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Business ethics

Prevention of bribery and anti-competitive practices

The prevention of bribery and anti-competitive behavior is an important factor in honest and fair business practice.

Our anti-corruption policy

As unethical or inappropriate behavior can have considerable negative consequences, at the moral, financial and reputational level for the Group, preventing all forms of unfair practices is key.

Our Anti-Bribery Manual relating to corruption and the policy on gifts and hospitality are regularly revised to ensure the required updates and improvements. This Policy aims to provide clear guidelines for staff, including financial limits, on giving and receiving gifts and hospitality.

In 2021, it was decided to simplify the structure of the Anti-Bribery Manual (which was to become the “Anti-bribery Code of Conduct”) with a framework document and appendices dedicated to each topic to be covered in accordance with the Recommendations of the French Anti-corruption Agency and in accordance with the bribery risk mapping. Subject to approval by the top management and the employee representative bodies, this revised version should be published in the 2022 second half.

An anti-bribery e-learning training campaign has been deployed to maintain and reinforce the anti-bribery awareness and knowledge of staff. At the end of 2021, the realization rate for this training had reached 85%. Awareness is also reinforced through, for example, information meetings and discussions, improved access to compliance documents and regular communication on such matters by the Group’s General Management.

Compliance and fair business conduct

The Compliance activities are based on compliance programs, executed within the context of a formalized framework. New legislation or requirements relating, for example, to anti-bribery or data privacy are taken into account when establishing the compliance programs and their increased appropriation is ensured via, amongst other initiatives, awareness-raising campaigns, and dedicated processes or projects which are organized to guarantee compliance.

The Compliance Officers within Air France-KLM are tasked with overseeing the implementation of the Compliance programs within the Group. They are supported by a network of compliance correspondents in the activities or departments and subsidiaries. Depending on the type of business transaction and the complexity within the activities or departments and entities, subject matter experts and compliance correspondents facilitate compliance with specific legislation and the roll-out of the relevant elements of the compliance program.

The compliance program is mainly based on training and awareness-raising. Matters that require greater awareness and transcend businesses, like the prevention of bribery and anti-competitive behavior, are the subject of information campaigns. These campaigns are supplemented by dedicated training which is available to individual employees. Employees can also ask questions or raise concerns with the Compliance Officers and legal experts.

The Air France-KLM Group ensures that the compliance and fair business conduct rules are duly respected through an evaluation by a third party.

Whistle-blower procedure

Since all employees are required to respect these rules, employees in all the Group’s entities are encouraged to discuss any compliance concerns with their line managers. They can also contact a Compliance Officer directly.

Employees can also choose to flag any issues via the Whistle-blower procedure. These procedures also include the possibility of reporting any serious situations, notably relating to corruption offences and the duty of vigilance (human rights, fundamental freedoms, health and safety, environment) across all the businesses, pursuant to the regulation in force.

The whistle-blower mechanism includes guidance for employees on the factual reporting of incidents and states the measures undertaken to ensure the strict confidentiality of the alert and identity of the relevant employees. It also includes a guarantee that no sanctions will be taken against employees reporting any such incidents in good faith, as provided under the applicable law. Reports under the whistle-blower procedures are investigated and the appropriate corrective actions are implemented.

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