The Meggitt Code of Conduct

1.0 PURPOSE

Meggitt PLC and all subsidiary companies will conduct business fairly, impartially, and in compliance with all applicable laws and regulations. Our values of Teamwork, Integrity and Excellence are at the heart of how we do things, and we reinforce these daily by applying our high performance culture principles. We are firmly committed to integrity, honesty and respect for others in all our business relationships, including those with customers, suppliers, communities where we conduct business, and amongst employees. The highest standard of ethical behaviour is expected from all of our employees, directors, and from those who act on Meggitt’s behalf in the performance of their professional responsibilities and in their own personal conduct.

Our Code of Conduct promotes “doing the right thing” and “doing things right” so that we maintain our personal and business integrity. No Code of Conduct can address every possible situation. Where a specific action is not mentioned or you are not sure what action to take, you should always seek guidance. This Code will help you identify the right resources and the people who can help you.

2.0 POLICY

Employees, directors, and those who act on our behalf, in accordance with our related policies and procedures, should:

• Regularly read this Code of Conduct;
• Familiarise yourself with our policies and processes;
• Participate in training to learn about business ethics, compliance, laws and regulations that affect your role and our business;
• Be alert to any Code of Conduct violations, illegal or unethical conduct and promptly report them to management or other appropriate officials (see below). If you believe that our Code of Conduct or related policies are being violated, you have a responsibility to speak up;
• Raise questions or concerns about the business and follow them through to appropriate conclusion according to our Escalation Policy (available on MC2 or from your local Ethics Champion);
• Comply with all applicable laws and regulations;
• Deal fairly and impartially in all transactions;
• Not participate in activities that may raise questions as to your own or Meggitt’s integrity, impartiality, and reputation;
• Not engage in conduct that might create a conflict of interest for Meggitt or for yourself individually;
• Safeguard all Meggitt and customer assets and use them only for approved activities. Never seek personal gain through the inappropriate use of our intellectual property and confidential information or the intellectual property or confidential information of any third party which has been entrusted into our care;
• Never seek personal gain through the inappropriate business dealings;
• No one shall buy or sell shares of Meggitt PLC:
  1. whilst in possession of price sensitive information; or
  2. during a Closed Period for transactions as advised from time to time.
• Be familiar with and refer to the other relevant policies, including our Anti-corruption Policy (available on MC2 and from your local ethics champion).

Our Anti-corruption Policy covers the following issues:

• Bribery
• Gifts and Entertainment
• Conflicts of Interest
• Competition and anti-trust
• Sales representatives
• Distributors
• Political contributions and lobbying activities

Our Financial Crime Policy covers the following issues:

• Money laundering
• Fraud
• Tax evasion and facilitating tax evasion

Meggitt has implemented an Ethics and Business Conduct Programme across the Group in order to:

• Explain our policies and procedures which relate to ethical business conduct;
• Provide regular training in ethics and business conduct;
• Create an engaged environment where employees feel confident that they may raise questions or concerns and report suspected violations without fear of punishment or retaliation for doing so or for participating in an investigation;
• Sponsor an independently operated and monitored Speak-aUp Line to enable employees to report questions or concerns about possible misconduct or to seek guidance about the proper course of action. The free telephone numbers are provided at the end of this Code and on posters in our sites. You can also raise issues or concerns using the website or app;
• Provide a safe and productive work environment in which we promote employee’s health and well-being and protect others from the consequences of alcohol, drug and substance misuse;
• Monitor compliance with this Code.

Meggitt will rigorously enforce compliance with this Code. Violations may subject employees to disciplinary action, including, in serious cases, the termination of employment. However, the statutory employment rights of employees will always be honoured.

If you have any questions or concerns about any aspect of this Code of Conduct or the way in which we are conducting business or treating people, you should address them to your line manager or your local site or product group leader. You may contact Human Resources at any time or your local ethics champion. If you do not consider these options appropriate you may also email the Group ethics team on ethics@meggitt.com, or contact any of the following directly:

Ethics team

Rebecca Mayfield
Ethics & Corporate Responsibility Director
+44 (0) 7392 197 320

Marina Thomas
Group Company Secretary
+44 (0) 7432 738 520

Legal team

Eric Lardiere
Senior Vice President, Secretary & General Counsel (US)
+1 805 217 6876

Kate Coulson
Senior Legal Counsel (UK)
+44 (0) 2476 668 973

Andrew Garard
Group General Counsel & Director, Corporate Affairs
+44 (0) 7880 751 094

Contact details for Speak-Up Line are:

Australia: 1 800 121 889
Belgium: 0800 71025
Brazil: 0800 891 8807
Canada: 1888 268 5816
China: 10800 441 0078
Denmark: 8088 4368
France: 0800 900 240
Germany: 0800 182 3246
India: 000 800 440 1286
Mexico: 01800 123 0193
Netherlands: 0800 022 9026
Singapore: 800 4411 140
Spain: 900 944 401
Switzerland: 0800 563 823
UK: 0800 374 199
USA: 1 877 533 5310
Vietnam: 02513 836 622

Originally approved by the Board on 12 May 2005. Last reviewed and approved by the Board on 12 December 2019.