Safran group Ethical Guidelines

Upholding the law

In all the countries in which the Group operates, its personnel must uphold the laws in force. It may sometimes be difficult to understand the laws in a legal and cultural environment very different from that in which people have previously worked. In case of doubt, employees should immediately consult a supervisor or the legal department. Personnel working in a subsidiary jointly owned by a Group company and a foreign company must uphold the laws of the country in which the subsidiary is based, of the countries in which it operates and of the country (or countries) in which its shareholders are based.

The Group applies international conventions on combating corruption of public officials.

Use of business consultants or agents offers an effective means of developing Group business, due to their expertise. Fees stipulated in their contract must always correspond to a real service rendered and payment must comply with applicable laws.

All personnel must take particular care to uphold laws on competition, the final destination of products sold, labor and employment, health, safety and environmental protection.

Behavior towards customers

Each employee must uphold the principles of fairness and integrity in their dealings with customers. Given the Group’s products and services, absolutely no compromise is acceptable in terms of safety. Any situation that may seem questionable to an employee must immediately be reported to a supervisor or Quality manager.

Relations with shareholders

The Group regularly provides shareholders with comprehensive, transparent information. It takes particular care to apply international corporate governance standards and principles.

Relations with suppliers

The Group chooses suppliers on the basis of objective criteria in the sole interest of the Group. The Group demands high performance and excellence from its suppliers to fully meet the expectations of its customers. Under no circumstances will the Group use suppliers involved in child or forced labor.

Integrity

Group employees may under no circumstances damage its reputation, the integrity of its assets or its information systems. Paid work of any type that personnel may have outside their job must not cause conflicts of interest with their duties inside the Group.

Similarly, considerable caution is required with regard to the purchase of shares, directly or via an intermediary, in companies doing business with the Group. Such restrictions do not apply to listed companies, unless confidential information is used which may be construed as insider trading.

Under no circumstances may Group employees accept gifts or benefits, except those of a symbolic nature, from suppliers. Similarly, no one may propose or award such gifts or benefits with a view to obtaining a contract.

No one should display the slightest indulgence with respect to active or passive corruption.

Sustainable development

Today, more than ever, protecting the environment is an essential concern for all Group employees, from product design through the entire production process.

Political and religious activities

Le Groupe ne finance aucun parti politique. Les activités politiques et les pratiques religieuses que peuvent avoir les membres du personnel s’exercent exclusivement en dehors des lieux et du temps de travail.

Protecting the confidential nature of certain information

Everyone, in the course of their duties, has access to confidential information, which, even if partial, represents one of the Group’s key assets and must not be divulged to the competition. Similarly, employees may hold information concerning National Security. It is essential to bear in mind at all times the importance of protecting such information from third parties.

At the same time, in each Group company, everyone must make sure the information required for the proper execution of work circulates normally inside or outside the company and that it is always accurate.

Respect for other people

Ensuring health and safety is a primary objective for all Group employees. As a matter of principle the Group guarantees equal opportunity for all its employees. Recruitment and promotion are based exclusively on professional qualities, without any form of discrimination. The Group undertakes to respect the dignity and privacy of each of its employees. Furthermore, one of the Group’s key values is to create the necessary conditions for everyone to achieve fulfillment in their professional career.

Hierarchical authority may not be used for any other purpose than ensuring the proper running of the company. It must be exercised with restraint and discernment, and must not lead to any form of abuse or harassment.

Ethical guidelines

The Group brings the contents of these ethical guidelines to the attention of each employee, requiring his or her compliance. In the event of doubt about the appropriate conduct, it is up to each employee to immediately consult a supervisor or the Group’s Legal Department.

PARIS – 2005, May 11th