Measures for the Prevention of Fraud, Bribery and Corruption
AXA IM has adopted the AXA Group Fraud Control Policy and Anti-Bribery and Corruption Standards along with Whistleblowing procedures designed to report fraud and other misconduct.
These standard applies to all AXA IM entities and establishes the minimum anti-bribery standards to be implemented throughout the AXA IM Group. It applies to all AXA IM employees as well as contractors and other third parties acting on AXA IM's behalf.
The objectives of our standards are the following:
Aid AXA IM to fulfill its commitment to complying with anti-bribery and anti-corruption laws and regulations in conducting its business.
Ensure that the best interests of clients are not directly or indirectly compromised if business is directed according to personal financial (or other) incentives
Avoid of conflicts of interests or the appearance of such conflicts.
AXA IM strictly prohibits the offering, giving, requesting, receiving, facilitation or authorization of bribes, facilitating payments or any other illegal inducement when conducting business. Breaches of this principle will be treated as a serious matter by AXA IM companies and are likely to result in disciplinary action.
Bribery is understood as a financial or non-financial advantage intended to induce a person to give improper assistance in breach of their duties, or to otherwise influence someone with the purpose of improperly obtaining/retaining business or an advantage in the course of business.
In conducting its operations AXA IM entities must not award or seek business or make particular business commitments based on improper personal incentives. All employees have an obligation to transact business on the merits of the products and services offered, and not on factors that improperly benefit the employee or client.
AXA IM employees, contractors, vendors and business partners that become aware or have strong suspicions of instances of fraud or bribery are encouraged to notify the Fraud Control Officer (Head of Compliance) of the concerned entity at ZRHIM-IOC@axa-im.com, or the Chief Fraud Control Officer at firstname.lastname@example.org.