We pursue the highest ethical standards in all aspects of our
business. Ethical behaviour is an asset that we value, encourage
Our ethics and compliance programme is underpinned by twelve key
- Top-Level, Top Down ethical management
committed to ethical conduct, compliance with all laws and
regulations fostering a culture of ethical conduct and
- Continual oversight of the Programme by the
Board, the Group Executive, the Corporate Responsibility and
Sustainability Committee and Business Ethics and Compliance
- Establish and maintain Code of Business Conduct
(CoBC) and Corporate Framework (CF).
- Establish and maintain procedures proportionate to
ethics and compliance risks,
- Periodic risk assessment of certain areas of ethics and
compliance (e.g., bribery, USG contracting and export
- Appropriate due diligence on employees,
including potential employees, and third parties who will perform
services for or on behalf of the Group.
- Periodic and practical communications of, and training
on, the Group's ethical standards, policies, etc to
employees and, as appropriate suppliers, partners and other third
- Monitoring and auditing of business practices,
policies, and internal controls for (i) compliance with
the CoBC, CF and Group policies and (ii) prevention of criminal
conduct and fines and penalties.
- Periodic evaluation of the program's
- Maintain publicised internal reporting
mechanism by which employees may report suspected
instances of improper conduct and which encourages employees to
make such reports.
- Promoting or enforcing the programme through incentives
and disciplinary actions for unethical or criminal
- Timely response to and disclosure of criminal
conduct where appropriate and credible evidence
All these have an ethical dimension, but the following are worth
Establish and maintain Code of Business Conduct
Our Code of Business Conduct, reviewed and issued annually,
is our cornerstone document and sets out our core
ethical values and culture. The Code of Business Conduct describes
the levels of personal integrity we expect from all employees and
how to deal with possible breaches. The Code of Conduct has been
translated into Danish, French, Finnish, German, Swedish and
Latin-American Spanish and is available for download in English. It has also been
circulated to all employees to ensure all have access to the
standards of behaviour that Cobham expects.
The Code of Business Conduct is just one part of our
comprehensive ethics and compliance programme. This programme
creates the knowledge, structures and processes to ensure we comply
with all applicable laws and regulations, and drive a world-class
culture of integrity and ethical behaviour throughout Cobham.
We have clear management responsibilities
for implementing our ethics and compliance programme. In addition,
we have separate processes in place to maintain transparent and
appropriate relationships with customers and governments.