The Business Ethics and Compliance Programme was developed following a risk based approach, creating the knowledge and structure to drive a world-class culture of integrity.

Our strategy is to implement, and continually develop. a world-class ethical and compliance programme, helping employees in their daily work by providing policies, procedures and training.  We encourage reporting of any issues as an early detection system, this helps identify a potential problem and allows us to take steps in order to prevent situations becoming serious, or to prevent any reoccurrence. 

The Programme, which encompasses Cobham’s Anti-bribery/Anti-corruption programme, is underpinned by 12 key principles:

  • Top-Level, Top Down ethical management committed to compliance with all laws and regulations and fostering a culture of ethical conduct. There are various aspects to this including: 
    • Recognising the importance of setting the tone from the top, David Lockwood writes an introductory message in the Code of Business Conduct, which emphasises the importance of demonstrating ethical behaviour.
    • The Business Ethics & Compliance Committee oversees the Programme and regularly reviews any issues, the investigations raised through the Helpline to ensure they are carried out consistently, efficiently and independently. 
    • The Cobham Board receives a regular update progress report, including details of the annual plan and any suggested improvements made.  Members of the Board are able to amend, challenge or provide feedback. 
    • The Audit Committee receives a regular report on the ethical issues that have been investigated and the outcomes and actions taken as a result. 
    • The Group Executive receives monthly reports on any specific ethics and compliance issues.
    • Cobham's message to employees is that senior leaders are fully committed to embedding ethics and compliance into the fabric of business operations, and they believe it is an important way to do business.  Encouragement is given to our management to live the values, to walk the walk and not just talk the talk.
  • Continual Executive oversight of the Programme by the Board, the Audit Committee, the Group Executive, the Corporate Responsibility and Sustainability Committee and Business Ethics & Compliance Committee
  • Establish and maintain Code of Business Conduct (CoBC or Code) and Corporate Framework
  • Establish and maintain policies and procedures proportionate to ethics and compliance risks
  • Periodic risk assessment of areas of ethics and compliance (e.g., bribery, USG contracting and export controls)
  • Appropriate due diligence on employees, including potential employees, and intermediaries who will perform services for or on behalf of the Group
  • Regular training on the Group's ethical standards for employees and intermediaries as appropriate
  • Monitoring and auditing of business practices, policy requirements and internal controls for (i) compliance with the Code, Corporate Framework and Group policy requirements and processes and, (ii) prevention of criminal conduct and fines and penalties
  • Periodic evaluation of the programme's effectiveness
  • Operate and publicise a Helpline by which employees may report suspected instances of improper conduct and encourage employees to make such reports
  • Promoting and enforcing the programme by providing both rewards for demonstrating good ethical behaviour and disciplinary actions for unethical or criminal conduct
  • Timely response to and disclosure of criminal conduct where appropriate and credible evidence exists

Cobham is committed to creating a strong ethical culture to protect our reputation, by empowering people to act correctly and to do the right thing in the right way. 


The Cobham Ethics and Compliance Programme (CECP) is managed on a day to day basis by Group Legal & Compliance.  Each year the CECP plan is approved by the audit committee, which is a Cobham plc Board committee.  Oversight of management of the CECP during the year is provided by the Business Ethics and Compliance Committee, which comprises the CEO, CEO, EVP HR, the Group General Counsel and other senior leaders in Cobham. The audit committee provides additional oversight of the CECP, receiving a report from the Group General Counsel on a regular basis.  The Group General Counsel reports to the CEO and is also a member of the Group Executive, and as such has a reporting line for any significant concerns directly to the Board.


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