Cobham

The most important thing we build is trust

 

If an employee believes someone has violated our standards, we want them to tell us so that we can look into the matter and correct any problems.

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 24/7. 

 

Cobham's Helpline

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 permits.

 

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 investigation.

 

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

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.

Profiles

Stephen Powner (120,120)

Stephen Powner

Business Ethics & Compliance Committee Chair and Ethics and Compliance Working Group Chair 

Stephen joined Cobham in January 2016 as SVP, Head of Contracts, Commercial & Legal and has been a practising lawyer for almost 30 years. Stephen's team at Cobham is responsible for global oversight of all contracting and commercial aspects of the customer and supplier engagement process as well as Cobham's compliance with all legal and regulatory requirements and ethical standards. 

Mark Thomas (120,120)

Mark Thomas

Business Ethics & Compliance Committee Member and Ethics and Compliance Working Group Member 

Mark is Vice President Legal & Compliance for Cobham plc.  He has been with Cobham since August 2011. Before that he worked for a large US aerospace manufacturer and in private practice.

 
 
Mark Barclay (120,120)

Mark Barclay

Business Ethics & Compliance Committee member 

Mark is the President of Cobham Mission Systems Sector and has more than 30 years of international experience in the defence, aerospace and services industries. Mark is a chartered engineer, a Fellow of the Institute of Engineers and Technology, and a Fellow of the Association of Programme Management.

Michel Emelianoff (120,120)

Michel Emelianoff

Business Ethics & Compliance Committee member 

Michel joined Cobham as President of Cobham Communications and Connectivity Sector in December 2015. Michel has a diverse range of experience starting his career as an engineer then moving into the telecoms including 6 years based in California, USA and France. Michel lives near Paris, France and is fluent in French, English and German.

 
 
Peter Nottage (120,120)

Peter Nottage

Business Ethics & Compliance Committee member 

Peter Nottage is President of Cobham Aviation Services. Peter has more than 30 years' experience within the aviation industry, commencing his career as an Aircraft Maintenance Engineer in 1982.  Peter has a strong technical and commercial background with considerable experience in managing large, complicated procurement and mobilisation projects for Government and Defence performance-based contracts in numerous countries.

Martin Burgess (120,120)

Martin Burgess

Business Ethics & Compliance Committee member 

Martin is the Executive Vice President of Human Resources and Communications.  Martin started at Cobham in 2006 and is a member of the Group Executive. Martin has over 30 years experience working at senior levels in Human Resources in large Aerospace, Defence and Technology organisations. Martin has a BA in Modern History and a Postgraduate Degree in Law.

 
 
Andrew Shepherd (120,120)

Andy Shepherd

Ethics and Compliance Working Group member 

Andy is the Senior Vice President of Human Resource Operations.

Although not a formal member of the Business Ethics & Compliance Committee, Senior Vice President, Internal Audit and Assurance, is an attendee at all committee meetings. 

Do PostBack