Conducting Business Ethically
Cobham competes on the basis of its products, technology, quality, service, price and similar competitive factors.  Cobham does not seek to gain any improper advantage through the use of any unfair dealings or practices. 

Cobham is committed to complying with all competition and anti-trust laws applicable in the countries where it operates. 

Working with Third Parties
Cobham endeavours to develop trusted interpersonal and customer relationships.  We understand our customers' needs, deliver on customer commitments and strive to exceed them every day by staying committed to remaining "customer focussed".

Cobham expects its suppliers, contractors, and all other third parties to maintain the highest standards of integrity and to comply with laws and regulations that govern their business and the business they do on Cobham's behalf.  Cobham requires all third parties to comply with Cobham's Code of Business Conduct. 

Intermediary Engagement Process
Cobham's representatives, including agents, advisors, consultants, dealers, resellers and distributors (collectively "Intermediaries") are an extension of Cobham and are chosen and monitored carefully.  All such Intermediaries  are required to comply with applicable laws and regulations, as well as Cobham policies and Cobham's Code of Business Conduct or equivalent.  All Intermediaries must first be approved appropriately by following the Intermediary Engagement Process. 

The Intermediary Engagement Process is applicable to all Intermediaries used by Cobham businesses.  Cobham has established a robust risk assessment and due diligence process to carry out checks on any Intermediary that represents or promotes the interest of Cobham.  An Intermediary must be registered in Cobham's central database and is then risk assessed and categorised accordingly.  Appropriate on-boarding due diligence review is conducted according to risk, with a business case submitted for high and moderate risk levels.  This business case is approved by the Intermediary Review Board (IRB).  The IRB is chaired by Stephen Powner (Senior Vice President, Head of Contracts, Commercial and Legal), and other members are Mark Thomas (Vice President Legal & Compliance) and the other Senior Vice Presidents Commercial and Contracts for each Sector. 

Once approved, agreements with Intermediaries have a fixed term depending upon the risk level.  Agreements contain audit rights and a clause which allows immediate termination should any breach of failure of obligations occur, which includes violations of any applicable anti-bribery/anti-corruption laws or regulations. 

During the term of the agreement, additional due diligence is performed to confirm that the services are being provided appropriately, that any approval conditions have been met and that there have been no changes that may increase the bribery risks. 

When the agreement is close to expiry, if Cobham wishes to continue the relationship with the Intermediary, the Intermediary Renewal Process must be followed. This process includes a review of current due diligence checking for any changes in circumstances or any red flags raised which changes or increases the bribery risks.  Such review must be approval by the approving body prior to a new agreement being executed for the term permitted.

Offset Obligations
Cobham monitors any contract offset obligations on a regular basis to ensure compliance to all laws and regulations, including the risk that an offer to fulfil offset obligations could be used in a corrupt or otherwise inappropriate manner. 

Human Rights, Anti-Slavery/Anti-Human Trafficking
Cobham supports the principles contained in the Universal Declaration of Human Rights and seeks to reflect these in the context of its business activities wherever possible.

Cobham respects the Human Rights of its employees as set down in the International Labour Organization Declaration on Fundamental Principles and Rights at Work. These include the right to an injury-free workplace, a statutory minimum wage, freedom of association,  the elimination of slavery and human trafficking (including forced, compulsory, bonded or child labour), and the elimination of all forms of discrimination in the workplace.

Cobham expects its suppliers to adopt the same principles as Cobham itself and has therefore implemented a supplier due diligence process to ensure that no Cobham suppliers are involved in slave labour or human trafficking.  Training on Human Trafficking and Forced Labour is provided to all relevant as well as to Cobham employees to raise awareness of these issues. 

Customer Relations
The diversified nature of our business means that Cobham sells its leading-edge technologies world-wide. We operate in a number of markets, with a significant presence in the defence industry. We specialise in supplying components and subsystems for the military equipment that our customers manufacture. This means we are often a second-or third-tier supplier to the end user. We do also deal directly with governments and military organisations, both supplying products and providing services.

Cobham operates in a highly regulated industry designed to protect the national security and foreign policy objectives of the countries in which we operate. We comply with the laws and regulations of these countries (including export controls) which limit the sale of our products/services outside a list of approved countries.

Government Relations
National governments are some of the largest end users of our products and services, and we engage with them regularly to ensure we understand their needs and priorities. We aim to ensure governments recognise our skills and capabilities, and how our products and services can support their objectives.

We are transparent in all our dealings with governments, and comply with all applicable laws. All employees and agencies who engage with governments must do so in line with our Code of Business Conduct.

Our internal government relations teams carry out most of our work in this area. The largest such team is based in Washington, D.C., as the United States Government is one of our most important customers. We also communicate regularly with the governments of the UK, Australia and India (among others).

We employ several professional government relations agencies in the United States, and engage on specific issues through industry bodies such as Aerospace, Defence and Security (ADS) in the UK and the Aerospace Industries Association (AIA) in the United States.

Our priority is to ensure we continue to have access to governmental contracts. In this context we engage directly with the United States Government to ensure fair treatment for foreign-based companies such as Cobham.

Cobham does not make any corporate contributions to political parties. In the United States, our employees can make voluntary contributions through our Political Action Committee (PAC), which operates in line with the requirements of the Federal Election Campaign Act.  The PAC is permitted to make bipartisan contributions to politicians who are broadly supportive of business - and of our industry in particular.

Governments in some parts of the world have more stringent requirements with regard to gifts, entertainment and hospitality offered to officials.  Employees dealing with Government officials are required to make sure they understand any rules and regulations that apply in the country they are dealing with. Any employees who are  in any doubt about their obligations should seek advice from the Cobham Legal Team.  This includes dealing with Government delegations, where it is generally acceptable to demonstrate and explain Cobham's products and to make delegates feel welcome but completely unacceptable to attempt to obtain an improper advantage by doing so. 

Corporate Framework
The Cobham Corporate Framework sets out the Company's governance structure including the roles of Board and its committees as well as the responsibilities of the Group Executive and of all Cobham employees.  It also sets out the key requirements of Cobham's policies, processes and procedures which have been developed to help employees understand their responsibilities.  These requirements cover many areas of Cobham's business activities and are regularly reviewed to ensure they are kept current.