AXA’s values are shared through its Group Compliance and Ethics Guide (the "Guide"). The Guide applies to all AXA’s worldwide employees and subsidiaries.
The Guide provides principles and guidelines that cover individual conduct, outside activities and interests; confidential information and disclosure practices; internal fraud and money laundering and more broadly compliance practices (with laws, with Group standards etc.). All senior officers across the Group are required to formally certify their compliance with the Guide on an annual basis.
The Group’s approach to fighting against misconduct (fraud, corruption, guide breaches, breaches in ethics, etc.) focuses on maintaining a legal and ethical environment which encourages all stakeholders to protect the Group’s assets and escalate any suspicion of misconduct.
AXA encourages the reporting of any suspected, alleged or identified breaches of the Guide, as well as any practices or actions that are believed to be inappropriate and/or inconsistent with AXA standards.
AXA has a zero tolerance to fraud and corruption.
At AXA, whistleblowing is taken very seriously. AXA scrutinizes all escalated or identified misconducts cases with the objective of ensuring an adequate response, to any alleged, suspected or confirmed situations (which could constitute a breach of the Guide or AXA’s values). A Global Head of Special Investigation was appointed in 2015 to refine this process.
The primary missions of this new position are:
When misconduct cases arise each one is carefully reviewed and, if assessed as being credible and serious, investigations are systematically undertaken.
If an investigation concludes that misconduct has taken place, appropriate disciplinary action, legal proceedings and/or other corrective action is considered.
AXA is fully committed to implement measures to recover, minimise and prevent further loss and impacts on the Group. Loss may be judged in financial, reputational or regulatory terms.
In order to improve AXA’s global whistleblowing process, as well as to facilitate reporting of misconducts in a consistent manner across Group entities, incidents are classified in 7 categories such as human resources matters, misappropriation of assets, financial statement fraud or corruption.
Misconduct cases are systematically presented and discussed with local executive management, as well as with Board members of all relevant entities through local audit committees. An overview of those events is also being provided to entities risk committees (post mortem review).
In 2016, our reporting on compliance guide breaches features the following indicators: