Cobham

 

 

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 such concerns. These include raising the issue with a supervisor, manager, Human Resources or via Cobham's Helpline. In addition, a confidential internal email address is also provided to employees (ethicsofficer@cobham.com). Employees may report anonymously, where local law permits.

Cobham's Helpline

Cobham’s Helpline is hosted and maintained by an independent third party.  Concerns or queries can be raised to the Helpline online, or by telephone, in a number of different languages.  The online and telephone routes are also available for following up on initial concerns or queries.

The secure web address for Cobham’s Helpline is cobham.ethicspoint.com, where concerns can be raised  or questions asked using an online form.  Dedicated local in-country telephone numbers are available for reports to be made via the telephone if preferred.

These telephone numbers are published on Cobham's extranet ‘Cobham Connect’, as well as on Helpline posters which are displayed at each site.  The telephone Helpline is hosted by a third party independent of Cobham who answers all calls.  Caller ID is never used and no effort is made to trace the calls. When a report is made to the Helpline, a case is generated and entered directly on a secure server. Cobham is committed to maintaining confidentiality around any issue to the maximum extent possible. Details of any given case are only available to specific individuals within the company who are involved in investigating the issue. 

The investigation is overseen by the Ethics & Compliance Working Group (ECWG). A written process document (The Ethics Investigation Process or EIP) provides a guidance framework for conducting Helpline investigations, including escalation routes to senior staff for consideration and disposition, (which may include notification to authorities), as appropriate in each case.  The EIP is reviewed and updated as required. The ECWG review all helpline reports promptly after being received. The ECWG appoints an appropriate independent investigator from a pool of trained investigators to investigate Helpline concerns.  If the issue is serious, (as defined in the EIP, but which includes fraud or bribery), the matter is escalated to senior leadership at the outset - the CEO in the case of bribery - and the ECWG may assign an appropriately qualified investigator who is external to Cobham.  The investigator is responsible for ascertaining the facts.  The individual who made the report is kept informed of progress during the investigation.  

Once the investigation has been completed, the final report is reviewed by the relevant ECWG members.  Appropriate feedback is provided to the individual who raised the concern. Corrective actions may be recommended by the investigator, and/or the ECWG, and implemented by the relevant business.     

For more information on the number of Helpline issues raised, Helpline investigations and their outcomes, including the number of cases resulting in disciplinary action and employee terminations, please visit our performance data page.

The Business Ethics & Compliance Committee (BE&CC)

The BE&CC is a sub-committee of the Group Executive. It oversees the management of the Cobham Ethics & Compliance Programme (CECP), the conduct of Ethics Helpline investigations, and other ethics and compliance initiatives in each of the Sectors and at Group level.  The BE&CC has a sub-committee, the Ethics & Compliance Working Group (ECWG), responsible for the day to day management of these areas. The ECWG reports regularly to the BE&CC.  These reports include information on Helpline cases and their status, together with information on any trends. The members of the BE&CC and ECWG are listed below. 

 

Profiles

Gillian Duggan (120,120)

Gillian Duggan

Business Ethics & Compliance Committee Chair 

Gillan joined Cobham in 2017 as EVP HR & Communications of Cobham plc.  Gillian was previously Group HR Director at Berendsen plc, a FTSE 250 company.

David Lockwood (120,120)

David Lockwood

Business Ethics & Compliance Committee Member and CEO of Cobham plc. 

David joined Cobham in 2016 as the CEO.  Prior to joining Cobham, David was CEO of Laird plc.  He has also held a number of senior industry positions at BT, Thales and BAES Systems.  David has worked with the UK Cabinet Office as part of the Cyber Security Industry Working Party developing the nation’s strategic agenda for cyber security.

 
 
David Mellors (120,120)

David Mellors

Business Ethics & Compliance Committee Member and CFO of Cobham plc. 

David joined Cobham in 2017 as the CFO.  Prior to joining Cobham, David was the CFO of QinetiQ.  David has also held positions at Logica plc, CMG, Rio Tinto and Price Waterhouse.

Chris Shaw (120,120)

Chris Shaw

Business Ethics & Compliance Committee Member and COO of Cobham plc. 

Chris joined Cobham in 2015 and became Chief Operations Officer in 2017.  As a member of Cobham’s Group Executive team, Chris is responsible for Operations, Procurement, Quality, Continuous Improvement, Engineering, Programme Management, IT, and Safety, Health and Environmental (SHE). With a background in both the automotive and aerospace industries, Chris previously worked for Goodrich Actuation Systems, and PSA Peugeot Citroen.

 
 
Mark Thomas (120,120)

Mark Thomas

Ethics and Compliance Working Group Member 

Mark is a practising lawyer who joined Cobham in 2011 as VP Legal & Compliance having previously worked in the aerospace division of GE and before that in private practice.  Mark is responsible for overseeing ethics investigations on a day to day basis.

Rachel Cass (120,120)

Rachel Cass

Ethics and Compliance Working Group Member. 

Rachel joined Cobham more than 20 years ago and is a long-standing member of Cobham’s HR Leadership Team, providing a vital link between the HR community and the Ethics and Compliance Working Group.

 
 
Gerhard Du Plessis (120,120)

Gerhard Du Plessis

Business Ethics & Compliance Committee Secretary and Chair of the Ethics & Compliance Working Group 

Gerhard joined in January 2019 as Group General Counsel and also assumed the role of Company Secretary in April 2019.  He is a qualified lawyer in the United Kingdom and South Africa with over 20 years of experience working internationally including at ExxonMobil, Invensys, the Smiths Group and Laird.  He has held various senior in-house and executive positions overseeing the identification and management of legal and compliance risk.

The BE&CC provides a report to the audit committee of the Board on ethics and compliance matters on a regular basis.  The report includes information on Helpline cases together with information on any trends etc.

An additional escalation route for serious ethical issues is provided through the Group General Counsel (GC). In addition to acting as secretary of the BE&CC, the GC reports to the CEO and as such, has a direct escalation route to the Board for further consideration of such matters, including any required disclosures. 

The BE&CC set KPIs for the CECP on an annual basis to help measure the effectiveness of the programme.  The results of the KPIs are reviewed and the following year’s plan updated as necessary. 

 

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