BBD.B.TO
Our Code of Ethics
Table of contents
A word from our Chief Executive Officer
Who must follow the code?
How is the code governed?
Foundation of the code
Committing to the code Following the law
Upholding the world's largest sustainability initiative
Our responsibilities
What employees must do What management must do
Other bombardier policies and procedures Reporting potential violations of the code Cooperating with internal reviews and investigations Penalties for violations
Who to contact
Ethics and compliance office
Bombardier's reporting system
Ambassadors
Promoting a healthy and sustainable workplace
Equal employment opportunities
Harassment
Health and safety
Environment
3
Safeguarding our property
18
4
Company property
18
5
Intellectual property
18
Protection of confidential data and information
18
6
Data privacy
19
6
Acting with professionalism in our communications
20
7
Social media
21
7
Communications with others
22
8
Public communication
22
9
Cyber-security
23
10
Use of bombardier it resources
25
12
Upholding sound business practices
26
13
Securitiy laws and insider trading
26
13
Anti-corruption
28
13
Gifts and entertainment
29
14
Donations, sponsorships and requests for funds
30
14
Fraud
30
Conflicts of interest
31
14
Money laundering
31
14
Books and records
31
15
Dealing responsibly with third parties
32
15
Competition law compliance
33
15
Customs, export control and embargo compliance
34
16
Governments and lobbying
34
17
Political activities
34
A word from our Chief Executive Officer
Bombardier has repositioned itself as a pure-play business aviation company with clear goals: to deliver exceptional value to our customers and predictable financial performance to our shareholders through a highly engaged and inclusive workforce. We focus our efforts on bringing the same exceptional performance that has defined our aircraft to every aspect of our company and each customer interaction.
To achieve this, we must strive to be an organization that is truly people and customer-centric; that values performance, operational excellence and team spirit. A company that is transparent and authentic at all times and at every level.
This Code of Ethics ("the Code") is our roadmap to put these values into action. Our mutual success depends on each of us making the right individual choices every day. A single bad choice made by just one person can damage the reputation of our entire company. That's why it is so important that all of us strictly adhere to this Code and reaffirm our commitment to acting with the highest ethical principles in everything we do.
We earn our customers' business by delivering exceptional experiences. But we earn their respect by doing so with personal and professional integrity. By exemplifying the principles outlined in the Code, we will promote a winning culture where talented people want to work; where suppliers are honoured to have our business; and where customers trust us to deliver on our commitments.
I'm counting on you to share and live the values of our Code of Ethics and to help our company achieve sustainable success.
Éric Martel President & CEO
BOMBARDIER CODE OF ETHICS
3
Who
must follow the Code?
Our CODE OF ETHICS, which sets the global standards for our business and activities, applies to all members of the Bombardier community, including the Board of Directors, management and employees at every level, in every country and from every Bombardier legal entity (including joint ventures where Bombardier has a majority/controlling interest).
Management and employees are also expected to comply at all times with all Bombardier policies, directives and procedures. Bombardier suppliers, service providers and consultants are expected to adhere to Bombardier's Supplier Code of Conduct when dealing with or acting on behalf
of Bombardier.
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How
is the Code governed?
BOMBARDIER'S ETHICS AND COMPLIANCE OFFICE has implemented a governance structure to ensure that the principles of this Code are observed, promoted and managed effectively throughout the organization. The Ethics and Compliance Office oversees Bombardier's efforts to promote an ethical work environment and business practices of the highest ethical standards.
All Bombardier employees holding managerial positions have a responsibility to ensure that the Code is actively distributed, understood and followed within their teams.
BOMBARDIER CODE OF ETHICS
5
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Disclaimer
Bombardier Inc. published this content on 10 February 2022 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 10 February 2022 22:57:01 UTC.