Anti-bribery and Corruption
Statement from the 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.
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.
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.