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 (email@example.com). Employees may report anonymously, where local law permits.
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.