Standards of Ethics and Business Conduct

Bombardier's Code in the Work Environment

  • Employment Practices

    Bombardier treats all employees fairly, ethically, respectfully and with dignity. The Corporation offers equal employment opportunities without regard to any distinctions based on age, gender, sexual orientation, disability, race, religion, citizenship, marital status, family situation, country of origin or other factors, in accordance with the laws and regulations of each country where it does business.

  • Harassment and Personal Security

    Bombardier policies protect employees from harassment, bullying and victimization in the workplace, including all forms of sexual, physical and psychological abuse. As an employee, you are entitled to, and are expected to preserve, a positive, harmonious and professional work environment.

  • Health, Safety and the Environment

    The occupational health and safety of employees and environmental protection are priorities at Bombardier, where they are regarded as a fundamental corporate social responsibility.  We strive to reduce the impact of our activities and of the performance of our products on the environment, and work towards a "total life-cycle" view in product design, while maintaining our competitiveness.

    Bombardier and its employees comply with all applicable laws and regulations. We adopt standards, procedures, contingency measures and management systems to ensure that our operations are managed safely, ecologically and in a sustainable way.

    To protect their own safety as well as that of their colleagues and communities, employees undertake not to work under the influence of any substance that could impair their judgment or interfere with the effective and responsible performance of their duties.

Bombardier's Code in Business Practices

  • Company Property

    Company property should only be used for legitimate business purposes. Bombardier employees are expected to take good care of company property and not expose it to loss, damage, misuse or theft.

  • Intellectual Property

    Intellectual property comprises trademarks, domain names, patents, industrial designs, copyrights and trade secrets. Employees have a duty to protect Bombardier's intellectual property, just as they have the obligation to respect that of others. Subject to applicable laws, any inventions or discoveries made by employees during the course of their work are Bombardier's property. 

    Intellectual property is considered confidential information. Therefore, it is covered by the non-disclosure guidelines set out in the "Confidential Information" section of this Code.

  • Books and Records

    Bombardier's books and records are complete, fair and accurate and comply with all legal reporting requirements. Supported by Bombardier's systems of internal controls, they reflect all assets, liabilities, transactions and events and conform to required accounting principles.

    Bombardier employees manage, store, archive and dispose of books and records − both print and electronic − according to established policies and legal requirements.

  • Communications

    As a Bombardier employees, you should be truthful and straightforward in dealings and not intentionally mislead colleagues, customers or suppliers.  Use appropriate, professional language, both in written documents and public conversations.

    Communications with the media, the investment community and regulators are the responsibility of designated Corporate spokespersons. Inquiries received by an employee must be referred to an authorized spokesperson.

  • Electronic Mail and Internet Usage

    Bombardier's electronic mail and Internet systems are provided for business use. When using electronic mail, you should remember that it is susceptible to interception, creates a permanent record, can be printed or forwarded to others by the recipient and will likely be retained on the recipient's computer for a long time.

    Therefore, exercise the same care in sending electronic mail as in other written business communications. Never use Bombardier's Internet connection or computer equipment to access, transmit or download content that is inappropriate and does not meet business requirements.

  • Gifts and Entertainment

    Employees, suppliers, partners and other third parties representing Bombardier must avoid giving or receiving gifts or entertainment if these might improperly influence the recipient's judgment or might be perceived to do so. Gifts can include goods, services, favours, loans, trips, accommodation or use of property.

    Sometimes in business, for example, in certain cultures, an exchange of gifts is appropriate. In such instances, the gifts should be reasonable, in good taste, and have token or nominal value. Employees must never give or accept gifts when prohibited from doing so by law or by the recipient’s or donor organization’s policies.

  • Confidential Information

    Confidential information is information belonging to Bombardier that is not subject to public disclosure. Confidential information encompasses information produced by Bombardier or obtained in confidence from a third party and covered by a non-disclosure agreement.

    Examples of confidential information are:

    • Financial data
    • Strategic plans
    • Intellectual property
    • Information on bids
    • Personal employee information
    • Legal documents
    • Information on customers and suppliers

    Do not divulge confidential information to anyone other than the person or persons for whom it is intended, unless authorized or legally required to do so. This includes confidential information provided by suppliers and customers. Employees agree to maintain such confidentiality at all times, even after leaving the employ of Bombardier.

    Employees should also exercise caution to avoid misusing or inadvertently disclosing confidential information. This includes:

    • Keeping electronic and paper documents and files containing confidential information in a safe place;
    • Not discussing confidential matters where they could be overheard, for example, in public places such as elevators, hallways, restaurants, airplanes and taxis;
    • Exercising caution when discussing confidential matters on wireless telephones or other wireless devices;
    • Transmitting confidential documents by electronic devices, such as by fax or e-mail, only when it is reasonable to believe this can be done under secure conditions; and
    • Avoiding unnecessary copying of confidential documents.

  • Securities Laws and Insider Trading

    It is illegal for anyone who has material information about a public corporation that has not been made public to buy, sell or trade in securities of said corporation, or to pass on undisclosed material information to anyone else. Material information is defined as any information relating to a company that, if disclosed, could reasonably be expected to influence investors, or to affect the market price of the company's shares. Examples of this type of information include:

    • Unpublished financial information, including quarterly or annual financial results not yet disclosed to the public;
    • A major corporate acquisition, disposition or joint venture;
    • A significant change in senior management or to the Board of Directors of the Corporation; and
    • Obtaining or losing a significant contract.

    Therefore, if you have any knowledge of undisclosed material information about the Corporation, you are prohibited from trading in Bombardier securities until the information has been fully disclosed to the public and a reasonable period of time has passed for the information to be widely disseminated by way of a press release. Securities include common shares (such as Bombardier Class B shares), preferred shares or bonds.

    Similarly, if you have knowledge of undisclosed material information about third parties, such as customers, vendors and suppliers, you are prohibited from trading in securities of that third party until the information has been fully disclosed and a reasonable period of time has elapsed.

    Under no circumstances shall any employee engage in hedging activity or in any form of transactions of publicly-traded options on Bombardier securities, or of any other form of derivatives relating to Bombardier securities, including "puts" and "calls." No employee of Bombardier shall sell Bombardier securities that he or she does not own (a "short sale").

    All employees are absolutely prohibited from conveying undisclosed material information (known as "tipping") about Bombardier to anyone, including outside professional advisors, other employees of Bombardier or members of their families, unless doing so in the necessary course of Bombardier business.

    Since it may be extremely difficult to distinguish between information that is "material information," as defined above, and information that is not, and in order to avoid the appearance of possible impropriety, as an employee, you are required to comply with the following rules:

    • At all times, avoid recommending the purchase or the sale of the securities of Bombardier Inc. to third parties;
    • If, as an employee, you wish to buy, sell or trade in securities of Bombardier Inc. for yourself or otherwise, the Corporation strongly suggests that you do so only during a trading period of 25 calendar days, starting the fifth working day following the publication of Bombardier Inc.'s quarterly or annual financial reports; and
    • It is understood, however, that at all times, even during this 25-day period, you cannot trade in securities of Bombardier Inc. if you are aware of, or have access to, any undisclosed material information as defined above, or if Bombardier Inc. has provided notice to its employees under its corporate Disclosure Policy that trading in Bombardier securities is prohibited.

  • Conflicts of Interest

    Avoid conflicts of interest, whether real or perceived, in the performance of your duties. A conflict of interest is considered to be any situation or arrangement where your personal activities or interests conflict with your responsibilities to Bombardier.

    Do not put yourself in a position where there is or could be an obligation to any third party who might benefit from such situation at the expense of Bombardier. Your actions must never lead to personal gain to the detriment of Bombardier's stated business interests.

    Situations of conflict of interest can also arise when you take on outside work that could compromise the diligent performance of your duties for Bombardier. Should such a situation arise, you are encouraged to discuss it with your supervisor or the Compliance Officer to assess the impact the outside work could have on your duties for Bombardier.

  • Illegal and Improper Payments

    Bombardier employees, suppliers, partners and other third parties are strictly prohibited from offering or taking any form of illegal or improper payment. Bombardier funds and assets must never be used for any unlawful purpose.

    As an employee, you must never approve, authorize or make any payment, gift or favour to any person in a position of authority, such as a government or corporate official, in order to obtain favourable treatment in negotiations or the awarding of contracts, or any other dealings.

  • Anti-Corruption Laws

    Bombardier complies with anti-corruption legislation in all jurisdictions where it operates. This legislation includes the Corruption of Foreign Public Officials Act of Canada (and its amendments), which applies to Bombardier's global business.

    Bombardier employees, suppliers, partners and other third parties (such as agents) must never make or approve an illegal payment to anyone, under any circumstances. If you are authorized to deal with third-party agents, you must comply with Bombardier's Policy Concerning Practices in International Business and Marketing.

  • Political Activity

    As a Bombardier employee, you may, subject to applicable laws, engage in legitimate political activity, as long as it is carried out on your own time and without using Bombardier property. You may seek election or other political office, but you must notify your supervisor or the Compliance Officer to discuss the impact your involvement may have on your duties at Bombardier. You may express your views on public or community issues of importance but it must be clear at all times that the views expressed are not those of Bombardier.

    Bombardier and its employees abide by all laws and regulations governing political contributions in every jurisdiction where the Corporation does business.

Bombardier's Code in Relationships with External Stakeholders

  • Customers

    Bombardier is committed to meeting the needs of its customers and strives to provide high-quality services and products. In customer relationships, employees behave in an ethical fashion. Sensitive, private or confidential customer information is safeguarded according to Bombardier's standards, with access restricted to those who have a need to know.

  • Suppliers, Partners and Third Parties

    Bombardier suppliers, partners and other third parties must know and agree to comply with the Code. All agreements with suppliers, partners and third parties must be in writing and must specify the goods and services to be provided and the fees to be paid. Such agreements must be in line with reasonable competitive and market practices, the principles established in this Code and relevant corporate policies.

  • Competition

    Bombardier employees and suppliers, partners and third parties must never employ unethical or illegal practices to collect competitive intelligence. Bombardier complies with antitrust laws wherever it does business.

    In general, we must guard against:

    • Price-fixing or arranged market segmentation; or
    • Monopolistic behaviour that aims to reduce competition

  • Governments

    Given its international and diversified nature, Bombardier is subject to a great variety of national and local laws and regulations. The Corporation and its employees and partners comply with all legal and contractual obligations in dealing with the various governments and regulatory agencies with which they are in contact. Employees and partners of Bombardier who deal with government officials and negotiate contracts are responsible for knowing and complying with all applicable laws and regulations, including those pertaining to lobbying activities.