We have a clear purpose that unites all parts of the Company and a set of behaviours against which we judge ourselves; it’s what drives us to a higher level of performance, and we believe in pushing our potential to the maximum.
To underpin this commitment, and to create the right ethical culture, Cobham seeks to recognise employees who demonstrate the right behaviours. Annual employee performance reviews specifically assesses employees not just on ‘what’ they have achieved, but also by reference to ‘how’ they have achieved their objectives. Each measure affects the annual remuneration for each employee.
Our ethical standards, and the behaviours we encourage, are trust, integrity and doing the right thing in the right way. These reinforce our purpose ‘Every Mission Matters’.
Ethics Champions are appointed for each location. Ethics Champions are trusted senior leaders who carry out a range of compliance activities to help promote a good ethical culture, including acting as a ‘sounding boar’”, to whom business unit employees can bring questions or raise concerns in confidence. As such they also provide another channel for the raising of ethical concerns and other issues.
There is a full suite of induction training assigned to every new starter, which covers a range of topics. These include various aspects of the Cobham Ethics and Compliance Programme, such as Anti-bribery/Anti-corruption, Corporate Responsibility and Sustainability, Health & Safety and Anti-modern Slavery/Human Trafficking. There is additional induction training which is more tailored, depending on the role of the employee.
For existing employees, we provide annual online training, on various aspects of the Code of Business Conduct, which include a detailed section on Anti-bribery and Anti-corruption. This training is also provided on a face-to-face basis for those employees without computer access. This training is translated into the ‘core’ languages of our employees to maximise understanding. Training completion rates are tracked and reported to the Group Executive by way of oversight and this helps completion training on a timely basis. Feedback is requested from employees following the training to help measure its effectiveness.
More detailed training on Anti-bribery/Anti-corruption is provided to those employees who may face higher risks of bribery or corruption (e.g. by virtue of their function or the market in which they operate).
Members of the board are also provided with annual Code/Anti-bribery/Anti-corruption training.
Cobham's International Trade Controls team have sourced specific training for those employees involved in import and exports.
Cobham's United States Government Contracting Compliance team have created a suite of induction courses, covering a number of relevant topics depending upon the role of the individual concerned. Further face-to-face training is delivered, by the Director of US Government, to employees in relevant businesses on an ad-hoc basis throughout the year.