Bringing our values to life

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.

Escalating misconduct

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.

Identifying misconduct

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:

• to strengthen the Group’s ability to identify incidents and to coordinate the community of staff involved in investigations,
• to enhance the process to address misconduct globally (including sharing knowledge and experience, training etc.),
• to oversee all internal and non-routine (‘special’) investigations performed across the Group,
• to make reports on fraud and misconduct issues to the Group’s executive management and Audit Committee.

Addressing misconduct

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.

Reporting misconduct

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:

• 275 whistleblower allegations case rise to in-depth investigations overseen by AXA Group Internal Audit which is responsible for oversight of whistleblower notifications and for reporting those notifications and the results of associated investigations to the Group Management Committee and to the Audit Committee of AXA's Board of Directors.
• The predominant channels of whistleblower misconduct allegations in 2016 were Line Managers (42% of cases reported) and Internal Audit (also 42% of cases reported).
• The large majority of whistleblower allegations (77%) were related to theft of company property, misappropriation of other assets and HR matters.
• On average, 48% of investigated cases of alleged misconduct were confirmed with respect to one or more of the allegations in question.
• 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 72% of the cases where allegations were deemed founded.