How to Raise a Concern
The Code helps employees make an informed decision and describes
what actions to take. If employees are ever unsure about what
to do or believe someone has violated our standards, there are a
number of ways to report any concerns. These include a report to a
supervisor, manager or via Cobham's Helpline that is available
Reports can be made online or by telephone in a number of
different languages. The secure web address is www.cobham.ethicspoint.com
where employees can file a report, ask a question or follow up on a
report. Dedicated country telephone numbers are also provided
if an employee does not wish to complete an online form.
These numbers are also published on Cobham's intranet and on Ethics
Helpline posters which are displayed at each site.
The Helpline is hosted by a third party who answers all
calls. Caller ID is never used and no effort is made to trace
the calls. Employees may report anonymously, where local law
When an employee ("Reporter") contacts the Helpline, a case is
generated and entered directly on a secure server to prevent any
possible breach of security. Details of any given case are only
available to specific individuals within the company who are
charged with evaluating the report. This is overseen by the
Business Ethics & Compliance Committee (BE&CC).
Cobham is committed to maintaining confidentiality to the maximum
extent possible. A prompt and thorough investigation is conducted
and the Reporter is kept informed of progress during the period of
Once the investigation has been completed, the final report is
reviewed and approved by the BE&CC. Any remedial actions
will be taken to address violations of law, regulations and our
Code of Business Conduct or Corporate Policies. Appropriate
feedback will be provided to the Reporter, though not a full copy
of the investigation report. Cobham treats all
investigation-related information with upmost discretion.
For more information on results and actions taken from ethics
issues this year please visit our performance data page.
Ethics champions are appointed in each Sector and Business
Unit. At Sector level, the ethics champion is a trusted
senior manager nominated by the Sector President who acts as the
point of contact within the Sector and helps with the
implementation of any corrective actions within the
businesses. At Business Unit level, ethics champions are
trusted senior BU managers, trained as investigators and promoted
as the ethics champion for the business to whom BU employees can
bring questions or concerns in confidence.
The Business Ethics & Compliance Committee (BE&CC)
The BE&CC is a sub-committee of the Group Executive and
oversees the Cobham Ethics & Compliance Programme, the conduct
of Ethics Helpline investigations and other ethics and compliance
initiatives in each of the Sectors. The BE&CC has a
sub-committee, the Ethics & Compliance Working Group (ECWG),
responsible for the day to day management of these areas and who
reports quarterly to the BE&CC. The members of the
BE&CC and ECWG are listed below.