual property rights of third parties.We should never infringe on the intellectual property rights of others, including byviolating copyrights or downloading software without the permission of the owner.

Maintaining accurate recordsAvoiding insider tradingMBDA, our shareholders and business partners relyon the accuracy of the information contained in ourbusiness records.We therefore have a responsibility to ensure that theinformation we provide is accurate.This applies to all of our business records, includingexpense reports, contract documentation and time records.In maintaining our financial records, we must follow internalcontrol procedures.We may not create or participate in the creation of recordsthat are intended to mislead or conceal any improper activity.This means, in part, that we must never make false, misleadingor unrecorded entries.We are expected to maintain company documents in accordancewith any records retention legal requirements and internalprocedures.Consult a dedicated focal point or a manager with questions to howlong you should retain a document or how to destroy it properly.Many countries have enacted insider trading laws.In line with these laws, we may not buy or sell the stock of any company while inpossession of inside or privileged information about that company.This rule applies to the stock of our shareholders, as well as the stock of ourcustomers, suppliers and partners listed on a public stock exchange.In addition, we must not disclose any inside or privileged information to anyone,including co-workers, family members or friends.Communication and relations with the mediaMedia relations are the responsibility of the Communications Directorate.Unless approved in advance by the company, no MBDA employee is authorised torepresent MBDA, express opinions or statements or to issue any information onbehalf of the company to the media.This applies to all forms of communication media including internet socialnetworking platforms e.g. social forum web sites, blogs or chat rooms.All MBDA material for media distribution shall be validated through theCommunications Directorate and, where appropriate, the Legal Directorate.This material shall be compliant with the MBDA graphic standards and beretained on record.9

A SOCIALLY RESPONSIBLECOMPANYEnvironmentMBDA has a responsibility to our global community to protect the environment.We must promote eco-efficiency in all of our business activities by striving to reducethe overall MBDA carbon and global environmental footprint.Environmental protection and eco-efficiency will be conducted within the frameworkof Sustainable Development and supported by Sustainable Procurement practices.In addition, we must comply with all applicable laws and regulations wherever we dobusiness.Lastly, all of us as employees are encouraged to contribute to this collective effortand more generally to adopt individual environment-friendly behaviours.10DonationsDonations to public-interest or private organisations on behalf of MBDA may bepermitted in compliance with all applicable laws and regulations.Decisions to engage the company in any donations to our communities or charitiesis subject to prior approval of MBDA and must be properly recorded.Political contributions and activityPolitical contributions are often subject to national laws and vary from country tocountry.MBDA’s policy is not to make contributions, financial or in kind, to politicalparties or organisations, or to individual politicians.MBDA respects the rights of its employees to participate as individuals in theircommunity and civic affairs.This must be done at a personal level or through a Political Action Committeewhen permitted by law (such as in the US), in their own time and at their ownexpense, consistent with applicable laws.Employees need to carefully separate their own political activities from MBDAactivities and avoid any conflict of interest.

Key reference documents12MBDA Business Ethics Policy and Procedure (MP M3.0356)Policy and Procedures Concerning Gifts and Hospitality (MP M3.0001)MBDA Procurement Policy (BMS0726)MBDA General Security Policy (BMS0367)Policy for the Control of US Material (ITAR / EAR) (BMS0935)Security Principles of the MBDA Group (BMS0913)MBDA Information Security Policy (MP S5.1000)Business Travel Security (BMS0949)Manage Human Resources and Competencies (BMS0585)MBDA Health and Safety Policy (MP S5.0063)Ethics Charter in Favour of Diversity (BMS1135)Manage Finance (BMS0607)Manage Communications (BMS0611)MBDA Group Environment Policy (MP M3.0511)The Code of Ethics and thepolicies it refers to areavailable on the MBDAintranet.

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