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One AXA Compliance & Ethics Code for all AXA Employees

In 2024 AXA has launched a revised AXA Compliance and Ethics Code. Thomas Buberl (Group CEO) introduces the new Code with the following message:

The AXA Compliance and Ethics Code is applicable to all worldwide AXA employees across the Group, to make sure we have a common understanding of the compliance and ethical principles. This Code covers a variety of matters and topics, including specific rules concerning prevention of conflicts of interest, bribery and corruption, and money laundering, financing of terrorism and breaching of international sanctions, fair and professional treatment of customers, protection and responsible use of personal data, and protection of the environment and Human Rights.

Fighting against bribery and corruption

A zero-tolerance culture

AXA has zero tolerance for any form of bribery and corruption.

Tone at the Top

Having a Senior Management who supports our engagement and sets the tone at the top is essential. Senior officers of AXA Group Companies are asked to submit an annual certification stating that they are in compliance (or to report any potential deviations) with the AXA Compliance and Ethics Code and their local anti-corruption code of conduct.

A global Anti-Bribery and Corruption Program

At AXA, we have a Group Anti-Bribery and Corruption standard and Policy (the ABC Policy) that establishes the minimum standards for anti-bribery and corruption that must be implemented by AXA entities. This policy is updated on an annual basis to notably take into account regulations (for example, the French law known as Sapin II n°2016-1691 of December 9, 2016, on transparency and the fight against corruption and the modernization of the economy).

A Group Anti-Bribery Officer oversees the global ABC Programme at Group level and monitors its implementation across the Group. AXA entities have designated local Anti-Bribery Officers to implement their local policies in accordance with the Group’s ABC Policy.

The objective is to achieve a consistent Anti-Bribery and Corruption (ABC) programme across the Group to prevent corruption risks.

Escalating misconduct

AXA has zero tolerance to any misconduct related to a behaviour or a process believed to be inappropriate, unethical or illegal which may cause detriment to (an) individual(s) or AXA.  

Allegations can be raised through various channels, for example line management, a trusted colleague, the dedicated local whistleblowing hotline, local Audit, or Group Audit directly. speak-up@axa.com is accessible internally via local intranets and externally via axa.com that is globally reachable to employees, suppliers, business partners, and external stakeholders. 

Whatever the channels, when a concern is submitted, its content is evaluated and triaged by independent Investigations teams, based on pre-established criteria, including categories and impact severity of the reported concern. 

Addressing misconduct

All allegations received will be acknowledged to the whistleblower promptly (target response time is within 7 working days of receipt) and monitored either by the relevant professional family or directly by the Investigation teams. An update to the whistleblower will be provided within 3 months. 

If at any point it becomes clear that the allegation is not admissible under the Whistleblowing & Investigations Policy, the reasons will be provided in writing to the whistleblower. 

The investigation is intended to confirm or refute each element of the allegation, through interviews, documentary evidence reviews and could also involve advanced tools for data analysis.  

In whistleblowing, everyone, anonymous or otherwise, can be confident that they will be treated fairly. Any disclosure made to Investigation teams will be taken seriously and handled confidentially, with strict adherence to data privacy regulations. Any leakage of confidential information can be subject to appropriate disciplinary action.  

The whistleblower’s identity will be known only to those involved in the independent investigation unless there is a specific legal requirement, or the whistleblower decides otherwise. Any person facilitating the reporting of a whistleblowing is also protected under the AXA’s Whistleblowing and Investigations policies

Protection linked to the whistleblowing’s mechanism

Independent Investigation teams across the Group ultimately reporting to or supervised by Internal Audit, investigate the allegations. Whistleblowing and investigations are confidential.

Retaliation against whistleblowers or anyone who is part of the process or reports of allegations in bad faith is not tolerated by AXA and can be subject to appropriate disciplinary action.

Wording in employment contracts and settlement agreements for employees leaving AXA must not prohibit those employees from reporting a whistleblowing disclosure, regardless of whether such a prohibition is permitted by local law.

Annual investigation trends

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 and corruption & bribery, financial misstatement, anti-money laundering.

In 2024, our reporting on alleged misconduct received through the whistleblowing process, includes:

• 423 cases which qualified as High or Very High severities
  - non-people related cases grew by +12%
  - people-related cases decreased for the first time in 5 years (-19.2%)

Non-people related cases (64%) commonly reported were linked to internal fraud (125 cases) which is still the most frequent category, followed by:

• Leakage of data or intellectual property (66 cases)
• Corruption, Bribery and conflicts of interests (47 cases)
• Breach of laws and regulations (19 cases)
• Theft of money, belongings or assets (6 cases)
• Financial misstatements (5 cases)
• Money laundering, financing terrorism or breaching sanctions (1 case)

Non-people related cases by automated controls are a growing source of reporting.

The total number of people related allegations represented 36% of the total portfolio (154 allegations), of which:

• 68 allegations of other harassment
• 32 allegations of sexual harassment
• 40 allegations of inappropriate behaviour
• 14 allegations of discrimination

Other harassment remains the highest reported category of people-related allegations (36% of the total).

The tone at the top at AXA remains strong: misconduct where proven, is sanctioned.

AXA has a policy not to make financial contributions to political campaigns or political organizations. For further information on this topic, please visit our Public affairs page.