What is the AXA Compliance and Ethics Code?
AXA has a Compliance and Ethics Code for the Group (hereinafter the "Code") which applies to all its companies, employees, and business partners around the world.
In 2024, AXA revised its Code of Ethics, and introduced a new global Compliance and Ethics Code. The aim of this Code is to provide a clear, user-friendly document with a modern and accessible design. Its content addresses the challenges of today's context and includes key issues such as our commitment to the responsible use of social media, environmental protection, the prevention of discrimination and harassment, as well as the responsible use and safeguarding of customer data.
Our Values and Ethics
As AXA Group CEO Thomas Buberl states: "Values guide our conduct, which drives results. Customer First, Integrity, Courage, and AXA One, are not meaningful unless they are shared and taken on by everyone. They must be applied every day and in every sense. When we face uncertainty about the right course of action, our values guide us while keeping our mission in mind: to empower people to lead better lives. AXA has a long-standing commitment to strong professional ethics. We have developed this Compliance and Ethics Code to establish a shared understanding of what is expected from each of us as well as of the Group's business conduct.
These commitments must guide each of us in our daily work. Strong business performance and high standards of ethics, compliance, and governance are not mutually exclusive; on the contrary, they are mutually dependent on each other. That's why I encourage everyone at AXA to make a personal commitment to upholding the principles set out in our Compliance and Ethics Code.
Committed to preventing criminal activity.
AXA has adopted a zero-tolerance policy towards any form of criminal activity and is fully committed to complying with all applicable laws and regulations aimed at combating corruption and bribery wherever they occur.
Whistleblowing Channel
What is the whistleblowing channel?
This communication channel enables us to receive and process reports or information from AXA employees and professionals, its shareholders, unit holders, and members of the administrative, management, or supervisory bodies, including non-executive members, as well as any person working for, or under the supervision and direction of, the organization's contractors, subcontractors, and suppliers, concerning possible irregular conduct they may be aware of that is contrary to the Code of Ethics or Rules of Conduct, whether occurring internally and externally.
What should I report?
You are encouraged to share any concern you may have over any irregularities or inappropriate conduct you have detected or witnessed on the part of any employee or third party associated with any entity of AXA Group in Spain.
These may include but are not limited to: corruption and bribery; Human Resources matters (including any form of harassment or discrimination); fraud in financial statements, misappropriation of assets (including physical or digital assets and data); other fraudulent misrepresentations; and legal infringements (including the alteration, misrepresentation, or falsification of documents).
Where can I report an irregularity or inappropriate behavior: Whistleblowing channel?
You can also report such conduct anonymously as follows:
- Sending a fax message either in your name or anonymously to 91.555.02.06
- By post or internal post addressed to “Investigaciones Internas -Auditoría Interna” (Internal Investigations - Internal Auditing), in a sealed envelope marked "Confidential/Personal".
What protection do I have if I make a report in good faith?
Both internal regulations and applicable laws and regulations provide specific protection to the reporting person. Disclosure of their identity, or of any information that could lead to their identification, is prohibited except where required by court order.
All persons involved in the reporting and investigation process must maintain the strictest confidentiality.
If, in the course of the investigation, it becomes necessary to disclose such identity to additional persons (for example, in connection with disciplinary measures or legal proceedings), those who become aware of that identity shall remain subject to a permanent duty of confidentiality, and any breach thereof may result in disciplinary action.
Furthermore, AXA does not tolerate any form of retaliation against anyone who, in good faith, reports actual or suspected misconduct or irregularities.
What happens after a report is made?
All escalated or identified cases are investigated thoroughly in order to ensure an independent review.
If there are elements that substantiate the report, an investigation will be initiated.
For an investigation to be concluded as substantiated, it must be based on objectively proven facts in order to guarantee the presumption of innocence. Accordingly, any person who may be under investigation is also given the highest level of protection regarding their identity.
When the investigation is complete, a confidential official report is issued.
Whistleblowing channel data protection:
AXA SEGUROS GENERALES S.A. DE SEGUROS Y REASEGUROS, with TIN: A60917978 and registered address at Calle Monseñor Palmer nº1. 07014, Palma de Mallorca (Spain) will process all personal data voluntarily sent by whistleblowers to the queries and reporting email addresses provided, for the following purposes:
- Process and resolve received reports.
In the event of a report where the whistleblower is identified, the whistleblower, as the data subject, has the right to contact AXA, Ejercicio derechos de privacidad – Atención Cliente (Customer Service - Data Protection Rights), calle Emilio Vargas, 6, 28043, Madrid or via email buzon.lopd@axa.es, in order to exercise the following rights: access, rectification and erasure, restriction or withdrawal of consent to the processing of their data, and objection to the processing of their data.
