Anti-bribery and Corruption

Statement from the General Counsel

One of the fundamental principles of GKN Aerospace is to conduct its business in an open, honest and ethical manner. We take a zero tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all business dealings and relationships, within all jurisdictions in which we operate. Bribery and corruption represent a barrier to economic and social development.

GKN Aerospace reputation for lawful and ethical business relations is of utmost importance and we require all employees and other business associates, whether employed directly or indirectly (including customers, suppliers, agents, distributors, and others working for or on behalf of GKN Aerospace), to act professionally and with integrity at all times.

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all employees across GKN Aerospace; each employee is required to avoid any activity that might constitute, lead to, or suggest, bribery and/or corruption activities.

Julie Smyth, General Counsel

Anti Bribery and Corruption Policy

GKN Aerospace has issued its Anti Bribery and Corruption Policy to ensure that key employees and business associates are fully aware of their responsibilities and the consequences for non-compliance. The policy also provides guidance in relation to the enhanced bribery and corruption risks that exist for the group and how to reduce such risks.

This policy applies to all individuals working at all levels of GKN Aerospace, including senior managers, officers, directors, employees (whether permanent, fixed-term, or temporary), contractors, trainees, casual workers/agency staff, or any other person working for GKN Aerospace throughout the world.

The ABC Summary Policy can be found in the Policies section.

This ABC Summary Policy also applies to any person, or any organisation, working for or performing a service for or on behalf of GKN Aerospace – for example, pension trustees, consultants, lawyers, accountants, other business advisers, agents, distributors, joint venture partners, or other persons whilst they are working for, or performing a service for or on behalf of GKN Aerospace anywhere in the world. They are responsible for ensuring they read, understand and comply with the ABC Summary Policy. This should be confirmed in writing by them if requested by GKN Aerospace. GKN Aerospace may cease to continue working with an external associate (acting for or on its behalf) who it believes to have breached the ABC Summary Policy.

More information on how we do business, can be found in the Responsible Business section.

ABC Risk Assessment Process

We routinely and regularly undertake risk assessments in key compliance areas which then informs the risk based approach together with leading best practice.

Training

All relevant employees receive regular Anti Bribery and Corruption training via elearning. We are currently working on a new training format that will be introduced in Q4-2022. All relevant employees will then receive training at least annually.

Employee Incentives

At GKN Aerospace, we use consistent and accurate incentive models across our business, to ensure we reward our people fairly for their individual efforts and measurable contribution to our team success, whilst helping to build a sustainable business. Objectives are set annually in an individual Performance and Development Plan (PDP) to measure and reward individual and team performance against relevant goals. Weighing the employees’ behaviour against the GKN Aerospace Culture Principles is part of the Performance Process and is part of the performance score of the employee. This underpins the importance of social and ethical behavioural standards in our business. Incentives are proportionate and have standardized scoring categories to promote fair performance scoring. The performance score is one of the elements in the incentive plan of an employee to drive performance in a social and ethical way. The incentive plan contains a claw back clause in case of misconduct or unlawful behaviour such as involvement in bribery or corruption by an employee.

Reporting and oversight

The executive committee is routinely updated on (material) compliance matters including the outcome of any risk assessment. The ultimate shareholder – Melrose – receives regular updates in relation to (material) compliance matters.