Trade Compliance Policy

PURPOSE

Compliance with governmental trade controls is essential for Meggitt PLC and its businesses which export and/ or import, directly or indirectly; however, an effective trade compliance programme requires more than merely following the law.  The programme requires adherence to Meggitt’s core values of Teamwork, Integrity, and Excellence.  More specifically, employees are expected to understand the parties, products and services and nature of the transactions related to their job and seek assistance from trained professionals when necessary.

Sending, receiving, communicating or otherwise sharing data and/ or hardware frequently involves trade regulations, even when it is “dual-use” or destined for a civilian use.  The precise content of the rules and regulations governing Meggitt businesses will vary between and among countries and locations.  These regulations frequently change and evolve.  This presents a complex and highly-regulated business environment.  Meggitt expects its employees to utilize the training they receive, consult Trade Compliance professionals as needed, and exercise sound judgment in the performance of their duties.

POLICY

Meggitt is committed to maintaining full compliance with the laws and regulations governing trade controls in all jurisdictions in which it operates.  The global compliance programme includes executive oversight, training, audit and assurance, policies and procedures, investigative capability, and enforcement mechanisms when appropriate.  The Board of Directors has oversight of Meggitt PLC’s global trade compliance programme and of any trade compliance issues that arise.

APPLICABILITY

Meggitt has established a Trade Compliance Programme which has been implemented across the Group and is applicable to all employees. The programme is continuously reviewed and enhanced based on regulatory and business requirements. The Trade Compliance Function, Division Presidents, Product Group and site leaders are responsible for implementing and maintaining the programme and for ensuring that they have the highest standard of trade controls.

More specific details of the Trade Compliance Programme have been made available to our businesses and further information can be found on Meggitt’s internal Trade Compliance website.

Any questions, comments or concerns should be addressed to:

Andrew Garard – Group General Counsel and Director, Corporate Affairs

(+44 7880 751094)

Josephine Nettleton – Senior Director, Trade Compliance

(+44 7534 261685)

Eric Lardiere – Senior Vice President, General Counsel and Secretary, Meggitt-USA, Inc.

(+1 805 526 5700 x 6650)

Barry Matthews – Senior Vice President, General Counsel UK

(+44 7774 727379)

Erin Devery – General Counsel, Asia Pacific

(+61 414 431 211)

Barry White – Senior Vice President, Commercial

(+44 7535 481055)

 

Approved by the Meggitt PLC Board of Directors on 10 December 2020.

 


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