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ARIANEULY 17 10868 LogoV CMJN14/03/201724, rue Salomon de Rothschild - 92288 Suresnes - FRANCETél. : 33 (0)1 57 32 87 00 / Fax : 33 (0)1 57 32 87 87Web : www.carrenoir.comÉQUIVALENCE QUADRICYAN 100 % MAGENTA 35 %Ce fichier est un document d’exécution créé surIllustrator version CS6.NOIR 100 %ETHICS CHARTER
MESSAGE FROM THE CEOAs a leading European space sector company, ArianeGroup is driven by anambitious purpose: “Pioneering the European way to space, for the well-being ofall citizens in a safe world.”Our actions are strongly inspired by the humanists’ ideal of progress and by the beliefthat technological innovation in the field of space should improve the daily life, securityand well-being of people everywhere, while contributing to the long-term preservationof Earth. We are ultimately working for peace and a safer world through our defenseactivities.Committed to shaping a better future for humanity, we want this socially responsiblegoal to create a trusted business environment for our employees and shareholders,customers, suppliers and partners. We are determined to seize all opportunitiesoffered worldwide by the space sector, to be a global leader at the cutting edge ofinnovative solutions, to provide new space mobility, and to secure European nations’access to space.In this aim, Ethics is a cornerstone of our leadership model and we demand thehighest ethical standards as well as socially responsible ways of doing business.The example we give to the world on a daily basis, as a company and as individuals,in demonstrating our culture of ethics through our behaviors and business activities,will definitely make the difference. Striving for excellence in all areas and beingpioneers in innovation means using Ethics as a way forward and as a competitiveadvantage in the space race. Only through the engagement of each and every oneof our employees and stakeholders will we achieve ArianeGroup’s sustainable growth.From this perspective, Ethics is a space enabler!We are living in a challenging and exciting era, and I am thoroughly convincedthat space is a source of solutions and progress for the future of humanity, providedthat we operate in a responsible way. While ArianeGroup affiliate companies carry outtheir respective business independently, Ethics must be part of the common DNA ofour whole group. As we work together to make this forward-looking vision a reality,I count on you to embody these common values and make ArianeGroup a place whereeach of us can find opportunities for personal development, collaborative practicesand an entrepreneurial mindset: in a nutshell, an attractive company of which we canall be proud. I am hoping you will find inspiration in the ArianeGroup Ethics Charter.André-Hubert Roussel2This document and the information it contains are property of ArianeGroup Holding, ArianeGroup SAS & ArianeGroup GmbH. It shall not be used for anypurpose other than those for which it was supplied. It shall not be reproduced or disclosed (in whole or in part) to any third party without ArianeGroupHolding, ArianeGroup SAS & ArianeGroup GmbH prior written consent. ArianeGroup Holding, ArianeGroup SAS & ArianeGroup GmbH – All rights reserved.CONTENTS
ETHICSCHARTERAt ArianeGroup, we conduct ourThis Ethics Charter aims to providebusiness with integrity and pursueguidance in key areas in order to helpthe highest standards of Ethics andus always operate in accordance withCorporate Social Responsibility,our company’s values. It applies towhich we consider to be a crucialall ArianeGroup employees. Unlesspart of business excellence. We aimstated otherwise, any reference toto foster sustainable growth andArianeGroup in this Ethics Charter refersto build a better tomorrow for ourto ArianeGroup and its subsidiaries1.employees and our stakeholders.This Charter cannot address everychallenging situation that may arise.When in doubt, each of us has aresponsibility to seek advice. In addition,we should disclose any situation thatmay violate laws, internal policies orstandards, and report any concerns.Each and every one of us has anindividual and collective responsibility tocomply with and promote the standardsgiven in the Ethics Charter.We also recognize our responsibilityto uphold these standards acrossthe extended enterprise with allArianeGroup stakeholders, and inparticular in our supply chain, throughthe ArianeGroup Supplier Ethics Charter.1 - A subsidiary being defined as any entity in whichArianeGroup Holding directly or indirectly holds more than50% of the shares and/or voting rights3This document and the information it contains are property of ArianeGroup Holding, ArianeGroup SAS & ArianeGroup GmbH. It shall not be used for anypurpose other than those for which it was supplied. It shall not be reproduced or disclosed (in whole or in part) to any third party without ArianeGroupHolding, ArianeGroup SAS & ArianeGroup GmbH prior written consent. ArianeGroup Holding, ArianeGroup SAS & ArianeGroup GmbH – All rights reserved.CONTENTS
TABLE OF CONTENTS1.3.FOCUSING ON PEOPLE ENGAGING INPAGE 5RESPONSIBLEBUSINESS PRACTICES1.1 Respecting people1.2 Ensuring workplacehealth and safety1.3 Encouraging open dialogueand whistleblowing1.4 Promoting diversityand fostering our talent1.5 Protecting privacyand personal dataPAGE 93.1 Respecting our customers3.2 Committing to productsafety and quality3.3 Ensuring mutually beneficialrelationships with suppliersand subcontractors3.4 Zero tolerance of corruption3.5 Avoiding conflicts of interest2.RESPECTING ANDPROTECTING ASSETSAND INFORMATIONPAGE 72.1 Protecting our assets3.6 Competing and operating fairly3.7 Combatting money laundering3.8 Complying with importand export laws3.9 Ensuring fair relationswith shareholders3.10 Cooperating with authorities2.2 Communicating andprotecting our image2.3 Protecting third-party information2.4 Complying with defense regulations2.5 Maintaining accurate records2.6 Trading securities4.WORKING TOWARDSSUSTAINABILITYPAGE 124.1 Establishing responsible businessstandards at every level4.2 Conducting responsible sourcing4.3 Developingour local communities4.4 Striving for eco-efficiency4.5 Building a better tomorrow4This document and the information it contains are property of ArianeGroup Holding, ArianeGroup SAS & ArianeGroup GmbH. It shall not be used for anypurpose other than those for which it was supplied. It shall not be reproduced or disclosed (in whole or in part) to any third party without ArianeGroupHolding, ArianeGroup SAS & ArianeGroup GmbH prior written consent. ArianeGroup Holding, ArianeGroup SAS & ArianeGroup GmbH – All rights reserved.
1. FOCUSING ON PEOPLEPeople are ArianeGroup’s most precious asset.We foster the continued engagement of employees at all levelsand promote an environment of trust and collaboration amongst teamsin order to achieve collective success.1.1.Respecting peopleWe recognize that fully respectingemployees’ rights fosters a positiveworkplace environment that boostsinnovation, a key to our competitiveness.We are committed to safeguardingand promoting human rights, asdefined by the Universal Declarationof Human Rights, the United NationsGuiding Principles on Business andHuman Rights, the OECD Guidelinesfor Multinational Enterprises, andthe International Labor Organization(ILO) Declaration on FundamentalPrinciples and Rights at Work, internallyand throughout our supply chain. Wecondemn human trafficking, all forms offorced labor and modern slavery, andchild labor.1.2.Ensuring workplacehealth and safetyEmployees’ health and safety is ofutmost importance to us. We aretherefore committed to pursuing thehighest health and safety standards inthe workplace and in all our activities.We are responsible for reporting anyrisk situation or incident to our manager,the person responsible for Health,Safety & Environment or, for specificrisks, the person in charge of radiationprotection/nuclear safety.1.3.Encouraging opendialogue andwhistleblowingWe promote an open and trust-baseddialogue with employees at all levels ofArianeGroup and their representatives.Employees are strongly encouragedto openly communicate, discuss, andclarify their questions or concerns, andmanagement is encouraged to listenand be responsive.We also encourage all employeesto report any situation or behaviorconflicting with the Ethics Charterthrough regular business channelssuch as the line manager or a HumanResources, Ethics & Compliance, orLegal representative, who shall giveWe respect the dignity and private life ofthem appropriate support in return.each employee. We do not tolerate anyIn addition, the dedicated ArianeGroupform of harassment in the workplace,whether moral, physical, visual or verbal.confidential alert system or existingsubsidiary-specific alert system may beused.We are committed to protectingwhistleblowers and will not tolerateany direct or indirect retaliation, orattempted retaliation, against anemployee who speaks up in good faith.5This document and the information it contains are property of ArianeGroup Holding, ArianeGroup SAS & ArianeGroup GmbH. It shall not be used for anypurpose other than those for which it was supplied. It shall not be reproduced or disclosed (in whole or in part) to any third party without ArianeGroupHolding, ArianeGroup SAS & ArianeGroup GmbH prior written consent. ArianeGroup Holding, ArianeGroup SAS & ArianeGroup GmbH – All rights reserved.CONTENTS
FOCUSING ON PEOPLE1.4.Promoting diversityand fosteringour talentIn keeping with our focus on excellence,we aim to attract and retain leadingedge talent and consider diversity one ofour greatest strengths.1.5.Protecting privacyand personal dataWe always respect and protectindividuals’ privacy and related rightsof employees, customers, suppliersand third parties. While we may collect,process, use, and store employees’and third parties’ personal data in theWe support diversity of all kindsundertaking of our operational activities,and we do not tolerate any form ofwe must also ensure that the way wediscrimination.deal with them is compliant with allWe recruit and select individuals forcareer advancement on the basisof their competences, potential,performance, behavior, and willingnessto work in different departments andapplicable obligations and in particularwith the European Union General DataProtection Regulation 2016/679 (GDPR)as well as national data protectionregulations.ArianeGroup’s or subsidiaries’ Dataentities.While fostering individuality contributesto rich cultural diversity, our high-Protection Officers (DPOs) should becontacted for any query.performance culture requires us toconstantly promote the ArianeGroup’scommon values and behaviors in ourdealings with each other and with ourstakeholders.6This document and the information it contains are property of ArianeGroup Holding, ArianeGroup SAS & ArianeGroup GmbH. It shall not be used for anypurpose other than those for which it was supplied. It shall not be reproduced or disclosed (in whole or in part) to any third party without ArianeGroupHolding, ArianeGroup SAS & ArianeGroup GmbH prior written consent. ArianeGroup Holding, ArianeGroup SAS & ArianeGroup GmbH – All rights reserved.CONTENTS
2. RESPECTING AND PROTECTINGASSETS AND INFORMATIONProtecting our property, our information, our competencies, and our know-how,as well as any assets entrusted to us, is key in order to bothbuild trust and maintain our competitiveness.We must constantly work to ensure that none of these assetsis stolen, damaged, misused or improperly destroyed.2.1.Protecting our assetsWe each have a duty to protectArianeGroup’s assets, both tangibleand intangible. To this regard, wecomply with Security and Cyberdefensepolicies as well as applicable laws andregulations.We treat all property entrusted to us ina professional manner and in support ofArianeGroup’s business goals. We use itin a safe, ethical, lawful, and productivemanner.We treat company information andknow-how as key assets of ArianeGroupand protect them accordingly. Access tosensitive information is strictly on a needto-know basis. It can only be disclosed toauthorized co-workers or outside partieswho need this information for legitimatebusiness purposes, or if required by law.We are encouraged to developinnovative solutions for products,2.2.Communicating andprotecting our image2.3.Protecting third-partyinformationArianeGroup’s reputation is a veryOur customers, suppliers, and otherimportant asset. It is therefore crucialpartners often entrust us with theirthat we promote and protect our image.own confidential and proprietaryWe must provide accurate and truthfulinformation. As a trustworthy partner,information to the public regarding ourwe must handle third-party proprietarybusiness.information in accordance with theOnly designated persons may respondto formal outside requests forinformation, especially by the media.terms of its disclosure and in strictcompliance with all applicable laws andregulations.We must not under any circumstancesprovide information or engage insocial media activities on behalf ofArianeGroup.In addition, ArianeGroup sponsorshipsshall be in line with our strategic focusand our ethical standards and mustalways be transparent and accuratelyrecorded in company books andrecords.services and business models. Wemust always ensure that we secureand protect ArianeGroup intellectualproperty and avoid knowinglyinfringing the intellectual propertyrights of others.7This document and the information it contains are property of ArianeGroup Holding, ArianeGroup SAS & ArianeGroup GmbH. It shall not be used for anypurpose other than those for which it was supplied. It shall not be reproduced or disclosed (in whole or in part) to any third party without ArianeGroupHolding, ArianeGroup SAS & ArianeGroup GmbH prior written consent. ArianeGroup Holding, ArianeGroup SAS & ArianeGroup GmbH – All rights reserved.CONTENTS
RESPECTING AND PROTECTINGASSETS AND INFORMATION2.4.Complying withdefense regulations2.5.Maintaining accuraterecordsThe nature of our core business makesOur stakeholders as well as governmentit all the more crucial for us to strictlyregulators rely on the accuracycomply with all applicable internal andand correctness of the informationexternal security rules and regulations.contained within our business records.Access to government-classifiedinformation requires specific clearances.Any exchange or transmission ofclassified information or material mustWe therefore have a responsibility toensure that the information we provideis accurate, timely, complete, fair, andunderstandable.comply strictly with the relevant securityIn maintaining our financial records,process. Any actual or suspectedwe must follow the applicable internalincident or misuse must be immediatelycontrol procedures. We must not createreported to the ArianeGroup Securityor participate in the creation of recordsdepartment or the person responsiblethat mislead or conceal any improperfor Security in subsidiaries.activity.2.6.Trading SecuritiesWe must not disclose any informationthat could influence the value ofArianeGroup shareholders’ stockprice before it has been publicallycommunicated.In line with laws relating to insidertrading, we must not buy or sellthe stock of any company while inpossession of inside or privilegedinformation about that companyobtained in the course of our work.In addition, we must not disclose anyinside or privileged information toanyone, including co-workers, friends,and family.We are expected to maintain anddestroy ArianeGroup documents inaccordance with record retentionschedules and procedures.8This document and the information it contains are property of ArianeGroup Holding, ArianeGroup SAS & ArianeGroup GmbH. It shall not be used for anypurpose other than those for which it was supplied. It shall not be reproduced or disclosed (in whole or in part) to any third party without ArianeGroupHolding, ArianeGroup SAS & ArianeGroup GmbH prior written consent. ArianeGroup Holding, ArianeGroup SAS & ArianeGroup GmbH – All rights reserved.CONTENTS
3. ENGAGING IN RESPONSIBLEBUSINESS PRACTICESUpholding values of integrity, honesty and transparency, ArianeGroup aimsto be an unfailingly trustworthy partner for all its customers and stakeholders.We are committed to conducting our business in a highly responsible way,in compliance with applicable laws and regulations in all countrieswhere we do business as well as internal rules and procedures.3.1.Respectingour customersWe are committed to dealing honestlyand fairly with all our customers,whatever the size of their business, andto honor our contractual commitments.3.2.Committingto product safetyand qualityWe should never sacrifice product safetyor quality. Maintaining high standards ofproduct safety is in our interest as wellas in the interest of our customers andall our stakeholders.3.3.Ensuringmutually beneficialrelationshipswith suppliersand subcontractorsSuppliers deliver a high proportion ofthe value of ArianeGroup products, andWe must comply with all quality-controlthus play an important role in customerstandards and procedures that governsatisfaction. We are committed toour responsibilities. Product quality andsustaining fair relationships withsafety depends heavily on informationsuppliers and subcontractors and tofeedback. We are thus expected to alertsecuring our relationships with themin full transparency when anomaliesto achieve goals of mutual benefit. Thisor deviations to our processes aremeans promoting the exchange of bestobserved, to stop and remedy anypractices and sharing synergies wherequality and safety issue, and then torelevant.propose appropriate prevention andThe Procurement department isimprovement actions.responsible for ensuring that allsupplier relationships are handled in anequitable and compliant manner. Weeach have a duty to make certain thatissues with suppliers are professionallydealt with at all times, and that ourselection of suppliers is based solely onwhat is best for the company.9This document and the information it contains are property of ArianeGroup Holding, ArianeGroup SAS & ArianeGroup GmbH. It shall not be used for anypurpose other than those for which it was supplied. It shall not be reproduced or disclosed (in whole or in part) to any third party without ArianeGroupHolding, ArianeGroup SAS & ArianeGroup GmbH prior written consent. ArianeGroup Holding, ArianeGroup SAS & ArianeGroup GmbH – All rights reserved.CONTENTS
ENGAGING IN RESPONSIBLEBUSINESS PRACTICES3.4.Zero toleranceof corruption3.5.Avoiding conflictsof interest3.6.Competing andoperating fairlyOur good reputation is one of our mostAs part of our efforts to protectWe believe in fair competition andprecious assets, and could be foreverArianeGroup’s reputation and ensure webehave accordingly, strictly excludingdamaged by the misconduct of a singleare acting on the basis of what is bestall agreements, behaviors or exchangeemployee or any third party. Hence, thefor our company, we shall always seekor disclosure of commercially sensitivefight against corruption is utterly criticalto act with loyalty and to avoid situationsinformation relating to competitors,to us.where our personal interests interfere,customers or suppliers, that mayor appear to interfere, with our abilityrestrain or alter competition or trade.to perform our jobs without bias. If weWe operate in good faith at all times,cannot avoid a conflict of interest, weand rule out any fraudulent behaviorshall disclose it to our manager and tofrom the way we do business.We must never engage in any kind ofcorrupt practice or hire someone else todo anything that we cannot ethically orlegally do ourselves.We must never offer, attempt to offer,authorize or promise any sort of bribe,facilitation payment or kickback to athe ArianeGroup Ethics & Compliancedepartment or the Compliance Officer insubsidiaries.public official or private body for thepurpose of obtaining or
business with integrity and pursue the highest standards of Ethics and Corporate Social Responsibility, which we consider to be a crucial part of business excellence. We aim to foster sustainable growth and to build a better tomorrow for our employees and our stakeholders. This Ethics Charter aims to provide guidance in key areas in order to help
