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 unethical.
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 Anti-Bribery/Anti-Corruption Policy.
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.