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.

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 “”.

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 improve AXA’s global whistleblowing process, and to facilitate reporting of misconduct consistently across Group entities, incidents are classified in categories including human resources matters, misappropriation of assets, financial statement fraud, conflict of interest, corruption, document forgery, fraudulent claims, etc. 

In 2019, our reporting on alleged misconduct and others concerns shared through the whistleblowing process, includes the following indicators:

  • 281 allegations raised resulted in an investigation conducted or overseen by AXA Internal Audit (responsible for receiving and monitoring whistleblowing and for providing the Group Audit Committee with a quarterly overview of allegations).
  • The main escalation channels used to share concerns were Line Management (37% of cases), Internal Audit (23% of cases) and the dedicated whistleblowing hotline (15% of cases).
  • The categories of allegation commonly reported were linked to suspicions of: Data Leakage and misappropriation of assets: 29% of case; HR matters: 19% of cases; Document forgery: 12% of cases; Breaches of procedures:14% of cases; and other inappropriate practices: 26% of cases (none of the related categories reaching or exceeding 10%).
  • Among the 281 allegations raised, 60% were at least partly substantiated. None of the confirmed allegations were material to the Group's consolidated financial position or results of operations or to the Group's consolidated financial statements.
  • Disciplinary action (ranging from verbal warning to termination) has already been taken in 84% of the cases where allegations were deemed founded.
  • In the same way and to prevent misconduct from re-occurring, corrective actions have now been taken in 70% of cases notably to strengthen processes & controls, training, communication campaigns to raise awareness, etc.

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