1° honesty ◆ (compliance and ethic) ◆ fairness ensure compliance with applicabl

1° honesty ◆ (compliance and ethic) ◆ fairness ensure compliance with applicable laws ◆ ng term ◆ (TRUST) business conversations ◆ in accordance with ◆ (confidentiality) reputation ◆ 2° honesty compliance and ethics ◆ ensure compliance laws long term (trust ◆ business conversations ◆ rEputation ◆ 3° honesty 1° honesty ◆ (comp iance) fairness ensure co pliance with applicab e laws ◆ tions ◆ long term ◆ (TRUST) reputation ◆ 3° honesty AXA Group Compliance and Ethics Guide 2011 AXA Group Compliance and Ethics Guide 2011 I. A MESSAGE FROM THE CHAIRMAN AND CHIEF EXECUTIVE OFFICER OF AXA 1 II. INTRODUCTION AND ANSWERS TO FREQUENTLY ASKED QUESTIONS 3 IiI. COMPLIANCE AND ETHICS GUIDE 9 1. OUR PROFESSIONAL ETHICS REFLECT AXA’S VALUES 10 2. YOUR INDIVIDUAL CONDUCT, ACTIVITIES AND INTERESTS 11 2.1 — Conflicts of interest 11 2.2 — Outside directorships and other outside activities and interests 11 2.3 — Protection and proper use of AXA Group assets 12 2.4 — Corporate opportunities and resources of the Group 12 2.5 — Gifts, entertainment and other inducements 12 2.6 — Procurement ethics 13 3. CONFIDENTIAL INFORMATION AND DISCLOSURE PRACTICES 14 3.1 — Confidentiality 14 3.2 — “Ethical wall” policy 14 3.3 — Accuracy of disclosure 14 3.4 — Improper influence on conduct of audits 15 3.5 — Record keeping and retention 15 4. COMPLIANCE WITH LAWS AND REGULATIONS/REGULATORY INQUIRIES AND LITIGATION 15 4.1 — Compliance with laws, rules and regulations 15 4.2 — Insider trading 16 4.3 — Antitrust and fair dealing 16 4.4 — Relationships with government personnel 16 4.5 — Political contributions by or on behalf of Group companies 16 4.6 — Regulatory inquiries, investigations and litigation 17 5. INTERNAL FRAUD AND MONEY LAUNDERING 18 5.1 — Internal fraud 18 5.2 — Money laundering/Terrorist financing 18 6. REPORTING MISCONDUCT 19 6.1 — General policy statement 19 6.2 — Reporting to the designated complaint recipient 19 7. WAIVERS AND ANNUAL CERTIFICATIONS 21 7.1 — Waivers of the Compliance and Ethics Guide 21 7.2 — Monitoring compliance – Annual certifications of compliance 21 8. COMPLIANCE PRACTICES/POLICIES OF GROUP SUBSIDIARIES 21 ANNEXES 22 A Policy statement on control and use of material non-public information 23 (“Ethical wall policy”) B Policy statement on record keeping and retention 25 C Policy statement on trading in AXA Group securities (“Insider trading policy”) 26 I. A MESSAGE FROM THE CHAIRMAN AND CHIEF EXECUTIVE OFFICER OF AXA A MESSAGE FROM HENRI DE CASTRIES, CHAIRMAN AND CHIEF EXECUTIVE OFFICER OF AXA 2 AXA Group Compliance and Ethics Guide — 2011 A message from the Chairman and CEO of axa Our success and our reputation are not only dependent on the quality of our products and the service provided to our clients, but also on the way in which we do business. The latter is based on the trust our clients, employees, shareholders, suppliers and partners place in us. The heart of our business is to accompany our clients through the management of their risks, which leads us to make and uphold long-term commitments to them. Trust is an essential factor in this, and the cornerstone of our success and reputation around the world. It underpins our signature brand. It is also the common denominator for our commitments, which bind us to our partners, clients, shareholders, employees, and suppliers as well as to our communities and the environment. Honesty, integrity and the highest ethical and professional standards are all reflected in our values and are critical to instill trust and confidence. Proper implementation of these principles also guarantees our credibility with regulatory authorities. To gain and keep the trust of our partners, each one of us must adhere to a stringent code of professional ethics in line with the level of quality and service that our stakeholders, as well as the public in general, are entitled to expect from a group such as AXA. The Group has a long history of adhering to and promoting strong professional ethics. It is—and must continue to be—a key part of our culture. We have developed the AXA Compliance and Ethics Guide to establish a shared vision of standards and practices for the Group’s businesses, grouping them together in a single document. Its principles and common sense must guide each one of us in the performance of our daily functions. The long term success of our Group depends on it and our reputation is at stake. I am, above all, counting on your personal integrity and common sense in your day-to-day activities to ensure compliance with the principles defined in this guide. Henri de Castries II. INTRODUCTION AND ANSWERS TO FREQUENTLY ASKED QUESTIONS INTRODUCTION 4 AXA Group Compliance and Ethics Guide — 2011 Introduction AXA is committed to conducting its business according to the highest standards of honesty and fairness. This commitment to observing the highest ethical standards is designed not only to ensure compliance with applicable laws and regulations in the various jurisdictions where we operate but also to earning and keeping the continued trust of our clients, shareholders, personnel and business partners. This Group’s Compliance and Ethics Guide (the “Guide”) is not intended to be an exhaustive guide to all the detailed rules and regulations governing the conduct of business by AXA Group companies and their personnel in all the various countries where the Group does business. Rather, it is intended to establish certain guiding principles and Group-wide policies designed to insure that all AXA Group companies and their personnel have a common vision of the Group’s ethical standards and operate in accordance with those standards. The Guide establishes minimum standards to be observed by all Group companies and includes the following Group policies (the “Policies”):  Compliance and Ethics Guide  Policy statement on control and use of material non-public information (“Ethical wall policy”) included in the Guide as Annex A  Policy statement on record keeping and retention included in the Guide as Annex B  Policy statement on trading in AXA Group securities (“Insider trading policy”), included in the Guide as Annex C ANSWERS TO FREQUENTLY ASKED QUESTIONS 5 AXA Group Compliance and Ethics Guide — 2011 Answers to frequently asked questions 3. How do I report misconduct or other matters that I believe should be reported under the Policies in the Guide? The Group has adopted a Policy statement on handling of employee complaints which is included in section 6 of the Guide. AXA Associates should consult that Policy statement for information on the procedures to follow if they have something to report under any of the other Policies included in the Guide. Taking pro-active steps to prevent problems is part of the AXA Group’s culture and speaking to the right people is one of your first steps to understand and resolve what often can be difficult questions. Anyone reporting misconduct as described in the Guide in good faith will be protected against retaliation. Section 6 of the Guide constitutes the minimal process for AXA Group companies. However, this process (as with any Policy or specific provision or a Policy contained in the Guide) might conflict with applicable legal/regulatory requirements and will therefore not directly apply to you or your AXA Group company until such time as these conflicts have been resolved (see question 6 below for more detail). For example, in France, the processes described in section 6 cannot be applied directly. AXA Associates working for a French company are therefore required to contact their local human resources, legal or compliance department for further information. 4. What are the consequences of failing to comply with the principles in the Guide? As noted above, AXA Group companies do business in approximately 60 countries around the world, each of which has its own unique business, legal and regulatory environment. Consequently, the Guide does not attempt to define a uniform set of rules or sanctions for failure to comply with the Policies set forth in the Guide. Most AXA Group companies have well defined internal regulations and other policies governing employee relations, including matters such as disciplinary measures in the event of misconduct as described in the Guide. The consequences of failing to comply with the Policies set forth in the Guide will depend on the internal regulations and policies in force at your particular AXA Group company and any sanction or other action taken as a result of a failure to comply will be in accordance with those internal regulations and policies. As discussed below, in the event that any Policy (or specific provision of a Policy) contained in the Guide conflicts with the internal regulations or policies of your AXA Group company (including those governing employee relations) or with applicable legal/regulatory requirements, General 1. Who does the Guide apply to? Unless specifically stated otherwise, the Policies set forth in the Guide apply to all AXA Group companies1 and to their directors, officers, and employees as well as to their tied agents and other personnel who have the status of employees2 (collectively, “AXA Associates”). The Guide does not apply uploads/Industriel/ axa-complianceguide-2011.pdf

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