Doing international business requires being especially vigilant so as to ensure that all companies belonging to the EADS Group always comply with all applicable laws and regulations relating to international sales, as well as with very high business ethics and integrity standards. EADS aims at setting standards to govern its business ethics and integrity policies which often go beyond applicable laws and regulations.

To achieve this aim, EADS International has been implementing a comprehensive set of rules and processes since 2000 aiming at ensuring compliance with such laws, regulations and business ethics and integrity standards.

Policy

Organisation

EADS has implemented a detailed corporate policy, the Foreign Trade Rules, which applies to all international operations of the Group entities, and which is intended to detect and prevent bribery and unfair dealing in international sales. This policy has been published in EADS’ Corporate Handbook, which is available to all employees through the company intranet.

The policy entails effective control of international operations, through the conduct of appropriate due diligence of business partners, regular audit and reporting mechanisms and enhanced training sessions within all BUs. It also sets out appropriate guidelines regarding the acceptance of gifts and hospitality.

The main pillars of the Foreign Trade Rules are the following:

Those policies and procedures normally apply to all operations directly or indirectly relating to foreign trade.

The Group’s business partners must respect these policies and procedures, and any failure to do so may lead to early termination of the contract in place.

Furthermore, EADS conducts regular audits of implementation of all related agreements entered into by BUs to verify that Group policies and procedures are properly implemented and the BUs are instructed to report on a yearly basis on the implementation of such policies and procedures. This is especially the case concerning the payments made to the business partners, which must at all times be fully justifiable.

Since October 2002, EADS has set up a network of International Compliance Officers (“ICOs”) representing each BU. ICOs are responsible for ensuring the correct application of the policies and procedures within the Group. They are also in charge of nominating appropriate correspondents in foreign subsidiaries with a view to properly cascading the compliance duties in all operating countries.

EADS has also developed regular contacts with international bodies such as the OECD, the International Chamber of Commerce (“ICC”) and the European Union (“GRECO”) and peer companies with a view to setting and promoting integrity standards in the aerospace and defence sector. In this respect, EADS is pursuing a business dialogue with the European Aerospace & Defence Industries Association of Europe (“ASD”) and its members, (such as CIDEF and Groupement des Industries Françaises Aéronautiques et Spatiales (“GIFAS”) in France, BDI in Germany, AFARMADE in Spain or Society of British Aerospace Companies (“SBAC”) in the U.K.), and also with major European aerospace and defence companies, in order to launch a platform of principles aiming at setting high standards, exchanging best practices, promoting training and compliance programmes, and more generally generating common European industry positions on ethics and anti-corruption issues.

This platform would be open to all international aerospace and defence companies and associations, especially those belonging to OECD countries (e.g., United States), but also non-OECD countries at a later stage. As a matter of fact, EADS views such an international initiative as a perfect opportunity to enhance the level playing field which the OECD convention, and thereafter the UN Convention signed in Merida in December 2003, have started to establish.

EADS is also maintaining a relationship with the ICC anti-corruption Commission and the French Corruption Monitoring Council (Service central de prévention de la corruption), which signed a convention with EADS in 2003.

Performance and Best Practices

In December 2005, EADS amended the Foreign Trade Rules. The Foreign Trade Rules amendments resulted in particular from advice received from reputable international experts in business ethics and anticorruption laws and practices. The main objective of these amendments was to adapt the Foreign Trade Rules to the evolution of the Group, and to disseminate the identified best practices across the Group as a whole.

EADS conducts regular investigations and audits to detect and spread Group best practices in international business ethics.

In addition, the Group has developed a comprehensive training policy so as to disseminate an “awareness’ culture within all BUs. All employees dealing with international business attend such training sessions. In 2005, around 42 training sessions took place across EADS, sometimes with the attendance of third parties (prosecutors, representatives of international bodies, lawyers, etc.), in order to communicate and explain the Group’s corporate values and policies to all concerned. This represents a very significant increase compared to 2004, which tends to demonstrate that the dissemination of a compliance culture is a key element of EADS’ management system.

The Group issued a leaflet “EADS International Business Ethics Policy For Consultant Agreements: Transparency & Substantiation” in January 2004, which is given to all prospective international marketing consultants. This leaflet summarises Group policies and procedures regarding selection of international business partners. Such international business partners are also invited to attend specific training sessions when deemed appropriate.

The Group’s ICOs meet periodically to share concerns and best practices. An annual ICO Conference has been organised since 2003 involving more than 100 people involved in foreign trade business and operations. The ICO Conference of December 2005 was held in Paris with 114 participants from 22 BUs. Senior Executives presented and discussed issues focusing on business ethics at large.

EADS also releases Group-wide internal bulletins on a regular basis named ICO information letters. These focus on the evolution of the regulatory environment for foreign trade and highlight information reported by international media regarding the fight against corruption and economic crime worldwide. These bulletins are intended to complete and update the information given to EADS employees during the training sessions.

In relation with its international businesses, EADS uses third parties, such as consultants and international business partners in order to provide appropriate assistance and expertise to BUs on current or potential business for EADS and/or promote EADS products or services in various countries. The contractual arrangements for such services are governed by internal rules and policies that describe the entire contractual process, from the selection of the partner to the implementation and execution of the agreed service. In order to ensure that the rules are understood and strictly applied, consultant and service providers agreement are audited. The purpose of these audits is to check the substantiation of the contractual duties delivered by the third party in exchange of its remuneration. The table below presents information concerning the percentage of consultant files audited in each of the past three years. None of the audits have revealed any material deficiencies.