• Business integrity

  • Our priorities

    • Ensuring compliance and solid ethical standards

    Future commitments

    • Continuing to strengthen our governance, risk management and internal controls
    • Establishing a responsible procurement policy

    Why it matters

    Our commitment to adhering to the highest ethical standards is anchored in our core values of integrity, trust and respect. We believe that proper ethical practices create and preserve shareholder value. They also build goodwill and foster the trust of employees, customers, suppliers, investors and the public. That’s why we set high ethical standards and expect our employees and business partners to comply with them.

    Compliance and ethical conduct

    Our employees and business partners are guided by our Code of Business Conduct, robust compliance systems, training and support. Our compliance framework focuses on export control, security and anti-corruption. The Chief Compliance Officer provides monthly compliance reports to the Executive Management Committee and quarterly reports to the Board.

    In fiscal 2016, we began a five-year process of enhancing our Code of Business Conduct. We integrated our CSR core priorities into the Code and trained our managers on the Code. We continued to leverage our compliance review to reinforce our governance, risk management and internal controls.

    In fiscal 2016, 30% of our suppliers attested to meeting our Responsible Procurement policy, a percentage we intend to increase substantially over the next few years. We also started to screen new suppliers for labour practices and respect of human rights.

    UN Logo

    UN Global Compact

    In fiscal 2016, we became a signatory of the United Nations Global Compact and began integrating its 10 principles into our CSR approach. One of our first actions was to update our master agreement and request for proposals (RFP) templates in accordance with the UN Global Compact and the United Kingdom Modern Slavery Act. These documents now include compliance with laws prohibiting human trafficking and the use of child or forced labour.

    Vendors are now also required to confirm that their code of ethics/business conduct aligns with our Code of Business Conduct commitments. They must demonstrate their social and environmental commitment and provide any related certifications. One of our next steps in aligning with the UN Global Compact is to develop a companywide Human Rights policy.


    At CAE, we have zero tolerance for bribery and corruption.

    As a global business, we operate in countries with a potential risk of corruption. We have developed strict controls to limit our exposure to this risk, particularly with respect to foreign representatives working on our behalf. We monitor their activities closely as well as any exchange of gifts and entertainment with customers to ensure no attempt is made to secure an unfair competitive advantage.

    In fiscal 2016, as part of the Code of Business Conduct training, all of our managers were trained on anti-corruption rules and our foreign agent representatives attested to complying with these rules. We also rolled out a new anti-corruption manual for our employees, suppliers and partners.

    In an effort to strengthen and improve our practices, we conducted an internal audit of our anti-corruption program. The review resulted in several recommendations for improvement that will be implemented by the Compliance Office over the course of fiscal 2017.

    Export control training

    As part of our Export Control Reform project, 97% of our employees worldwide were trained online on International Traffic in Arms Regulations (ITAR) and Controlled Goods. We reviewed our export control guidelines to make them more user friendly and reflect regulatory changes related to the US Export Control Reform. We updated our export control business processes across all departments.

    We delivered a three-day training session on export control regulation, export control reform and self-assessments to our export control officers in Germany, Australia and the U.K. as well as our locations in Tampa, Halifax, Ottawa and Mirabel. We also offered specialized training on CAE export control processes and regulations to 650 employees from various departments in our Montreal headquarters.

    Feedback mechanisms

    We provide formal mechanisms through our Code of Business Conduct for employees to raise concerns or report violations or breaches of the code. A third-party anonymous ethics hotline also allows employees to report violations (1-866-294-9551). Our Whistleblowing policy protects good-faith whistleblowers from retaliation.



    Hélène V. Gagnon
    Vice President, Public Affairs and Global Communications
    +1 514 340 5536
    Pascale Alpha
    Director, Global Communications
    +1 514 340 5475

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