Corporate Responsibility

Bringing our values to life

AXA has a zero tolerance to fraud and corruption.

We educate, we train, and we support our employee to develop conducts that are respectful to the environment, as well as ethical behaviors in their daily activities. AXA’s values are shared through its AXA Group Compliance and Ethics Code which is applicable to all AXA’s worldwide employees and subsidiaries and local anti-bribery and corruption policies (“Codes”). All senior officers across the Group are required to formally certify their compliance with the Codes on an annual basis. Furthermore, human rights and environment commitments are embedded in the Vigilance plan (in the 4.6 section).

Escalating misconduct

AXA encourages the reporting of any suspected, alleged or identified breaches of the Codes, as well as any practices or actions that are believed to be inappropriate, unethical or illegal. In that perspective, there is a variety of escalation channels available to raise concerns: line management, Internal Audit, Compliance, Human Resource and Legal departments, as well as any other local whistleblowing channels. Any serious whistleblowing can also be addressed directly to the Group through the dedicated email address “speak-up@axa.com”.

Addressing misconduct

At AXA, whistleblowing is taken very seriously. AXA scrutinizes all escalated or identified cases of misconduct to ensure an appropriate response to any alleged, suspected or confirmed situations and which could constitute a breach of the Codes, applicable legislations, and our values as they should be applied every day in every way. Disciplinary actions, legal proceedings and/or corrective measures are always considered when investigative work has confirmed an allegation.

Reporting Misconduct

Misconduct case tracking and, for the most material incidents, detailed investigation results are systematically presented and discussed with executive management, as well as with the Board members that attend the Audit Committees. An overview of fraudulent schemes as well as suggestions to improve internal controls is also provided to entity risk management teams to look back and review.

Our performance indicators

In order to enhance AXA’s global whistleblowing process, and to facilitate consistent reporting of misconduct across Group entities, incidents are classified in categories including people-related matters, internal fraud, conflict of interest & corruption & bribery, financial misstatement, anti-money laundering…

In 2022, our reporting on alleged misconduct and others concerns shared through the whistleblowing process, includes:

• 382 allegations which qualified as “High” Or “Very High” cases resulted in an investigation conducted or overseen by AXA Internal Audit, which represents a continued increase compared to 2021 (+49 cases, +13%).
• In terms of markets, France saw the biggest increase (due to a surge in Internal Fraud resulting from an updated policy, improved awareness across staff, actions to increase the investigation team’s professionalism and continued improvement of the framework through automated, scenario-based detection), followed by Africa, AXA XL and Europe.
• Whistleblowers make use of all available channels (line management, direct to Internal Audit, HR, through the Whistleblowing hotline, Compliance, Legal). More people are willing to speak-up without remaining anonymous.
• Non-people related allegation (58%) commonly reported and investigated were linked to internal fraud (136 cases) which is still the most frequent category and increasing, followed by Corruption and Bribery (17 cases); conflicts of interests (14 cases), Money laundering, financing terrorism or breaching sanctions (2 cases); and other inappropriate schemes(i.e. Breaches of laws and regulation (33 cases) data leakage (15 cases) Theft of money, belongings or assets (6 cases).)
• The total number of people related allegations (sexual harassment and discrimination in particular) continues to increase more rapidly than the rest. People-related concerns represented 42% (159), of which: 31 cases of discrimination, 33 cases of sexual harassment, 78 cases of other harassment and 17 cases of inappropriate behaviour.

Greater awareness driven by the Inclusion & Diversity surveys of the last two years, and the introduction of the Group Harassment Policy have likely been key drivers:

• 46% of all allegations were at least partially substantiated, the category of cases with the highest substantiation rate are “internal Fraud” (81%) and “Data Leakage” (80%)
• The tone at the top is getting stronger, with more than 50% of founded allegations resulting in an exit, and other disciplinary actions include but are not limited to, verbal warning, coaching,  temporary suspension.

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