Upholding the highest standards of ethics and responsible business conduct

Achievements in 2024

• 6,214 employees potentially exposed to corruption and influence-peddling risks were trained, representing 100% of the target population.
• 64% of Group sales were generated by entities certified to ISO 37001.
• Over 15,000 employees completed the “Trade Compliance – General Awareness” training programme.
• 14,000 employees received training on the General Data Protection Regulation (GDPR).
• Thales adopted a new standard on personal data protection, with binding corporate rules approved by the CNIL, France’s national data protection authority.

Target: Provide mandatory training in the prevention of corruption and influence peddling, for all employees potentially exposed to these risks, within six months of their joining the Group or moving to a new position. Organise refresher courses at least every two years for all potentially exposed employees to ensure training of 100% of the target population.

Zero tolerance on corruption

Thales introduced a corruption risk prevention policy in the late 1990s in order to protect itself from corruption and bribery, which represent a major risk for multinationals. 

This policy is regularly reviewed, updated and strenghtened to reflect increasingly strict international rules and requirements on corruption and influence peddling.

This policy is based on:

• A dedicated governance structure: the Ethics and Integrity Department develops the Group’s anti-corruption compliance programme, which is implemented by a network of Chief Compliance Officers under the supervision of the Integrity and Compliance Committee.
• A set of principles clearly articulated by the Chairman and CEO and shared with all employees: all senior executives sign personal pledges to adhere to Thales’s integrity and compliance rules – including rules on corruption and influence peddling – and are required to refresh this pledge every two years.
• Thales’s Code of Conduct: Prevention of Corruption and Influence Peddling explains and illustrates – in clear and simple language – why preventing corruption and influence peddling is important, what types of behaviour are prohibited as likely signs of corruption or influence peddling, and how Thales employees should react in certain high-risk situations.
• A corruption and influence peddling risk map drawn up in accordance with Thales’s general risk mapping methodology.
• Third-party due diligence procedures mainly covering customers, suppliers, subcontractors and partners, which use risk profiles and include preventive measures proportionate to the identified risks.
• Accounting control procedures embedded in Thales’s internal control rules in order to prevent and detect acts of corruption and fraud.
• A training programme for employees exposed to corruption and influence peddling risk in their line of work, and for those in supporting roles who may be in a position to prevent or detect corruption and influence peddling. The programme is tailored to employees’ risk exposure.
• A disciplinary system that sets out what action employees will face if they breach the Code of Conduct: Prevention of Corruption and Influence Peddling or break the law more generally, up to and including dismissal for misconduct.
• An anti-bribery management system (ABMS) sets out the aims of Thales’s anti-corruption compliance programme, explains the associated rules, performance indicators and control procedures, and tracks breaches and improvement loops.

Responsible data use

In the course of its business activities, Thales processes a large amount of personal data, both on its own behalf and on behalf of its customers.

Personal data has become a major asset for businesses operating in key global markets. For this reason, Thales has made data protection a top priority: we seek to maximize the utility of the data we process while adhering to applicable legislation at all times.

At Thales, we make a two-fold pledge: to keep the data we process as secure as possible, and to demonstrate that commitment.

Responsible tax policy

Thales’s global tax policy applies to all countries and incorporates the Group’s ethics rules, including measures against tax evasion. As a global business, Thales pays significant taxes and duties in many countries. 

Thales adheres to tax rules at all times and is careful to comply with local regulations, international treaties and the guidelines of international organisations.

The tax that Thales pays is directly related to its business strategy and activities, and we only establish offices outside France for the purpose of developing our business or meeting operational needs. We also comply with the OECD Transfer Pricing Guidelines. 

The tax function is managed by the Group Tax Director, who reports directly to the SEVP, Finance & Information Systems, who is a member of Thales’s Executive Committee. Tax risk is fully integrated into the risk analysis role of the Audit, Risks & Internal Control Department and is one of the internal control assessment items of the Yearly Attestation Letter.

Responsible lobbying

For Thales, lobbying means providing useful information to inform public decision-making. More specifically, it involves transparently publicising and promoting our activities in order to give public decision-makers exhaustive information and technical expertise.

We engage in both national and supranational lobbying – and always in accordance with local laws and regulations. In particular, we comply with Article 25 of the French Transparency, Anti-Corruption and Economic Modernisation Act of 9 December 2016 (known as the Sapin II Act), with the aim to ensure transparency in relations between lobbyists and the French authorities and openly declare company’s business interests.

We have compiled a Best Practices Guide to Lobbying for employees whose role may involve lobbying French public officials, detailing the ethical and reporting obligations that apply in France and describing the procedure employees must follow.

Thales is committed lobbying transparently and with integrity. In particular, we:

• apply a zero-tolerance approach to corruption and influence peddling in accordance with our Code of Ethics and our Code of Conduct: Prevention of Corruption and Influence Peddling, and our Charter for Responsible Lobbying.
• comply with national laws, regulations and ethical rules, and with the rules of the institutions with which we have relationships.

• register as a lobbyist with the institutions with which we have relationships, in accordance with applicable law.

  For example, Thales is registered on the public register of lobbyists of the High Authority for Transparency in Public Life in France and reports the detailed information of its lobbying activities in all the countries where a legal obligation to registering is in place.

• report on the entire lobbying budget for Thales SA and Thales Alenia Space France (direct and indirect expenses), but also in the European Union, in the United States and in Canada in particular.
• refrain from financing political activities, including in countries where such financing is authorised, and adhere to the principle of political neutrality.
• promote best practices in responsible lobbying: : transparency and integrity in lobbying practices (by ensuring in particular the quality, reliability and traceability of information and documents transmitted to public decision-makers), training of our employees, internal audit…
• refrain from contracting with public officials to represent our interests.
• respect confidentiality rules when hiring a former public decision-maker.

Strict export controls

Because Thales mostly operates in strategic areas, our businesses are bound by a specific regulatory framework. We have developed rigorous procedures as part of a process of continuous improvement to ensure that our businesses comply with regulations at all times.

Thales sells its products, solutions and services across the world to a very large number of public and private customers, both directly and indirectly. The export and re‑export of many products, technologies and systems for military or dual use requires licences issued in advance by the authorities of the exporting countries. 

Other regulations – including extraterritorial regulations such as those issued in the USA by the Office of Foreign Assets Control (OFAC) – prohibit trading with certain states, bodies, companies or individuals. These regulations, which can often change, create a framework of restrictive measures and impose economic and criminal sanctions on any individual, organisation or state that breaches them.

The Group exports its equipment and systems according to very strict rules designed to protect the national security of democratic states and combat the proliferation of weapons of mass destruction throughout the world. Compliance with export control rules, embargoes and economic sanctions is therefore a critical challenge for us.

At Thales, we undertake to operate in strict compliance with export control requirements, embargoes and economic sanctions. Each of our countries of operation has its own sovereign interests and its own export control rules – so we need to comply with different sets of regulations.

A central plank of our governance model: Given the global nature of our business, a rigorous export control, embargo and economic sanction system is a clear necessity. The Export Control Department defines Thales’s strategy at corporate level, and Trade Compliance Officers and Trade Compliance Managers within each exporting entity are responsible for deployment worldwide. Compliance with export control rules, embargoes and economic sanctions is everybody’s business, so all our employees have access to online training.