Bringing our values to life

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 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 speak-up@axa.com.

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 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 & corruption & bribery, financial misstatement, anti-money laundering…

In 2023, our reporting on alleged misconduct and others concerns (including High and Very high severities) shared through the whistleblowing and alerts process, includes:

• 488 allegations which qualified as High Or Very High allegations, of which 470 cases resulted in an investigation conducted or overseen by AXA Internal Audit, which represents a continued increase compared to 2022 (+13% increase) .
• People related cases continue to grow substantially (+14%) but at a slower rate than in previous years (+18% in 2022, + 50% in 2021).
• The growth in non-people related cases (+13%) is accelerating due to the increased use of automated fraud detection tools, particularly at AXA France.

In terms of markets*, France continues to show the biggest increase (+50%) in the number of cases (due to a surge in Internal Fraud resulting from an updated policy, improved awareness across staff, actions to increase the investigation team’s professionalism and continued improvement of the framework through automated, scenario-based detection), followed by Southern Asia, Europe AXA XL

Non-people related allegation (73%) commonly reported were linked to internal fraud (155 cases) which is still the most frequent category and increasing, followed by :

• Breach of laws and regulations (61 cases),
• Corruption and Bribery and conflicts of interests (42 cases),
• Leakage of data or intellectual property (27 cases),
• Theft of money, belongings or assets (8 cases),
• Financial misstatements (7 cases),
• Money laundering, financing terrorism or breaching sanctions (3 cases)

The total number of people related allegations represented 38% of the total portfolio (185 cases), of which:

• 66 cases of other harassment
• 47 cases of sexual harassment
• 46 cases of inappropriate behaviour
• 26 cases of discrimination

High and very High Sexual harassment allegations show an increase across all entities and Other harassment is still the highest category raised for people related allegations.

The tone at the top continues to strengthen across all categories : misbehaviour, if proven, is sanctioned, resulting in an exit, and other disciplinary actions include but are not limited to, warning, coaching, mentoring, temporary suspension. However, an increasing number of the people related allegations are being made by employees who are preparing for an exit negotiation.

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.

* Markets are defined as follows: France, Asia from International Market (includes Korea, Indonesia, Philippines, Thailand), Europe, AXA XL, Northern Asia (encompasses China, Hong Kong and Japan), Africa, LATAM (covers Brazil, Colombia & Mexico), & Turkey, AXA Partners, AXA IM, GIE, AXA Group Operations & AGBS