MEGGITT Code of Conduct CODE OF CONDUCT 01 Enabling the Extraordinary To Fly To Power To Live MEGGITT Code of Conduct Contents Speak Up We want each and every employee to feel like they can Speak Up if they experience or witness any unethical conduct. All concerns will be dealt with confidentially and impartially. We will not tolerate retaliation against those that raise a concern and there is support in place for anyone who raises a concern. Raising a concern · You can raise a concern to the following people: · Your manager or anyone on your management team · Your site or functional ethics champion · A HR colleague · A member of the Legal team · A member of the Ethics team · Email ethics@meggitt.com ​​Or call the Speak Up Line which is independently run and anonymous, details of which can be found on the MC 2 Ethics pages​. 02 Contents Message from the Board 1. Our Business Processes Health & Safety Confidential Information and Business Secrets Conflict of Interest Honesty and Fair Dealing Product Integrity Inside Information and Share Dealing Financial and Accounting Controls & Records Tax Evasion and Facilitating Tax Evasion Gifts and Entertainment Competition and Competitor Relationships Speaking Up and ‘Whistleblowing’ 2. Our Colleagues Diversity and Inclusion, Respect, Dignity and Understanding Drugs and Alcohol Theft or Misuse of Property Harassment, Discrimination and Abusive Behaviour Preservation and Protection of Corporate Assets Creating Documents and Retaining Records Intellectual Property Privacy and Data Protection Use of Meggitt Systems and Data Security Information Security 3. Our Dealings Corporate Responsibility: Meggitt and our Stakeholders External Suppliers and Associated Parties Public Officials and Employees Money Laundering Official Requests for Information and Visits from Official Inspectors Contacts with the Media Advertising and Marketing Financial Crime, Bribery and Corruption Modern Slavery Political Donations and Activities Compliance with Laws and Policies 04 06 06 08 08 08 09 10 11 11 12 13 13 14 15 16 17 18 19 19 20 20 21 21 22 22 24 25 25 26 27 28 28 29 30 31 03 MEGGITT Code of Conduct Code of Conduct “Integrity is a core Meggitt value and we are absolutely committed to achieving the highest standards of ethical conduct in our business. We also expect the same commitment from our suppliers and others working on our behalf.” The Meggitt Board and Executive Committee 04 Message from the board Message from Board of Directors and Executive Committee Our success depends on us always doing the right thing in the right way, whether we are dealing with each other or with those outside the company, like our customers, suppliers and those in our local communities. Our values of Teamwork, Integrity and Excellence are at the heart of how we do things, and we support these by applying our high performance culture principles. This Code reflects many of the principles included in the policies and procedures that are already in place or may be implemented in the future, but does not repeat all of the details. It is not intended to cover every eventuality that could arise, but instead provides basic guidance as to how we should deal with a particular situation and where to go for further guidance and support. While our vision and goals provide us with clear guidance on how to maintain our success, our Code of Conduct keeps us focused on how we should act and behave in our daily business interactions. The Code of Conduct is incorporated in all of our employment contracts so it is vital that we all understand and comply with it. We take adherence to the letter and spirit of this Code very seriously and a breach of the Code could result in disciplinary action which may include reprimand, probation, suspension or termination of employment and legal action. If you believe that our Code of Conduct or related policies are being violated, you must Speak Up. We each have a personal responsibility to uphold our ethical principles outlined in this Code of Conduct. It’s the right thing to do, as well as being central to maintaining our reputation and to making this a great place to work. It’s also about acting with integrity and trusting your judgement. If something doesn’t feel right, then it probably isn’t right. If you don’t trust it, then check it, ask for help or Speak Up. Our Code of Conduct is intended to demonstrate our complete commitment to ethical business conduct, to comply with laws and regulations and to show that this conduct is a fundamental part of our values and culture. Integrity is a core Meggitt value and we are absolutely committed to achieving the highest standards of ethical conduct in our business. We also expect the same commitment from our suppliers and others working on our behalf. Thank you for your support in this. November 2020 Our Values Collaborating and building trusted global relationships through TEAMWORK Conducting ourselves with INTEGRITY Striving for operational EXCELLENCE 05 MEGGITT Code of Conduct 1.Our Business Processes Health & Safety Meggitt is committed to conducting our business with the highest concern for the health and safety of our colleagues, contractors, visitors, customers and the general public. We are all responsible for checking and ensuring that our working environment is healthy and safe. As well as considering our own health and safety, we must also consider that of anyone who may be affected by our actions or behaviour. We must always follow health and safety policies and guidelines and fully co-operate with the instructions of health and safety advisors. 06 Section 1 Our Business Processes Where can I find more information? Health and Safety Policy (CA-HS 01) Global Physical Security Policy (MCRES-POL 1) Who can I speak to for help or information? Health and Safety Team Security Team My Responsibility Look out for and report any Health and Safety breaches Be safety conscious Ask for advice if you are unsure 07 MEGGITT Code of Conduct Conflict of Interest This is when you have two relationships (often personal and business, but not always) competing against each other. We need to avoid any conflicts between our own personal interests and those of the company. If a conflict or potential conflict occurs you must inform your manager and your HR team straight away for their approval. Honesty and Fair Dealing We should be honest, fair and truthful in all of our dealings, acting always with integrity. We must never attempt to deceive or mislead others. Confidential Information and Business Secrets Everyone is responsible for protecting confidential information whilst working for and even after leaving Meggitt. We should never use any confidential information we’ve gained through being employed by Meggitt for our own advantage (whether that’s for ourselves, for our family, a relative, a friend or anyone else). Confidential information and business secrets include any of our information and technology, financial, operational or strategic plans or data. And any financial, commercial or technical information that is valuable to us and has not yet been released to the public and may be valuable to a third party if they had access to it. We all need to protect our confidential information and business secrets. We also need to act in the same way with information received from third parties. We must not use any unethical, unlawful or improper means to obtain confidential information from any competitor, supplier, customer or other third party. 08 Where can I find more information? Global Confidential Information Policy (MGP-3) Who can I speak to for help or information? Company Secretariat Legal Team My Responsibility Always tell your manager if you think you may have a conflict of interest If in doubt, check what confidential information you can share Live the Meggitt Value of Integrity, be honest and fair in all your dealings Section 1 Our Business Processes Where can I find more information? Corrective And Preventive Action (CAPA) and Quality Clinic processes Who can I speak to for help or information? Group Product Integrity Committee (GPIC) Corrective Action Board (CAB) Engineering Team Ethics Team Legal Team Product Integrity Here at Meggitt we have the highest standards and will ensure a product meets or exceeds a customer’s expectations for reliability, performance, quality and durability throughout its life; this is called product integrity. A product concern or issue has the potential to result in serious consequences leaving Meggitt exposed to reputational damage and product liability claims if anything were to go wrong. If you become aware that our products do not meet the required standards you must Speak Up. My Responsibility Uphold the highest ethical standards in relation to product integrity Raise your concerns if you a feel a product does not meet requirements in any phases of its lifecycle Speak Up if you are concerned about the quality of a product, equipment or services Apply proper care in all company communications and document writing including design drawings and change records 09 MEGGITT Code of Conduct Inside Information and Share Dealing Where can I find more information? Share Dealing Policy (CA-CSS 04) Global Confidential Information Policy (MGP-3) Who can I speak to for help or information? Company Secretariat Legal Team Inside information is information you might know about, from being an employee but which hasn’t been made public and may affect the share price if known outside of the relevant company. We must not buy, sell or transfer stock or shares of Meggitt PLC or any other companies, or buy or sell any property or assets, when we have ‘inside information’. We must not provide such information to others for the purpose of financial gain or avoiding a loss. To do so could be a criminal offence. Inside information should not be communicated to any other person with the expectation that they would deal in the shares of the company concerned. 10 My Responsibility If in doubt, check whether what you know is inside information Never deal in Meggitt shares if you have inside information Live the Meggitt Value of Integrity, by not using information for your own financial gain Section 1 Our Business Processes Financial and Accounting Controls & Records All information about us must be recorded and presented accurately, diligently and fairly, in accordance with good business practices, applicable accounting standards and local laws. The company has a system of limits and other controls for the proper authorisation of expenditure which must be followed. Tax Evasion and Facilitating Tax Evasion When choosing agents, contractors, suppliers or other intermediaries, we will carry out pre-contract due diligence to ensure that they do not condone tax evasion, and that they have procedures in place to prevent tax evasion and the facilitation of tax evasion. Where can I find more information? Financial Crime Policy (FIN-FCP 01) Speak Up Policy (CA-EBC 08) Ethical Business Conduct Policy (CA-EBC 01) Who can I speak to for help or information? Finance Team Ethics Team Legal Team My Responsibility If you have any queries about financial practices, speak to the Finance or Legal Teams Do not engage with an intermediary without conducting all due diligence by engaging the Commercial Team 11 MEGGITT Code of Conduct Gifts and Entertainment No-one (including family members) should give or accept any gift, entertainment, transportation, charitable donation or other benefit which might be intended or perceived as an attempt to improperly influence the business relationship between Meggitt and any current or prospective supplier, customer or other party doing business or connected with us. All gifts and hospitality of more than $100 or £75, given or received, must be approved via our online Gifts Registry on MC 2 . The gifts registry entry will be authorised or refused by your manager. Clearance from our Legal Counsel or the Group Director, Ethics & Corporate Responsibility must always be sought before making payments to public officials, because in some countries there is a presumption that such gifts are corrupt. Meggitt has an absolute prohibition on gifts to employees or representatives of the United States Government. Where can I find more information? Anti-Corruption Policy (CA-EBC 04) https://gift-register.meggitt.com/ Who can I speak to for help or information? Ethics Team Legal Team Company Secretariat My Responsibility Do not give or receive gifts intended to improperly influence business relationships Seek approval for all gifts over $100/£75 on our MC 2 Gift Registry https://gift-register.meggitt.com/ Never give gifts to employees or representatives of the US Government Seek Legal advice when interacting with a Government official 12 Section 1 Our Business Processes Competition and Competitor Relationships Where can I find more information? Anti-Corruption Policy (CA-EBC 04) Who can I speak to for help or information? Ethics Team Legal Team Speaking Up and ‘Whistleblowing’ If you suspect unethical business conduct or wrongdoing at work, including: • financial malpractice • fraud or bribery • modern slavery • tax evasion or facilitation of tax evasion Where can I find more information? Speak Up Policy (CA-EBC 08) https://meggittportal.sharepoint.com/ group-functions/Ethics/Pages/Ethics-hotline.aspx Ethical Business Conduct Policy (CA-EBC 01) Anti-Corruption Policy (CA-EBC 04) • failure to comply with a legal, compliance or regulatory obligation • dangers to health and safety • the environment • any criminal activity or breaches of this Code You should raise their concern by Speaking Up. You can speak directly to your manager or supervisor, to any other senior manager, or to any of the contacts given in our Ethics Policy or on MC 2 . You can also raise issues on our independent and anonymous Speak Up helpline. If you raise a concern in good faith you will not be criticised or retaliated against in any way even if it is shown, after investigation, that you were mistaken. Any form of reprisal or victimisation against anyone who has raised a concern will not be tolerated and will itself be treated as a serious disciplinary matter. A concern raised maliciously would also be a serious disciplinary matter. Collusion with competitors is strictly prohibited and may breach competition laws resulting in serious consequences for us including damage to our reputation and the possibility of heavy financial penalties. It is the responsibility of each of our business units to ensure full compliance with all competition laws and regulations governing its operations. Who can I speak to for help or information? Ethics Team Legal Team Company Secretariat My Responsibility If you are concerned about something, speak to someone you trust Always report unethical conduct by Speaking Up Remember your concerns will be dealt with confidentially 13 MEGGITT Code of Conduct 2.Our Colleagues 14 Section 2 Our Colleagues Diversity and Inclusion, Respect, Dignity and Understanding Everyone will be treated fairly and with dignity and respect, and have equal opportunities in their employment, as Meggitt recognises that a diverse and inclusive workforce is critical to running a sustainable and successful business. People are recruited for their aptitude, skills, experience and ability. Discrimination on any grounds including race, national origin, gender, gender identity or expression, age, disability, marital status, sexual orientation, pregnancy, maternity, socio-economic background, political opinion, religion or belief is not permitted and will not be tolerated. We are all responsible for promoting and implementing equal opportunities in the workplace. Where can I find more information? Diversity and Inclusion Policy (CA-DI 01) Who can I speak to for help or information? HR Team My Responsibility Treat everyone with respect Be Inclusive Go further to understand your colleagues irrespective of background, origin or lifestyle 15 MEGGITT Code of Conduct Where can I find more information? Speak Up Policy (CA-EBC 08) Ethical Business Conduct Policy (CA-EBC 01) Who can I speak to for help or information? Ethics Team Legal Team Company Secretariat Drugs and Alcohol My Responsibility Do not bring or use alcohol or drugs at our workplace 16 We must not use, distribute or possess illegal or unauthorised drugs on any of our premises. Colleagues whose behaviour, judgement or performance of their work responsibilities is impaired by drugs or alcohol will be stopped from entering our premises or engaging in company business and may be subject to disciplinary proceedings in appropriate circumstances. Section 2 Our Colleagues Theft or Misuse of Property Anyone found to be engaging in, or attempting, theft, fraud or misuse of any property of the company or personal property of other colleagues will be subject to disciplinary action which may result in dismissal. Any incidents may also be referred to public authorities for possible criminal prosecution. Where can I find more information? Speak Up Policy (CA-EBC 08) Ethical Business Conduct Policy (CA-EBC 01) Who can I speak to for help or information? My Responsibility Report any theft of company property Ethics Team Legal Team Company Secretariat 17 MEGGITT Code of Conduct Harassment, Discrimination and Abusive Behaviour We are committed to a working environment that is free from verbal, physical or online harassment and abuse. We will treat one another with courtesy, dignity and respect, and we will not tolerate any discrimination. Whilst Meggitt supports the right to free expression, employees must not defame, harass, threaten, abuse, offend or incite violence or hatred against any person or class of persons whether on the grounds of gender, race, religion, beliefs or otherwise. This includes material or content posted to any social media platform. When using social media we must not speak disparagingly of Meggitt, its employees, officers or any product or service provided by Meggitt. We must also not use the Meggitt name, brand or trademarks on social media without prior approval by the Communications department. Where can I find more information? Speak Up Policy (CA-EBC 08) Ethical Business Conduct Policy (CA-EBC 01) Group Acceptable Use Policy (MIS_4) Who can I speak to for help or information? Ethics Team Legal Team Communications Team Company Secretariat My Responsibility Do not discuss work issues or colleagues on social media Treat everyone with respect Speak Up if you witness any harassment, discrimination or abusive behaviour 18 Section 2 Our Colleagues Preservation and Protection of Corporate Assets We all have a duty to preserve and protect Meggitt’s assets, including our property, equipment and monies, and we are all expected to use those assets properly and appropriately. If you suspect fraud, theft or abuse of our assets by either a colleague or any third party, please Speak Up. Where can I find more information? Group Data Protection Policy (see Meggitt.com) Meggitt Records Retention Policy (MGP-1 Rev 1) Who can I speak to for help or information? Legal Team Company Secretariat Creating Documents and Retaining Records We must ensure that any documents created (electronically or otherwise) are accurate, clear, detailed and timely and must also be written in a polite tone. Please remember that what you write or type may, in certain circumstances, be read by people other than the intended recipient. It is important, therefore, that we don’t put anything in a document, email or on social media that may damage the reputation of any of our colleagues or Meggitt. My Responsibility Protect all Meggitt property Consider your audience when writing down information Secure all sensitive information before leaving the office 19 MEGGITT Code of Conduct Intellectual Property Our products consist primarily of intellectual property rights. We value our own intellectual property rights and respect those of others. We must safeguard ours or any third party licensed confidential information, business secrets and intellectual property (including copyrights, trademarks and patents) in the same way that they must protect all of our other important assets. Anyone involved in acquisition and divestiture activities may be required to sign individual non-disclosure agreements. Where can I find more information? Intellectual Property (CA-IP 01) Who can I speak to for help or information? Company Secretariat Legal Team My Responsibility Secure all sensitive information before leaving the office Keep your computer station safe and locked when unattended Do not share any of our Intellectual Property outside of your project team or outside of the organisation without appropriate approval Privacy and Data Protection Where can I find more information? Information Security Policy (MIS-03) Data Protection Policy (see Meggitt.com) www.meggitt.com/about-us/our-responsibility/ group-policies/group-data-protection-policy/ Cyber Security Incident Handling Procedure Who can I speak to for help or information? Company Secretariat Legal Team MIS Security Team 20 We must at all times respect and protect all personal data we handle, relating to Meggitt’s employees, customers, suppliers, shareholders, and any other third party personal data we might have in our possession. If you handle personal data at Meggitt, you must follow the Meggitt Data Protection Policy; failure to do so could result in disciplinary action, termination of contract or even criminal prosecution. My Responsibility Always protect and respect personal data Report to MIS any concerns of computer viruses Keep Meggitt data secure Section 2 Our Colleagues Information Security Please inform mis.servicedesk@meggitt.com immediately if you suspect any computer may have a virus and do not use it again until informed it is safe to do so. Where can I find more information? Use of Meggitt Systems and Data Security We are all accountable for our actions on Meggitt systems including ERP (SAP, etc), internet, MC 2 , SharePoint, CRM and email systems. Only share information with those authorised to view it and do not store Meggitt’s sensitive or confidential information on a device unless the data is encrypted and password protected. Sensitive information should always be encrypted when sending it by email or otherwise. Information Security Policy (MIS-03) Global Physical Security Policy (MCRES-POL 1) Trade Compliance Policy (CA-TC 01) Global Confidential Information Policy (MGP-3) Acceptable Use Policy (MIS-04) Who can I speak to for help or information? Legal Team Trade Compliance Team MIS Security Team Company Secretariat Whilst our systems are intended for business purposes, you may use email systems for limited (and reasonable) non-business purposes in line with company policies. Meggitt reserves the right to monitor usage of company systems, telephones, email and internet facilities in compliance with the law and ethical best practice. In addition, all Meggitt sites use CCTV and employees may be recorded when working from our premises subject to data privacy restrictions. My Responsibility Do not take advantage of Meggitt systems for personal use Be aware of security systems Keep Meggitt data secure 21 MEGGITT Code of Conduct 3.Our Dealings Corporate Responsibility: Meggitt and our Stakeholders Meggitt PLC’s shareholders are the ultimate owners of our business and we are fully committed to delivering value to them and our other stakeholders. We also have responsibilities to our employees, customers, suppliers and the wider community to conduct our operations in a safe, responsible and sustainable manner. Where can I find more information? Corporate Responsibility and Sustainability Policy (CA-CR 01) Who can I speak to for help or information? Ethics Team 22 Section 3 Our Dealings 23 MEGGITT Code of Conduct External Suppliers and Associated Parties Our external suppliers of goods and services, and other associated parties are important to our business and should be treated with respect and fairness at all times. We will observe high ethical standards in all our dealings with suppliers and other associated parties. We will also seek to promote the same ethical standards and high level of corporate responsibility with them as we operate within Meggitt. We are committed to ensuring compliance with the principles of the United Nations Universal Declaration of Human Rights and international sanctions and embargoes, specifically, we support and respect international human rights within Meggitt’s sphere of influence. We are committed to ensuring that we are not knowingly complicit in human rights abuses. It is our intention only to contract with suppliers and other associated parties who can satisfy our standards or pass our checks with regards to labour and welfare conditions, anti-slavery, anti-bribery, the prevention of tax evasion and/or facilitation of tax evasion, information and cyber security, health and safety, international sanctions and embargoes, and environmental management or who have given a commitment to achieve these standards within an agreed time-frame. Procurement decisions are made on the basis of ethical standards, quality, service, price, delivery, best value and other similar factors. Where can I find more information? Procurement Policy (MGP-05) Who can I speak to for help or information? Procurement Team My Responsibility When purchasing goods and services always engage the Procurement Team before engaging with third parties 24 Section 3 Our Dealings Public Officials and Employees We must avoid any dealings that might be perceived as attempts to influence improperly public officials in the performance of their official duties and we must not give to, or receive any gifts from, government employees or officials. There are also laws restricting companies from hiring as an employee, or retaining as a consultant, a present or former government employee (other than secretarial, clerical, or other similar employees). These restrictions may also cover informal arrangements for prospective employment. We must obtain written clearance from our Legal teams before discussing proposed employment or retention with any current or any former government employee who left government employment within the past two years. Money Laundering We must not engage in any transaction which we know or suspect involves the proceeds of criminal activity and should carry out reasonable enquiries to validate sources of funding. Where can I find more information? Anti-Corruption Policy (CA-EBC 04) Financial Crime Policy (FIN-FCP 01) Speak Up Policy (CA-EBC 08) My Responsibility Speak Up if anyone offers you a bribe or requests you to do anything that is wrong Contact the Ethics or Legal Team if you have any concerns over a business dealing Uphold the highest ethical standards when conducting business Who can I speak to for help or information? Ethics Team Legal Team 25 MEGGITT Code of Conduct Official Requests for Information and Visits from Official Inspectors You should notify our Group General Counsel immediately if you are contacted by government regulators or authorities, agents or investigators, by lawyers who do not represent Meggitt or by other third parties seeking company information or documents concerning visits, investigations or potential or actual litigation. 26 My Responsibility If you wish to work with a Government official of any country, you must engage Legal prior to starting conversations Familiarise yourself with the Gifts Register and the policy of giving and receiving gifts Section 3 Our Dealings Contacts with the Media We are committed to delivering accurate and reliable information to the media, financial analysts, investors, brokers and other members of the public; and responding to all public, media and other enquiries appropriately. Our Group Communications team handles all external communications concerning the company and its businesses. No statement should be made or opinion expressed to the press or any third party without the explicit supervision of Group Communications. All enquiries from the press and other media must be reported to Group Communications. You should also alert Group Communications if you are aware of any story relating to Meggitt that might attract the interest of the press. Where can I find more information? MC 2 Communications functional pages Who can I speak to for help or information? Group Communications Team My Responsibility Always contact the Group Communications Team if approached by the press or media Familiarise yourself with social media conduct 27 MEGGITT Code of Conduct Advertising and Marketing All our advertising and marketing must be ethical and lawful. To achieve this, we need to be accurate and avoid misrepresenting ourselves, our products or our services, avoid defaming our competitors and respect the privacy rights of individuals to whom we may direct marketing materials. Where can I find more information? MC 2 Communications functional pages Who can I speak to for help or information? Group Communications Team Legal Team Financial Crime, Bribery and Corruption Where can I find more information? Anti-Corruption Policy (CA-EBC 04) Financial Crime Policy (FIN-FCP 01) Speak Up Policy (CA-EBC 08) Who can I speak to for help or information? Ethics Team Legal Team 28 We must all strive to ensure that all of our financial and administrative processes are carried out with honesty and integrity, and with a commitment to maintaining accuracy and transparency and that all decisions are taken objectively and free of personal interest, and that financial crime is not committed either deliberately or inadvertently. Anyone who solicits, participates in or condones a bribe or other unlawful payment or benefit, or attempts to participate in any such activity, will be subject to strict disciplinary action, including dismissal and may be the subject of criminal prosecution. We all must be vigilant to anything you think may be a bribe and report this to your manager or supervisor immediately or using our Ethics Policy contacts or Speak Up. Section 3 Our Dealings Modern Slavery We are committed to ensuring that Meggitt and our employees do not engage in practices such as slavery, human trafficking, forced labour and child labour and do not violate applicable laws and regulations relating to human trafficking and modern slavery. Where can I find more information? Corporate Responsibility and Sustainability Policy (CA-CR 01) Who can I speak to for help or information? Ethics Team Company Secretariat 29 MEGGITT Code of Conduct Political Donations and Activities It is our policy not to make cash donations to political parties or to participate in any political party activity. We do, however, ensure our views are expressed to governments in an appropriate and effective manner on matters that affect our business through our Government Relations team. Any political activity and participation in electoral politics by our colleagues must occur strictly in an individual and private capacity and not on behalf of Meggitt. We only make charitable donations that are legal and ethical under local laws and practices. Where can I find more information? Anti-Corruption Policy (CA-EBC 04) Group Sponsorship and Charitable Giving Policy (CA-CR 02) Who can I speak to for help or information? Ethics Team Legal Team Government Relations Team My Responsibility Send requests for charitable donations to the Ethics Team Speak Up if you witness any unethical business conduct 30 Section 3 Our Dealings Where can I find more information? Anti-Corruption Policy (CA-EBC 04) Group Legal Services Policy (CA-LS 1) Procurement Policy (MGP-05) Who can I speak to for help or information? Compliance with Laws and Policies Everyone is responsible for complying with the laws, regulations and codes of practice applicable to their areas of responsibility. We must comply with all policies that are brought to your attention by your management team. If you suspect that any crime may have been committed, you must report it to a member of our Legal Team who will make the determination whether we need to inform law enforcement authorities. Ethics Team Legal Team Procurement Team Commercial Team HR Team My Responsibility Speak Up if you witness any unethical business conduct Seek advice if you have queries Familiarise yourself with company policies Live the Value of Integrity 31 www.meggitt.com 032