What is AXA's Code of Ethics and Compliance?
AXA has a Group Code of Ethics and Compliance (the "Code") that applies to all its entities, employees, and business partners worldwide.
In 2024, AXA has renewed its code of conduct and developed a global Code of Ethics and Compliance. The Code aims to be an easy-to-use document, with a modern and accessible design. The content reflects today's challenges and includes topics such as commitment to social media, environmental protection, prevention of discrimination and harassment, and the protection and responsible use of customer data.
Values and Ethics
As stated by Thomas Buberl (Chief Executive Officer of the AXA Group): Values guide behaviors, which drive results. Customer First, Integrity, Courage, and One AXA, each of our values only makes sense if they are shared and embodied by everyone. They must be applied every day and in every way. If we have doubts about the best decision to make, our values help us decide, taking into account our mission to empower people to live a better life. AXA has a long history of commitment to strong professional ethics. We have developed this Code of Ethics and Compliance to establish a shared understanding of what is expected of each of us and of the Group's businesses.
These commitments must guide each of us in the performance of our daily work. There is no conflict between solid business performance and high standards of ethics, compliance, and governance which, in fact, support each other. That is why I expect everyone at AXA to personally commit to complying with the requirements of our Code of Ethics and Compliance.
Committed to preventing crimes.
AXA adopts a zero-tolerance policy against the commission of crimes, in any of its forms, and is fully committed to complying with all laws and regulations against corruption and bribery wherever it operates.
Whistleblowing Channel
What is the Whistleblowing channel?
It is a communication channel, through which we receive and manage communications or information provided by AXA employees and professionals, its shareholders, participants, and persons belonging to the administrative, management, or supervisory body of AXA, including non-executive members; and any person working for or under the supervision and direction of contractors, subcontractors, and suppliers of the organization, about possible irregular behaviors of which they have become aware, contrary to ethics or regulations, both external and internal.
What should I report?
We encourage you to report any concerns you may have about irregularities or inappropriate conduct that you have detected or witnessed by any employee or third party who has a connection with any AXA Group entity in Spain.
Among others, the following types of behaviors would be included:
- Bribery, corruption, and conflict of interest
- Money laundering, terrorist financing, or non-compliance with international sanctions
- Internal fraud
- Financial statement fraud
- Sexual harassment
- Other types of harassment
- Discrimination
- Inappropriate behavior
- Theft or larceny of money, belongings, or assets
- Data breach or intellectual property leakage
- Non-compliance with other laws and regulations, including AXA Spain's Code of Ethics and Compliance, anti-corruption regulations, and actions or omissions that may constitute a criminal or administrative offense implying economic loss for the Public Treasury or Social Security.
Where and how can I report an irregularity or inappropriate behavior: Whistleblowing channel?
The communication of irregularities is designed to allow it to be carried out directly or indirectly, verbally or in writing, and by any person who has a collaborative relationship with AXA Spain (employees, external collaborators/agents, and/or third parties), bearing in mind that the reported situation could cause harm to AXA Spain, or at least its reputation, as well as to clients, employees, distributors, suppliers, shareholders, or the general public.
You can also report it, identifying yourself or anonymously, through the following channels:
- By sending a fax to 91.555.02.06.
- Via postal service or internal mail addressed to “Internal Investigations - Internal Audit”, in a sealed envelope marked "confidential/personal".
What protection and guarantees do I have that nothing will happen to me if I report in good faith?
Both internal regulations and applicable laws and regulations specifically protect the whistleblower, prohibiting the disclosure of their identity or any information that could lead to their identification, except by court order.
All parties involved in the reporting and investigation process are obliged to maintain strict confidentiality.
If, during the investigation, it were necessary to disclose said identity to more people (for example, for disciplinary measures or legal actions), those who know said identity will be subject to a permanent duty of secrecy regarding that identity, and non-compliance will be punishable.
Furthermore, AXA does not tolerate any act of retaliation against anyone who reports in good faith an inappropriate or irregular conduct, real or alleged.
External communication channel
Information may be provided to the Independent Whistleblower Protection Authority or to the corresponding regional authorities or bodies, regarding the commission of any actions or omissions constituting a violation of the Law or a serious or very serious criminal or administrative offense, either directly or after communication through the corresponding internal channel ( AIPI )
As established by the Criminal Code, the communication of possible irregularities related to corporate criminal offenses for their effective management is mandatory.
What happens after filing a report?
All escalated or identified cases are thoroughly examined in order to ensure an independent investigation.
If there are elements that confirm the report, said investigation is carried out.
For an investigation to conclude as founded, it must be based on objectively proven facts. Therefore, the presumption of innocence is always guaranteed. And for that reason, any person who may be under investigation also enjoys the maximum protection regarding their identity.
The investigation always ends with the issuance of an official confidential report.
Data protection for the Whistleblowing Channel:
AXA SEGUROS GENERALES S.A. DE SEGUROS Y REASEGUROS, with CIF: A60917978 and registered office at Calle Monseñor Palmer nº1. 07014, Palma de Mallorca (Spain) will process all personal data voluntarily supplied by whistleblowers through the email mailboxes for queries and reports, for the following purposes:
- Process and resolve the received report.
In case of communication where the whistleblower is identified, as the data subject, they have the right to contact AXA, Exercise of privacy rights – Customer Service, Calle Emilio Vargas, 6, 28043, Madrid or the email address buzon.lopd@axa.es, to exercise the following rights: access, rectification and erasure, restriction or revocation of the processing of their data, objection to the processing of their data.
