Ethics & Compliance

Integrity is one of the five values of MBDA.

At MBDA, acting with integrity means acting in accordance with the company’s Code of Ethics. Our Code of Ethics aims to establish integrity in the conduct of our activities, in our relations with people, and in our environmental impacts. This is why MBDA is committed to comply with the law and applies the highest ethical standards in all the countries where it operates, as stated in its Code of Ethics. Our Code of Ethics asks us to obey the law and goes beyond the law, in the pursuit of what we think is right balancing the interests of the Business, the People, and the Planet.

This is why we act and decide using a double test: is it ethical and is it legal?

The Code of Ethics which is our foundation document was approved by MBDA Executive Committee. It is implemented by detailed policies and procedures, both at Group and National level which are approved by the CEO Office.

The Code and related policies and procedures are regularly updated.

They are mandatory to all MBDA entities and employees, directors and officers, regardless of location or role and apply also to our majority JVs.

 

Code of Ethics

As the corner stone of MBDA’s commitment to integrity, the MBDA Code of Ethics clearly sets forth the ethical principles that every employee, director and officer in the Group must follow.

The three general principles of the Code are as follows: compliance with laws and regulations; commitment to integrity; and seeking guidance and reporting concerns. These principles have been developed around four themes which are:

  • Business relationships
  • Our people
  • Protecting assets and information
  • Corporate Responsiblity

The MBDA Code of Ethics is available to each Group employee, director, and officer in her/his native language.

The Code of Ethics is a document that we refer to frequently in our Company not only at initial employee on-boarding. It is becoming a component of our company culture, driven by the management, in order to develop our culture of integrity among our internal and external stakeholders.

Our Code of Ethics cannot cover every diverse situation that employees may find themselves in. This is why we encourage our employees to ask questions to their line manager, another member of the management team, the Human Resources department, the Legal department or one of our ECR Officers.

We also recognise that, although we thrive to abide by our Code of Ethics, it is possible that one day, somewhere, one MBDA employee, director or officer, or one client or supplier do not act in accordance with our Code. Should this happen, we would like to know because we are committed to condemn the violation and remediate the situation.

We thrive for total quality in our products and the same standard of total quality applies in Ethics & Compliance. We want to do it right and to do it right the first time.

This is why we encourage speaking up on Ethics & Compliance. We believe that reporting near-misses or incidents in Ethics & Compliance is the same as reporting near-misses or incidents in Health and Safety or Quality.

If an employee, director or officer has reason to believe that a violation of the Code has occurred we encourage her/him to speak-up and report the alleged violation. Likewise, if any of our external stakeholders has reason to believe that our Code has been violated, we encourage reporting.

We offer several channels for speaking-up as we believe one should have the choice to use whatever channel one is more comfortable with: line manager or another member of the management team, the Human Resources department, the Legal department or an Ethics, Compliance and Responsibility Officer.

Reporters can also use our whistle-blowing line which comes in the form of an email that goes to the VP Human Resources and the Group General Counsel. The email address is report-allegations@mbda-systems.com. The identity of the person using the whistle-blowing line is kept confidential.

Irrespective of the channel of speaking-up that was used by the reporter, all reports are treated seriously and fairly as per our Allegation Policy and good-faith reporters and witnesses are protected by an anti-retaliation principle.

Anti-Corruption Compliance

MBDA is engaged in the fight against corruption because corruption hinders economic growth, diverts tax revenues, stales democracy, destroys trust and ruins equality.  We therefore prohibit any kind of corruption, whether public or private, direct or indirect, passive or active, including facilitation payments.

Our program addresses both hard and soft corruption risks, upstream in the supply chain and downstream in the sales function, covering all forms and shapes of corruption from bribes in money to improper sponsorship and donations, inadequate gifts and hospitality, or conflicts of interest, via ghost employees or partners and disguised transactions. We perform anti-corruption checks on all our third parties from suppliers to business partners.

Here is how our anti-corruption program works:

Our program is designed at Group level and deployed in our different countries and legal entities worldwide. Our program is classical in nature: identification and control of the risks; drafting and implementation of adequate policies and procedures; communication and training actions, detection and remediation.