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.