At Bombardier, we believe that open dialogue between governments, the public and the business community contributes to informed government decision-making and benefits the communities we are part of.
Our core values guide the decisions we take as an organization and how we act with public sector stakeholders.
Government decisions can impact our businesses and as such, we do advocate our views and positions on various subject matters. Our government interactions are compliant with applicable laws and regulations and subject to internal processes allowing us to meet required disclosures and reporting to authorities.
We adhere to the highest ethical standards when interacting with governments.
The Corporate Governance and Nominating Committee of the Board of Directors oversees the evolution of Bombardier’s corporate governance practices and policies, including the Code of Ethics (the Code), to ensure that Bombardier continues to comply with the highest standards of corporate governance.
Our Chief Ethics and Compliance Officer also ensures strict compliance with the Code and reports to the Audit Committee on a quarterly basis on various compliance matters.
Our internal policies consolidate business principles that apply to all employees, management and Board of Directors of Bombardier.
Our Code also indicates the channels available to employees or anyone to report compliance and violations concerns.
Code of Ethics
The Code explains the standards of behaviour that Bombardier expects from all members of the global Bombardier community, including the Board of Directors, management and employees at every level, in every country and from every Bombardier legal entity (including joint ventures where Bombardier has majority/controlling interest). It identifies guiding principles that help make decisions consistent with Bombardier’s values and reputation.
The Code states our approach for interactions with governments and it is expected from everyone who needs to follow the Code, to comply with all legal and contractual obligations in dealing with the various governments and regulatory agencies.
Anti-Corruption Policy and Gift and Entertainment Directive
Bombardier does not take part in nor tolerate any kind of corruption, whether passive or active, public or private. Bombardier’s Anti-Corruption Policy and Directive for Gifts and Entertainment state the core anti-corruption principles and standards regulating Bombardier in all its activities and dealings with third-parties.
The Anti-Corruption Policy and its supporting directive provide strict restrictions when dealing with public officials and prohibit all situations of conflict of interest or any illegal or improper payments, including facilitation payments.
In line with our internal policies, no political contribution to any political party, organization or event, or to any candidate for political office may be made by Bombardier and/or any employee on behalf of Bombardier unless proper prior approvals have been obtained. Certain of our employees who are United States citizens or lawful permanent residents engage in the political sphere through affiliated U.S. employee Political Action Committees (PAC). PACs are registered under the Federal Election Commission and comply with applicable legislation. PACs are solely funded through eligible contributors and enable them to support candidate or political parties.
Bombardier actively engages in the public debate and participates in public policy advocacy by communicating in a legal and appropriate manner with policymakers and regulators on issues that impact its businesses.
Our public advocacy activities are carried out under the governance of our Vice Presidents, Government Affairs, and Vice Presidents, Communications with the support of Bombardier’s legal department. They are responsible to ensure that employees who conduct lobbying activities are informed of their various obligations under applicable legislation and report those activities to Bombardier. Bombardier files reports pertaining to its Canadian federal lobbying activities with the Office of the Commissioner of Lobbying of Canada (OCL). You can view our reportable communications with designated public office holders in Canada on the website of the OCL.
Regarding Quebec provincial and municipal public office holders, information on Bombardier’s lobbying activities is available on the website of the Québec Registry of lobbyists which you can access via this link:
Similarly, the U.S. House of Representatives and United States Senate provide public access to Bombardier's federal lobbying reports in the United States. Such reports, filed quarterly pursuant to the federal Lobbying Disclosure Act, disclose Bombardier's lobbying expenditures, describe specific pieces of legislation that were the topic of communication and identify the lobbyist who made those communications on behalf of Bombardier.
Finally, Bombardier also files reports in other Canadian and U.S. jurisdictions (e.g. State, provincial or municipal) as required from time to time to comply with applicable local legislation.
Bombardier is a member of associations, trade organizations, industry group and coalitions in which it works with industry partners to advocate Bombardier’s or the industry’s interests.
Membership in or financial support of these various groups does not mean Bombardier agrees with or supports every position or lobbying action taken by them or their other members. We do not direct how membership dues that we and other members pay to such groups are used.
List of Memberships
In order to provide greater transparency on our engagement with governments, the below list includes some of the most significant organizations or associations whose role is to engage from a policy perspective and to which we pay yearly membership fees:
Aerospace Industries Association of Canada
Business Council of Canada
Canadian Association of Railway Suppliers
Canadian Chamber of Commerce
Canadian Manufacturers and Exporters
Canadian Urban Transit Association
Canadian Urban Transit Research & Innovation Consortium