Our Ethics and Compliance

Integrity is a core value of MBDA

At MBDA, acting with integrity means acting in accordance with the Company’s Code of Ethics and the law. Our Code of Ethics aims at upholding integrity in the conduct of our activities. MBDA is committed to comply with the law and applies the highest ethical standards in all the countries in which we operate. Our Code of Ethics requires us to obey the law and goes beyond, in the pursuit of what is right. 

Given our role as a trusted part of the defence community, we are committed to fight corruption and are holding a principle of zero tolerance. MBDA has designed and implemented an anti-corruption programme addressing the risk it faces and has developed associated control processes.

Training courses and awareness activities on ethics and anti-corruption are carried out to ensure all our employees have the level of knowledge and competencies inherent to their role. An internal reporting channel is available to raise a concern by placing an anonymous report in absolute confidence.

MBDA is committed to act as an industry benchmark for ethical standard. MBDA is a member of the Aerospace, Security and Defence Industries Association of Europe (ASD) and of the International Forum on Business Ethical Conduct (IFBEC). MBDA is ISO 37001 certified.

The Code of Ethics serves as a tool to help us operate at the highest ethical standards by setting out the principles that underpin our values and actions. It also explains how we should behave.

Complying with laws and regulations relating to our job, committing to integrity in our daily work and reporting concerns uphold our principles of action.

Our Code of Ethics applies to everyone in the Company, regardless of location or role. All employees are expected to assume responsibility for performing their duties with fairness and integrity. It is implemented through regularly updated policies and procedures, both at Group and National level.

ISO certified Anti-Corruption Management System

MBDA rejects corruption of any kind, under any circumstances, whether public or private, active or passive, direct or indirect and applies a zero-tolerance principle. MBDA supports the principles of the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. MBDA also complies with the laws and regulations in force in the countries where it is located and/or where it operates, e.g. the UK Bribery Act 2010, the Italian law-decree Dlgs 231/2001 and the French law n° 2016-1691 regarding transparency, the fight against corruption and the modernisation of economic life, known as Sapin II. Our commitment is underpinned by our Anti-Bribery and Corruption Policy, which allows each employee to understand the various forms of corruption they may face, the prohibited behaviours and the expected ways to respond to it.

As an integrated Group, MBDA operates its Anti-Bribery Management System across its companies in France, the UK, Germany, Italy and Spain. MBDA’s Anti-Bribery Management System has been certified by an independent accredited certification body, as meeting the internationally recognised standard ISO 37001. The certification evidences the effectiveness of the system and the strength of commitment to anti-bribery compliance by the 20,000 people working within MBDA.

Our programme details the measures and procedures for raising awareness, preventing, detecting, and sanctioning corruption.

It is structured around the following principles:

• the continuous personal commitment of our senior management, overseeing the programme and its effectiveness;
• the periodic identification and mapping of corruption risks within our operations and processes;
• our anti-bribery and corruption policy illustrating the prohibited behaviours;
• a comprehensive awareness and training programme to allow our employees to detect and respond to corruption scenarios;
• due diligence performed on the integrity of third parties including suppliers and business partners;
• the prevention of conflicts of interests through a dedicated policy;
• a group gifts and hospitality policy;
• the Integrity Line, our internal reporting channel;
• an internal control system complemented by periodic internal audits;
• disciplinary measures implemented in accordance with national laws and regulations.

MBDA’s policy is not to make contributions, financial or in kind, to political parties or organisations, or to individual politicians. MBDA fully subscribes to laws and regulations regarding lobbyists in the countries where it is located and/or where it operates.

At MBDA, we develop a strong culture of integrity through senior management leadership, awareness actions and a multi-year training programme. Each employee completes training on ethics and anti-corruption. Depending on their role within the organisation, employees may be subject to enhanced training designed to address specific scenarios. In particular, employees in roles which are exposed to corruption and influence peddling attend live training.

Managers have the duty to promote MBDA ethical standards and effectively communicate the Code’s principles, as well as relevant policies and procedures that apply to their job areas to all those who report to them. They are required to attend training to help them be prepared to answer questions and create a comfortable working environment in which employees feel encouraged to bring forth concerns.

Awareness and training are delivered through regularly refreshed courses designed by our Learning and Culture team.

At MBDA, we are committed to the highest ethical standards and encourage open and honest communications. We want our employees to feel comfortable in raising concerns when they see, know of or suspect something unsafe, unethical or unlawful.

Recognising that MBDA employees might face a situation that seems contrary to our Code of Ethics or the law, we encourage employees to speak up and report violations in good faith and protect them and any person facilitating the report of violations from any retaliation from any employee and from the Company. Employees may reach out to their managers, Human Resources, Legal or Compliance. In situations where they would prefer to raise a concern by placing an anonymous report in absolute confidence, they are encouraged to use our Integrity Line.

The Integrity Line is open to anyone with a working relationship with MBDA (employees, apprentices, interns, graduates, suppliers, customers, partners, contingent workers, etc.), and any stakeholder wherever located in the world. 

As stated in our Code of Ethics, MBDA fully subscribes to the international instruments establishing prohibition of forced labour, elimination of all forms of child labour, right to dignity at work, freedom of association or freedom of expression, assembly and association.

Those principles are in particular embodied in the ILO’s Core Conventions, the 1996 United Nations covenants on Civil and Political Rights (ICCPR) and on Economic, Social and Cultural Rights (ICESCR), the United Nations Guiding Principles on Business and Human Rights, the Voluntary Principles on Security and Human Rights.

MBDA is committed to abiding by these fundamental principles with respect to its employees, suppliers and providers, and to ensuring a safe and healthy working climate, free from any threat or violence.

MBDA also states its adherence to the national laws and regulations of the countries where it is located and in particular to the principles enshrined in the UK Modern Slavery Act.