The most important thing we build is trust


The Business Ethics & Compliance Programme was developed following a risk based approach, creating the knowledge and structure to drive a world-class culture of integrity.

The Programme is underpinned by 12 key principles:

  • Top-Level, Top Down ethical management committed to compliance with all laws and regulations and fostering a culture of ethical conduct
  • Continual Executive oversight of the Programme by the Board, the Audit Committee, the Group Executive, the Corporate Responsibility and Sustainability Committee and Business Ethics & Compliance Committee
  • Establish and maintain Code of Business Conduct (CoBC or Code) and Corporate Framework
  • Establish and maintain policies and procedures proportionate to ethics and compliance risks
  • Periodic risk assessment of areas of ethics and compliance(e.g., bribery, USG contracting and export controls)
  • Appropriate due diligence on employees, including potential employees, and intermediaries who will perform services for or on behalf of the Group
  • Regular training on the Group's ethical standards etc  to employees and intermediaries as appropriate
  • Monitoring and auditing of business practices, policy requirements and internal controls for (i) compliance with the Code, Corporate Framework and Group policy requirements and processes and (ii) prevention of criminal conduct and fines and penalties
  • Periodic evaluation of the programme's effectiveness
  • Operate and publicise a Helpline by which employees may report suspected instances of improper conduct and encourage employees to make such reports
  • Promoting and enforcing the programme -by providing both rewards for demonstrating good ethical behaviour and disciplinary actions for unethical or criminal conduct
  • Timely response to and disclosure of criminal conduct where appropriate and credible evidence exists

Our vision is to create a strong ethical culture to protect our reputation by empowering people to act correctly and to want to do the right thing. 


Our strategy to do so is to implement and continually develop a world-class ethical and compliance programme, helping employees with day to day work by providing policies, procedures and training.  We encourage reporting of any issues as an early detection system which helps identify such issues and allows us to take steps in order to prevent situations becoming serious or to prevent any reoccurrence. 


Employee Training
We provide all employees with training on business ethics.  This is primarily online training.  We train employees annually on Code of Business Conduct and Anti-bribery and Anti-Corruption.  There is a full suite of training when employees start with Cobham which covers a number of other subjects such as Corporate Responsibility and Health & Safety and more tailored training depending on the role of the employee. 


Cobham's International Trade Controls team have sourced specific training for those employees involved in import and exports.


Cobham's United States Government Contracting Compliance team have created a suite of courses covering a number of relevant topics depending upon the role of the individual concerned. 

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