Cobham is focussed on conducting business in a lawful and
ethical way at all times. This includes educating employees about
what to do if they are offered or are tempted to accept a bribe or
other corrupt benefit, or to do anything else unlawful or
All Cobham employees must comply with the
Anti-Bribery/Anti-Corruption Policy at all
times. Employees must never offer, promise, or agree to
receive or accept a bribe, kickback, facilitation payment or other
unlawful benefit, or engage in any other prohibited activity.
The prohibition applies to business dealings in all circumstances.
This includes dealings with those representing other organisations
as well as private individuals and government/public officials. It
also applies irrespective of the motive - whether that may be to
obtain or retain business or to otherwise influence an individual,
an organisation or a government/public official to act improperly
for the benefit of Cobham.
Gifts, Entertainment and Hospitality
Cobham understands that the exchange of gifts and entertainment is
a cultural expectation in many parts of the world, and can often
promote successful working relationships and foster goodwill.
However, as a Cobham employee, you must also be are aware that
there is a risk that the giving and receiving of gifts,
entertainment or hospitality may be perceived as an unlawful
attempt to improperly influence a business decision.
Employees are therefore required to become familiar with and to
follow the Gifts & Hospitality Policy. The principle underlying
this policy is the need to be mindful that regardless of value,
the perception of undue influence must always be carefully
considered before acceptance.
Gifts and Hospitality Policy
Facilitation payments are defined as unofficial payments to a
Government Official to expedite or secure the performance of a
routine action, which has already been paid for or to which Cobham
is already legally entitled. These can be contrasted with official
payments to government authorities which are made transparently and
are properly accounted for e.g. a payment made to a passport agency
to have a replacement passport issued urgently. Facilitation
payments are prohibited under the Cobham
Charitable and Political Donations
Cobham does not seek to discourage employees from supporting bona
fide charitable organisations through their own fundraising or
individual efforts or from personal donations outside and
unconnected to their employment. However, making charitable
gifts/donations or political contributions using Cobham funds can
be classified as a form of bribery/corruption and is prohibited
under the Cobham Anti-Bribery/Anti-Corruption Policy.