Safran’s Responsible Lobbying Charter

Lobbying can be defined as “Any communication, written or oral, between a representative or an interest group and a public decision-maker in order to influence decision-making.”

Context

Safran Nacelles est un leader du marché mondial des nacelles pour moteurs d’avion.

Situé à proximité des avionneurs, le site d’intégration de Toulouse assure un support sur la chaîne d’assemblage final : il livre au client un ensemble propulsif complet (moteur et nacelle).

Safran defines lobbying as its transparent contribution to the development of public policy and legislation on subjects concerning its businesses. The aim is to support the understanding and legitimization of our businesses, and to foster the conditions needed for their long-term development, in compliance with environmental protection and the interests of local communities, including our employees, customers and suppliers. With laws and regulations that could impact our businesses expanding and becoming more complex, Safran has to provide the technical expertise needed by both decision-makers and stakeholders. Our technical input is designed to keep them informed on the consequences and practical scope of the laws and political decisions under consideration.

Safran recognizes that other stakeholders (unions, NGOs, international organizations, etc.) may also present their positions on relevant matters to decision-makers. Safran's lobbying activities are developed in line with our corporate social responsibility (CSR) and anti-corruption commitments.

This charter applies to employees who undertake lobbying efforts for Safran and its companies, and to the relations between these employees and all decision-makers and stakeholders concerned: elected officials, government representatives, NGOs, unions, researchers, opinion-leaders, think tanks, trade associations, etc. The charter is to be circulated among all Safran companies and their subsidiaries. It is applied by all employees carrying out lobbying, as well as lobbyists working for us. It is also distributed to stakeholders, and published on our website

Internal organization

Responsibility for lobbying activities depends on the country:

  • France: Safran Institutional Affairs department
  • Other European countries: Safran European Affairs department
  • United States: President of Safran USA
  • Brazil: President of Safran Brazil
  • Mexico: President of Safran Mexico
  • China: President of Safran China
  • India: President of Safran India
  • Malaysia: President of Safran Malaysia
  • Australia: President of Safran Pacific
  • Other countries: Zone Directors in Safran's European and International Affairs division (DGREI).

 

When a Safran company calls on an outside lobbyist, the company's Trade Compliance Officer (TCO) will prepare a partner validation request for Safran DGREI (GRP-0026).

Lobbying Charter – Safran SA

Integrity

Safran pledges to:

  • respect the codes of conduct and regulations of organizations involved in its lobbying activities (business, employer and trade associations);
  • ensure that neither its employees nor hired lobbyists enter into a real or potential conflict of interest with the authorities;
  • exercise lobbying actions in compliance with Safran's Code of Ethics, which above all rule out all types of corruption; Safran will:
    • comply with the Group procedure concerning "Gifts, hospitality and sponsored trips" (GRP-0153);
    • ensure that lobbyists hired by the Group are fully aware of and comply with our Code of Ethics and the associated Group procedure "International trade compliance" (GRP-0026);
    • enable the clear identification of the initiative undertaken and the interests involved: Safran's experts and, if applicable, outside consultants, must clearly indicate that they are working on behalf of Safran during discussions with stakeholders;
  • be listed on the lobbyist registries, when applicable, of the organizations that we are lobbying.

 

Any Safran representative or a service provider that does not comply with the provisions in this charter will immediately be subject to an appropriate penalty, up to and including the termination of their contract with Safran.

Information and communications

Safran pledges to:

  • provide reliable information;
  • publish its main corporate positions on its website and update them regularly, especially in line with the timetable for public debate. By "main public positions", we mean all public positions on new legislation or political decisions that have a potential material impact on Safran, whether promoted directly by Safran, or via trade associations;
  • publish the list of the main think tanks and trade associations to which Safran belongs and where it takes an active role. By "main think tanks and trade associations", we mean the main organizations whose international stature could influence legislation or political decisions;
  • provide annual information to the Group's stakeholders of any political donations;
  • advocate with rating agencies the need to take into account the lobbying practices of the organizations they are evaluating, and thereby foster the development of high standards throughout the industry.