Code of Business Conduct

Our most important document

COBHAM SATCOM PRIVATE

CODE OF BUSINESS CONDUCT

Table of Contents
Introductory message 3 Classified and national security information 16
Document retention 16
Our Ethics 4
Global trade compliance and controls 17
Doing what’s right 5 Inside information 17
What’s expected of employees? 6 Customers and other partners 18
What’s expected of managers? 7 Suppliers 18
What are the consequences of violating our Code? 8 United States Government officials 18
Zero retaliation 8 Working with Government officials 18
Getting help 8 Intermediaries and representatives 19
See it? Say it… Speak Out! 8 Fair competition 19
Special Security Agreement (SSA) 9 Corporate opportunities 20
What happens when you contact the Helpline? 9 Trade associations 20
What happens next? 9 Communities and the public 21

Our Business 10 Our People 23

Corporate Framework and policies 11 Our People 24
Anti-bribery, anti-corruption and improper payments 11 Health and safety 24
No facilitation payments 11 Prevention of workplace discrimination and harassment 24
Acceptable gifts and hospitality 12 Prevention of sexual harassment 25
Accurate records 13 Inappropriate pressure to meet the numbers 26
Delivering accurate cost and pricing data 13 Equality, diversity and inclusion 26
Recording labour and other costs 13 Teamwork and collaboration 26
Anti-fraud 14 Conflicts of interest disclosure 27
Anti-money laundering 14 Drug and alcohol free workplace 28
Anti-tax evasion 14 Prevention of workplace violence 28
Price sensitive information reporting obligation 15 Privacy and data protection of personal information 29
US Government contractor disclosure requirements 15 Careful use of social media 29
Confidentiality and intellectual property 15
Protect company assets 16 Five Key Takeaways 30
Information classification and handling 16
Helpline Contact Details 31

C O B H A M P R I V A T E – This version of our Code introduced August 2020, replaces any previous versions issued and applies worldwide to all officers, directors and employees of Cobham SATCOM and its subsidiaries. 2
CODE OF BUSINESS CONDUCT

Introductory Message
At Cobham SATCOM, we have a clear Our Code can’t cover every eventuality or every challenge you
may face, but it serves as a guide to help you make the right
purpose that unites; it’s what drives us to a decisions. When faced with a difficult decision or if you’re ever
higher level of performance, and we believe unsure about what to do, ask your supervisor, manager or Human
in pushing our potential to the maximum. Resources representative. If you’re uncomfortable doing that, you
can use the Helpline to ask your question or to raise a concern.
Regardless of the size or complexity of the
job ahead, we believe in putting the same The global business environment in which we operate grows ever
tougher and presents us with unprecedented challenges. Some
high-level of scrutiny, tenacity and energy things though remain clear and constant, we maintain a zero
into everything we do - for us, Every Mission tolerance policy towards any kind of bribery or corruption, or
Matters. retaliation for raising a concern.

Our ‘One Winning SATCOM’ culture of trust, acting with integrity

Our reputation is founded on a culture of trust, acting with at all times and of doing the right thing in the right way, helps
integrity and of doing the right thing in the right way. Success protect our business, our reputation, our stakeholders and every
depends upon our reputation. employee. It’s up to all of us to maintain a good culture and to
shape the business into one that we all want to work for and are
Our Code of Business Conduct, or ‘Code’, is the centrepiece of our
proud of.
commitment and emphasises the importance that each of us plays
in building trust with each other, our customers, and partners.

Our Code sets out how we can have a clear, shared purpose that
unites all parts of Cobham SATCOM. Work which compromises our
culture, is not work we want to do and you should be confident
that, if you make the right decision and walk away, it will be
supported by believes that ‘success is nothing without integrity’. Leif Ottosson

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CODE OF BUSINESS CONDUCT

Our Ethics
This section of our Code describes the culture we
expect all employees to embrace, to make sure we
operate in a fair, ethical, legal and safe manner,
which enables us to work together towards our
common goals, and to the highest standards of
business ethics.

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CODE OF BUSINESS CONDUCT

Doing what’s right

We must all comply with the relevant laws and
regulations in the countries in which we operate.

Our Code requires the highest degree of integrity in all interactions, with
each other and with all of our stakeholders such as: partners, suppliers, local
communities, governments, and the general public.

Our Code is more than a company policy, it’s integral to our success:

• It sets out the same rules and standards for all

• It protects our reputation which is key to our business success

• It keeps us operating within the laws and regulations

• It helps us to operate ethically

Each of us are responsible for our own actions and the decisions we make.
You will not be able to justify, or be excused from the consequences of your
actions, if prohibited by the Company, or because you were ordered to perform
the action by someone higher in authority. No one is ever authorised by the
Company to direct another employee to commit a prohibited act.

OUR
CODE IS MORE
THAN A COMPANY
POLICY, IT’S INTEGRAL
TO OUR SUCCESS

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CODE OF BUSINESS CONDUCT

What’s expected of employees?

In order to uphold our Code we must: applicable to your own assigned duties and responsibilities, and conduct yourself
accordingly. Remember that compliance with the letter of the law is not always
• Understand and follow the laws and regulations that are applicable to your role. enough and we must strive to act in accordance with its spirit i.e. the principle
• Read and understand your obligations under our Code and other policies. behind the law.
• Complete all company training in a timely manner.
In a business situation, if faced with a difficult decision, don’t take immediate
• Respect each other, be inclusive, champion diversity, embrace individuality and action, step back and consider these questions first:
listen to others.
• Fully co-operate with any internal or external investigations, audits or courts. • Is it legal?
Never discuss details of investigations with others without specific permission.
• Is it in line with our culture or the behaviours we’ve set for ourselves?
• Never alter or destroy any documents or electronic records in response to
litigation, an investigation or an audit. • Does it comply with our Code or Corporate Framework policies and policy
• Notify Legal if you learn that a government agency is conducting an requirements?
investigation or is making enquiries about a suspected violation.
• Would other people support your decision if you told them?
• Report any potentially price sensitive information as soon as you become aware
of it. • Would you feel comfortable if you read about your actions in a newspaper?
• Report all violations or suspected violations of our Code, company policy, or
If you hesitated when answering or your answer to any of these questions is ‘no’,
violation of law or other alleged misconduct.
then don’t do it.
• Ask your supervisor, manager, Human Resources or contact the Helpline for
advice, if you’re ever unsure about what to do.

You must make sure you’re acquainted with the legal standards and restrictions

“INTEGRITY IS
DOING THE RIGHT THING,
EVEN WHEN NO ONE IS WATCHING”
C.S. Lewis
Writer and Scholar

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CODE OF BUSINESS CONDUCT

What’s expected of managers?

Our leaders should embrace our purpose and behaviours,
execute our strategy, lead by example and deliver on their
promises:
• Lead by example, we ‘walk the walk’, we don’t just ‘talk the talk’. We act with integrity
and trust that our team want to do the right thing. We help them to do so in the right
way.
• Talk with our team about ethics and integrity.
• Work together as a team, cultivate a workplace environment that embraces our purpose
and behaviours, one where everyone is proud to work.
• Listen to others and encourage frank and open discussions by having an ‘open door’
philosophy.
• Maintain a workplace which is inclusive and free of harassment and discrimination.
• Allow our teams time to complete assigned training.
• Make sure working relationships do not create, or give the appearance of, favouritism
with all decisions being based on job performance.
• Ensure any ethical issue raised is treated confidentially, sensitively, and dealt with
appropriately, including escalating it to the most appropriate company resource.
• Allow our teams time to co-operate with internal investigations.

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What are the consequences See it? Say it… Speak Out!
of violating our Code? We believe that our employees are our most important asset and by creating an open
channel of communication, we can maintain a positive and comfortable work environment
Failure to comply with any provision of this Code is a serious violation and may result for everyone.
in disciplinary action, including termination of employment. Such consequences may
apply to employees who commit misconduct, and to those who condone it, or fail to However, sometimes things can go wrong. If something isn’t right, we want you to tell
report it. someone so the situation can be looked into and any problems addressed before they
become too serious.

Zero retaliation Our Helpline is available 24/7 and reports can be made online or by telephone in a number
of different languages. Calls to the Helpline are answered by a third party, caller ID is never
used and no effort is made to trace a call. Reports can be made anonymously, where local
We want you to ‘speak out’ and share your concerns or issues. That’s why we don’t law permits, but the more information that is provided, the easier it is to investigate any
tolerate retaliation against anyone raising a concern. If you suspect you’ve become issue and to respond. We have a zero tolerance towards retaliation, so concerns can be
a target of retaliation, you should raise the matter to an appropriate company raised without fear of retribution.
resource.

Getting help
Our Code helps you understand what you need to do should you think something is
wrong. Always be aware and curious, ask questions and if necessary bring concerns
to the attention of a relevant company resource or make a report via the Helpline.
The sooner we identify an issue, the sooner we can stop it becoming serious.

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CODE OF BUSINESS CONDUCT

Special Security Agreement What happens next?

(SSA) A thorough independent investigation will be conducted into the report made. In
some instances this can take some time to complete due to the complexity of the
If you work in a company operating under a special security agreement (SSA) and you wish issue. Individuals will be kept informed of progress during this period wherever
to raise a concern about a matter involving classified information, you must not include the possible. To facilitate the thoroughness of the investigation, they may also be
classified material in the initial report. You should contact the Facility Security Officer in the requested to provide clarification of the details and to answer questions that may
first instance to determine if there would be a disclosure or not. arise during the course of the investigation. They’re required to co-operate with
the investigation into the concern but can remain anonymous should they wish
If you believe you need to include ‘technical data’ when reporting a concern, this may to.
require an export licence from the government. When in doubt, contact the Facility Security
Officer. Individuals who reported a concern are encouraged to check the status of their
report by using the case login details provided to them when they made the
report. This is especially important if they have submitted a concern or enquiry

What happens when you anonymously because this is the only contact information available.

contact the Helpline? Once the investigation has been completed, the individual will be notified of the
outcome and any corrective actions necessary, to the extent possible.

Reports are entered directly on a secure server and a case number is generated. The
reports are only available to specific individuals within the Company who are charged with
evaluating the report. This process is overseen by individuals who are appointed to review
ethics cases. We’re committed to maintaining confidentiality to the maximum extent
Q: I’m not sure if what I’ve observed or heard is a
possible.
violation of company policy, or involves unethical
conduct, but it doesn’t look right to me. What
should I do?
A: You can ask for advice from your supervisor or manager.
If you’re not comfortable doing that, either file a report
or ‘ask a question’ through the Helpline. We’d rather you
report a situation that turns out to be harmless than let
possible unethical behaviour go unchecked.

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CODE OF BUSINESS CONDUCT

Our Business
This section of our Code explains how we
operate and do business at Cobham SATCOM. It
outlines how we are expected to behave in the
relationships we have with customers, industry
partners, suppliers and the wider marketplace,
and how we interact and generate positive
relationships with the communities in which we
operate and the world around us.

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CODE OF BUSINESS CONDUCT

Corporate Framework Q: A potential supplier has offered me a site tour

and policies to demonstrate technology that we may want to
use on a project. Is this a problem?
The Corporate Framework provides a concise overview of our structure and
governance. The policies that sit under the Corporate Framework cover a number A: Probably not, as long as the trip has a legitimate
of important areas and set out what we need to do to comply with laws, rules and business purpose and that you – and not your
regulations, and provides the information needed to do so. These documents are on
prospective supplier - pay your travel and related
the intranet, Cobham Connect, under CCL, policies and procedures.
costs. You should, however, be aware of bribery risks
associated with the visit and comply with the
Anti-bribery, anti-corruption Gifts and Hospitality policy.

and improper payments*

We have a zero tolerance towards any form of bribery or corruption. No facilitation payments*
The offer of, the promise of, the payment of, to solicit, to request, agree to receive or
Facilitation payments are unofficial payments to a government official to expedite
agree to accept, a bribe or kickback or other prohibited payment or activity, whether or secure the performance of a routine action, which has already been paid for
in cash or any other form of inducement (e.g. gifts, entertainment or hospitality) is or to which one is already legally entitled. Examples include obtaining licences
prohibited. This prohibition applies to dealings with private individuals, foreign public or other documents to do business in a foreign country, process visas or obtain
officials or government officials, in order to obtain or retain business or to influence customs clearance.
those individuals or foreign public or government officials to act improperly in their
duties or favourably toward us. You must not make facilitation payments of any kind or allow others to make
them on behalf of the Company.
* Refer to Anti-bribery/anti-corruption policy
* Refer to Anti-bribery/anti-corruption policy

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CODE OF BUSINESS CONDUCT

Acceptable gifts and Q: I’m aware that my manager has been given a gift that

hospitality* I think is inappropriate. If I report it, won’t they get

the report, cover it up anyway and retaliate against me
The exchange of gifts, meals or event attendance, can promote successful
for raising it?
working relationships and goodwill. However, there’s also the risk that any gift or
hospitality may be deemed to be an attempt to improperly influence a business A: Any concern submitted via the Helpline has a specific
decision, which not only harms our reputation but may result in civil and criminal distribution which is designed so that implicated parties are
penalties. Regardless of value, even the appearance or perception of influence, not notified or granted access to reports in which they have
must always be considered before giving or receiving a business courtesy. Some
been named, regardless of the individual’s position in the
governments have stricter rules, so additional consideration should always been
given to the country you are in. company. This allows reports to be independently investigated
at all times. We have a zero tolerance against retaliation, so if
You must therefore carefully consider whether to give or accept gifts or hospitality
before you do so. The Gifts and Hospitality policy is based on principles in order
your manager did retaliate against you, you must raise it as a
to help you exercise good judgement when deciding if a gift or hospitality event separate issue which will be dealt with accordingly.
of nominal value, is acceptable or not. Any exchange of gifts or hospitality must
comply with the Gifts and Hospitality policy and any item over £10 , or equivalent,
even if declined, must be recorded in the relevant gifts & hospitality register.

* Refer to Gifts and Hospitality policy

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CODE OF BUSINESS CONDUCT

Accurate records* Recording labour and

All books, records, accounts, and financial statements must fully, fairly, and
accurately reflect the nature of the transactions recorded, be provided in a timely
other costs
manner, conform both to applicable legal and accepted accounting principles, as You’re required to keep an accurate record of your time.
well as to our system of internal controls. All financial reporting is to be prepared
in accordance with International Financial Reporting Standards (IFRS) which has Accurate cost data is essential to any business. It is especially essential to us
been adopted by the Company. Compliance with the Financial Manual and the because many of our US contracts are based on cost and pricing data. For the
Minimum Standards of Financial Control is mandatory. labour costs to be accurate, you must submit your labour record on a timely
basis, and only charge activities you’ve been assigned and authorised to work
Financial transactions must be lawful, made for the purposes stated and on. For other costs such as travel, other direct costs, subcontracts, etc., you
authorised by the Company. must capture the costs accurately, properly documenting the charge to a
contract number, indirect number, or other cost objective. Some contracts may
* Refer to Accounting policy and Finance Manual
be unallowable or contract non-reimbursable for US Government contracts, and
these costs must be properly captured and excluded from cost claims.

Delivering accurate cost

and pricing data
Our customers expect great products at fair and reasonable prices. If you’re
involved with the negotiation of US Government procurement that requires cost
or pricing data, you’ll need to make sure the cost or pricing data is current,
complete and accurate. Cost and pricing data are all facts that a prudent buyer
and seller would reasonably expect to significantly affect negotiations. Examples
of data include, vendor quotations, non-recurring costs, production methods,
business projections, operational costs, unit-cost, make or buy decisions, and
any management decision that could have a significant bearing on cost, or cost
allocations.

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CODE OF BUSINESS CONDUCT

Anti-fraud Anti-money laundering

Forging or altering documents belonging to the Company is an act of fraud and Money laundering is the process by which individuals or entities, move criminal
strictly forbidden. funds through the financials of an organisation, in order to hide traces of the
criminal origin of such funds. We’re committed to fighting money laundering. You
Be alert to fraudulent scams. If you receive a request to change account may not be in a position to violate money laundering laws, but you need to be on
information, either verbally or by email, never do so without obtaining verification the lookout for irregularities in the way payments are made.
from the relevant contact first, and also obtaining suitable approval to make such
an amendment.

Anti-tax evasion
Q: My manager has told me to close a works order, We don’t tolerate any form of tax evasion and strictly comply with local tax laws
as if the work is fully complete, so we can invoice wherever we operate. We and those who work on our behalf, must not behave
the customer to record revenue in order to meet dishonestly to deliberately facilitate tax evasion either for personal gain or for
the benefit of others.
our financial targets. My manager said I can
just finish off the work afterwards so it will be
fine. I’m uncomfortable doing this, but is my
manager right?
A: No. This would lead to inappropriate recording of
revenue which is fraud and must not be done in any
circumstances. If you feel you are able, you should
explain to your manager that this is not acceptable. If you
don’t feel comfortable in having this discussion, then raise
your concern to another company resource.

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US Government contractor Confidentiality and

disclosure requirements intellectual property*
The Company and those individuals who have primary supervisory or We use information of all types and in all forms in our daily work, this includes
management responsibility within a business, may have an obligation to report information about our customers and other third party confidential, proprietary
potential violations of certain US criminal or civil laws or overpayments by the information, processes, or intellectual property, personal information or personal
US Government. These violations may relate to procurement and contract fraud, data, export controlled information, and classified information.
bribery/kickbacks, gratuities, false statements or claims to the government,
human trafficking and counterfeit parts. If you believe there has been a violation All such information must be handled, stored and protected pursuant to
or suspect there’s been a violation, or have questions on your obligations, please contractual, legal or other requirements, and not accessed or disclosed without
contact Legal. requisite business purposes or authority. Intellectual property includes, but is not
limited to, trademarks, copyright, patents, inventions, know how, design, mask
works, and trade secrets. Our success is dependent on such information and
it must be preserved and protected against disclosure, whether intentional or
unintentional.

With the wide use of computers and telecommunications, the protection of

information in electronic format is of particular concern.

The following must all be protected:

Confidential information assets, proprietary information, Company intellectual

property and data or information whose destruction or disclosure outside of the
Company could result in any of the following: financial loss, loss of competitive
position, degraded business operation, violation of a confidentiality agreement
with another party, or its use for personal gain.

* Refer to Intellectual Property policy

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Protect Company assets Classified and national

We all have a duty to the Company and our customers to use assets and facilities
responsibly and for their intended purposes only. You are expected to take
security information
reasonable care in the use, maintenance and security of company owned or You must take all necessary steps to protect any such information. It’s never
leased property. In addition, you must not wilfully interfere with or misuse any appropriate to disclose such information to another person, without explicit
machinery or other office equipment of any nature. Use of company or customer approval from the appropriate body.
facilities, property or funds for anything other than official company business is
prohibited, unless permitted in our policies or procedures or approval is given

Document retention†
by prior written authorisation from the General Manager of the business unit
managing the relevant facilities.

We deal with large quantities of documents and records. It’s important to know

Information classification how long these should be retained and how to properly dispose them. You should
understand and follow the Document Retention policy and relevant country

and handling* procedures.

† Refer to Document Retention policy

All information is a valuable asset and should be classified based on an
assessment of the impact it would have, should the information be disclosed to
an unauthorised person, or be lost or destroyed inappropriately. All such company
information must be marked in accordance with this classification.

* Refer to Information Classification and Handling policy

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Global trade compliance

and controls*
As a global company, we serve the needs of our customers worldwide through the
delivery of products and services. All import, export and re-export activities
and/or transactions shall be conducted in full compliance with all applicable
import and export control laws, regulations, sanctions, embargoes and policies.
This includes recognising potentially illegal boycott requests under all applicable
laws.

An “export” can occur when a product, service, technology, or piece of

information is shipped to a person in another country or to a foreign person either
in the country or abroad. If you transport and/or use goods and technology
subject to export or import controls, you must understand and follow the relevant
laws, regulations and policies.

Consequences for violating trade controls are severe for the Company and for
the individuals involved, and can result in termination of employment, substantial
fines and imprisonment.

If you have any queries, contact the relevant Export Compliance function.

* Refer to Export and Import compliance policy

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Customers and other Working with Government

partners officials**
We should ensure we understand our customers’ needs, deliver on customer Governments in some parts of the world have more stringent requirements with
commitments and strive to exceed them every day. We need to stay committed to regard to gifts and hospitality that is offered to officials. Breaches of these laws
remaining ‘customer focussed’ and achieving operational excellence. and regulations can be serious offences. If dealing with government officials,
make sure you understand any rules and regulations that apply to the country
you are in and if in doubt seek advice from the Legal department.

Suppliers* With regard to state and other similar delegations, it is acceptable to demonstrate
and explain our products and to make them feel welcome. However, because
When seeking new suppliers and other partners we conduct due diligence. some countries have very strict restrictions on hosting State Trade delegations,
We have a supplier Code of Conduct which provides guidance on what we you should take specific legal advice to check that what you’re planning is
expect from them. We also conduct annual due diligence with regard to human acceptable and there should never be any attempt to seek improper advantage or
trafficking/modern slavery, bribery and conflict minerals risks. decisions by doing so.

* Refer to Responsible Supply Chain Management policy If you are asked to provide information in connection with a government or
regulatory agency investigation, you must ensure any information provided
is accurate and true. Always seek advice from the Legal department before

United States Government

responding to any such requests.

The hiring of an ex-government official is subject to additional legal requirements

officials† in many countries and Cobham must consider any such additional checks and
take external advice where necessary before hire. If in doubt, always seek advice
from the Legal department or the relevant Human Resources function or refer to
The United States Government (USG) has adopted specific laws and regulations the Hiring Current and Former USG Employees policy.
on providing gifts and hospitality to certain USG employees, which includes
USG Executive Branch employees (political appointees and civilian and military ** Refer to Hiring Current and Former USG Employees policy
personnel), Legislative Branch employees (members of the U.S. Congress and
congressional employees) and Judicial Branch employees. The US Government
Gratuities policy sets out what is and what is not permissible and is in addition to
the Gifts and Hospitality policy requirements.

† Refer to USG Gratuities policy

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Intermediaries and Fair competition†

representatives* We compete in the marketplace on the basis of our products, technology,
quality, service, price and similar competitive factors. We do not seek to gain any
An Intermediary is defined as any third party whose proposed activities include improper advantage through the use of manipulation, concealment, dishonesty,
representing the Company or promoting the interests of the Company. The abuse of privileged information, misrepresentation of facts, or any other unfair
Intermediary policy sets out the requirements before engagement, which includes dealing practice.
performing appropriate due diligence both pre-engagement and during the term
We’re required to interact fairly with each other as well as with our customers,
of the agreement, to ensure that any risks associated with third parties are
suppliers and competitors. Stealing or illegally appropriating proprietary
systematically managed in a rigorous and consistent manner.
information, disclosing proprietary information without authorisation, possessing
* Refer to Intermediary policy trade secret information improperly obtained, inducing such disclosures from past
or present employees of other companies or taking such information from prior
places of employment is prohibited.

The use of information, offered or found, to which the Company has no right, is
unacceptable. This could include such things as unauthorised bids, proposals or
source selection material.

You must never make a payment that is for the benefit of any supplier, customer,
or other person, for the purpose of inducing that person to act against the
interest of their employer.

We’re committed to open and fair competition and complying with all competition
and anti-trust laws applicable in the countries where it operates. Anti-trust, trade
and competition laws prohibit agreements and practices that are anti-competitive
and undermine fair competition.

You must not make any formal or informal agreements or conduct any formal
or informal discussions with competitors regarding prices or pricing policies,
allocating customers, supplier or customer selection or classifications, or
allocating markets or territories in which competitive products are sold or in which
there are customer or supplier boycotts, or where competitors are excluded from
the marketplace or trade is unfairly restricted.

† Refer to Unfair Competition and Anti-trust policy

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Corporate opportunities Trade associations

If you learn of a business or investment opportunity through the use of corporate A trade association is an organisation founded and funded by businesses that
property or information from a competitor or actual or potential customer, client, operate in a specific industry. A trade association can benefit competition in
supplier, or business associate of the Company, you may not participate in the several ways. However, trade associations pose certain risks because their
opportunity or make the investment without the prior written approval of the membership is often made up of competing firms.
Legal department. We must not use any corporate property or information for
improper personal gain. You must take care that contact with competitors does not create a basis for
creating an unlawful agreement or result in illegal information exchange. Before
joining a trade association you should ensure you understand its purpose, the
number of members, when it was formed and if there is a lawyer on its staff.

You should not join any trade association that intends to discuss pricing,
competition, or customers, or which restricts its membership to only certain
industry members. Discuss participation with a supervisor, manager or the Legal
department and gain approval before discussing with the relevant contracts and
commercial support person.

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Communities and the public

Working with communities Charitable gifts and donations*
We want to generate positive relationships in our local communities and in our Charitable gifts and donations cannot be made using company funds except if in
end user markets. As such we want to minimise disruption to our neighbours, compliance with the Community Involvement policy.
provide an effective complaints mechanism, ensure full and fair opportunity
We don’t seek to discourage anyone from supporting bona fide charitable
is given to local companies and local people to engage with us at the most
organisations through their own fundraising or individual effort outside of and
appropriate level and contribute to our communities in an appropriate way.
unconnected to their employment.

We wish to minimise any social and environmental impacts and risks associated
with our products and services throughout their lifecycle and to enhance their
social and environmental benefits. Political contributions*
Contribution of company funds or the use of Company assets or facilities for the
benefit of political parties or candidates anywhere in the world is prohibited.
Respecting the environment You are entitled to make personal donations and this includes, for the avoidance
This means the efficient use of energy, raw materials and natural resources of doubt, making personal contributions to a Political Action Committee (PAC) in
throughout product design, operations, supply chain management and logistics; the US. The Company will not reimburse you for any such contribution.
reduction in the type and use of hazardous substances; and protection of the
Company’s operations and supply chain from the significant adverse effects of * Refer to Anti-bribery/anti-corruption policy
climate change such as storms, flooding, wildfires and drought.

All of us, our facilities and our operations must comply with all applicable safety,
health and environmental (SHE) laws, rules and regulations as a minimum and
report any accident, injuries, ill-health and environmental incidents or concerns.

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Human rights, anti-modern slavery and There are millions of people trapped in some form of slavery, whether they are
forced to labour against their will with no means of escape, or are forced to
anti-human trafficking* endure physical punishment. There are many indicators of these practices to
look out for within the business environment and you should be vigilant at all
We seek to demonstrate respect for basic human rights through the principles times and learn to recognise victims so you can report any instances, or potential
and policies contained in this Code, the Corporate Framework and the company instances, found.
policies.
We also expect our suppliers to work likewise, towards implementing operations
We support the principles contained in the Universal Declaration of Human and supply chains that are free from modern slavery and human trafficking.
Rights and seek to reflect these in the context of its business activities wherever
possible, bearing in mind the Declaration is aimed at nation states rather than * Refer to Anti-slavery and Anti-human Trafficking policy
businesses.

We respect the human rights of our employees as set out in the International
Labour Organization Declaration on Fundamental Principles and Rights at Work.
This includes: paying at least a statutory minimum wage; freedom of association;
non-discrimination; the elimination of slavery such as forced, compulsory, bonded
and child labour; and the elimination of human trafficking and discrimination and
harassment in employment and occupation.

We oppose modern slavery and human trafficking in all its forms and seek to
identify and eradicate its occurrence within our own operations and within our
supply chain wherever possible through a due diligence process.

COBHAM PRIVATE 22
CODE OF BUSINESS CONDUCT

Our People
This section of our Code outlines our
commitment to you, to each other and describes
in more detail the conduct and behaviour
expected from all of us to ensure a respectful
and inclusive working environment.

COBHAM PRIVATE 23
CODE OF BUSINESS CONDUCT

Our People Prevention of workplace

Cobham SATCOM has a unique role in the world; we’re a company that has both discrimination and
harassment
been places, and is going places in the future. Those places can be dangerous,
thrilling, life enhancing and a million things in-between. While the projects we
undertake are incredibly varied, we approach them all with same mind-set;
we’re bold, we’re determined, we’re inventive and we work together - with our Any kind of discrimination, harassment or bullying by or against a colleague,
customers, our partners and each other, as a team. customer or supplier will not be tolerated.

Discrimination could relate to gender, identity or expression, race, colour, sex,

Health and safety ethnicity, sexual orientation, physical or mental disability, age, pregnancy, religion,
veteran status, national origin, or any other legally protected status.

We are committed to providing a safe workplace for everyone who works at Harassment is directed at an individual. It can take the form of demeaning,
Cobham SATCOM and for ensuring the safety of the products and services we insulting or derogatory comments, slurs or innuendos, or intimidating behaviour.
provide.

We are committed to striving towards zero harm i.e. continuously reducing

accidents, injuries, ill-health, and the environmental impacts arising from our
operations, activities, products and services, wherever practicable. We each
Q: I’m friends with a man who I work with. Sometimes
have a personal duty of care to ourselves and to each other, the communities we share jokes in my office that might be considered
in which we operate, and to society in general to promote and foster a positive offensive to others but we’re careful to shut the
and proactive culture with respect to safety, health and environment and to work door so no-one hears. We also forward each other
towards achieving zero harm.
funny jokes via email. Could this be considered
The Company (level 2) SHE standard documents establish minimum requirements inappropriate behaviour, even though it’s between
that must be met by every Cobham SATCOM site and every employee. They set two friends and not shared with anyone who would
out a standardised leadership approach to the management of safety, health
and environment relating to the Company’s operations, activities, products and be offended?
services, in order to comply with the Company’s stated objectives under the
Corporate SHE policy statement. A: We don’t attempt to regulate your private behaviour,
however the situation described takes place on company
property, in company time and using company assets.
This behaviour is not acceptable and does not fit into our
workplace, even in the privacy of an office.

COBHAM PRIVATE 24
CODE OF BUSINESS CONDUCT

Prevention of sexual
harassment
Sexual harassment is defined as unwelcome sexual advances, requests for sexual
favours and other verbal or physical conduct of a sexual nature, when such
conduct is made either as an explicit or implicit condition of employment or is
used as the basis for an employment decision affecting the harassed employee.
Cobham SATCOM has a zero tolerance of harassment policy.

Sexually harassing behaviour is strictly prohibited and includes sexual

propositions, sexual innuendo, suggestive comments, sexually oriented kidding,
teasing or practical jokes, jokes about gender-specific traits, obscene language or
gestures, display of obscene printed or visual material and any unwanted physical
contact such as patting, pinching or brushing against another person’s body.

Q: I’ve noticed that my new boss, John, leans

extremelyclosetomewhenwe’rereviewingreportsHe

Q: I’ve noted that my new boss, John, leans A: Either tell John directly that such behaviour is making you
extremely close to me when were reviewing reports. feel uncomfortable and it should stop immediately or if
He also touches my hand or shoulder frequently as you’re not comfortable doing so, then make a complaint to a
we discuss work. I’ve tried relevant company resource. There is no reason for you to feel
moving away, but he doesn’t seem to be getting uncomfortable in the workplace and there is no valid reason for
the message and his behaviour continues. John to engage in such behaviour.
What should I do?

COBHAM PRIVATE 25
CODE OF BUSINESS CONDUCT

Inappropriate pressure to Teamwork and

meet the numbers collaboration
• Never put an inappropriate amount of pressure on anyone to meet targets, We’re all a part of the same team - working collaboratively, with integrity, trusting
disregard procedures or to cut corners. in each other.

While it’s understood that many long-term relationships are formed at work,
• Never let the pressure to ‘meet the numbers’ compromise your integrity, or care must be taken to avoid the perception of an improper relationship between
the safety, health and environmental impact on other colleagues, our products
management and anyone in their reporting chain, particularly where work
or services or the community. We must always do the right thing in the right
assignments, career advancement or compensation can be directly or indirectly
way.
influenced. An improper relationship could arise due to personal or family
relationships. We must never have any direct management authority over a
family member or someone we have a close personal relationship with. Should
Equality, diversity and such a relationship develop, you should discuss the situation with a supervisor,
manager or Human Resources, to decide on necessary actions with a written

inclusion* record of the discussion being retained on file.

We recruit, employ, train, promote and compensate individuals based on

merit, performance, job related qualifications, requirements of the job and the
organisation.

Diversity and inclusion are embedded in our culture and we’re committed
to providing equal opportunities in all aspects of employment. We value our
differences and work better together because of them. A work environment
which values individual differences and encourages the full contribution of every
employee, strengthens us.

* Refer to Diversity and Inclusion policy

COBHAM PRIVATE 26
CODE OF BUSINESS CONDUCT

Conflicts of interest
disclosure
We understand and respect our employees’ right to engage in activities outside You must provide written disclosure of any actual or potential conflict of interest
of their jobs. However, you must avoid any investment, interest or association to your supervisor, manager or Human Resources, even if the conflict of interest
that interferes, may interfere or creates the appearance of interfering with, the is realised after the situation has arisen. If you consider undertaking an activity,
judgement you exercise, or the performance of your responsibilities. You must including an investment that may create an actual, apparent or potential conflict
avoid any scenario where personal interests conflict with, or are perceived to of interest, you must seek written approval from your supervisor, manager or
conflict with, those of the Company. Human Resources, immediately who will keep a written record of such disclosures
and approvals on file.
Examples (non-exhaustive list) of potential conflicts of interest include:
All employees electronically sign a statement, via the annual Code/ABAC training,
• Doing business with a company managed by a close friend or family member to confirm that they either do not have a conflict or have disclosed a conflict and
it has been approved.
• Paying a supplier more than contractually agreed for the goods or services

• Working as a consultant to a supplier, customer or competitor

• Using confidential company information or improperly using company property,

information, or opportunities for personal benefit or the benefit of others

• Outside work that interferes with your performance at

work or diverts business away from the Company

• Financial investments that may reasonably be considered

to lessen your impartiality

COBHAM PRIVATE 27
CODE OF BUSINESS CONDUCT

Drug and alcohol free Prevention of workplace

workplace violence
Using illegal drugs, controlled substances or alcohol, can have an adverse Any kind of hostile, violent, intimidating, threatening or other aggressive conduct
effect on performance, jeopardise the safety of colleagues and constitute a in the workplace will not be tolerated. This behaviour could include pushing,
risk to the business and interests of the Company. You must not distribute, hitting, or any type of potentially dangerous physical acts. You must not bring,
possess, sell, transfer, use or be under the influence of alcohol, illegal drugs or possess or use a weapon or anything intended to be used as a weapon to inflict
controlled substances on company property, on company time, in connection harm or physical damage or injury or for threatening or intimidation purposes,
with company business, or in a manner that may affect performance of company into company buildings. You must report any instance of violence, hostile
responsibilities. If alcohol is served during work events, you need to exercise behaviour or possession of weapons immediately.
moderation and good judgement but never drive under the influence of alcohol
or over the legal limit permitted. This will help prevent accidents and injuries In a case of imminent danger contact the
to colleagues and other persons, protect our overall business performance and police immediately.
protect employees from convictions.

With regard to prescribed medication, you should consult with your medical
practitioners or pharmacists prescribing medication, if there are any possible side
effects relating to workplace safety and disclose such use to Human Resources,
where required to do so.

We, as a US Government contractor, must comply with the Drug Free Workplace
Act and applicable local laws. While marijuana has been legalised in certain US
States and under other initiatives, it is still illegal under US Federal law and does
not change our prohibition on the distribution, possession, sales transfer or use
of that drug.

COBHAM PRIVATE 28
CODE OF BUSINESS CONDUCT

Privacy and data protection Careful use of social media†

of personal information* We provide most employees with access to the internet on work computers. You
must be careful to protect our reputation and business information by not posting
We respect employee privacy and therefore will collect, use and retain information any comments or documents on any social media sites that are confidential
only where there is a valid business or employment reason. Internal disclosure or could be attributed to our Company. You should never use company time,
is therefore limited and all personal data is protected against unauthorised or property or networks for non-work related social media communications. If you
accidental disclosure, modification or destruction. choose to communicate via social media, make sure the communications do
not violate the law, disparage or insult the Company, customers, suppliers or
We’re all responsible for keeping personal data secure and observing the privacy competitors. If speaking about your professional life, clearly state that these are
of individuals. Any data collected must be processed and held in line with personal views and not necessarily the views of the Company. Always safeguard
applicable laws and the Personal Data Protection policy. personal information.

* Refer to Personal Data Protection policy † Refer to Social Media policy

COBHAM PRIVATE 29
CODE OF BUSINESS CONDUCT

Five Key Takeaways

Important points to remember

1. Always comply with applicable laws, regulations and corporate policies

2. Never accept or give a bribe or kickback
3. Don’t ever compromise your integrity
4. Always do the right thing, in the right way
5. See it? Say it. Speak out!

Training
Our Code is supported by annual Code of Conduct training, which every employee “SUCC ESS I S NOTHI NG
needs to complete. WI THOUT I NTEG RI TY”

COBHAM PRIVATE 30
Helpline
https://cobhamsatcom.whistleblowernetwork.net
or
Call International Toll-Free numbers:

United States +1 (833) 2113671

Denmark +45 80830045

The reporter needs to enter code 68631

to identify it as a Cobham SATCOM issue

www.cobhamsatcom.com