COMMITMENT TO TRANSPARENCY

Ethics & Compliance

    1. ETHICS & COMPLIANCE
      1. Anti Bribery
        1. Counterparty acknowledges that AXA Mansard:
          • Is committed to abide by the applicable laws and regulations prohibiting corruption and influence peddling (together “corruption”); and
          • has implemented and will maintain within its organisation policies, including but not limited to its Group Compliance and Ethics Guide, that prohibit any such actions by its officers, employees, affiliates, agents, subcontractors and any other Third Parties acting on its behalf.

           

        2. Corruption can be defined as the act by which a person invested of a specific public or private function, solicits or accepts a gift, offers or promises to perform, delay or omit to perform an act that enters, directly or indirectly, within the scope of its functions.
        3. Influence peddling can be defined as the solicitation or to approve, at any time, directly or indirectly, offers, promises, donations, gifts or benefits of any kind, for himself or for others, to abuse or have abused his real or supposed influence in order to obtain distinctions, jobs, contracts or any favorable decision from a public authority or administration. 
        4. Counterparty represents, warrants and covenants that, in connection with this Agreement:

           

          • neither Counterparty, nor its officers, employees, affiliates, agents, Subcontractors, nor any other Third Party acting on its behalf, have committed or will commit any bribery of a AXA Mansard’s officer, employee, affiliate, agent Subcontractor, or any other Third Party acting on its behalf; and
          • Counterparty has implemented and will maintain adequate anti-bribery polices and controls in place to prevent and detect bribery throughout its organization, whether committed by its officers, employees, affiliates, agents, subcontractors, or any other Third Party acting on its behalf.

           

        5. In particular, the Counterparty shall refrain from promising, offering, or granting to any person, directly or indirectly, any undue advantage so that such person performs or refrains from performing any act within the scope of its functions in the performance of this contract; or in order to make such person using its real or supposed influence over a Third Party in order to obtain any advantage.
        6. The Counterparty acknowledges that he did not offer any kind of undue advantage to AXA Mansard or to any Third Party to be awarded with the Agreement.
        7. To the extent permitted by the applicable Law, Counterparty shall notify AXA Mansard immediately upon becoming aware or upon becoming reasonably suspicious that an activity carried out in connection with this Agreement has contravened or may have contravened this Section Anti-Bribery or any anti-bribery law or regulation.
        8. AXA Mansard may at any time request evidence of Counterparty’s compliance with its obligations under this Section Ethics and Compliance. To the extent permitted by the applicable Law, AXA Mansard may also at any time request from the Counterparty a list of all gifts and entertainment and any other benefits in excess of 50 Euros (unless another amount is indicated in the Transaction Agreement) cumulatively, offered or provided by or on behalf of the Counterparty to officers, employees, affiliates, agents, Subcontractors, or any other Third Party acting on its behalf in connection with this Agreement.
        9. If the AXA Mansard has reasons to believe that the Counterparty is not complying with the obligations contained in this Section Anti-Bribery, the AXA Mansard may suspend the performance of the contract until the Counterparty provides reasonable evidence that it has not committed or is not about to commit a breach. AXA Mansard shall in no event be liable for any damage or loss caused to the Counterparty by the suspension of the Agreement.
        10. Breach of this Section Anti-Bribery by Counterparty shall be deemed a material breach of this Agreement. AXA Mansard may terminate this Agreement with immediate effect upon written notice as of right and without any judicial authorization if during the term of this Agreement the Counterparty:
          • fails to comply with this Section Anti-bribery;
          • fails to comply with any anti-bribery law or regulation even if not connected to this agreement; or
          • is convicted of an act of bribery.

           

        11. To the extent permitted by the applicable law, Counterparty shall notify AXA Mansard immediately upon becoming aware or upon becoming reasonably suspicious that an activity carried out in connection with this Agreement has contravened or may have contravened this Section Anti-Bribery or any anti-bribery law or regulation.
        12. Counterparty authorizes the AXA Mansard to carry out audits at any time to ensure that the Counterparty complies with its obligations under this Section. In this respect, the Counterparty undertakes to provide AXA Mansard, or any external Counterparty designated by it with all the documents and data necessary for the preparation and performance of the audit and to give it access to any site of the Counterparty or its affiliated companies.

         

      2. Conflict of Interest
        1. Counterparty shall maintain a process for identifying and managing conflicts of interest to ensure that no explicit or potential conflict of interests jeopardize the provision of the Services to AXA Mansard. Counterparty shall notify AXA Mansard as soon as practicable if the performance of the Services, or any instructions or directions from AXA Mansard, pose a conflict of interest.
        2. The Counterparty undertakes to declare any potential conflict of interest with AXA Mansard.
        3. Without prejudice to the foregoing, Counterparty shall take such action as is necessary to ensure that any identified conflict of interest is either eliminated or managed to AXA Mansard’s satisfaction whilst ensuring that the provision of the Services is uninterrupted, and the Services continue to be met to the standards required by this Agreement. Notwithstanding the foregoing, the Parties acknowledge that the Counterparty providing services to AXA Mansard competitor or other Third Party shall not, of itself, create a conflict of interest.

         

      3. Whistleblowing
        1. In accordance with relevant local laws and regulations, AXA Mansard has set up an internal alert system open to the Counterparty. The Counterparty may disclose or report:
          • a crime or offense, a serious and manifest violation of an international engagement duly ratified or approved by France, a serious and manifest breach of a unilateral act of an international organization taken on the basis of such an undertaking, a serious and manifest breach of law or regulation or a serious threat or harm to the general interest, under the condition that the facts disclosed concern AXA Mansard and that the natural person has disclosed or reported them disinterestedly and in good faith and is personally aware of the facts disclosed; and
          • the existence or realization of risks or serious abuse or damage of human rights and fundamental freedoms, health and safety of people of the environment, resulting from AXA Mansard’s business or that of suppliers or subcontractors with which AXA Mansard has an established business relationship, as long as the business of such subcontractors or suppliers is linked to their relationship with AXA Mansard.

           

        2. Reports must be sent by email to the following address: speak-up@axa.com.

         

      4. Ethics and Compliance Program
        1. AXA Mansard applies the highest standards in terms of ethics and integrity in the conduct of its activities and has notably established a Compliance and Ethics Code and an Anticorruption Code of Conduct that governs the conditions under which its employees must conduct their activities and their relationships with third parties. In this respect, AXA Mansard expects its Counterparties to share the same highest standards.
        2. AXA Mansard’s Code of Ethics is available on its website at the following address:
          https://www.axa.com/en/newsroom/publications/compliance-ethics-guide

          

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