Business Code of Conduct
Fundamental to the values of Hexcel is the respect for the privacy and dignity of all individuals, as reflected in
our Code of Business Conduct. Our salaried employees annually certify their compliance with the
Code, which includes a pledge to comply with all applicable laws in the countries where Hexcel does business.
Supplier Code of Conduct
We require our suppliers to comply with certain requirements and to maintain appropriate management systems to ensure
adherence to these requirements, including compliance with laws related to equal opportunity and nondiscrimination,
and laws prohibiting human trafficking and slavery. Hexcel continues to develop its worldwide supplier network and
has an established program for supplier quality and compliance auditing. The majority of our supplier spend is from
suppliers manufacturing in the U.S., Europe, Japan and South Korea, all regions with a deep respect for human
rights.
Anti-Corruption Policy
Hexcel strictly forbids bribery and corruption of any kind. This includes a prohibition on all facilitation payments.
Hexcel believes it is essential that we operate with the highest level of integrity in accordance with the Hexcel
Values, and compete solely on objective commercial terms. Hexcel has an Anti-Corruption Policy which sets forth our
policy, practices and processes on corruption for all Hexcel employees, officers, directors and third party
intermediaries world-wide, along with a robust set of internal controls designed to deter, detect and prevent
potential violations. We provide our employees with extensive resources and training for the practice of ethics and
compliance that correspond with our Hexcel Values and to ensure compliance with the U.S. Foreign Corrupt Practices
Act and the laws and regulations of other countries where we do business. These resources and training include
annual ethics and compliance training for all employees and more detailed anti- corruption training for employees
directly interfacing with our customers, suppliers and intermediaries. Hexcel also makes available numerous
resources for employees to seek guidance on anti-corruption and other legal matters, and various methods for
employees and third parties to report any anti-corruption concerns. We conduct risk based due diligence on all of
our third party intermediaries and require them to annually confirm their compliance with global anti-corruption
laws and our Anti-Corruption Policy.
Fiscal Transparency
At Hexcel, we are committed to compliance with the tax regulations in force in the countries in which we operate, consistent with our values and our internal policies and procedures. The majority of our business is in six countries, all of which have robust tax laws and oversight. These six countries include the United States, France, United Kingdom, Spain, Germany and Austria. More than 95% of our long-lived assets and more than 90% of our employees are located in these six countries. Further, approximately 80% of our purchasing in fiscal year 2022 and the prior three years was invoiced from these six countries and in both 2022 and 2019, more than 95% of our tax payments were paid in these six countries (note that tax payments by country in 2021 and 2020 were distorted by losses in certain regions due to the impact of the Covid-19 pandemic on Hexcel’s business).
Modern Slavery Act Disclosure
We will not tolerate modern slavery, forced or child labor, nor deal with businesses that do. We expect the same of
our partners and suppliers in our worldwide supply chain. And, we will act with speed should any audit or accusation
uncover a violation of these principles. Learn more:
Conflict Minerals Policy
Data Privacy and Cybersecurity
Hexcel respects individuals’ privacy and is committed to protecting it.
At Hexcel, we are committed to the security of our products, services and data.
Employee Training
We provide recurring training on relevant ethics, compliance, diversity and inclusion, and environmental health and safety topics as well other pertinent topics and laws affecting our
global business. In addition, we require targeted groups of employees to complete
online training to reinforce their understanding of specific values, laws or regulations that are highly
relevant to their roles, such as anti-corruption, antitrust/competition, harassment/discrimination, conflicts of
interest and trade compliance.
Political Contributions Disclosure
Hexcel has historically not made corporate contributions to political candidates, parties or other organizations.
Hexcel operates a political action committee to allow its eligible U.S. employees to make voluntary contributions
that are used to contribute to candidates for federal office who support issues and concerns of importance to
Hexcel. The Hexcel PAC donated $18,000 in 2022, did not make any donations in 2021, donated $5,000 in 2020 and $10,000 in 2019.