Financial Crime Policy

1.0 PURPOSE AND SCOPE

Financial Crime Policy

Meggitt strives to ensure that all its financial and administrative processes are carried out with honesty and integrity, and with a commitment to maintaining accuracy and transparency, ensuring that all decisions are taken objectively and free of personal interest, and that financial crime is not committed either deliberately or inadvertently. This commitment extends to dealings by organisations that Meggitt have asked to undertake financial processing activities on our behalf, including third parties and contractors. There are clear escalation procedures where employees have concerns about financial crime, either through management or on the independently run ethics hotline. Senior management will deal promptly, firmly and fairly with suspicions and allegations of financial crime.

Scope

This policy applies across Meggitt. The Policy covers anti-money laundering, fraud prevention and corporate tax evasion. The policy also more generally prohibits any financial crime within Meggitt as determined under local legislation.

2.0 MONEY LAUNDERING

Definition:

“Money laundering is the process by which individuals or entities try to conceal illicit funds, or otherwise make these funds look legitimate.” Meggitt will not condone, facilitate or support money laundering.

Few Meggitt employees will ever personally be in the position to infringe money laundering laws but the following areas of potential risk are highlighted:-

1. irregularities in the way payments are made, such as payments in currencies other than that specified in the invoice; payments by someone not a party to the contract; payments to/from an account other than the normal business relationship account; requests for an overpayment; and
2. Customers, suppliers, and intermediaries whose operations appear to lack integrity.

3.0 FRAUD

Definition:

1. Fraud: A deliberate intent to acquire money or goods dishonestly through the falsification of records or documents. The deliberate changing of financial statements or other records by an employee. The criminal act is the attempt to deceive and attempted fraud is therefore treated as seriously as accomplished fraud.
2. Theft: Dishonestly acquiring, using or disposing of physical or intellectual property belonging to Meggitt or to our employees.
3. Misuse of equipment: Deliberately misusing materials or equipment belonging to Meggitt for financial or material benefit.
4. Abuse of position: Exploiting a position of trust within Meggitt for financial or material benefit.

Meggitt will not condone, facilitate or support fraud, theft, misuse of equipment or abuse of position by our employees or anyone doing business or performing services for or on behalf of Meggitt in any capacity. Behaviour which breaches or runs counter to this position may lead to prosecution, severe penalties and termination of contracts and relationships with Meggitt.

4.0 TAX EVASION AND FACILITATION OF TAX EVASION

Definition:

“Tax evasion” means deliberately or dishonestly cheating the public revenue or fraudulently evading tax. “Facilitation of tax evasion” means being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax (whether UK tax or tax in a foreign country) by another person, or aiding, abetting, counselling or procuring the commission of that evasion.

It is Meggitt’s expectation that anyone doing business or performing services for or on behalf of Meggitt in any capacity will conduct themselves in accordance with laws relevant to countering tax evasion. Behaviour which breaches or runs counter to this position may lead to prosecution, severe penalties and termination of contracts and relationships with Meggitt.

As such, no employee or third party when acting for or on behalf of Meggitt may either evade tax, facilitate tax evasion by another person (including another Meggitt entity), or provide assistance to anyone who they know or suspect is engaged in tax evasion. This principle applies regardless of what the tax is, extending to all direct and indirect taxes, including VAT and duties, and employment taxes. It also applies irrespective of the location of the employee or third party or the other person and notwithstanding that the person may not actually succeed in evading tax.

Employees and third parties should be alert to any signs (or “red flags”) that third parties are looking to or are actually evading tax in their dealings with Meggitt.

5.0 OTHER FINANCIAL CRIME

Other financial crimes as determined under local legislation are prohibited. If any employee suspects that an employee or anyone doing business or performing services for or on behalf of Meggitt in any capacity is committing a financial crime this should be escalated to management or using the ethics hotline.

6.0 RESPONSIBILITIES

The Board of Directors are responsible for oversight of this Policy. Matters relating to financial crime are generally delegated to the Audit Committee.

The Chief Executive has delegated responsibility in this area to the Chief Financial Officer and Group Company Secretary. Divisional and functional leaders are responsible for ensuring all employees understand their responsibilities and for ensuring this Policy is implemented locally.

In addition to complying with the Policy, employees must ensure that people they manage or supervise understand their responsibilities.

This Policy will be enforced through regular training, monitoring and auditing.

7.0 BREACHES OF THIS POLICY AND REPORTING OBLIGATIONS

Violations of this Policy are punishable by disciplinary action up to and including termination of employment. Violations may also result in criminal prosecution of the individuals involved.

Any employee who suspects or becomes aware of any violation of this Policy shall report the suspicion or violation to one of his or her supervisor; to the Chief Financial Officer, the Executive Director, Commercial & Corporate Affairs; the Group Company Secretary, UK or US Legal Counsel. Anyone making such a report will be protected from punishment or retaliation in accordance with Meggitt’s Code of Conduct. Anyone receiving such a report shall be responsible for escalating the report to the next higher level or to another appropriate senior employee, and for following up until it is resolved. See Meggitt’s Escalation Policy.

Names and contact information for people who can help, are contained in the Code of Conduct and on posters provided throughout your facility.

Meggitt also provides an independently operated Ethics Line, available 24 hours a day, seven days a week, which may be used to raise questions or concerns. Each Meggitt facility contains posters listing the toll free phone number to be used to place such calls. Those phone numbers are also available on line, on Meggitt’s public web site: www.meggitt.com.

An internet application is also available for these purposes at www.expolink.co.uk/meggitt. Log on information will be provided on message boards throughout the company.

Each employee has received a copy of the Code of Conduct which also contains the Ethics Line phone numbers. The Code of Conduct and the phone numbers are available from your site’s Ethics Coordinator. The Ethics Line should also be used if reports made to supervisors do not appear to have been addressed satisfactorily.

Approved by the Board of Directors on 30 October 2018.