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:

Number of questions

% score based on public information

Leadership, Governance and Organisation

10

75%

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%

Topic

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-ofdirectors.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/ethicscompliance/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/businesssuppliers/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/ethicscompliance/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/AntiCorruption/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 anticorruption agenda of the company. This engagement could take the form of leading an anticorruption 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. Additionally, our employees are encouraged to speak up and seek guidance if they have any ethical or compliance concerns. Commitment to Building Trust. Our employees protect the property and confidential information of the Company and of our stakeholders. Protecting confidential data, keeping accurate records, and adhering to all laws governing our business are key to our long-term success. Commitment to Conducting Ethical Business. Business meals, hospitality, and modest nonmonetary gifts may be given or accepted if they reflect customary business practices. However, all business decisions must be based solely on the merits. Only clean business is sustainable business. Corruption is detrimental to the work environment, stifles innovation, and is illegal. Our Company has a zero tolerance policy towards corruption of any kind. Commitment to Corporate Citizenship. Our Company is committed to being a good corporate citizen. We acknowledge our responsibilities towards the environment, our local communities, and our stakeholders. Commitment to be Responsive. Our Company is committed to respond to employees’ concerns and suggestions. Our Division Compliance Officers and our Ethics & Compliance representatives are always available to offer guidance and support. Additionally, the Airbus Group OpenLine can be contacted to report an incident or raise a concern, confidentially and without fear of retaliation.’ (p.7): ‘Our Commitment to Integrity. We conduct our business with integrity, respecting applicable laws and regulations.’ (p.32): ‘Products with Integrity from People with Integrity. Our success is built on our product integrity ensured by the dedicated work of our people with integrity.’ Annual Review 2013, p.55: ‘Integrity in Practice While fostering a culture of high performance, Airbus Group's top management emphasises that it is not only results that matter, but the way they are achieved. Integrity is considered a paramount value in the Group. In 2013, the “Standards of Business Conduct” were updated and implemented across the Group. In addition a company-wide document “Our Integrity Principles”, outlining the Group’s key integrity commitments in a simple userfriendly format was rolled out across the Group and explained by managers to each individual employee in team meetings. Airbus Group is committed to building a culture of integrity by providing employees with the right tools and role-modelling the right behaviour.’ Corporate Responsibility & Sustainability Report 2013, p.3: AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

‘Ethics and Compliance Live Our Integrity Principles on a daily basis and speak up to improve our performance and preserve our reputation. Align our business conduct to best practices within the Group to maintain our top-tier position in Ethics and Compliance. Build on our robust anti-bribery programme to promote integrity throughout our supply chain and keep our suppliers and subcontractors engaged in the fight against corruption.’ (p.15): ‘In 2013, the Group published its Integrity Principles, describing the six preeminent values. A large communication campaign was launched and the Integrity Principles (see below) were rolled out by means of talks between managers and their employees’ http://www.airbusgroup.com/dam/assets/airbusgroup/int/en/group-vision/responsibilitysustainability/documents/AIRBUS_GROUP_CR-S_2013/AIRBUSGROUP_CRS_2013.pdf

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A5: Does the company belong to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption? Score: 2 Comments: Based on public information, there is evidence that the company is a signatory to the United Nations Global Compact and the ASD Common Industry Standards, and is a member of the International Forum on Business Ethical Conduct.

References: Public: Company website: Ethics & Compliance ‘Setting Industry Standards Looking beyond its own four walls, Airbus Group is contributing to establishing global standards for the aerospace and defence industry. We are an active participant in a number of forums, such as the United Nations Global Compact and International Forum on Business Ethical Conduct for the Aerospace and Defence Industry, of which Airbus group is a co-chair. These efforts have led to the adoption in 2009 of the ‘Global Principles of Business Ethics’ by European and US industry associations.’ ‘International cooperation Actively contributing to international standards for ethics and good governance within our industry is a top priority for Airbus Group. To ensure a fair and level playing field, and to succeed in our business globally, Airbus Group is a strong promoter of international cooperation between private and public partners. Our interest, shared by our industrial partners, is to generate synergies and share best practices in compliance. This is not only in the interest of our company, but of all competitors to protect our industry and promote its reputation worldwide. Consequently, Airbus Group is part of numerous initiatives, uniting companies from around the world with the same objective: to promote a fair and equal environment for our industry and our clients. These include: -UN Global Compact AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

-ASD Common Industry Standards -International Forum on Business Ethical Conduct (IFBEC)’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A6: Has the company appointed a Board committee or individual Board member with overall corporate responsibility for its ethics and anti-corruption agenda? Score: 1 Comments: Based on public information, there is limited evidence that the Audit Committee has overall corporate responsibility for the company’s ethics and anti-corruption agenda. The company therefore scores 1. To score higher the company would need to provide details of what this responsibility entails, ideally through terms of reference.

References: Public: Company website: Organisation ‘The Audit Committee has the responsibility for ensuring that the internal and external audit activities are correctly directed and that audit matters are given due importance at meetings of the Board of Directors. Thus, it discusses with the auditors their audit programme and the results of the audit of the accounts and it monitors the adequacy of the Group’s internal controls, accounting policies and financial reporting. It also oversees the operation of the Group’s ERM system and the Compliance Organisation.’ http://www.airbusgroup.com/int/en/group-vision/governance/organisation.html Standards of Business Conduct (January 2014), p.2: ‘The Board appointed the Chief Compliance Officer to oversee the Ethics & Compliance Programme under the supervision of the Audit Committee. The Chief Compliance Officer and the Ethics & Compliance Team provide support and guidance to assist in understanding and applying these Standards.’ Company website: Ethics & Compliance ‘The Airbus Group Ethics & Compliance organisation balances proximity to day-to-day business activities with a degree of necessary independence. Consequently, the Group’s Ethics & Compliance Officer (ECO), who is appointed by the Board of Directors, reports both AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

to the Group’s Chief Executive Officer and the Audit Committee of the Company’s Board of Directors, while the Divisions’ Ethics & Compliance Officers report both to their Division CEO and the Group ECO. Each Division Ethics & Compliance Officer runs a Divisional Ethics & Compliance Organisation that is embedded in the business through a network of Ethics & Compliance representatives.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A7: Has the company appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anticorruption agenda, and who has a direct reporting line to the Board? Score: 2 Comments: Based on public information, there is evidence that the company has given Chief Compliance Officer Pedro Montoya, responsibility for implementing the company’s ethics and anti-corruption agenda. Mr Montoya reports to the CEO and the Audit Committee.

References: Public: Company website: Ethics & Compliance ‘The Airbus Group Ethics & Compliance organisation balances proximity to day-to-day business activities with a degree of necessary independence. Consequently, the Group’s Ethics & Compliance Officer (ECO), who is appointed by the Board of Directors, reports both to the Group’s Chief Executive Officer and the Audit Committee of the Company’s Board of Directors, while the Divisions’ Ethics & Compliance Officers report both to their Division CEO and the Group ECO. Each Division Ethics & Compliance Officer runs a Divisional Ethics & Compliance Organisation that is embedded in the business through a network of Ethics & Compliance representatives.’ ‘At Airbus Group, we prohibit all forms of corruption, public or private. As such, a dedicated anti-corruption programme and organisation were put in place at an early stage under the leadership of the Group International Compliance Officer.’ ‘Airbus Group has organised a risk-based, centralised network of experts in anti-corruption headed up by the Group International Compliance officer.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Standards of Business Conduct (January 2014), p.2: ‘The Board appointed the Chief Compliance Officer to oversee the Ethics & Compliance AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

Programme under the supervision of the Audit Committee. The Chief Compliance Officer and the Ethics & Compliance Team provide support and guidance to assist in understanding and applying these Standards.’ Annual Review 2013, p.19: Chief Compliance Officer Pedro Montoya. Corporate Responsibility & Sustainability Report 2013, p.14: ‘The Ethics & Compliance (E&C) Organisation designs and implements its E&C Programme, focusing on developing a culture of integrity while addressing the Group’s compliance risks.’ Registration Document 2013, p.136: ‘Hence, the Group SVP Ethics & Compliance Officer (“ECO”), who is appointed by the Board of Directors, reports both to the Group Chief Executive Officer and the Audit Committee while the Divisions’ Ethics & Compliance Officers report both to Division CEO and the Group ECO.’ (p.137): ‘At Group level, dedicated Compliance Risks Officers are empowered to issue standards applicable throughout the Group, test effectiveness and control adherence. The Group International Compliance Office addresses corruption and bribery risks. The Group 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 Group Procurement Compliance Offi cer supervises compliance in the supply chain while the Group Data Protection Compliance Officer is in charge of data privacy risk.’ ‘The Group ECO reports to the Audit Committee on compliance allegations twice a year. The report contains details on Group significant compliance allegations, including the allegations described above under “— 1. Information on Group’s Activities — 1.1.9 Legal and Arbitration Proceedings”. As a matter of transparency and to leverage on lessons learned, this report is shared with the top management.’ http://www.airbus-group.com/dms/airbusgroup/int/en/investorrelations/documents/2014/AGM-Annual-Report--BV/airbuseads_rd_ev_webversion_090414/EADS%20Registration%20Document%202013.pdf Pedro Montoya DII Bio (2014) ‘Pedro Montoya, Airbus Group, Svp, Group Ethics & Compliance Officer’ ‘Pedro Montoya was appointed Group Chief Compliance Officer by the Board of Directors of Airbus Group in October 2008’ http://www.dii.org/system/files_force/Bio%20PM%202014.pdf?download=1

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

Registration Document 2012, p.137: ‘The Board of Directors appointed the EADS Group Chief Compliance Offi cer (“CCO”) to design and implement the EADS Ethics and Compliance Programme, which supports the Group’s commitment to adhering to the highest ethical and compliance standards in order to sustain the Group’s global competitiveness. The CCO heads the group-wide compliance organisation, the operations of which are overseen by the Audit Committee.’ http://www.airbusgroup.com/dam/assets/airbusgroup/int/en/investorrelations/documents/2013/AGM--annual-report/EADS-Registration-Document2012/EADS%20Registration%20Document%202012.pdf

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A8: Is there regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda? Score: 2 Comments: Based on public information, there is evidence that the company commissioned an external review of its anti-corruption agenda in 2013. ETHIC Inteligence completed a review of the company’s anti-corruption system, with 24 audits carried out and all company divisions having received certification.

References: Public: Company website: Resposibilities and Powers of the members of the Board of Directors ‘Approving principles and guidelines governing the conduct of the Group in matters involving non-contractual liabilities (like environmental matters, quality assurance, financial announcement, integrity) as well as the corporate identity of the Group’ ‘Approving other measures and business of fundamental significance for the Group or which involve an abnormal level of risk’ http://www.airbusgroup.com/int/en/groupvision/governance/organisation/responsibilities-powers-board-of-directors.html Company website: Ethics & Compliance ‘Policies and Guidelines The policies listed below are the key Group-wide applicable compliance-related policies. They are updated regularly to take into consideration the most recent legislative changes and any other relevant circumstances.’ ‘In 2013 and 2014 Ethic Intelligence awarded the Airbus Group and its Divisions certificates stating that “The anticorruption policy is properly designed in a coherent manner, corresponding to international best practices, with regard to the risk of corruption of Airbus Group” and that “the Policy is consistently implemented throughout the Division”.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

Corporate Responsibility & Sustainability Report 2013, p.12: 24 audits undertaken in the context of anti-bribery certification (p.17): ‘Airbus Group is committed to eliminating bribery and corruption risks. The Group commissioned an external audit of its control framework, while strengthening its controls and providing ongoing training.’ ‘In 2013, ETHIC Intelligence, a leading compliance specialist, successfully completed its review of the Group’s anti-corruption system. The review of this system at Airbus Group level concluded with the Certification of Airbus Group for the design of its Anti-Corruption Compliance Programme, highlighting the quality of the business partner vetting process. ETHIC Intelligence carried out 24 audits in the course of its work. Some of the Divisions also received the Certification of ETHIC Intelligence in 2013. All other Divisions have received the same in the beginning of 2014.’ Registration Document 2013, p.137: ‘The Group ECO reports to the Audit Committee on compliance allegations twice a year. The report contains details on Group significant compliance allegations, including the allegations described above under “— 1. Information on Group’s Activities — 1.1.9 Legal and Arbitration Proceedings”. As a matter of transparency and to leverage on lessons learned, this report is shared with the top management.’ ‘In 2013, the Group was audited by an external verifi cation company called ETHIC Intelligence on its anti-corruption programme and was certified.’ North America Airbus Group website: EADS Commissions External Audit of Group Compliance ‘The EADS Board of Directors and the Group Executive Committee have regular reviews of compliance-related matters with the Chief Compliance Officer.’ External review commissioned in response to GPT corruption case http://northamerica.airbus-group.com/northamerica/usa/en/news/press.20121115_eads_compliance.html Registration Document 2012, p.137: ‘In order to achieve the objectives set by the Chief Executive Officer and discussed with the Audit Committee, the EADS Group CCO has established a compliance “roadmap” based on international standards. The roadmap provides an overview of compliance activities such as: — a periodic assessment and reporting of the main compliance risks as part of the EADS ERM system; — the monitoring of Ethics and Compliance policies; AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

— empowerment of compliance organisation and transparent reporting to the Audit Committee and discussions with the Executive Committee; — communication and training activities across the Group; and — the investigation of compliance allegations and the functioning of the alert system OpenLine, through which employees may raise ethical and compliance concerns in strict confidentiality and without fear of retaliation.’ ‘Programme progress reports are presented are quarterly to the Board of Directors Audit Committee. Additionally, the EADS Group CCO providesa semi-annual Compliance Report to the Audit Committee on compliance allegations. The report contains details on potentially signifi cant compliance violations affecting the Group of which the CCO is currently aware, including the compliance allegations described above under “— 1. Information on EADS’ Activities — 1.1.9 Legal and Arbitration Proceedings”. Reflecting transparency across the Group, this report is shared with the top management.’

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A8(a): Is there a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based, and evidence of improvement plans being implemented when issues are identified? Score: 1 Comments: Based on public information, there is some evidence of a plan that guides the review of the ethics and anti-corruption agenda by the Board or senior management. The Audit Committee receives quarterly programme progress reports and semi-annual compliance allegations reports. The Corporate Responsibility & Sustainability Report 2013 contains evidence of monitoring indicators, such as training uptake, as well as the steps of the ethics and compliance cycle. The company therefore scores 1. To score higher there must be evidence of a written plan that clearly guides how the review of the anti-corruption agenda should be undertaken, as well as evidence of improvement plans being implemented.

References: Public: Registration Document (2012), p.137: ‘In order to achieve the objectives set by the Chief Executive Officer and discussed with the Audit Committee, the EADS Group CCO has established a compliance “roadmap” based on international standards. The roadmap provides an overview of compliance activities such as: — a periodic assessment and reporting of the main compliance risks as part of the EADS ERM system; — the monitoring of Ethics and Compliance policies; — empowerment of compliance organisation and transparent reporting to the Audit Committee and discussions with the Executive Committee; — communication and training activities across the Group; and — the investigation of compliance allegations and the functioning of the alert system OpenLine, through which employees may raise ethical and compliance concerns in strict confidentiality and without fear of retaliation.’ ‘Programme progress reports are presented are quarterly to the Board of Directors Audit AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

Committee. Additionally, the EADS Group CCO providesa semi-annual Compliance Report to the Audit Committee on compliance allegations. The report contains details on potentially significant compliance violations affecting the Group of which the CCO is currently aware, including the compliance allegations described above under “— 1. Information on EADS’ Activities — 1.1.9 Legal and Arbitration Proceedings”. Reflecting transparency across the Group, this report is shared with the top management.’ Corporate Responsibility & Sustainability Report 2013, p.12:

(p.14):

Registration Document (2013), p.137:

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‘The Group ECO reports to the Audit Committee on compliance allegations twice a year. The report contains details on Group significant compliance allegations, including the allegations described above under “— 1. Information on Group’s Activities — 1.1.9 Legal and Arbitration Proceedings”. As a matter of transparency and to leverage on lessons learned, this report is shared with the top management. In 2013, the Group was audited by an external verifi cation company called ETHIC Intelligence on its anti-corruption programme and was certified.’

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A9: Does the company have a formal process for review and where appropriate update its policies and practices in response to actual or alleged instances of corruption? Score: 2 Comments: Based on public information, there is evidence that the company’s Ethics & Compliance Officer reports to the Audit Committee on compliance allegations twice a year. If corrective action is required it will be decided by the appropriate level of management. Furthermore, TI notes that prompted by the allegations surrounding the GPT subsidary, the company conducted internal audits and commissioned an external investigation.

References: Public: EADS OpenLine Policy (January 2013), p.4: ‘If recommendations or corrective actions are necessary, they will be decided by appropriate level of management. The CCO and his compliance team are also responsible for oversight of any corrective actions, which may include disciplinary procedures according to national rules.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Corporate Responsibility & Sustainability Report 2013, p.15: ‘The Airbus Group ECO reports to the Audit Committee on compliance allegations twice a year. The report, which is shared with top management in order to ensure transparency and leverage on lessons learned, contains details on the Group’s significant compliance allegations.’ The Telegraph Website: EADS launches anti-corruption review in wake of bribery allegations ‘The company said it had appointed Ethic Intelligence, a certification agency specialising in anti-corruption compliance, to immediately begin tests on EADS’s processes.’ http://www.telegraph.co.uk/finance/financial-crime/9681781/EADS-launches-anticorruption-review-in-wake-of-bribery-allegations.html AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

Reuters website: EADS says Airbus audit shows no wrongdoing ‘"An internal audit of Airbus sales campaigns confirmed compliance with both internal and international regulations and gave no indication of irregularities," EADS said in a statement. "European aerospace and defence group EADS had launched a formal audit immediately after having taken notice of such allegation from a media report on March 21," it said.’ http://uk.reuters.com/article/2007/04/03/uk-airbus-audit-idUKL0313488220070403 Registration Document 2012, p.137: ‘Programme progress reports are presented are quarterly to the Board of Directors Audit Committee. Additionally, the EADS Group CCO providesa semi-annual Compliance Report to the Audit Committee on compliance allegations. The report contains details on potentially significant compliance violations affecting the Group of which the CCO is currently aware, including the compliance allegations described above under “— 1. Information on EADS’ Activities — 1.1.9 Legal and Arbitration Proceedings”. Reflecting transparency across the Group, this report is shared with the top management.’ Registration Document 2013, p.50: ‘GPT Prompted by a whistleblower’s allegations, the Company has conducted internal audits and commissioned an external investigation relating to GPT Special Project Management Ltd. (“GPT”), a subsidiary that Airbus Group acquired in 2007. The allegations called into question a service contract entered into by GPT prior to its acquisition by Airbus Group, relating to activities conducted by GPT in Saudi Arabia. Following the allegations, Airbus Group conducted comprehensive internal audits in 2010 that did not detect any violations of law. The UK Serious Fraud Office (the “SFO”) subsequently commenced a review of the matter. In 2011, Airbus Group retained PricewaterhouseCoopers (“PwC”) to conduct an independent review, the scope of which was agreed with the SFO. In the period under review and based on the work it undertook, nothing came to PwC’s attention to suggest that improper payments were made by GPT. Further, the review did not find evidence to suggest that GPT or through GPT, any other Group company, asked specific third parties to make improper payments on their behalves. The PwC review was conducted between November 2011 and March 2012, and a copy of its report was provided by Airbus Group to the SFO in March 2012. Separately, in August 2012, the SFO announced that it had opened a formal criminal investigation into the matter. Airbus Group is cooperating fully with this investigation. Eurofighter Austria In March 2012, the German public prosecutor, following a request for assistance by the Austrian public prosecutor, launched a criminal investigation into alleged bribery, tax evasion and breach of trust by current and former employees of EADS Deutschland GmbH and Eurofi ghter Jagdfl ugzeug GmbH as well as by third parties relating to the sale of Eurofi ghter aircraft to Austria in 2003. The Company is cooperating fully with this investigation, AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

and has also engaged external legal counsel to conduct an independent review of the matter.’ (p.137): ‘The Group ECO reports to the Audit Committee on compliance allegations twice a year. The report contains details on Group significant compliance allegations, including the allegations described above under “— 1. Information on Group’s Activities — 1.1.9 Legal and Arbitration Proceedings”. As a matter of transparency and to leverage on lessons learned, this report is shared with the top management.’

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A9(a): Does the company have a formal anti-corruption risk assessment procedure implemented enterprise-wide? Score: 2 Comments: Based on public information, there is evidence that the company has a formal anticorruption risk assessment procedure. The Enterprise Risk Management (ERM) system is designed for operational risk and opportunity management, and internal control management. The system mitigates a range of risks including compliance risks. The four areas of focus in compliance are corruption, export, procurement and personal data protection. Compliance risk officers issue standards aplicable throughout the company, test effectiveness and control adherence. These officers manage a network of over 100 risk specialists that are embedded in the company’s divisions. Specifically for corruption risks, the company has an anti-corruption programme and organisation under the leadership of the Group International Compliance Officer.

References: Public: Company website: Enterprise Risk Management ‘Airbus Group’s long-term development and production lifecycle make Enterprise Risk Management a crucial mechanism for both mitigating the risks faced by the company and identifying future opportunities. In 2013, the Enterprise Risk Management (ERM) function also streamlined its activities to reflect the Group consolidation. Consequently, there is one Group ERM function, with direct responsibility for Airbus. Vincent Leroy is the head of this function and coordinates groupwide the ERM functions at Airbus Helicopters and Airbus Defence and Space. By mapping all material risks, planning how to mitigate them and how to seize related opportunities, ERM is designed to protect the achievement of the following: 1. Strategy: selection of high level strategic objectives consistent with risk appetite 2. Operations: effectiveness and efficiency of operations and resource allocation, in line with performance and financial targets 3. Reporting: reliability of reporting, in particular 4. Compliance: compliance with applicable laws and regulations. AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

Mapping and mitigating the risks ERM is a governance system for:  

operational risk and opportunity management (Programmes, Projects and Functions) internal control management (i.e. risk and opportunity management concerning internal processes) As ERM is applied more consistently across the Group, its subsidiaries and major suppliers, there is increasingly a common understanding, methodology, practice and language. Tools for fostering ERM include policies, reviews, training, internal controls and IT systems.’ http://www.airbusgroup.com/int/en/group-vision/governance/enterprise-riskmanagement.html Company website: Ethics & Compliance ‘Airbus Group's Ethics & Compliance Programme follows a risk-based approach with the aim of preventing, detecting and responding to Ethics & Compliance risks. A strong team focuses on four key areas to support our employees in living by our Standard of Business Conduct and our Integrity Principles. At Group level, dedicated Compliance Risk Officers are empowered to issue standards applicable throughout the Group, test effectiveness and control adherence. These Compliance Risk Officers manage a network of more than 100 risk specialists that are embedded in the Divisions within the business structure.’ ‘4 main focal points Following a risk assessment carried out by Airbus Group, four compliance areas were identified as of primary importance and relevant structures and staffing were set up to respond to those risks: International Compliance - Zero tolerance to corruption At Airbus Group, we prohibit all forms of corruption, public or private. As such, a dedicated anti-corruption programme and organisation were put in place at an early stage under the leadership of the Group International Compliance Officer. Its mission is to reinforce a culture of anti-bribery and to protect the Group against any legal, financial or reputational risk. This is carried out while selecting business partners and conducting M&A operations or investment projects. Notably, the Group International Compliance Office develops and implements the Airbus Group Business Ethics Policy and Rules. Export Compliance - Global export for business continuity Many components integrated in products and services we buy and sell are subject to export control regulations, requiring various licenses. The Export Compliance Organisation provides beginning-to-end business process control. With its worldwide team of 110 export compliance professionals, it ensures full compliance with national and international export laws and regulations and implements the Group Export Compliance Policies and procedures. Procurement Compliance - Growing together Suppliers deliver a high proportion of the value of our products, and thus play an important role in customer satisfaction. At Airbus Group, we believe we must strive to promote ethical AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

and mutually beneficial relationships with these partners. The Group Procurement Compliance Officer mitigates risks arising from exposure to liability in procurement operations and from suppliers’ activities. In order to meet the highest standards of responsibility throughout our supply base, we request that our suppliers commit to our Suppliers Code of Conduct, Growing Together and cascade these principles to their employees and through their own supply chain. Personal Data Protection Compliance - Global standard for personal data processing The Group Data Protection Compliance Office manages the risks and business impacts of European, national and international data protection legislations. It ensures a consistent and globally valid data protection approach and sets data security standards for personal data processing, based on globally accepted principles. It also oversees all ongoing activities related to the development and the implementation of the Airbus Group Data Protection Policies, as well as the Binding Corporate Rules (BCR).’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Annual Review 2013, p.61: ‘In 2013 a compliance risk assessment of the Supply Chain was performed aimed at mapping risks associated with the procurement process, taking into account a variety of topics such as geopolitical situation, sensitive countries, corruption risk, tax havens, sensitive commodities and procurement process compliance. This assessment led to a strengthened procurement process and an implementation of further procurement compliance Key Performance Indicators (KPIs).’ Registration Document 2013, p.137: ‘At Group level, dedicated Compliance Risks Officers are empowered to issue standards applicable throughout the Group, test effectiveness and control adherence. The Group International Compliance Office addresses corruption and bribery risks. The Group 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 Group Procurement Compliance Officer supervises compliance in the supply chain while the Group Data Protection Compliance Officer is in charge of data privacy risk. These Compliance Risks Officers manage a network of more than 100 risks specialists that are embedded in the Divisions within the Business.’

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A10: Does the company have a formal anti-corruption risk assessment procedure for assessing proposed business decisions, with clear requirements on the circumstances under which such a procedure should be applied? Score: 2 Comments: Based on public information, there is evidence that the company has a formal anticorruption risk assessment procedure for assessing proposed business decisions. Before working in certain sensitive countries the company’s top management performs an anticorruption risk assessment, and prior to any mergers or acquisitions the company performs anti-bribery due diligence. In particular detailed information is given on the assessment of potential business partners and mergers and acquisitions.

References: Public: Company website: Ethics & Compliance ‘Airbus Group M&A Anti-bribery Compliance Guidelines The guidelines follow the logic of a typical mergers and acquisitions transaction whereby the Airbus Group would acquire control of a target company and move into the post-deal integration stage. Anti-bribery compliance risks and key steps necessary to address them are presented through the successive stages as a transaction moves forward.’ ‘Sensitive Country Process The Sensitive Country Process is an end-to-end business process control applying to all business activities from the first step of an operation. It allows the Airbus Group top management to perform a prior assessment on any potential risk for the Group in doing business with certain sensitive countries. The process applies to all companies under the control of any entity of Airbus Group irrespective of whether it is for military, dual-use or civil hardware, software, technology and services.’ ‘International Compliance - Zero tolerance to corruption At Airbus Group, we prohibit all forms of corruption, public or private. As such, a dedicated AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

anti-corruption programme and organisation were put in place at an early stage under the leadership of the Group International Compliance Officer. Its mission is to reinforce a culture of anti-bribery and to protect the Group against any legal, financial or reputational risk. This is carried out while selecting business partners and conducting M&A operations or investment projects. Notably, the Group International Compliance Office develops and implements the Airbus Group Business Ethics Policy and Rules.’ ‘Introduction to the guidelines for the assessment of Airbus Group Partners: The guidelines identify certain situations which an Airbus Group Company (hereafter "the Company") should consider before entering into any kind of agreement or contract with a Partner and where it would be necessary (1) to carry out additional investigations – the outcome of which would need to be positive and (2) to take the necessary measures to allow proper implementation of the contractual relationship with the Partner. The situations one could be faced with may not correspond to what it described in these Guidelines. In any case, the following parameters should always be taken into account in the assessment of these situations and the responses provided thereto: 

the level of risk of corruption in the country/countries concerned (using the Transparency International corruption perceptions index);  the business sector in which the planned transaction is to take place (certain sectors have commonly been identified as presenting a higher risk than others);  the amounts at stake in the planned transaction or assignment and the remuneration, structure and amount to be paid to the Partner. After having checked that the Airbus Group company has the right to enter into an agreement with a Partner, the Partner has to be selected according to certain criteria, based on risk analysis. Then will come the definition of the contract which is intended to be entered into. The process then goes through the validation phase as described in the Business Ethics Policy, Processes & Guidelines or in other Airbus Group processes (M&A, supply chain etc.). Once this validation is done, the Airbus Group company will then be in the position to sign the agreement and implement it. Hence, these Guidelines are organized around the following main chapters: -Section 1.Know your Partner -Section 2. Define the relationship -Section 3. Go through the adequate validation process -Section 4. Implement the contract with the Partner In each section, the document indicates:  

The check(s) to be performed The element of alerts which must be analyzed further before entering into the agreement with the selected Partner  Elements to be obtained in case further investigation is required and which may allow the mitigation of identified risks  Principles of line of conduct in front of certain situationS The check-lists which are provided for are not exhaustive and in any case, the International Compliance Officer of the company is there to help appraising the situation the Airbus AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

Group company may be faced with when detecting an element of alert.’ ‘Introduction to compliance guidelines M&A When conducting M&A projects, Airbus Group faces the risk that a target may potentially have ethics and compliance standards lower than Airbus Group and, in some instances, practices which would not comply with Airbus Group standards and applicable laws and regulations. The consequences of such a situation may have significant effects on the potential transaction analysis and economics. For example: • If the target was obtaining business by using practices which would need to be discontinued or significantly adjusted by Airbus Group after the acquisition, key performance indicators of the target may suffer material changes (decreases in revenues, decreases in margins, decreases in the success rate of tender bids etc.). This would obviously change the analysis of the transaction price and, potentially, Airbus Group interest in the transaction; • If the target’s practices and procedures will require significant remediation efforts to adjust them to Airbus Group ethics and compliance standards, it would be important to know the potential cost of this remediation and to include it in the transaction suitability analysis. It is also important to understand that once the transaction is concluded, the acquirer may inherit liabilities related to the practices non-compliant with applicable laws, even if the instances of non-compliance occurred prior to the acquisition date. To illustrate the impacts of inheriting these liabilities, some consequences can be listed as follows: • Debarment from government contracts; • Criminal, civil and financial proceedings against the company, its directors, employees and partners; • Expensive settlement agreements (many recent cases have settled for hundreds of millions of Euros including fines and disgorgement of profits); • Triggering of liabilities under other laws e.g. money-laundering, books and records violations etc.; • Adverse media attention; • Appointment of court / independent monitors; • Director disqualifications; • Employee de-motivation; • Significant professional fees; • Substantial occupation of management time… Those risks are rising rapidly through improved anti-corruption awareness and activism, greater incentives and encouragement for whistle-blowing, improved enforcement tools and more frequent and extensive cooperation between authorities in different countries. In this respect, when considering a transaction, Airbus Group takes specific steps to protect from potential reputational and legal risks from the early stages of the potential M&A AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

transaction thought out the conduct of the deal : Anti-bribery due diligence are conducted to identify risks and find responses which should be proportional to those risks. To that end adequate information is collected and analyzed on a timely basis to allow Airbus Group to take an appropriate decision related to the potential transactions and the steps required to safeguard its interests. This includes the involvement of the Anti-corruption Department in the review of the agreements to be agreed upon with the potential sellers or buyers. The guidelines are designed to assist Airbus Group entities personnel involved in M&A activities in collecting and analyzing information necessary to consider anti-bribery compliance risks that may be encountered and which need to be addressed as part of these activities. In particular, these guidelines should be used by officers in charge of anti-corruption to improve their understanding of M&A activities and the anti-bribery compliance risks that arise in this context. Other functions may also find it useful to familiarize themselves further with anti-bribery compliance issues that may arise from M&A transactions they are working on and improve their understanding of challenges that the International Compliance function may face in this respect.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Corporate Responsibility & Sustainability Report 2013, p.17: ‘A set of anti-bribery tools has been available for many years in the Group. These tools are regularly updated: for example, guidelines were established to support detection and mitigation of anti-bribery compliance risk linked to mergers and acquisitions (M&A AntiBribery Compliance Guidelines, published in 2012). Moreover templates of documents to be used in the selection of business partners (Compliance Pack, including questionnaires, representation and warranties, bank letter templates), the Airbus Group Business Ethics Main Principles, which are a summary of the Business Ethics Policy and Processes are now distributed to all Business Partners as an attachment to the Compliance Pack, whereas updated standard clauses (such as Consultant Agreement, Service Provider Agreement, etc.) have been edited together with the Airbus Group Policy, Processes & Guidelines in 2013.’ Annual Review 2013, p.61: ‘In 2013 a compliance risk assessment of the Supply Chain was performed aimed at mapping risks associated with the procurement process, taking into account a variety of topics such as geopolitical situation, sensitive countries, corruption risk, tax havens, sensitive commodities and procurement process compliance. This assessment led to a strengthened procurement process and an implementation of further procurement compliance Key Performance Indicators (KPIs).’

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A11: Does the company conduct due diligence that minimises corruption risk when selecting or reappointing its agents? Score: 1 Comments: Based on public information, there is evidence that the company conducts due diligence that minimises corruption risk when selecting agents. A capacity due diligence is implemented with the information business partners provide in the Compliance Pack. TI notes that the ETHIC Intelligence review of the company’s anti-corruption system highlighted the quality of the business partner vetting process. The company therefore scores 1. To score higher on this question the company would need to provide evidence that the due diligence process is refreshed at least every 3 years and / or when there is a significant change in the business relationship.

References: Public: Company website: Ethics & Compliance ‘Introduction to the guidelines for the assessment of Airbus Group Partners The guidelines identify certain situations which an Airbus Group Company (hereafter "the Company") should consider before entering into any kind of agreement or contract with a Partner and where it would be necessary (1) to carry out additional investigations – the outcome of which would need to be positive and (2) to take the necessary measures to allow proper implementation of the contractual relationship with the Partner. The situations one could be faced with may not correspond to what it described in these Guidelines. In any case, the following parameters should always be taken into account in the assessment of these situations and the responses provided thereto:   

the level of risk of corruption in the country/countries concerned (using the Transparency International corruption perceptions index); the business sector in which the planned transaction is to take place (certain sectors have commonly been identified as presenting a higher risk than others); the amounts at stake in the planned transaction or assignment and the remuneration, structure and amount to be paid to the Partner.

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After having checked that the Airbus Group company has the right to enter into an agreement with a Partner, the Partner has to be selected according to certain criteria, based on risk analysis. Then will come the definition of the contract which is intended to be entered into. The process then goes through the validation phase as described in the Business Ethics Policy, Processes & Guidelines or in other Airbus Group processes (M&A, supply chain etc.). Once this validation is done, the Airbus Group company will then be in the position to sign the agreement and implement it. Hence, these Guidelines are organized around the following main chapters: -Section 1.Know your Partner -Section 2. Define the relationship -Section 3. Go through the adequate validation process -Section 4. Implement the contract with the Partner In each section, the document indicates:  

The check(s) to be performed The element of alerts which must be analyzed further before entering into the agreement with the selected Partner  Elements to be obtained in case further investigation is required and which may allow the mitigation of identified risks  Principles of line of conduct in front of certain situationS The check-lists which are provided for are not exhaustive and in any case, the International Compliance Officer of the company is there to help appraising the situation the Airbus Group company may be faced with when detecting an element of alert.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Airbus Group Business Ethics Policy Processes & Guidelines – Main Principles (January 2014), p.1: ‘The Airbus Group Business Ethics Policy, Processes and Guidelines apply to all national and international business transactions with Business Partners and are mandatorily enforced by every entity of the Airbus Group without any exception, and in full consistency with the Airbus Group Code of Ethics and with international anti-corruption legislations.’ ‘Business Partner A company with which an Airbus Group Company plans to enter into or has entered into an agreement in relation with its domestic and foreign trade, in the fields of marketing, lobbying, public relations, strategic and market intelligence, support to negotiations, financial engineering, offset arrangements, etc. and by extension to secure current or potential business opportunities for the supply of products and/or services to customers.’ (p.2): ‘Airbus Group has defined the key principles listed below, as the backbone of the Policy: AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

· Transparency; · Collegiality; · Centralization; · Traceability; · Substantiation; and, · Monitoring. 2/ Process of selection of Business Partners a) Based on the above principles, Airbus Group will verify if the potential Business Partner profile and credential meet the requirements of the envisaged Mission. To that end, a capacity Due Diligence will be conducted based upon information mandatorily provided by the Business Partner (the “Compliance Pack”). The Compliance Pack shall include: · a questionnaire; and · representation and warranties giving the firm commitment from the Business Partner to abide by all anti-corruption legislations, both documents being necessarily signed by the Business Partner legal representative; and · accompanying documents such as by-laws, certificate of incorporation, list of shareholders and directors, P&L of the last three years, bank letter, etc.’ http://www.airbusgroup.com/dam/assets/airbusgroup/int/en/group-vision/ethicscompliance/documents/2014-01---Airbus-Group-Business-Ethics-Policy-main-principlesversion-intranet/2014%2001%20%20Airbus%20Group%20Business%20Ethics%20Policy%20main%20principles%20version%2 0intranet.pdf Corporate Responsibility & Sustainability Report 2013, p.17: ‘A set of anti-bribery tools has been available for many years in the Group. These tools are regularly updated: for example, guidelines were established to support detection and mitigation of anti-bribery compliance risk linked to mergers and acquisitions (M&A AntiBribery Compliance Guidelines, published in 2012). Moreover templates of documents to be used in the selection of business partners (Compliance Pack, including questionnaires, representation and warranties, bank letter templates), the Airbus Group Business Ethics Main Principles, which are a summary of the Business Ethics Policy and Processes are now distributed to all Business Partners as an attachment to the Compliance Pack, whereas updated standard clauses (such as Consultant Agreement, Service Provider Agreement, etc.) have been edited together with the Airbus Group Policy, Processes & Guidelines in 2013.’ ‘In 2013, ETHIC Intelligence, a leading compliance specialist, successfully completed its review of the Group’s anti-corruption system. The review of this system at Airbus Group level concluded with the Certification of Airbus Group for the design of its Anti-Corruption Compliance Programme, highlighting the quality of the business partner vetting process. ETHIC Intelligence carried out 24 audits in the course of its work. Some of the Divisions also received the Certification of ETHIC Intelligence in 2013. All other Divisions have received the same in the beginning of 2014.’ AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A12: Does the company have contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption? Score: 1 Comments: Based on public information, there is some evidence that the company has contractual rights and processes for the behaviour, monitoring, control and audit of agents. Business partners are provided with a copy of the Airbus Group Business Ethics Main Principles. If a business partner fails to provide the company with regular and documented reporting, the company is entitled to terminate the contract; this reporting may be periodically audited. The company therefore scores 1. To score higher on this question the company would need to provide further information of the monitoring and auditing process and provide evidence of contractual rights to deal with unethical behaviour.

References: Public: Airbus Group Business Ethics Policy Processes & Guidelines – Main Principles (January 2014), p.3: ‘Once the Airbus Group internal validation procedure is successfully completed, the Airbus Group Company shall set up the Agreement with the Business Partner. Such Agreement must comply with all applicable anti-corruption legislations and shall not be signed with a view to obtain any improper advantage. b) While performing the Business Partner Agreement, evidencing that the Mission has been effectively performed and that the remuneration is in line with it is a critical path for any Airbus Group Company. Therefore, it is mandatory to ensure that during the full period of validity of the Business Partner Agreement, i.e. until full completion of the Mission, the Business Partner provides the Airbus Group Company with a regular and documented reporting (such as activity reports, exchange of emails etc.) in line with such Mission. This reporting duty in a form, substance and quality satisfactory to the Airbus Group Company is of the essence and a condition for the payment of corresponding invoices. Failure to supply such reporting shall be deemed a major default under the Business Partner AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

Agreement, likely to entitle the Airbus Group Company to early terminate the Business Partner Agreement. c) The Business Partner reporting may be audited from time to time by any relevant authority, such as external auditors and tax administration.’ Corporate Responsibility & Sustainability Report 2013, p.9: ‘To impose standards consistent with our own, as defined in the Supplier Code of Conduct, and to provide regular feedback on performance.’ (p.17): ‘the Airbus Group Business Ethics Main Principles, which are a summary of the Business Ethics Policy and Processes are now distributed to all Business Partners as an attachment to the Compliance Pack, whereas updated standard clauses (such as Consultant Agreement, Service Provider Agreement, etc.) have been edited together with the Airbus Group Policy, Processes & Guidelines in 2013. The tools will be updated in 2014 to take into account the Group rebranding. In addition, the International Compliance Programme includes regular internal control of business partner files by, and reporting mechanisms from Division International Compliance Officers (Division ICOs) to the Group International Compliance Officer (Group ICO) using a risk-based approach. Management within Group subsidiaries is responsible for reporting any deviation from the Business Ethics Policy, Processes & Guidelines to the concerned Division ICO and/or to the Group ICO, as applicable.’

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A13: Does the company make clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance? Score: 2 Comments: Based on public information, there is evidence that suppliers must commit to the company’s Supplier Code of Conduct, which includes a zero-tolerance policy of bribery and corruption. There is also evidence of contractual rights for disciplinary action, with the company able to terminate a supplier’s contract if they fail to adhere to the ‘EADS Corporate Social Responsibility in Sourcing document’.

References: Public: Company website: Ethics & Compliance ‘Supplier Code of Conduct Growing together: determined to ensure the highest standards of responsibility throughout its supply base, Airbus Group requires that suppliers commit to its Supplier Code of Conduct and cascade these principles to their employees and through their own supply chain.’ ‘Procurement Compliance : growing together Suppliers deliver a high proportion of the value of our products, and thus play an important role in customer satisfaction. At Airbus Group, we believe we must strive to promote ethical and mutually beneficial relationships with these partners. The Group Procurement Compliance Officer mitigates risks arising from exposure to liability in procurement operations and from suppliers’ activities. In order to meet the highest standards of responsibility throughout our supply base, we request that our suppliers commit to our Suppliers Code of Conduct, Growing Together and cascade these principles to their employees and through their own supply chain.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Growing Together (October 2010), p.2: AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

‘EADS requests that suppliers commit to our Code of Conduct and cascade these principles through their own supply chain.’ (p.3): ‘Giving or soliciting inducements, such as money, goods or services, with the intention of influencing a person, a corporation or a public official, is strictly forbidden. EADS suppliers do not tolerate any form of bribery, extortion or corruption. They prevent corruption in line with the OECD Convention on combating the bribery of foreign public officials in international business transactions.’ http://www.airbusgroup.com/dam/assets/airbusgroup/int/en/group-vision/businesssuppliers/suppliers/linklist-1/EADS-Supplier-Code-of-Conduct_GROWINGTOGETHER/EADS%20Supplier%20Code%20of%20Conduct_GROWING%20TOGETHER.pdf EADS Corporate Social Responsibility In Sourcing (October 2010), p.1: ‘to be acknowledged and observed by all Suppliers of EADS Group companies in connection with all orders issued under EADS General Purchasing Conditions’ ‘The Supplier undertakes to respect the following values and principles: The OECD Convention on combating bribery of foreign public officials in international business transactions ; The First Protocol to the Convention on the Protection of the European Communities' Financial Interests and the Convention on the Fight against Corruption Involving Officials of the European Communities (EC) or Officials of Member States of the European Union as implemented by the EU Member States.’ ‘The Supplier is committed to respect values of honesty and integrity. Any and all forms of corruption, bribery, extortion and embezzlement are strictly prohibited. The Supplier shall strictly refrain from offering, promising or granting any gifts of money, non-monetary gifts, invitations, services or any other advantages to EADS employees with the aim to influence the business relation in a prohibited or improper way. Advantages other than gifts of money which do not exceed an amount of forty (40) € are excluded thereof. In case of non-compliance with the prohibitions as per Section 5, EADS may charge a penalty equal to the amount of the granted advantage, but in any case a minimum amount of five thousand (5.000) €. EADS herewith reserves any further rights and claims.’ ‘On request of EADS, the Supplier shall demonstrate the means implemented in order to ensure adherence of EADS CSR Sourcing provisions. EADS reserves the right to audit Supplier’s adherence or to ask a third party to perform such an audit after having informed the Supplier in due time.’ ‘In case of non compliance with EADS CSR Sourcing provisions, the Supplier shall, following a written notice of EADS, implement the appropriate measures. EADS and the Supplier shall agree on an appropriate time frame for the said implementation which shall not exceed sixty (60) days following reception of the notice of EADS. 11 If the Supplier does not succeed to achieve compliance with EADS´ CSR Sourcing provisions within the agreed time frame, EADS reserves the right to terminate the contract(s) with the Supplier.’ http://www.airbusgroup.com/dam/assets/airbusgroup/int/en/group-vision/businessAIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

suppliers/suppliers/linklist-1/05_CSR-Annex/05_CSR%20Annex.pdf Corporate Responsibility & Sustainability Report 2013, p.17: ‘The Airbus Group Business Ethics Main Principles, which are a summary of the Business Ethics Policy and Processes are now distributed to all Business Partners as an attachment to the Compliance Pack, whereas updated standard clauses (such as Consultant Agreement, Service Provider Agreement, etc.) have been edited together with the Airbus Group Policy, Processes & Guidelines in 2013.’ Standards of Business Conduct (January 2014), p.23: ‘We expects our supplier base to understand, share and adhere to our business ethics standards. Suppliers may be asked to provide evidence of the application of these principles as appropriate, in particular in the areas of business ethics, anticorruption, human rights, labour standards and environmental sustainability.’

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A13(a): Does the company explicitly address the corruption risks associated with offset contracting? Score: 1 Comments: Based on public information, there is evidence that the company addresses the corruption risks of offset contracting at a general level. In the Airbus Group Business Ethics Policy Processes & Guidelines Main Principles document, a company that assists with offset arrangements is defined as a business partner. Therefore, policies that ensure that business partners abide by all anti-corruption legislations also apply to those working for the company on offset contracts. The company therefore scores 1. To score higher the corruption risk from offset contracting must be explicitly addressed in the company’s offset policies, procedures and contractual terms.

References: Public: Airbus Group Business Ethics Policy Processes & Guidelines – Main Principles (January 2014), p.1: ‘The Airbus Group Business Ethics Policy, Processes and Guidelines apply to all national and international business transactions with Business Partners and are mandatorily enforced by every entity of the Airbus Group without any exception, and in full consistency with the Airbus Group Code of Ethics and with international anti-corruption legislations.’ ‘Business Partner A company with which an Airbus Group Company plans to enter into or has entered into an agreement in relation with its domestic and foreign trade, in the fields of marketing, lobbying, public relations, strategic and market intelligence, support to negotiations, financial engineering, offset arrangements, etc. and by extension to secure current or potential business opportunities for the supply of products and/or services to customers.’ (p.2): ‘Airbus Group has defined the key principles listed below, as the backbone of the Policy: AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

· Transparency; · Collegiality; · Centralization; · Traceability; · Substantiation; and, · Monitoring. 2/ Process of selection of Business Partners a) Based on the above principles, Airbus Group will verify if the potential Business Partner profile and credential meet the requirements of the envisaged Mission. To that end, a capacity Due Diligence will be conducted based upon information mandatorily provided by the Business Partner (the “Compliance Pack”). The Compliance Pack shall include: · a questionnaire; and · representation and warranties giving the firm commitment from the Business Partner to abide by all anti-corruption legislations, both documents being necessarily signed by the Business Partner legal representative; and · accompanying documents such as by-laws, certificate of incorporation, list of shareholders and directors, P&L of the last three years, bank letter, etc.’

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A13(b): Does the company conduct due diligence that minimises corruption risk when selecting its offset partners and offset brokers? Score: 1 Comments: Based on public information, there is evidence that the company conducts due diligence that minimises corruption risk when selecting its offset partners and offset brokers. The Airbus Group Business Ethics Policy Processes & Guidelines Main Principles document defines a company that assists with offset arrangements as a business partner, and clearly states that a capacity due diligence is carried out on the information provided by a business partner. TI notes that the ETHIC Intelligence review of the Company’s anti-corruption system highlighted the quality of the business partner vetting process. The company therefore scores 1. To score higher the company would need to provide evidence that it refreshes the due diligence at least every 3 years and/or when there is a significant change in the business relationship.

References: Public: Company website: Ethics & Compliance ‘Introduction to the guidelines for the assessment of Airbus Group Partners The guidelines identify certain situations which an Airbus Group Company (hereafter "the Company") should consider before entering into any kind of agreement or contract with a Partner and where it would be necessary (1) to carry out additional investigations – the outcome of which would need to be positive and (2) to take the necessary measures to allow proper implementation of the contractual relationship with the Partner. The situations one could be faced with may not correspond to what it described in these Guidelines. In any case, the following parameters should always be taken into account in the assessment of these situations and the responses provided thereto:   

the level of risk of corruption in the country/countries concerned (using the Transparency International corruption perceptions index); the business sector in which the planned transaction is to take place (certain sectors have commonly been identified as presenting a higher risk than others); the amounts at stake in the planned transaction or assignment and the remuneration,

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structure and amount to be paid to the Partner. After having checked that the Airbus Group company has the right to enter into an agreement with a Partner, the Partner has to be selected according to certain criteria, based on risk analysis. Then will come the definition of the contract which is intended to be entered into. The process then goes through the validation phase as described in the Business Ethics Policy, Processes & Guidelines or in other Airbus Group processes (M&A, supply chain etc.). Once this validation is done, the Airbus Group company will then be in the position to sign the agreement and implement it. Hence, these Guidelines are organized around the following main chapters: -Section 1.Know your Partner -Section 2. Define the relationship -Section 3. Go through the adequate validation process -Section 4. Implement the contract with the Partner In each section, the document indicates:  

The check(s) to be performed The element of alerts which must be analyzed further before entering into the agreement with the selected Partner  Elements to be obtained in case further investigation is required and which may allow the mitigation of identified risks  Principles of line of conduct in front of certain situationS The check-lists which are provided for are not exhaustive and in any case, the International Compliance Officer of the company is there to help appraising the situation the Airbus Group company may be faced with when detecting an element of alert.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Airbus Group Business Ethics Policy Processes & Guidelines – Main Principles (January 2014), p.1: ‘The Airbus Group Business Ethics Policy, Processes and Guidelines apply to all national and international business transactions with Business Partners and are mandatorily enforced by every entity of the Airbus Group without any exception, and in full consistency with the Airbus Group Code of Ethics and with international anti-corruption legislations.’ ‘Business Partner A company with which an Airbus Group Company plans to enter into or has entered into an agreement in relation with its domestic and foreign trade, in the fields of marketing, lobbying, public relations, strategic and market intelligence, support to negotiations, financial engineering, offset arrangements, etc. and by extension to secure current or potential business opportunities for the supply of products and/or services to customers.’ (p.2): ‘Airbus Group has defined the key principles listed below, as the backbone of the Policy: · Transparency; AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

· Collegiality; · Centralization; · Traceability; · Substantiation; and, · Monitoring. 2/ Process of selection of Business Partners a) Based on the above principles, Airbus Group will verify if the potential Business Partner profile and credential meet the requirements of the envisaged Mission. To that end, a capacity Due Diligence will be conducted based upon information mandatorily provided by the Business Partner (the “Compliance Pack”). The Compliance Pack shall include: · a questionnaire; and · representation and warranties giving the firm commitment from the Business Partner to abide by all anti-corruption legislations, both documents being necessarily signed by the Business Partner legal representative; and · accompanying documents such as by-laws, certificate of incorporation, list of shareholders and directors, P&L of the last three years, bank letter, etc.’

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A15: Does the company have an anti-corruption policy that prohibits corruption in its various forms? Score: 2 Comments: Based on public information, there is evidence that the company has an anti-corruption policy, which prohibits all forms of corruption in all operations of the company. This includes bribery, facilitation payments and kickbacks.

References: Public: Company website: Ethics & Compliance ‘Airbus Group considers it its duty to combat all forms of corruption, public or private. These Policy and Rules govern all contractual arrangements entered into by the Airbus Group companies, in relation to any business or project partners or any associated third parties.’ ‘International Compliance - Zero tolerance to corruption At Airbus Group, we prohibit all forms of corruption, public or private. As such, a dedicated anti-corruption programme and organisation were put in place at an early stage under the leadership of the Group International Compliance Officer.’ ‘Airbus Group has established and regularly updated since 2001 an anti-corruption policy prohibiting all forms of corruption, whether public or private. The policy applies to all operations of Airbus Group, at any stage of the negotiation or execution of any kind of agreements or contract: e.g. commercial contracts, joint-venture partnership agreement related to any field of activity (e.g. product sales, offset arrangements, mergers & acquisitions projects, etc.). This policy applies wherever the Group carries out national and international business transactions, to all employees, Directors and Officers of the Airbus Group companies.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Standards of Business Conduct (January 2014), p.16: AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

‘Zero Tolerance of Corruption No Airbus Group employees may engage in any kind of corruption, whether public or private. We may never offer, attempt to offer, authorise or promise any sort of bribe, facilitation payment or kickback to a public official or private body for the purpose of obtaining or retaining business or an improper advantage. Likewise, we must never solicit or accept a bribe or kickback from a public official or private body. In addition, we must never hire someone else to do anything that we cannot ethically or legally do ourselves. We must apply our anti-corruption policies in the negotiation and execution of commercial contracts as well as to mergers and acquisitions and other projects.’ Corporate Responsibility & Sustainability Report 2013, p.14: ‘There are two foundation documents in the Airbus Group E&C Programme: the Standards of Business Conduct, which was revised in 2013, and Our Integrity Principles, a leaflet summarising the Group’s six key E&C commitments, rolled out Group-wide to each individual employee in 2013 by his/her manager.’ (p.17): ‘Airbus Group is committed to eliminating bribery and corruption risks.’

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A16: Is the anti-corruption policy explicitly one of zero tolerance? Score: 2 Comments: Based on public information, there is evidence that the company has an explicit zero tolerance policy of corruption, specifically in regard to bribery.

References: Public: Company website: Ethics & Compliance ‘Airbus Group considers it its duty to combat all forms of corruption, public or private. These Policy and Rules govern all contractual arrangements entered into by the Airbus Group companies, in relation to any business or project partners or any associated third parties.’ ‘International Compliance - Zero tolerance to corruption At Airbus Group, we prohibit all forms of corruption, public or private. As such, a dedicated anti-corruption programme and organisation were put in place at an early stage under the leadership of the Group International Compliance Officer.’ ‘Airbus Group has established and regularly updated since 2001 an anti-corruption policy prohibiting all forms of corruption, whether public or private. The policy applies to all operations of Airbus Group, at any stage of the negotiation or execution of any kind of agreements or contract: e.g. commercial contracts, joint-venture partnership agreement related to any field of activity (e.g. product sales, offset arrangements, mergers & acquisitions projects, etc.). This policy applies wherever the Group carries out national and international business transactions, to all employees, Directors and Officers of the Airbus Group companies.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Corporate Responsibility & Sustainability Report 2013, p.17: ‘Airbus Group is committed to eliminating bribery and corruption risks.’ AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

Standards of Business Conduct (January 2014), p.16: ‘Zero Tolerance of Corruption No Airbus Group employees may engage in any kind of corruption, whether public or private. We may never offer, attempt to offer, authorise or promise any sort of bribe, facilitation payment or kickback to a public official or privatebody for the purpose of obtaining or retaining business or an improper advantage. Likewise, we must never solicit or accept a bribe or kickback from a public official or private body.’

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A17: Is the company's anti-corruption policy easily accessible to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company? Score: 2 Comments: Based on public information, there is evidence that the company’s anti-corruption policy is easily accessible to Board members and employees. The Standards of Business Conduct are available online and on the company’s intranet portal in six different languages.

References: Public: Company website: Ethics & Compliance Standards of Business Conduct available in 6 languages (English, German, French, Spanish, Portuguese, Arabic) Our Integrity Principles available in 7 languages (English, Chinese, German, French, Spanish, Portuguese, Arabic) http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Standards of Business Conduct (January 2014), p.29: ‘The Standards of Business Conduct are available online at www.airbus-group.com Our Integrity Principles, Standards of Business Conduct and the policies they refer to are available on the Airbus Group intranet portal, myAirbus, under “Our Governance”. More information is also posted on myAirbus: • Ethics & Compliance resources • Procedures and guidelines • How to contact OpenLine • Questions and answers and learning aids’

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A17(a): Is the company’s anti-corruption policy easily understandable and clear to Board members, employees and third parties? Score: 2 Comments: Based on public information, there is evidence that the company’s anti-corruption policy is understandable and clear to Board members and employees. The anti-corruption section of the Standards of Business Conduct is written in simple language and provides definitions of the key forms of corruption.

References: Public: Company website: Ethics & Compliance ‘Employee Awareness Airbus Group acknowledges that the Standards of Business Conduct cannot address every challenging situation that may arise. To create a strong ‘speak up’ culture, the company encourages employees, through communication campaigns, to raise questions and concerns, helping them to identify the appropriate experts to consult and to make the right decisions. E-learning modules have also been developed at corporate level to raise employees’ awareness of the Standards of Business Conduct.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Standards of Business Conduct (January 2014), p.16: ‘Zero Tolerance of Corruption No Airbus Group employees may engage in any kind of corruption, whether public or private. We may never offer, attempt to offer, authorise or promise any sort of bribe, facilitation payment or kickback to a public official or private body for the purpose of obtaining or retaining business or an improper advantage. Likewise, we must never solicit or accept a bribe or kickback from a public official or private body. In addition, we must never hire someone else to do anything that we cannot ethically or legally do ourselves. We must apply our anti-corruption policies in the negotiation and AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

execution of commercial contracts as well as to mergers and acquisitions and other projects.’

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A18: Does the anti-corruption policy explicitly apply to all employees and members of the Board? Score: 2 Comments: Based on public information, there is evidence that the anti-corruption policy explicitly applies to all employees and Board members.

References: Public: Company website: Ethics & Compliance ‘International presence   

In 2013, the company enlarged the footprint of Ethics & Compliance representatives and they are now present in all functions and locations of our business. They are the voice and face of the Ethics & Compliance Programme. In 2013, the Company also extended the breadth of the Airbus Group Ethics & Compliance Programme by appointing Ethics & Compliance managers in four key countries: Brazil, Russia, India and Saudi Arabia. In 2014, China was also added to this list. The various country Ethics & Compliance Managers report to the ECO.’

‘There are 2 foundation documents in the Airbus Group Ethics & Compliance Programme: the ‘Standards of Business Conduct’, which was revised in 2013, and ‘Our Integrity Principles’, a leaflet summarising the Group’s 6 key Ethics & Compliance commitments, rolled out group-wide to each individual employee in 2013 by his/her manager.’ ‘We want to develop the Ethics & Compliance culture that permeates throughout the organisation, from top to bottom, to all of our businesses, everywhere we operate. We can leverage the strong commitment we have from our highest ranking executives. We reach out to all our employees in our communication and training campaigns. We encourage them to speak up and offer continuous support through various channels, such as the OpenLine.’ ‘Our anti-corruption policy: ‘zero tolerance’ to corruption AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

Airbus Group has established and regularly updated since 2001 an anti-corruption policy prohibiting all forms of corruption, whether public or private. The policy applies to all operations of Airbus Group, at any stage of the negotiation or execution of any kind of agreements or contract: e.g. commercial contracts, joint-venture partnership agreement related to any field of activity (e.g. product sales, offset arrangements, mergers & acquisitions projects, etc.). This policy applies wherever the Group carries out national and international business transactions, to all employees, Directors and Officers of the Airbus Group companies.’ Standards of Business Conduct (January 2014), p.2: ‘The Board of Directors endorsed the Standards of Business Conduct and requires the Airbus Group leadership team to lead by example with respect to adhering to the Integrity Principles and these Standards.’ (p.16): ‘Zero Tolerance of Corruption No Airbus Group employees may engage in any kind of corruption, whether public or private. We may never offer, attempt to offer, authorise or promise any sort of bribe, facilitation payment or kickback to a public official or private body for the purpose of obtaining or retaining business or an improper advantage. Likewise, we must never solicit or accept a bribe or kickback from a public official or private body. In addition, we must never hire someone else to do anything that we cannot ethically or legally do ourselves. We must apply our anti-corruption policies in the negotiation and execution of commercial contracts as well as to mergers and acquisitions and other projects.’ (p.26): ‘Our Integrity Principles and Standards of Business Conduct are applicable to all employees regardless of employment positions or geographical locations.’

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A20: Does the company have a policy on potential conflicts of interest, and does it apply to both employees and board members? Score: 1 Comments: Based on public information, there is evidence that the company has a minimal policy on potential conflicts of interest. It states that employees must avoid both actual and apparent conflicts of interest at all times, and includes a definition and example. However, the rules of the policy are unclear, which might make it hard for employees to implement. The company therefore scores 1. To score higher the company would need to provide evidence of further examples to help employees understand and implement the policy. TI notes the Directors’ Charter details a similar policy for Directors.

References: Public: Company website: Ethics & Compliance ‘Conflicts of Interest Guidelines Airbus Group's Conflicts of Interest Guideline stipulates that any employees acting on the company’s behalf must be free from conflict of interest or personal interests that could adversely influence their judgment, objectivity or loyalty to the company in conducting Airbus Group business activities and assignments.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Standards of Business Conduct (January 2014), p.18: ‘As part of our efforts to protect Airbus Group’ reputation and ensure we are acting on the basis of what is best for the Company, we must avoid both actual and apparent conflicts of interest at all times, and if we cannot avoid a conflict of interest, we must make it known to our supervisor. In particular, when hiring current and former public officials or government employees, we should comply with all applicable laws, regulations and directives, including those dealing with conflicts of interest. These rules extend to negotiations or contracts with government employees relating to potential employment by Airbus Group either on the payroll or as consultants or subcontractors.’ AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

‘What is a conflict of interest? A conflict of interest arises when our personal interests interfere, or appear to interfere, with our ability to perform our jobs without bias in the Group’s best interest. For example, a conflict might arise when an employee, family members, near relatives or personal friends have a significant undisclosed financial interest in a customer, supplier, partner or competitor of Airbus Group.’ Directors’ Charter (June 2014), pp.2-3: ‘Any conflict of interest or apparent conflict of interest between the Company and Directors is to be avoided. Each Director shall immediately report any such or potential conflict to the Chairman and shall provide him with all relevant information. Where conflicts nevertheless arise, the non-executives Directors shall be responsible for ensuring that in dealing with such conflicts Dutch law and the Dutch Corporate Governance Code and all other applicable laws, rules and regulations are complied with. A Director shall not take part in the deliberations or decision-making if he has a direct or indirect personal interest which conflicts with the interests of the Company and of the enterprise connected with it. Decisions to enter into transactions under which Directors would have conflicts of interest that are of material significance to the Company and/or to the relevant Director require the approval of the Board and are to be agreed on terms that are customary to the sector in which the Company operates its business.’ http://www.airbusgroup.com/dam/assets/airbusgroup/int/en/groupvision/governance/organisation/documents/Directors--Charter-of-the-BoD-of-AirbusGroup-N.V.-as-of-June-2-2014/Directors%20Charter%20of%20the%20BoD%20of%20Airbus%20Group%20N.V.%20as %20of%20June%202%2C%202014.pdf

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A21: Does the company have a policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery? Score: 1 Comments: Based on public information, there is evidence that the company has a policy for the giving and receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. However, tt is minimal in description, though employees are encouraged to record all gifts received. The company therefore scores 1. To score higher the company would need to provide evidence that it sets upper limits for gift exchange or has a requirement for senior management authorisation if a certain threshold is exceeded.

References: Public: Company website: Ethics & Compliance ‘Gifts and Hospitality Principles It is appropriate, in instances such as product demonstrations or promotional events, to give and receive reasonable and proportionate gifts and/or hospitality. However, these gifts or hospitality must always meet three conditions – compliance with law, business purpose and social acceptability. Airbus Group has adapted principles on gifts and hospitality in order to ensure that the giving or receiving of gifts and hospitality is managed ethically and consistently throughout the Airbus Group.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Standards of Business Conduct (January 2014), pp.17-18: ‘Business courtesies, such as gifts and hospitality, given to or received from customers, suppliers and other partners are commonly used to build goodwill and acknowledge appreciation in business relationships. However, these courtesies must reflect a normal courtesy of business and may not influence, or give the appearance of influencing, any business decision. Good judgment should always guide us in these situations. Business courtesies are prohibited by law under certain circumstances and in certain countries. We must each follow the policies that apply to us. Gifts of cash or cash equivalents, such as gift certificates and vouchers, are never permitted. In the interest of full transparency and to AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

facilitate possible audits or reviews, any giving or receiving of gifts or hospitality must be fully and accurately recorded.’

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A22: Does the company’s anti-corruption policy include a statement on the giving and receipt of hospitality that ensures that such transactions are bona fide and not a subterfuge for bribery? Score: 1 Comments: Based on public information, there is evidence that the company has a policy for the giving and receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. However, it is minimal in description, though employees are encouraged to record all hospitality received. The company therefore scores 1. To score higher the company would need to provide evidence that it sets upper limits for hospitality exchange or has a requirement for senior management authorisation if a certain threshold is exceeded.

References: Public: Company website: Ethics & Compliance ‘Gifts and Hospitality Principles It is appropriate, in instances such as product demonstrations or promotional events, to give and receive reasonable and proportionate gifts and/or hospitality. However, these gifts or hospitality must always meet three conditions – compliance with law, business purpose and social acceptability. Airbus Group has adapted principles on gifts and hospitality in order to ensure that the giving or receiving of gifts and hospitality is managed ethically and consistently throughout the Airbus Group.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Standards of Business Conduct (January 2014), pp.17-18: ‘Business courtesies, such as gifts and hospitality, given to or received from customers, suppliers and other partners are commonly used to build goodwill and acknowledge appreciation in business relationships. However, these courtesies must reflect a normal courtesy of business and may not influence, or give the appearance of influencing, any business decision. Good judgment should always guide us in these situations. Business courtesies are prohibited by law under certain circumstances and in certain countries. We AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

must each follow the policies that apply to us. Gifts of cash or cash equivalents, such as gift certificates and vouchers, are never permitted. In the interest of full transparency and to facilitate possible audits or reviews, any giving or receiving of gifts or hospitality must be fully and accurately recorded.’

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A23: Does the company have a policy that explicitly prohibits facilitation payments? Score: 2 Comments: Based on public information, there is evidence that the company has a policy that explicitly prohibits facilitation payments. Although the company provides minimal supplementary information on how the policy is to be implemented in practice, a detailed definition of facilitation payments is provided and examples of the circumstances under which employees might be asked to engage in them are outlined.

References: Public: Standards of Business Conduct (January 2014), p.16: ‘We may never offer, attempt to offer, authorise or promise any sort of bribe, facilitation payment or kickback to a public official or private body for the purpose of obtaining or retaining business or an improper advantage. Likewise, we must never solicit or accept a bribe or kickback from a public official or private body.’ (p.17): ‘What are facilitation payments? Small unofficial payments to low-level public officials to speed up or obtain routine administrative processes.’ Airbus Group Business Ethics Policy Processes & Guidelines – Main Principles (January 2014), p.1: ‘Facilitation Payments Small unofficial payments to low level foreign Public Officials to speed up or obtain routine administrative processes, such as obtaining permits, licenses, or other official documents, processing governmental papers, such as visas and work orders, providing police protection, mail pick-up and delivery, providing phone service, power and water supply, loading and unloading cargo, or protecting perishable products; and scheduling inspections associated with contract performance or transit of goods across country.’

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(p.2): ‘Facilitation Payments are not allowed’

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A24: Does the company prohibit political contributions, or regulate such contributions in order to prevent undue influence or other corrupt intent? Does the company record and publicly disclose all political contributions? Score: 1 Comments: Based on public information, there is evidence that the company’s political contributions are regulated. However, there is a lack of information explaining the policy, as only one short sentence in the Standards of Business Conduct document states that the company has such regulations. The company therefore scores 1. To score higher the company would need to provide information on the application of the regulations and publically declare the recipients of contributions.

References: Public: Standards of Business Conduct (January 2014), p.24: ‘Corporate donations to public-interest or private organisations may be permitted if not limited or forbidden by local law. Political contributions must always be reviewed and approved according to the relevant internal policies and applicable laws and regulations. Key Airbus Group Documents to Reference: - Sponsoring Guidelines - Donation Guidelines’ Company website: Ethics & Compliance ‘Sponsoring and donations guidelines At Airbus Group, all sponsoring and donation projects must strictly comply with the Airbus Group Standards of Business Conduct, as well as with all applicable national laws and regulations. The guidelines help to reach a coherent and transparent approach for sponsoring and donation activities throughout the Airbus Group.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A25: Does the company have a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, and discloses the issues on which the company lobbies? Score: 0 Comments: Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities.

References: Public: NA

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A25(a): Does the company prohibit charitable contributions, or regulate such contributions in order to prevent undue influence or other corrupt intent? Score: 0 Comments: Based on public information, there is some evidence that the company regulates charitable contributions. The company’s Corporate Responsibility & Sustainability Report 2013 states that the Airbus Group operates three charitable foundations, including the Airbus Group Corporate Foundation. TI assumes that as part of the foundations’ mandates there are controls in place to prevent undue influence or other corrupt intent. However, as these controls, in addition to the recipients of the contributions, are not made clear the company is unable to score on this question.

References: Public: TI notes: Company website: Ethics & Compliance ‘Sponsoring and Donations Guidelines At Airbus Group, all sponsoring and donation projects must strictly comply with the Airbus Group Standards of Business Conduct, as well as with all applicable national laws and regulations. The guidelines help to reach a coherent and transparent approach for sponsoring and donation activities throughout the Airbus Group.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Airbus Foundation website http://fondation.airbus-group.com/content/en/ Company website: Sponsorship Airbus sponsors museums and sports teams http://www.airbusgroup.com/int/en/group-vision/sponsorships.html

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Corporate Responsibility & Sustainability Report 2013, p.50: ‘The Group operates three charitable foundations – the Airbus Group Corporate Foundation, Airbus Corporate Foundation and Airbus Helicopters Corporate Foundation – which are separate legal entities, with their own governance, personnel and projects. Additionally, its employees support charitable causes at grass roots level.’ (p.51): Airbus Group Corporate Foundation (AGF) has a budget of 26 million euros over 5 years. Airbus Corporate Foundation (ACF) has a budget of 4.9 million euros over 5 years. Airbus Helicopters Corporate Foundation (AHF) has a budget of 2 million euros over 5 years.

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A26: Does the company provide written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda? Score: 0 Comments: Based on public information, there is no readily available evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda. The section on ethics and anticorruption in the Standards of Business Conduct is short, but provides definitions of the key forms of corruption. The Our Integrity Principles document only lists the ethical principles of the company. To score higher the company would need to provide written guidance that contains scenarios to ensure that any areas of uncertainty are fully explained.

References: Public: TI notes: Company website: Ethics & Compliance ‘Employee awareness Airbus Group acknowledges that the Standards of Business Conduct cannot address every challenging situation that may arise. To create a strong ‘speak up’ culture, the company encourages employees, through communication campaigns, to raise questions and concerns, helping them to identify the appropriate experts to consult and to make the right decisions. E-learning modules have also been developed at corporate level to raise employees’ awareness of the Standards of Business Conduct.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Standards of Business Conduct (January 2014), pp.16-17: Definitions are provided for key terms, eg bribery, public official, facilitation payment (p.29): ‘The Standards of Business Conduct are available online at www.airbus-group.com Our Integrity Principles, Standards of Business Conduct and the policies they refer to are AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

available on the Airbus Group intranet portal, myAirbus, under “Our Governance”. More information is also posted on myAirbus: • Ethics & Compliance resources • Procedures and guidelines • How to contact OpenLine • Questions and answers and learning aids’ Annual Review 2013, p.55: ‘Integrity in practice While fostering a culture of high performance, Airbus Group's top management emphasises that it is not only results that matter, but the way they are achieved. Integrity is considered a paramount value in the Group. In 2013, the “Standards of Business Conduct” were updated and implemented across the Group. In addition a company-wide document “Our Integrity Principles”, outlining the Group’s key integrity commitments in a simple userfriendly format was rolled out across the Group and explained by managers to each individual employee in team meetings. Airbus Group is committed to building a culture of integrity by providing employees with the right tools and role-modelling the right behaviour.’ Our Integrity Principles (February 2014): Provides the ethical principles of the company.

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A27: Does the company have a training programme that explicitly covers anticorruption? Score: 2 Comments: Based on public information, there is evidence that the company has an explicit anticorruption module as part of its ethics and compliance training programme. In 2013, 9,447 anti-corruption training sessions were carried out.

References: Public: Company website: Ethics & Compliance ‘75,000 training sessions on Ethics & Compliance matters were delivered to Airbus Group Employees in 2013. Airbus Group employees' support in bringing the Standards of Business Conduct to life is vital. That is why communication and training activities are critical components. We implement our own communication and training strategy concerning Ethics & Compliance. Surveys enable us to assess our achievement in this area.’

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

‘Employee Awareness Airbus Group acknowledges that the Standards of Business Conduct cannot address every challenging situation that may arise. To create a strong ‘speak up’ culture, the company encourages employees, through communication campaigns, to raise questions and concerns, helping them to identify the appropriate experts to consult and to make the right decisions. E-learning modules have also been developed at corporate level to raise employees’ awareness of the Standards of Business Conduct. Targeted populations Specific departments, e.g. Mergers & Acquisitions, Marketing & Sales, Finance & Controlling, Procurement, Airbus Group programmes and Human Resources receive periodic and specific training courses conducted by the compliance specialists in these areas. These include experts for export compliance, business international compliance, procurement compliance and data protection compliance.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A28: Is anti-corruption training provided in all countries where the company operates or has company sites? Score: 2 Comments: Based on public information, there is evidence that ethics and compliance training is provided in all countries where the company operates.

References: Public: Company website: Ethics & Compliance ‘75,000 training sessions on Ethics & Compliance matters were delivered to Airbus Group Employees in 2013. Airbus Group employees' support in bringing the Standards of Business Conduct to life is vital. That is why communication and training activities are critical components. We implement our own communication and training strategy concerning Ethics & Compliance. Surveys enable us to assess our achievement in this area.’

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

‘Employee Awareness Airbus Group acknowledges that the Standards of Business Conduct cannot address every challenging situation that may arise. To create a strong ‘speak up’ culture, the company encourages employees, through communication campaigns, to raise questions and concerns, helping them to identify the appropriate experts to consult and to make the right decisions. E-learning modules have also been developed at corporate level to raise employees’ awareness of the Standards of Business Conduct. Targeted populations Specific departments, e.g. Mergers & Acquisitions, Marketing & Sales, Finance & Controlling, Procurement, Airbus Group programmes and Human Resources receive periodic and specific training courses conducted by the compliance specialists in these areas. These include experts for export compliance, business international compliance, procurement compliance and data protection compliance.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Corporate Responsibility & Sustainability Report 2013, p.14: ‘In 2013, the Company also extended the breadth of the E&C Programme, by appointing E&C managers in four key Countries: Brazil, Russia, India, and Saudi Arabia. Furthermore, an E&C manager will be hired in China in 2014.’ (p.17): ‘The Group ICO initiates and defines training modules for all employees of the Group adapted to the level of risk they potentially face. The Group ICO performs training at Group level. Division ICOs customise and perform training at Division level, as do International Compliance Officers at subsidiary level. In 2013, there were more than 9,000 training sessions specifically for raising awareness on bribery and corruption.’ AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A29: Does the company provide targeted anti-corruption training to members of the Board? Score: 0 Comments: Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board.

References: Public: NA

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A30: Does the company provide tailored ethics and anti-corruption training for employees in sensitive positions? Score: 2 Comments: Based on public information, there is evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions. This includes specific departments such as Procurement and Marketing, and the training is conducted by compliance specialists in their areas.

References: Public: Company website: Ethics & Compliance ‘75,000 training sessions on Ethics & Compliance matters were delivered to Airbus Group Employees in 2013. Airbus Group employees' support in bringing the Standards of Business Conduct to life is vital. That is why communication and training activities are critical components. We implement our own communication and training strategy concerning Ethics & Compliance. Surveys enable us to assess our achievement in this area.’

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

‘Employee Awareness Airbus Group acknowledges that the Standards of Business Conduct cannot address every challenging situation that may arise. To create a strong ‘speak up’ culture, the company encourages employees, through communication campaigns, to raise questions and concerns, helping them to identify the appropriate experts to consult and to make the right decisions. E-learning modules have also been developed at corporate level to raise employees’ awareness of the Standards of Business Conduct. Targeted populations Specific departments, e.g. Mergers & Acquisitions, Marketing & Sales, Finance & Controlling, Procurement, Airbus Group programmes and Human Resources receive periodic and specific training courses conducted by the compliance specialists in these areas. These include experts for export compliance, business international compliance, procurement compliance and data protection compliance.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Corporate Responsibility & Sustainability Report 2013, p.14: ‘In 2013, the Company also extended the breadth of the E&C Programme, by appointing E&C managers in four key Countries: Brazil, Russia, India, and Saudi Arabia. Furthermore, an E&C manager will be hired in China in 2014.’ (p.17): ‘The Group ICO initiates and defines training modules for all employees of the Group adapted to the level of risk they potentially face. The Group ICO performs training at Group level. Division ICOs customise and perform training at Division level, as do International Compliance Officers at subsidiary level. In 2013, there were more than 9,000 training sessions specifically for raising awareness on bribery and corruption.’ AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A31: Does the company have a clear and formal process by which employees declare conflicts of interest? Score: 0 Comments: Based on public information, there is no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest. The Standards of Business Conduct document only states that employees should make it known to a supervisor if they cannot avoid a conflict of interest. To score on this question the company would need to provide evidence, that employees are instructed to declare conflicts of interest to a manager in writing or to an independent department.

References: Public: TI notes: Company website: Ethics & Compliance ‘Conflicts of Interest Guideline Airbus Group's Conflicts of Interest Guideline stipulates that any employees acting on the company’s behalf must be free from conflict of interest or personal interests that could adversely influence their judgment, objectivity or loyalty to the company in conducting Airbus Group business activities and assignments’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Standards of Business Conduct (January 2014), p.18: ‘As part of our efforts to protect Airbus Group’ reputation and ensure we are acting on the basis of what is best for the Company, we must avoid both actual and apparent conflicts of interest at all times, and if we cannot avoid a conflict of interest, we must make it known to our supervisor. In particular, when hiring current and former public officials or government employees, we should comply with all applicable laws, regulations and directives, including those dealing with conflicts of interest. These rules extend to negotiations or contracts with government employees relating to potential employment by Airbus Group either on the payroll or as consultants or subcontractors.’ AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

‘What is a conflict of interest? A conflict of interest arises when our personal interests interfere, or appear to interfere, with our ability to perform our jobs without bias in the Group’s best interest. For example, a conflict might arise when an employee, family members, near relatives or personal friends have a significant undisclosed financial interest in a customer, supplier, partner or competitor of Airbus Group.’ Directors’ Charter (June 2014), pp.2-3: ‘Any conflict of interest or apparent conflict of interest between the Company and Directors is to be avoided. Each Director shall immediately report any such or potential conflict to the Chairman and shall provide him with all relevant information. Where conflicts nevertheless arise, the non-executives Directors shall be responsible for ensuring that in dealing with such conflicts Dutch law and the Dutch Corporate Governance Code and all other applicable laws, rules and regulations are complied with. A Director shall not take part in the deliberations or decision-making if he has a direct or indirect personal interest which conflicts with the interests of the Company and of the enterprise connected with it. Decisions to enter into transactions under which Directors would have conflicts of interest that are of material significance to the Company and/or to the relevant Director require the approval of the Board and are to be agreed on terms that are customary to the sector in which the Company operates its business.’

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A32: Is the company explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities? Score: 0 Comments: Based on public information, there is no readily available evidence that the company has an explicit commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities.

References: Public: NA

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A33: Does the company have multiple, well-publicised channels that are easily accessible and secure, to guarantee confidentiality or anonymity where requested by the employee (e.g. web, phone, in person), to report concerns or instances of suspected corrupt activity? Score: 2 Comments: Based on public information, there is evidence that employees can report concerns or instances of suspected corrupt activity using multiple, well-publicised channels. Employees are encouraged to report any issues or concerns using normal business channels, such as a manager, a Human Resources Business Partner (HRBP) or an Ethics and Compliance representative. The company also provides the OpenLine alert system. The OpenLine is operated by an external provider and employees must declare their indentity on the understanding it will be kept confidential by the external operator. The contact details of all Chief Compliance Officers in Airbus Group and the OpenLine are provided in the Our Integrity Principles document.

References: Public: Company website: Ethics & Compliance ‘We strive to support all our employees in the many countries we operate, which is why a worldwide network of Ethics and Compliance representatives and officers has been set up throughout Airbus Group. Ethics and Compliance representatives are employees trained by the Compliance Office, who spend a part of their work time on Ethics and Compliance matters. Employees can ask them for advice and support, while the representatives convey important information and guidelines about Ethics and Compliance risks for their Division.’ ‘The OpenLine alert system is available at all times to all Airbus Group employees. The OpenLine enables employees to confidentially raise their concerns via the internet or by phone. Already available in Europe, it is continuously being expanded to new countries, such as Brazil and Australia.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html OpenLine website: Home AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

Available in 5 different languages. https://www.airbusgroupopenline.com/default OpenLine website: Make a report ‘Your identity will also be kept confidential and will not be passed on to the Airbus Group Group Ethics and Compliance Officer unless: -legal proceedings require disclosure -you accept disclosure on your own volition, or -you intentionally misused the OpenLine by not acting in good faith.’ https://www.airbusgroupopenline.com/MakeReport OpenLine website: Tutorial Tutorial only available in English ; French, German and spanish ‘Coming soon’. The english mode does include audio. https://www.airbusgroupopenline.com/Tutorial/index.htm# OpenLine website: Ask a question Provides contact details if an employee has questions about OpenLine https://www.airbusgroupopenline.com/AskQuestion Standards of Business Conduct (January 2014), p.26: ‘Because the right answer is not always obvious, all employees are strongly encouraged to openly communicate and to clarify their questions or concerns. It is equally important that all managers build a positive working environment and that they encourage their employees to openly communicate. Employees can approach any member of the Ethics & Compliance Team to clarify an ethical issue. A list of Ethics & Compliance Team members can be found on the Ethics & Compliance corner of myAirbus or on Divisional intranets. All Employees are strongly encouraged to report their concerns through the normal business channels, such as your manager, your Human Resources Business Partner (HRBP), or your Ethics & Compliance Team.’ ‘OpenLine is also available for use by all Employees. It is operated by an external provider. The use of OpenLine is entirely voluntary, and conditions for use are available on the Group intranet and communicated broadly within Airbus Group. An inquiry or concern can be submitted confidentially without fear of retaliation.’ Our Integrity Principles (February 2014), p.1: Provides the contact details of all Chief Compliance Officers in Airbus Group and its different divisions. Also lists the OpenLine contact details

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

EADS OpenLine Policy (January 2013), p.1: ‘All EADS Group employees are strongly encouraged to report their concerns through the normal business channels such as, immediate supervisors, ethics and compliance personnel, human resources representatives, members of the legal department, or senior management representatives. The OpenLine is a supplementary and exceptional process through which an employee may raise concerns if for any reason that employee is uncomfortable with using the normal business channels or with the answers that he has received from them. The system is available for use by all EADS Group employees.’ ‘To enhance the confidentiality of the system, and since the system is not anonymous, EADS has chosen to outsource the management of the telephone line and the web-site that will receive the alerts and has contracted a specialist external service provider, “Deloitte & Touche Investments (Proprietary) Limited”, located outside the European Union, in South Africa. Alerts will be handled in a secure environment by a restricted number of the external service provider’s professionally trained personnel.’ (p.2): ‘Users of the alert system will be required to identify themselves to the service provider. The service provider will transmit the concern without disclosing the identity of the person who raised it. However, users may request that their identity can be transmitted to EADS. If that is the case, EADS will make all possible efforts to protect the identity of the person making the alert. All reports will be kept confidential, to the extent possible, consistent with the need to conduct a thorough and effective investigation, or as required by law or court proceedings.’

(p.3): ‘Alerts will be received by the external service provider and reports will be prepared for communication to the CCO. The reports will include only objectively presented information that is in direct relation to the permissible scope of the alert system and strictly necessary for the verification of the alleged facts. All reports provided to the CCO will eliminate any element that would identify the employee. However, the identity of an employee will be provided to the CCO if one of the following conditions is met: (1) The employee has previously given his/her verbal consent to the external service provider to communicate his/her identity to EADS. (2) EADS provides written evidence to the external service provider of legal proceedings that require the communication of the identity of the employee. (3) EADS substantiates to the external service provider that the allegations are malicious.’

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(p.5): ‘An EADS employee can get in contact with the OpenLine: - Connecting to the EADS OpenLine website: www.eadsopenline.com - Calling the following numbers France, Germany, Spain, UK: 00 800 27 00 00 07 Australia: 18 00 24 91 39 Brazil: 080 08 91 87 15 Canada: 18 55 22 53 002 For French, German, Spanish and Portuguese an operator is available from 07:00 to 16:00 (CET)2, with an automatic voice messaging outside working hours. The OpenLine is operated in English 24/7. Requests for further information should be referred to the CCO: Mr. Pedro Montoya Group Chief Compliance Officer EADS 37, Boulevard de Montmorency 75016 Paris (France)’ https://www.airbusgroupopenline.com/Documents/OpenLine_Policy/OpenLine_Policy_28_ January_2013_en.pdf

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A33(a): Are the whistleblowing channels available to all employees in all geographies? Score: 2 Comments: Based on public information, there is evidence that whistleblowing channels are available to all employees, in all geographies. Employees are encouraged to report any issues or concerns using the normal business channels such as a Human Resources Business Partner (HRBP) or an Ethics and Complaince representative. The Ethics and Compliance respresentatives network is worldwide. Employees are also able to report issues or concerns to the OpenLine. However, TI notes that the current availability of the OpenLine is unclear. In some documents the company claims it is available to all Airbus Group employees, but in others it states that it is continuously being expanded to new countries, with China, Mexico and Saudi Arabia set to receive the system in 2014.

References: Public: Company website: Ethics & Compliance ‘We reach out to all our employees in our communication and training campaigns. We encourage them to speak up and offer continuous support through various channels, such as the OpenLine.’ ‘We strive to support all our employees in the many countries we operate, which is why a worldwide network of Ethics and Compliance representatives and officers has been set up throughout Airbus Group. Ethics and Compliance representatives are employees trained by the Compliance Office, who spend a part of their work time on Ethics and Compliance matters. Employees can ask them for advice and support, while the representatives convey important information and guidelines about Ethics and Compliance risks for their Division.’ ‘The OpenLine alert system is available at all times to all Airbus Group employees. The OpenLine enables employees to confidentially raise their concerns via the internet or by phone. Already available in Europe, it is continuously being expanded to new countries, such as Brazil and Australia.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

Standards of Business Conduct (Janaury 2014), p.26: ‘OpenLine is also available for use by all Employees. It is operated by an external provider. The use of OpenLine is entirely voluntary, and conditions for use are available on the Group intranet and communicated broadly within Airbus Group. An inquiry or concern can be submitted confidentially without fear of retaliation.’ Our Integrity Principles (February 2014), p.1: Provides the contact details of all Chief Compliance Officers in Airbus Group and its different divisions. Also lists the OpenLine contact details EADS OpenLine Policy (January 2013), p.3: ‘The use of the OpenLine is limited to employees of all companies controlled by the EADS Group and located in France, Germany, Spain, UK, Brazil, Australia, and Canada.’ Corporate Responsibility & Sustainability Report 2013, p.15: ‘The OpenLine system for employees to report compliance concerns confidentially was extended beyond the European home countries, Brazil and Australia, to include Russia and Saudi Arabia. The system gives employees a way to report concerns relating to accounting, finance, corruption, anti-competitive practices, conflicts of interest, harassment, disclosure of confidential information and product safety. In 2014, it will be extended to include China.’ Registration Document 2013, p.137: ‘Subject to local legal restrictions, OpenLine is available to employees of controlled entities in France, Germany, Spain and the UK. In 2013, it was extended to Australia, Brazil and Canada. It will be extended to China, Mexico and Saudi Arabia in 2014.’

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A33(b): Does the company have formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively? Score: 1 Comments: Based on public information, there is some evidence that the company has mechanisms to assure itself that whistleblowing by employees is not deterred and that whistleblowers are treated supportively. The company encourages employees to raise questions and concerns via communication campaigns, and managers receive training on the benefits of ethical and compliant behaviours. The company therefore scores 1. To score higher the company would need to provide evidence of detailed analysis of whistleblowing data, such as whistleblowing channel usage statistics, or independent employee surveys.

References: Public: Company website: Ethics & Compliance ‘We reach out to all our employees in our communication and training campaigns. We encourage them to speak up and offer continuous support through various channels, such as the OpenLine.’ ‘Airbus Group acknowledges that the Standards of Business Conduct cannot address every challenging situation that may arise. To create a strong ‘speak up’ culture, the company encourages employees, through communication campaigns, to raise questions and concerns, helping them to identify the appropriate experts to consult and to make the right decisions. E-learning modules have also been developed at corporate level to raise employees’ awareness of the Standards of Business Conduct.’ ‘Empowerment of Airbus Group managers in the promotion of Ethics & Compliance is critical to the success of such a programme. Furthermore, the relationship of trust between Airbus Group's employees and managers is the cornerstone of a successful ‘speak up’ culture. This is why, as part of our internal management development programmes, Airbus Group aims at raising all managers’ awareness on the benefits of ethical and compliant behaviours. In addition, they have Ethics & Compliance annual objectives that cover training AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

needs and communication requirements to their teams.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html EADS OpenLine Policy (January 2013), p.3: ‘Retaliation by any employee of the company, and/or by the company itself, directly or indirectly, against any person who, in good faith, submits an alert or provides assistance to those responsible for investigating the allegations will not be tolerated. Nor will any harassment against an employee or adverse employment consequences as a result of the submission in good faith of an alert be permitted.’

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A34: Does the company have well-publicised resources available to all employees where help and advice can be sought on corruption-related issues? Score: 2 Comments: Based on public information, there is evidence that the company has well-publicised resources available to all employees, where help and advice can be sought on corruptionrelated issues. This includes trained managers, a worldwide network of Ethics and Compliance representatives and the OpenLine alert system. The contact details of all Chief Compliance Officers in Airbus Group and the OpenLine are provided in the Our Integrity Principles document.

References: Public: Company website: Ethics & Compliance ‘Airbus Group acknowledges that the Standards of Business Conduct cannot address every challenging situation that may arise. To create a strong ‘speak up’ culture, the company encourages employees, through communication campaigns, to raise questions and concerns, helping them to identify the appropriate experts to consult and to make the right decisions. E-learning modules have also been developed at corporate level to raise employees’ awareness of the Standards of Business Conduct.’ ‘Thanks to the Airbus Group OpenLine and a strong network, we support our employees when dealing with Ethics and Compliance matters. We strive to support all our employees in the many countries we operate, which is why a worldwide network of Ethics and Compliance representatives and officers has been set up throughout Airbus Group. Ethics and Compliance representatives are employees trained by the Compliance Office, who spend a part of their work time on Ethics and Compliance matters. Employees can ask them for advice and support, while the representatives convey important information and guidelines about Ethics and Compliance risks for their Division.’ ‘The OpenLine alert system is available at all times to all Airbus Group employees. The OpenLine enables employees to confidentially raise their concerns via the internet or by AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

phone. Already available in Europe, it is continuously being expanded to new countries, such as Brazil and Australia.’ ‘Anti-corruption programme Airbus Group has organised a risk-based, centralised network of experts in anti-corruption headed up by the Group International Compliance officer. Employees of the Group have direct access to them and may ask questions or request the assistance of those experts either in the Airbus Group company where they belong or at Division/Group level. The main points of contacts for anti-corruption issues are given in Our Integrity Principles.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Standards of Business Conduct (January 2014), pp.26-27: Informs employees who to contact and provides contact details of the OpenLine and the Group Compliance Officer. Our Integrity Principles (February 2014), p.1: Provides the contact details of all Chief Compliance Officers in Airbus Group and its different divisions. Also lists the OpenLine contact details.

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

A35: Is there a commitment to non-retaliation for bona fide reporting of corruption? Score: 1 Comments: Based on public information, there is evidence that the company has a commitment to nonretaliation for bona fide reporting of corruption. However, there is no evidence that disciplinary measures are applied to employees who breach this policy. The company therefore scores 1.

References: Public: Company website: Ethics & Compliance ‘Airbus Group does not tolerate retaliation against employees making reports in good faith and/or assisting in investigations of suspected violations of the Standards of Business Conduct.’ http://www.airbusgroup.com/int/en/group-vision/ethics-compliance.html Standards of Business Conduct (January 2014), p.9: ‘Any direct or indirect retaliation, or attempted retaliation, against an employee who speaks up in good faith is strictly prohibited and will not be tolerated.’ EADS OpenLine Policy (January 2013), p.3: ‘Retaliation by any employee of the company, and/or by the company itself, directly or indirectly, against any person who, in good faith, submits an alert or provides assistance to those responsible for investigating the allegations will not be tolerated. Nor will any harassment against an employee or adverse employment consequences as a result of the submission in good faith of an alert be permitted.’

AIRBUS GROUP 18/11/14 WWW.AIRBUSGROUP.COM

Information Sources: Company website: www.airbusgroup.com Airbus Group Business Ethics Policy Processes & Guidelines – Main Principles (January 2014): http://www.airbusgroup.com/dam/assets/airbusgroup/int/en/groupvision/ethics-compliance/documents/2014-01---Airbus-Group-BusinessEthics-Policy-main-principles-version-intranet/2014%2001%20%20Airbus%20Group%20Business%20Ethics%20Policy%20main%20principles %20version%20intranet.pdf Annual Review 2013: http://www.airbusgroup.com/dam/assets/airbusgroup/int/en/groupvision/business-suppliers/Airbus_Group_Annual_Review_2013.pdf Corporate Responsibility & Sustainability Report 2013: http://www.airbusgroup.com/dam/assets/airbusgroup/int/en/groupvision/responsibility-sustainability/documents/AIRBUS_GROUP_CRS_2013/AIRBUSGROUP_CRS_2013.pdf Directors’ Charter (June 2014): http://www.airbusgroup.com/dam/assets/airbusgroup/int/en/groupvision/governance/organisation/documents/Directors--Charter-of-the-BoDof-Airbus-Group-N.V.-as-of-June-2-2014/Directors%20Charter%20of%20the%20BoD%20of%20Airbus%20Group %20N.V.%20as%20of%20June%202%2C%202014.pdf EADS Corporate Social Responsibility In Sourcing (October 2010): http://www.airbusgroup.com/dam/assets/airbusgroup/int/en/groupvision/business-suppliers/suppliers/linklist-1/05_CSRAnnex/05_CSR%20Annex.pdf

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EADS OpenLine Policy (January 2013): https://www.airbusgroupopenline.com/Documents/OpenLine_Policy/OpenL ine_Policy_28_January_2013_en.pdf Growing Together (October 2010): http://www.airbusgroup.com/dam/assets/airbusgroup/int/en/groupvision/business-suppliers/suppliers/linklist-1/EADS-Supplier-Code-ofConduct_GROWINGTOGETHER/EADS%20Supplier%20Code%20of%20Conduct_GROWING%20TO GETHER.pdf Our Integrity Principles (February 2014): http://www.airbusgroup.com/dam/assets/airbusgroup/int/en/groupvision/ethicscompliance/documents/Brochure_Code_of_Ethics_Airbusgroup_EN--2/Brochure_Code_of_Ethics_Airbusgroup_EN%20%282%29.pdf Registration Document 2012: http://www.airbusgroup.com/dam/assets/airbusgroup/int/en/investorrelations/documents/2013/AGM--annual-report/EADS-RegistrationDocument-2012/EADS%20Registration%20Document%202012.pdf Registration Document 2013: http://www.airbus-group.com/dms/airbusgroup/int/en/investorrelations/documents/2014/AGM-Annual-Report--BV/airbuseads_rd_ev_webversion_090414/EADS%20Registration%20Document%2020 13.pdf Standards of Business Conduct (January 2014): http://www.airbusgroup.com/dam/assets/airbusgroup/int/en/groupvision/ethics-compliance/documents/Standards_Airbusgroup_EN.pdf

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