Working with Third Parties and Preventing Bribery and Corruption

Our Commitment

Hexcel works with a wide variety of third parties, such as customers, suppliers, distributors, agents, resellers and consultants. Our commitment to integrity requires that we honor the anti-corruption and anti-bribery laws and rules of the countries in which we do business. This commitment also requires that we conduct comprehensive due diligence on certain third parties we engage to ensure that they are reputable and have comparable processes to guard against corruption and other non-compliant actions. We never engage in transactions that others could see as attempts to wrongly influence business decisions. To do so goes against Hexcel’s Values and may violate laws in the countries where we operate.

What Is Corruption?

Most countries have laws in place to fight corruption. Corruption has many forms but often involves a payoff demanded by or offered to a customer as a trade for a benefit for a person or company. The payoff may involve money or anything else of value. These cases often involve low-level bureaucrats who seek payment to perform routine, non-discretionary acts. Common examples involve permits or visas, or routine customs clearances.

How We Act with Integrity

Learn to identify prohibited activities and how to respond when these situations arise.
Choose third parties based on Hexcel’s needs and their commitment to ethical behavior and values, and monitor their behavior throughout the business relationship.
Be alert to any risks or subtle requests in your interactions with third parties and report to the Law Department.
Remember that even the appearance of an improper payment can harm our reputation.

Offer, ask for or accept bribes or kickbacks.
Offer anything of value directly or indirectly to a customer to unfairly affect a business outcome, including any attempt to obtain or retain business.
Pay a commission to a third-party agent not documented in an authorized Hexcel agency agreement, or pay more than the legal limit imposed in any country.
Use a third party to take actions that would violate the law, the Code or Hexcel policy.

Integrity in Action

Am I permitted to make a small “facilitating payment” to a customs official to move Hexcel in front of other requests to release imported goods?

No. Hexcel’s Anti-Bribery and Anti-Corruption Policy (CP 1.6) and most national anti-corruption laws prohibit these types of payment. If a government official, or someone who claims to represent them, asks for such a payment, you should contact the Law Department immediately.

Integrity in Action

An employee of one of our key customers asked if I could help secure a job interview for his son at Hexcel, suggesting it could be “mutually beneficial.” We have an upcoming bid with this customer. What should I do?

Do not agree to help. The phrase “mutually beneficial” implies that the employee might be offering Hexcel an unfair advantage in return for your assistance. In such situations, refer the individual to Human Resources to provide information on open positions and job application procedures.