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ROCKWELL COLLINS 09/09/14 HTTP://WWW.ROCKWELLCOLLINS.COM/

FINAL ASSESSMENT

ROCKWELL COLLINS

The following pages contain the detailed scoring for your company based on

public information.

The following table represents a summary of your scores:

Topic Number of

questions

% score based

on public

information

Leadership, Governance and

Organisation

10 70%

Risk Management 7 28.6%

Company Policy and Codes 12 95.8%

Training 5 70%

Personnel and Helplines 7 71.4%

Total 41 70.7%


A1:

Does the company publish a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company?

Score:

1

Comments:

Based on public information, there is evidence that the company publishes statements from the CEO and President supporting the ethics agenda of the company. The company therefore scores 1. To score higher the company would need to provide evidence of at least one other statement from the last two years supporting the ethics agenda of the company, or one statement specifically supporting the company’s strong stance against corruption.

References:

Public:

Company Website: A message from our CEO

‘Building a heritage of ethical behavior

Equally, we must maintain Rockwell Collins' deeply ingrained culture of ethical business performance.

The recognition we've received five years in a row from the Ethisphere® Institute as one of the World's Most Ethical Companies is a testament to our employees' high standards of business conduct. Good corporate citizenship starts from the top, but to be among the most ethical companies requires a real commitment from all employees – as well as our suppliers, our business partners and associates – to do the right thing, for the right reasons, every time.

Our pledge to you

As our company continues to grow, we pledge to maintain the highest environmental, social and ethical standards. Because it's how a successful company – one committed to building trust every day – conducts itself now and far into the future.

Kelly Ortberg

Chief Executive Officer and President

http://www3.rockwellcollins.com/csr/FromOurCEO/

[TI notes that the company website was last updated in 2014]



Standards of Business Conduct (2013):

Message from Kelly Ortberg (appointed August 2013)

http://www.rockwellcollins.co.uk/~/media/Files/Unsecure/Our%20Company/Ethics/SBC_Brochure_Final.aspx

Message from CEO and President Kelly Ortberg, Corporate Responsibility Report (the website version does not provide a date, but with copyright extended until 2014, it can be concluded that it pertains to the last two years):

‘Good corporate citizenship starts from the top, but to be among the most ethical companies requires a real commitment from all employees – as well as our suppliers, our business partners and associates – to do the right thing, for the right reasons, every time.’

http://www3.rockwellcollins.com/csr/EmpoweringOurTeam/



http://www3.rockwellcollins.com/csr/EmpoweringOurTeam/


A2:

Does the company’s Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company?

Score:

2

Comments:

Based on public information, there is evidence that the CEO and President demonstrate a personal, external facing commitment to the company’s ethics agenda. In addition, there is evidence of this engagement being delegated to others in the organisation.

References:

Public:

The company’s CEO and President serves on the Steering Board of the Defence Industry Initiative on Business Ethics and Conduct website.

http://www.dii.org/dii-steering-committee

Rockwell Collins Named as a 2014 World’s Most Ethical Company:

Quote from CEO and President Kelly Ortberg:

‘“The recognition we’ve received from the Ethisphere Institute is a testament to our entire workforce upholding our high standards of business conduct,” said Rockwell Collins CEO and President Kelly Ortberg, “Ethics are deeply ingrained in our company’s heritage and an integral part of our culture”.’

https://www.rockwellcollins.com/Data/News/2014%20Cal%20Year/RC/FY14RCNR27-Ethisphere.aspx

Non-Executive Chairman of the Board Clay Jones presented at the DII Annual Best Practices forum.

http://www.dii.org/groups/dii-community/2014-best-practices-forum

http://www.dii.org/dii-steering-committee



http://www.dii.org/groups/dii-community/2014-best-practices-forum


A3:

Does the company’s Chief Executive Officer demonstrate a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure?

Score:

1

Comments:

Based on public information, there is some evidence to indicate that the company’s Chief Executive Officer demonstrates a personal, internal-facing commitment to the ethics and anti-corruption agenda of the company. However, these are largely written communications, which do not allow for the highest score to be awarded. The company therefore scores 1.

References:

Public:

Promoting Ethics Internally:


http://rockwellcollins.com/Our_Company/~/media/4D401CD0131E46A097FE678D65FA64DB.ashx




A4:

Does the company publish a statement of values or principles representing high standards of business conduct, including honesty, trust, transparency, openness, integrity and accountability?

Score:

2

Comments:

Based on public information, there is evidence that the company publishes a statement of values or principles representing high standards of business conduct, including honesty, trust, transparency, openness, integrity and accountability. The company also demonstrates how these values can be translated into company policy.

References:

Public:

Company Website:

‘At Rockwell Collins, we are committed to conducting our business with the highest standards of ethics and in accordance with the laws and regulations of the countries in which we do business. Ethics is a cornerstone of our company's heritage and remains an important part of our culture and the way we do business.’

http://www.rockwellcollins.com/Our_Company/Ethics.aspx

‘To ensure our commitment to ethics is effectively communicated throughout our company, our employees, officers and directors are provided with a copy of our Code of Ethics, referred to as our Standards of Business Conduct.

Our ethics policies and standards of business conduct are designed to foster:

Honest and ethical conduct Full, fair, accurate, timely and understandable disclosure in public

communications Compliance with all applicable laws, rules, and regulations Fair dealing with our company’s customers, suppliers, competitors, and

employees


http://www.rockwellcollins.com/Our_Company/Ethics/~/media/Files/Unsecure/Our%20Company/Ethics/SBC_Brochure_Final.ashx


Everyone in our company is expected to be familiar with our standards of business conduct and apply them in the performance of their responsibilities. Additionally, all employees and members of our Board of Directors are required to complete an annual certification regarding compliance with our standards of business conduct.’

http://www.rockwellcollins.com/Our_Company/Ethics/Our_Standards.aspx

Standards of Business Conduct pdf on company website:

‘Our ethics policy and Standards of Business Conduct (SBC) are designed to foster: • Honest and ethical conduct • Full, fair, accurate, timely and understandable disclosure in public communications • Compliance with all applicable laws, rules and regulations • Fair dealing with our company’s customers, suppliers, competitors and employees, including properly maintaining the confidentiality of sensitive information • Protection and proper use of company assets • Prompt internal reporting of violations of law or the principles described in this document to appropriate personnel • Accountability for adherence to these standards • Maintaining accurate books and records’ http://www.rockwellcollins.com/Our_Company/Ethics/~/media/1902270829B048E58AB39A4C2AC48C8C.ashx

http://www.rockwellcollins.com/Our_Company/Ethics/Our_Standards.aspx

http://www.rockwellcollins.com/Our_Company/Ethics/~/media/1902270829B048E58AB39A4C2AC48C8C.ashx



A5:

Does the company belong to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption?

Score:

2

Comments:

Based on public information, there is evidence that the company is a member of the Defense Industry Initiative (DII).

References:

Public: Company website: Ethics http://www.rockwellcollins.com/Our_Company/Ethics.aspx TI notes that the company is also a member of TRACE International and was named as one of the World’s Most Ethical Companies (WME) for the fifth consecutive year in 2014 by the Ethisphere Institute.



A6:

Has the company appointed a Board committee or individual Board member with overall corporate responsibility for its ethics and anti-corruption agenda?

Score:

2

Comments:

Based on public information, there is evidence that the company has the Business Standards Compliance Committee with overall corporate responsibility for its ethics and anti-corruption agenda. There are clear terms of reference detailing what this responsibility entails.

References:

Public:

Company website:

‘Our Ethics and Business Compliance team works at the direction of the Audit Committee of our Board of Directors, and the Business Standards Compliance Committee (comprised of three senior leaders: the SVP General Counsel and Secretary, the SVP and CFO, and the SVP of Human Resources). These board members and senior leaders provide strategic direction and are actively engaged in setting program structure and reviewing compliance activities for the corporation.’

http://www.rockwellcollins.com/Our_Company/Ethics/Program_Structure.aspx

http://www.rockwellcollins.com/Our_Company/Ethics/~/media/Images/Pages/Our%20Company/Ethics/EBCorgchart.ashx



A7:

Has the company appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda, and who has a direct reporting line to the Board?

Score:

2

Comments:

Based on public information, there is evidence that the company has appointed Senior Vice President, General Counsel and Secretary, Robert Perna, with responsibility for implementing the company’s ethics and anti-corruption agenda.

References:

Public:

Company website:


http://rockwellcollins.com/Our_Company/Ethics/~/media/Images/Pages/Our%20Company/Ethics/EBCorgchart.ashx

Company website: Leadership

‘Perna is responsible for the services provided by the Office of the General Counsel, which includes providing legal services and advice, overseeing the company’s Ethics and Ombudsman programs and anti-bribery compliance activities, and providing export and import compliance services and advice.’

http://rockwellcollins.com/Our_Company/Leadership/Robert_Perna.aspx



http://rockwellcollins.com/Our_Company/Leadership/Robert_Perna.aspx


A8:

Is there regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda?

Score:

1

Comments:

Based on public information, there is evidence that there is periodic Board level monitoring and review of some aspects of the company’s ethics and anti-corruption agenda. TI notes that the scope for the review appears to be more monitoring on a continuous basis than a major review. The company therefore scores 1.

References:

Public:

‘Our Ethics and Business Compliance team works at the direction of the Audit Committee of our Board of Directors, and the Business Standards Compliance Committee (comprised of three senior leaders: the SVP General Counsel and Secretary, the SVP and CFO, and the SVP of Human Resources). These board members and senior leaders provide strategic direction and are actively engaged in setting program structure and reviewing compliance activities for the corporation.

We have a team of employees dedicated to ethics and compliance that serve as a resource for the enterprise and ensure compliance with company policies and U.S. and international laws throughout the organization.

The Ombudsman / Ethics & Business Conduct The Rockwell Collins Ombudsman Program upholds the integrity of our standards of business conduct by providing an avenue for our employees, customers, suppliers and shareowners to report suspected violations of law or our standards of business conduct, and to ask questions when faced with an ethical decision.

A comprehensive plan to communicate the Ombudsman's contact information ensures our employees and other stakeholders can easily access the Ombudsman if they have questions or concerns. Reports to the Ombudsman may be made anonymously if desired, unless prohibited by local country laws. We will maintain confidentiality to the extent permitted by law and by our company’s need to conduct a thorough investigation and take appropriate actions. Retaliation against those who report concerns or violations in good faith will not be

http://www.rockwellcollins.com/Our_Company/Ethics/~/media/Images/Pages/Our%20Company/Ethics/EBCorgchart.ashx

http://www.rockwellcollins.com/Our_Company/Ethics/~/media/Images/Pages/Our%20Company/Ethics/Ombud-Process.ashx


tolerated at Rockwell Collins and is strictly prohibited by our retaliation policy.

International Compliance The International Compliance team manages the company anti-bribery program which includes assessing anti-corruption risk, performing due diligence and contract administration of third parties, and anti-corruption training and communication with employees within the international marketplace.’


Audit Committee Charter, paragraph 6:

‘Meet periodically to review with management and the independent auditors their views on the Corporation's major financial and non-financial risk exposures, including the corporation’s risk assessment and risk management policies, and the steps management has taken to monitor and control such exposures. The Audit Committee should discuss guidelines and policies that govern the process by which risk assessment and management is undertaken.’ Paragraph 20: ‘Monitor compliance by the employees of the Corporation and its subsidiaries and controlled affiliated entities with applicable legal requirements and the Corporation's standards of business conduct and conflict of interest policies.’

https://www.rockwellcollins.com/Rockwell/Pages/ClickThrough.aspx?sii=26498635&rnum=0&rnam=1%20ROCKWELL%20COLLINS%2C%20INC.%20AUDIT%20COMMITTEE%20CHARTER%20...&rurl=http%3A//investor.rockwellcollins.com/files/doc_downloads/charters/COL_AuditCommitteeCharter04-20-10.pdf







A8(a):

Is there a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based, and evidence of improvement plans being implemented when issues are identified?

Score:

0

Comments:

Based on public information, there is no readily available evidence of a formal, clear, written plan that guides Board or senior management review, or evidence that improvement plans are put in place when issues are identified. TI notes that the Audit Committee Charter does not explicitly address the ethics and anti-corruption agenda, but rather focuses on financial audit and legal compliance.

References:

Public:

TI notes:

Audit Committee Charter, p.2:

‘Meet periodically to review with management and the independent auditors their views on the Corporation's major financial and non-financial risk exposures, including the Corporation’s risk assessment and risk management policies, and the steps management has taken to monitor and control such exposures. The Audit Committee should discuss guidelines and policies that govern the process by which risk assessment and management is undertaken.’







A9:

Does the company have a formal process for review and where appropriate update its policies and practices in response to actual or alleged instances of corruption?

Score:

1

Comments:

Based on public information, there is some evidence that the company has a formal process for review and update of company policies in the event of an actual or alleged instance of corruption. TI notes the Ombudsman Investigation Process particularly. However, it is not clear that policies and practices would always be reviewed and updated in the event of an actual or alleged instance of corruption. The company therefore scores 1.

References:

Public:


‘Meet periodically to review with management the independent auditors their view on the Corporation’s major financial and non-financial risk exposures, including the Corporation’s risk assessment and risk management policies, and the steps management has taken to monitor and control such exposures. The Audit Committee should discuss guidelines and policies that govern the process by which risk assessment and management is undertaken.’


Ombudsman Investigation Process:






http://rockwellcollins.com/Our_Company/Ethics/~/media/365CD44D1E954672B76BCF9CFBB05A54.ashx




A9(a):

Does the company have a formal anti-corruption risk assessment procedure implemented enterprise-wide?

Score:

1

Comments:

Based on public information, there is evidence that the company has a formal risk assessment procedure and it is understood that anti-corruption forms part of this risk assessment. However, there is limited evidence provided about this process and no readily available evidence of mitigation plans with clear ownership and timelines. The company therefore scores 1.

References:

Public:

Ombudsman Program:


http://www.rockwellcollins.com/Our_Company/Ethics/~/media/Images/Pages/Our%20Company/Ethics/Anti-Corruption-Program.ashx


‘Meet periodically to review with management the independent auditor’s view on the Corporation’s major financial and non-financial risk exposures, including the Corporation’s risk assessment and risk management policies, and the steps management has taken to monitor and control such exposures. The Audit Committee should discuss guidelines and policies that govern the process by which risk assessment and management is undertaken.’


Company website: Anti-Corruption

‘We've developed a comprehensive anti-corruption program and have a dedicated International Compliance team that works to identify operational and third party risk areas, conduct appropriate due diligence, ensure operating procedures address the risk and raise awareness of potential issues and best practices through regular employee outreach and







http://rockwellcollins.com/Our_Company/Ethics/~/media/Images/Pages/Our%20Company/Ethics/Anti-Corruption-Program.ashx


communications. The team also participates in and speaks at anti‐corruption conferences around the globe.’

http://rockwellcollins.com/Our_Company/Ethics/Anti-Corruption.aspx



A10:

Does the company have a formal anti-corruption risk assessment procedure for assessing proposed business decisions, with clear requirements on the circumstances under which such a procedure should be applied?

Score:

1

Comments:

Based on public information, there is some evidence that the company has a formal risk assessment procedure for assessing proposed business decisions, including third party risk areas. However, it is unclear how this procedure should be applied or to precisely which business decisions it applies. The company therefore scores 1.

References:

Public:

Ombudsman Program:




‘Meet periodically to review with management the independent auditor’s view on the Corporation’s major financial and non-financial risk exposures, including the Corporation’s risk assessment and risk management policies, and the steps management has taken to monitor and control such exposures. The Audit Committee should discuss guidelines and policies that govern the process by which risk assessment and management is undertaken.’


Company website: Anti-Corruption

‘We've developed a comprehensive anti-corruption program and have a dedicated International Compliance team that works to identify operational and third party risk areas, conduct appropriate due diligence, ensure operating procedures address the risk and raise awareness of potential issues and best practices through regular employee outreach and







http://rockwellcollins.com/Our_Company/Ethics/~/media/Images/Pages/Our%20Company/Ethics/Anti-Corruption-Program.ashx


communications. The team also participates in and speaks at anti‐corruption conferences around the globe.’




A11:

Does the company conduct due diligence that minimises corruption risk when selecting or reappointing its agents?

Score:

1

Comments:

Based on public information, there is evidence that the company has formal due diligence procedures for agents. However, there is no readily available evidence that the company refreshes the due diligence at least every 3 years and / or when there is a significant change in the business relationship. The company therefore scores 1.

References:

Public:

Message from the CEO, Corporate Responsibility Report:

‘Good corporate citizenship starts from the top, but to be among the most ethical companies requires a real commitment from all employees – as well as our suppliers, our business partners and associates – to do the right thing, for the right reasons, every time.’


Ombudsman Program:







A12:

Does the company have contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company has contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption.

References:

Public: TI notes: Standards of Business Conduct, p.25: ‘Rockwell Collins engages in business relationships with suppliers that have demonstrated high standards of ethics and business conduct. This expectation is defined in the Rockwell Collins Supplier Code of Conduct which can be found on the Supplier Portal.’

http://www.rockwellcollins.com/~/media/Files/Unsecure/Our%20Company/Ethics/SBC_Brochure_Final.aspx




A13:

Does the company make clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance?

Score:

1

Comments:

Based on public information, there is evidence that the company makes clear its ethics and anti-corruption policies to suppliers, contractors and sub-contractors. However, only basic information is provided publicly and there is no readily available evidence of contractual rights with regard to bribery and anti-corruption. TI notes that further information is likely provided on the Supplier Portal. The company therefore scores 1.

References:

Public: Standards of Business Conduct, p.25: ‘Rockwell Collins engages in business relationships with suppliers that have demonstrated high standards of ethics and business conduct. This expectation is defined in the Rockwell Collins Supplier Code of Conduct which can be found on the Supplier Portal.’


2014, Rockwell Collins Supplier Handbook:

https://www.supplycollins.com/portal/server.pt/gateway/PTARGS_0_0_510_201_0_43/http;/ptxapp.rockwellcollins.com/gadgets/FileUploadGadgetBrowser/viewrevision.aspx?documentid=7916







A13(a):

Does the company explicitly address the corruption risks associated with offset contracting?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company explicitly addresses offset contracting risk.

References:

Public:

NA


A13(b):

Does the company conduct due diligence that minimises corruption risk when selecting its offset partners and offset brokers?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting its offset partners and offset brokers.

References:

Public:

NA


A15:

Does the company have an anti-corruption policy that prohibits corruption in its various forms?

Score:

2

Comments:

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption in its various forms, including the giving and receiving of bribes.

References:

Public:

Company website:

‘At Rockwell Collins, we take anti-bribery laws very seriously and have a zero tolerance policy on corruption. Company policies are in place to ensure our employees operate in compliance with the FCPA, UK Bribery Act, and other anti-corruption laws in the countries in which we do business. This includes policies that prohibit facilitation payments, political or charitable contributions without prior approval, and any payments with corrupt intent.

We've developed a comprehensive anti-corruption program and have a dedicated International Compliance team that works to identify operational and third party risk areas, conduct appropriate due diligence, ensure operating procedures address the risk and raise awareness of potential issues and best practices through regular employee outreach and communications. The team also participates in and speaks at anti‐corruption conferences around the globe.

Our gratuities and business courtesies guidelines are clearly outlined in a chart that employees can download as a PDF or interactive mobile application on their portable electronic devices. All employees are expected to follow these guidelines and seek appropriate approvals before offering or receiving gifts that may violate our policies or anti-bribery laws.

Download copies of our anti‐bribery guidelines in the US and in other companies where we do business:’



http://www.rockwellcollins.com/Our_Company/Ethics/Anti-Corruption.aspx



A16:

Is the anti-corruption policy explicitly one of zero tolerance?

Score:

2

Comments:

Based on public information, there is evidence that the company has an explicit policy of zero tolerance of corruption.

References:

Public:

Company website:

‘At Rockwell Collins, we take anti-bribery laws very seriously and have a zero tolerance policy on corruption. Company policies are in place to ensure our employees operate in compliance with the FCPA, UK Bribery Act, and other anti-corruption laws in the countries in which we do business. This includes policies that prohibit facilitation payments, political or charitable contributions without prior approval, and any payments with corrupt intent.’




A17:

Is the company's anti-corruption policy easily accessible to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company?

Score:

2

Comments:

Based on public information, there is evidence that the company’s anti-corruption policy is easily available for all employees, contracted staff, and affiliated organisations. TI notes that the company’s Standards of Business Conduct are available in several languages.

References:

Public:

Company website:




A17(a):

Is the company’s anti-corruption policy easily understandable and clear to Board members, employees and third parties?

Score:

2

Comments:

Based on public information, there is evidence that the company’s anti-corruption policy is written in accessible, comprehensible language.

References:

Public:

Standards of Business Conduct: http://www.rockwellcollins.com/~/media/Files/Unsecure/Our%20Company/Ethics/SBC_Brochure_Final.aspx

Company Website:






A18:

Does the anti-corruption policy explicitly apply to all employees and

members of the Board?

Score:

2

Comments:

Based on public information, there is evidence that the company’s policy applies to all employees and members of the Board.

References:

Public: Standards of Business Conduct: ‘To whom does our SBC apply? Our SBC applies to all Rockwell Collins employees, contractors, consultants and representatives. Members of the Board of Directors of Rockwell Collins, Inc. are also expected to comply with our ethics policy and our Standards of Business Conduct to the same extent as if they were employees of the company. Any waiver, including implicit waiver or pre-approval, of our Standards of Business Conduct in any material respect for any executive officer or member of the Board of Directors must be reviewed and approved by the Board of Directors or a Board committee.’ http://www.rockwellcollins.com/Our_Company/Ethics/~/media/1902270829B048E58AB39A4C2AC48C8C.ashx Extract from Corporate Governance pdf: ‘Board Compliance with Corporate Policies Directors shall comply with Rockwell Collins Standards of Business Conduct to the same extent as if they were employees of the Corporation, except the review of each disclosed potential conflict of interest will be the responsibility of the disinterested members of the Board of Directors. Directors are required to execute annual standards of business conduct and conflicts of interest representations. Any waiver of these policies for Directors or executive officers may be made only by the Board of Directors or a Board Committee and shall be promptly disclosed to shareowners.’ http://investor.rockwellcollins.com/files/doc_downloads/governance/Guidelines%20on%20Corporate%20Governance%202.6.14.pdf



http://investor.rockwellcollins.com/files/doc_downloads/governance/Guidelines%20on%20Corporate%20Governance%202.6.14.pdf



A20:

Does the company have a policy on potential conflicts of interest, and does it apply to both employees and board members?

Score:

2

Comments:

Based on public information, there is evidence that the company has a policy on potential conflicts of interest, which includes a definition and several examples.

References:

Public: Standards of Business Conduct: ‘Conflict of interest The company requires you to avoid any conflict, or even the appearance of a conflict, between your personal interests and the interests of the company. A conflict exists when your interests, duties, obligations or activities, or those of a family member are, or may be, in conflict or incompatible with the interests of Rockwell Collins. Should any business or personal conflict of interest arise, or even appear to arise, you should disclose it immediately to leadership for review. Remember, a conflict of interest is not necessarily a violation of the SBC, but it is important to disclose it. This allows the situation to be properly reviewed and directed to the proper channel(s). Rockwell Collins will work with you to find an appropriate solution.’





A21:

Does the company have a policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery?

Score:

2

Comments:

Based on public information, there is evidence that the company has a policy for the giving and receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. This policy sets upper limits for gift exchange.

References:

Public: Standards of Business Conduct, pp.27-28: ‘Rockwell Collins has established policy and approval requirements for offering and receiving gratuities and business courtesies. All gratuities and business courtesies offered or received must be in accordance with the monetary limitations established by this policy. A mobile site is also available. From your smartphone (touchscreen only), visit m.rockwellcollins.com/sbc for access to the interactive site.’






A22:

Does the company’s anti-corruption policy include a statement on the giving and receipt of hospitality that ensures that such transactions are bona fide and not a subterfuge for bribery?

Score:

2

Comments:

Based on public information, there is evidence that the company has a policy for the giving and receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. This policy sets upper limits for hospitality exchange.

References:

Public: Standards of Business Conduct, pp.27-28: ‘Rockwell Collins has established policy and approval requirements for offering and receiving gratuities and business courtesies. All gratuities and business courtesies offered or received must be in accordance with the monetary limitations established by this policy. A mobile site is also available. From your smartphone (touchscreen only), visit m.rockwellcollins.com/sbc for access to the interactive site.’






A23:

Does the company have a policy that explicitly prohibits facilitation payments?

Score:

2

Comments:

Based on public information, there is evidence that the company prohibits facilitation payments to government or party officials. If employees are requested to make such a payment, they must notify the Office of the General Counsel immediately.

References:

Public:

Standards of Business Conduct, p.27:

‘Facilitation payments are small payments made to individuals who are considered a government official, or party official to secure, expedite, or avoid delays in the performance of routine services or actions that the company is otherwise entitled to receive. Facilitation payments are generally requested in connection with obtaining ordinary licenses, work permits, processing of visas and other similar customary governmental services. Rockwell Collins policy prohibits facilitation payments by our employees, officers, directors, and third parties who do business on our behalf. If you are requested to make a facilitation payment, you must notify the Office of the General Counsel immediately.’

‘Commercial bribery involves a situation where something of value is given to a current or prospective business partner with the intent to obtain business or influence a business decision. You must avoid participating in commercial bribery, or even the appearance of it, in all of our business dealings.’’





A24:

Does the company prohibit political contributions, or regulate such contributions in order to prevent undue influence or other corrupt intent? Does the company record and publicly disclose all political contributions?

Score:

2

Comments:

Based on public information, there is evidence that the company regulates political contributions to prevent corruption or other undue influence.

References:

Public:

Company website:

’Like many companies, Rockwell Collins participates in the U.S. political and regulatory process to ensure our company's interests are appropriately represented. In accordance with our Standards of Business Conduct, these activities are conducted with the highest standards of ethics and in accordance with all laws and regulations. Specific activities include:

Rockwell Collins Employee Political Action Committee

The Rockwell Collins Employee Political Action Committee (ePAC) is a voluntary, nonpartisan association of eligible Rockwell Collins employees who contribute to candidates for federal or state office who support Rockwell Collins' public policy objectives. The ePAC is governed by an advisory council comprised of senior management from across the company. The president of the ePAC is our company's Senior Vice President, Washington Operations.

The ePAC is regulated by the Federal Elections Committee (FEC) and contribution information may be found by searching for the Rockwell Collins Employee Political Action Committee (formerly the Rockwell Collins Good Government Committee) on the FEC website, www.fec.gov.

http://www.fec.gov/


Corporate Political Expenditures

Rockwell Collins has not made direct or indirect corporate political contributions to state and local candidates or organizations operated in accordance with Internal Revenue Code section 527 (e.g., political action committees). The company also has not made independent corporate expenditures for independent communications to the general public that expressly advocate the election or defeat of a clearly identified federal candidate or that are intended to influence the outcome of a ballot measure. The company has no present plans to make such contributions or expenditures. If such company contributions or expenditures were to be made in the future, they would be made solely to promote the company's interests and without regard to the private political preferences of any company officer. The company will continue to monitor these areas for legislative, judicial or regulatory changes and will review its position on such expenditures periodically. Any such future expenditure will be made in accordance with all laws and regulations and will be consistent with our standards of business conduct.’

http://www.rockwellcollins.com/Our_Company/Corporate_Public_Policy.aspx


‘Political and lobbying expenditures and activities U.S. law prohibits corporations from making contributions directly to a U.S. federal candidate or to the candidate’s campaign committee. The law also prohibits making expenditures on behalf of a candidate in coordination with a candidate or a candidate’s campaign committee. In addition, corporate political contributions in certain states and countries are illegal, or if legal, are subject to monetary limitations and regulatory notification requirements. All Rockwell Collins political contributions are subject to prior approval by the Senior Vice President, Washington Operations, after consultation with the Senior Vice President, General Counsel and Secretary and the Senior Vice President, Chief Financial Officer. If you incur U.S. lobbying or U.S. official honoring expenditures, you are required to report such expenditures to the company in support of the company’s obligation to report such expenditures to the U.S. Congress. U.S. official honoring expenditures include expenses incurred to sponsor an event that is intended to honor or recognize certain legislative or executive branch officials.’ http://www.rockwellcollins.com/~/media/Files/Unsecure/Our%20Company/Ethics/SBC_Brochure_Final.aspx Anti-Corruption Policies and Initiatives: ‘At Rockwell Collins, we take anti-bribery laws very seriously and have a zero tolerance policy on corruption. Company policies are in place to ensure our employees operate in compliance with the FCPA, UK Bribery Act, and other anti-corruption laws in the countries in which we do business. This includes policies that prohibit facilitation payments, political or charitable contributions without prior approval, and any payments with corrupt intent.’ http://www.rockwellcollins.com/Our_Company/Ethics/Anti-Corruption.aspx






A25:

Does the company have a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, and discloses the issues on which the company lobbies?

Score:

2

Comments:

Based on public information, there is evidence of a policy that clearly regulates lobbying activity to prevent undue influence or other corrupt intent, and guidelines on its application are clear. The company discloses its federal lobbying activities.

References:

Public:

Company website: http://www.rockwellcollins.com/Our_Company/Corporate_Public_Policy.aspx

‘Lobbying Expenditures

Federal lobbying activities are regulated by the Lobbying Disclosure Act (LDA). In full compliance with the LDA, Rockwell Collins' lobbying activities and expenses are disclosed to the U.S. Congress on a quarterly basis. These reports are publicly available at the U.S. House of Representatives Office of the Clerk website, www.lobbyingdisclosure.house.gov.’


‘Political and lobbying expenditures and activities U.S. law prohibits corporations from making contributions directly to a U.S. federal candidate or to the candidate’s campaign committee. The law also prohibits making expenditures on behalf of a candidate in coordination with a candidate or a candidate’s campaign committee. In addition, corporate political contributions in certain states and countries are illegal, or if legal, are subject to monetary limitations and regulatory notification requirements. All Rockwell Collins political contributions are subject to prior approval by the Senior Vice President, Washington Operations, after consultation with the Senior Vice President, General Counsel and Secretary and the Senior Vice President, Chief Financial Officer. If you incur U.S. lobbying or U.S. official honoring expenditures, you are required to report such expenditures to the company in support of the company’s obligation to report such


http://www.lobbyingdisclosure.house.gov/


expenditures to the U.S. Congress. U.S. official honoring expenditures include expenses incurred to sponsor an event that is intended to honor or recognize certain legislative or executive branch officials.’





A25(a):

Does the company prohibit charitable contributions, or regulate such contributions in order to prevent undue influence or other corrupt intent?

Score:

1

Comments:

Based on public information, there is some evidence that the company regulates such contributions to prevent corruption or other undue influence. However, the procedure for donations is not clear and there is no readily available evidence that donations are publicly declared. The company therefore scores 1.

References:

Public: Standards of Business Conduct, p.39: ‘Rockwell Collins’ philanthropic contributions of funds or property are made to organizations in our communities that support health, welfare, education, civic and cultural activities. Our primary consideration is given to organizations that promote education (with a focus on promoting student interests in science, technology, engineering and mathematics) and the business interests of the company, as well as organizations that provide services in locations where our company has employees and facilities.’

(p.26): ‘Anti-bribery and gratuities and business courtesies

The exchange of appropriate gifts and entertainment is often a way to build our business relationships. However, you must conduct business with customers (including U.S. and non-U.S. governments) and vendors without giving or accepting bribes. A “bribe” is giving anything of value that would improperly influence or appear to improperly influence the outcome of a transaction. “Anything of value” is very broadly defined and can include such things as:

• Cash • Gifts • Meals • Entertainment • Travel and lodging • Personal services • Charitable donations • Business opportunities


• Favors • Offers of employment’





A26:

Does the company provide written guidance to help Board members and

employees understand and implement the firm’s ethics and anti-corruption

agenda?

Score:

2

Comments:

Based on public information, there is evidence that employees have access to some materials such as the Standards of Business Conduct on the website, which includes some examples. The company also provides training and communications programmes which aid employees’ understanding of ethical and anti-corruption policies.

References:

Public:


‘Ethical decision-making

Our SBC provides clear expectations for conducting business at Rockwell Collins. In all circumstances you are expected to operate in accordance with our Standards of Business Conduct. In some cases the complexity of the situation may mean the right decision is not clear. You may face situations in which an action would not violate a law or a company policy, but does not seem to be the right thing to do. At Rockwell Collins it is important to consider the matter in the context of our ethical philosophy and standards.

To assist you, we have developed an ethical decision-making process (see the chart below). This process provides a consistent approach to the evaluation of ethical dilemmas you may face in a fast-paced and challenging business climate. Because our leaders have an important role in helping others make ethical decisions, specific expectations for them are also included.

When making ethical decisions, consider the following questions:


(p.26): ‘Examples of a government official include:

• Officers or employees of a government, regardless of rank or position

• Officials or employees of a governmentowned business enterprise

• Employees of public international organizations or any of their departments or agencies

• Members or officials of a political party

• Candidates for a political office

• Members of a royal family

• Members of a legislative body Remember, it is common for commercial entities (i.e. airlines) to be partially-owned by a government in some countries. You should consult with the Office of the General Counsel if you have questions about potential government ownership of companies we do business with.’

(p.27): ‘Bribery can also arise in situations that do not involve a government official.

Commercial bribery involves a situation where something of value is given to a current or prospective business partner with the intent to obtain business or influence a business decision.

You must avoid participating in commercial bribery, or even the appearance of it, in all of our business dealings.

In addition to bribery payments, you should also be aware of the following types of corrupt payments that you are responsible for avoiding:

Kickbacks are agreements to return a sum of money to another party in exchange for making or arranging a business transaction.

Facilitation payments are small payments made to individuals who are considered a


government official, or party official to secure, expedite, or avoid delays in the performance of routine services or actions that the company is otherwise entitled to receive. Facilitation payments are generally requested in connection with obtaining ordinary licenses, work permits, processing of visas and other similar customary governmental services. Rockwell Collins policy prohibits facilitation payments by our employees, officers, directors, and third parties who do business on our behalf. If you are requested to make a facilitation payment, you must notify the Office of the General Counsel immediately.’

‘Gratuities and business courtesies policy

Rockwell Collins has established policy and approval requirements for offering and receiving gratuities and business courtesies. All gratuities and business courtesies offered or received must be in accordance with the monetary limitations established by this policy. A mobile site is also available. From your smartphone (touchscreen only), visit m.rockwellcollins. com/sbc for access to the interactive site.’

(p.29): ‘Definitions and requirements

Gratuities – Tangible or intangible items of value – such as cash, gifts, goods, services, favors, use of property or facilities that confer a benefit on the recipient. The only time cash can be provided to another person as a gratuity is for customary tips (such as baggage handling tips) and the dollar value must be very modest.

Business courtesies – Accommodations – such as meals, refreshments, entertainment, transportation or lodging.’


Ethics and Compliance section of the company website:






A27:

Does the company have a training programme that explicitly covers anti-corruption?

Score:

2

Comments:

Based on public information, there is evidence that the company has an explicit anti-corruption module as part of its ethics and compliance training programme.

References:

Public:

Company website: Ethics – Employee Training

‘A comprehensive ethics and compliance training program has been developed by our team of subject matter experts. This training is deployed to all new employees within their first few months of service, and to all employees on an annual basis as a reminder to ensure that they understand and comply with company policies.

Legal Compliance Training Courses New Employee Legal Compliance Training Courses

Export and Import Compliance

Recruiting U.S. Government Employees

Anti-Bribery Handling Proprietary

Information Employment Laws SEC Laws Antitrust Laws Product Integrity Exporting Technical Data to

Foreign Nationals Integrity in Government

Procurements Intellectual Property Data Privacy

Ethics for New Employees Legal Compliance General Awareness 1

(topics include: export and import compliance, procurement integrity, recruiting U.S. Government employees, handling proprietary information, data privacy and employment laws)

Legal Compliance General Awareness 2 (topics include: antitrust and competition rules, anti-bribery laws, SEC laws, product integrity, and document creation and retention)


Annual Ethics Training

Our ongoing communication plan supplements this training and includes messages from leadership, educational tools and videos, our internal web pages, company newsletters and other employee publications including Rockwell Collins' Horizons magazine.’

http://www.rockwellcollins.com/Our_Company/Ethics/Employee_Training.aspx

http://www.rockwellcollins.com/Our_Company/Horizons.aspx



A28:

Is anti-corruption training provided in all countries where the company operates or has company sites?

Score:

2

Comments:

Based on public information, there is evidence that training is provided in all countries where the company operates or has company sites.

References:

Public:


‘A comprehensive ethics and compliance training program has been developed by our team of subject matter experts. This training is deployed to all new employees within their first few months of service, and to all employees on an annual basis as a reminder to ensure that they understand and comply with company policies.’




A29:

Does the company provide targeted anti-corruption training to members of the Board?

Score:

1

Comments:

Based on public information, there is evidence that the company provides targeted anti-corruption training to members of the Board, but it is not clear that they are re-trained at least every 3 years. The company therefore scores 1.

References:

Public: Corporate Governance pdf: ‘Director Orientation and Continuing Education All new directors are required to participate in the Corporation’s Orientation Program, which should be conducted within three months after election to the Board. This orientation will include matters appropriate to familiarize the new director with the Corporation, such as presentations by senior management to familiarize new directors with the Corporation’s strategic plans, its significant financial, accounting and risk management issues, its compliance programs, its ethics program, its principal officers, and its internal and independent auditors. The Corporation will provide directors with presentations from time to time on topics designed by the Corporation and/or third party experts to assist directors in carrying out their responsibilities. Directors are encouraged to engage in continuing education regarding the duties and responsibilities of Board and Committee members and the Corporation will pay the reasonable expenses for directors attending accredited third party training for these continuing education purpose.’





A30:

Does the company provide tailored ethics and anti-corruption training for employees in sensitive positions?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company provides tailored ethics and anti-corruption training to employees in high risk positions.

References:

Public:

TI notes:


‘A comprehensive ethics and compliance training program has been developed by our team of subject matter experts. This training is deployed to all new employees within their first few months of service, and to all employees on an annual basis as a reminder to ensure that they understand and comply with company policies.

Legal Compliance Training Courses New Employee Legal Compliance Training Courses

Export and Import Compliance

Recruiting U.S. Government Employees

Anti-Bribery Handling Proprietary

Information Employment Laws SEC Laws Antitrust Laws Product Integrity Exporting Technical Data to

Foreign Nationals Integrity in Government

Procurements Intellectual Property Data Privacy

Ethics for New Employees Legal Compliance General Awareness 1

(topics include: export and import compliance, procurement integrity, recruiting U.S. Government employees, handling proprietary information, data privacy and employment laws)

Legal Compliance General Awareness 2 (topics include: antitrust and competition rules, anti-bribery laws, SEC laws, product integrity, and document creation and retention)


Annual Ethics Training

Our ongoing communication plan supplements this training and includes messages from leadership, educational tools and videos, our internal web pages, company newsletters and other employee publications including Rockwell Collins' Horizons magazine.’


http://www.rockwellcollins.com/Our_Company/Horizons.aspx



A31:

Does the company have a clear and formal process by which employees declare conflicts of interest?

Score:

1

Comments:

Based on public information, there is evidence that the company has a clear and formal process for employees to declare conflicts of interest, but this is to leadership. There is some indication that independent departments – Human Resources and the Ombudsman – are involved, but there is insufficient public information to underpin a higher score. The company therefore scores 1.

References:

Public: Standards of Business Conduct, p.16: ‘The company requires you to avoid any conflict, or even the appearance of a conflict, between your personal interests and the interests of the company. A conflict exists when your interests, duties, obligations or activities, or those of a family member are, or may be, in conflict or incompatible with the interests of Rockwell Collins. Should any business or personal conflict of interest arise, or even appear to arise, you should disclose it immediately to leadership for review. Remember, a conflict of interest is not necessarily a violation of the SBC, but it is important to disclose it. This allows the situation to be properly reviewed and directed to the proper channel(s). Rockwell Collins will work with you to find an appropriate solution.’ (p.17): ‘Contact the Ombudsman or Human Resources for further guidance about making a disclosure and avoiding conflicts, or even the appearance of conflicts.’





A32:

Is the company explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities?

Score:

2

Comments:

Based on public information, the company has an explicit commitment to apply disciplinary procedures to employees who have violated its anti-corruption policy. The company Standards of Business conduct also apply to Members of the Board of Directors.

References:

Public: Standards of Business Conduct, p.5: ‘To whom does our SBC apply? Our SBC applies to all Rockwell Collins employees, contractors, consultants and representatives. Members of the Board of Directors of Rockwell Collins, Inc. are also expected to comply with our ethics policy and our Standards of Business Conduct to the same extent as if they were employees of the company. Any waiver, including implicit waiver or pre-approval, of our Standards of Business Conduct in any material respect for any executive officer or member of the Board of Directors must be reviewed and approved by the Board of Directors or a Board committee.’ (p.8): ‘What are the consequences for violating our Standards of Business Conduct? Any employee who violates the law or any of the company’s policies or these Standards of Business Conduct is subject to disciplinary action which, without limitation, may include strict discipline or other employment action, up to and including loss of employment. Any employee who knowingly makes or refers a false allegation to the Ombudsman or management is subject to discipline. Additionally, anyone who deliberately provides false information or refuses to cooperate in an investigation will be subject to disciplinary action. Any leader who fails to take appropriate actions after receiving a report of a suspected violation of our SBC will be subject to disciplinary action.’





A33:

Does the company have multiple, well-publicised channels that are easily accessible and secure, to guarantee confidentiality or anonymity where requested by the employee (e.g. web, phone, in person), to report concerns or instances of suspected corrupt activity?

Score:

1

Comments:

Based on public information, the company has multiple internal channels to report instances of suspected corrupt activity that are well publicised and allow for anonymity. However, the company does not have a portal that would allow for two-way communication whilst preserving anonymity, and lacks a channel operated independently (the Ombudsman, while an independent department, is part of the company). The company therefore scores 1.

References:

Public: Rockwell Collins Ethics Line from Standards of Business Conduct: ‘Contact the Ombudsman using the Ethics Line or through the “Contact the Ombudsman” webpage or the Ethics and Ombudsman webpage. The Ombudsman is available for you to ask questions, seek guidance, express concerns or report suspected violations of Rockwell Collins’ Standards of Business Conduct. Reports to the Ombudsman may be made anonymously if desired, unless prohibited by local country laws. We will maintain confidentiality to the extent permitted by law and by our company’s need to conduct a thorough investigation and take appropriate actions.’ ‘Responsibilities of our employees You are expected to know, follow and conduct yourself in accordance with our SBC. If you have knowledge of a violation of our SBC or the laws or regulations governing our business, you are expected and obligated to promptly report such violations. Contact your leader, a Human Resources representative, the Ombudsman or the Office of the General Counsel. Responsibilities of our leadership Any leader receiving a report is expected to promptly report the matter to higher management, the Ombudsman and the Office of the General Counsel and take such further action as directed. Some examples of issues that must be reported immediately include: • Non-compliance with laws and regulations’






A33(a):

Are the whistleblowing channels available to all employees in all geographies?

Score:

2

Comments:

Based on public information, there is evidence that across geographies, all employees have access to more than one reporting channel.

References:

Public: Rockwell Collins Ethics Line from Standards of Business Conduct: ‘Contact the Ombudsman using the Ethics Line or through the “Contact the Ombudsman” webpage or the Ethics and Ombudsman webpage. The Ombudsman is available for you to ask questions, seek guidance, express concerns or report suspected violations of Rockwell Collins’ Standards of Business Conduct. Reports to the Ombudsman may be made anonymously if desired, unless prohibited by local country laws. We will maintain confidentiality to the extent permitted by law and by our company’s need to conduct a thorough investigation and take appropriate actions.’

‘Responsibilities of our employees You are expected to know, follow and conduct yourself in accordance with our SBC. If you have knowledge of a violation of our SBC or the laws or regulations governing our business, you are expected and obligated to promptly report such violations. Contact your leader, a Human Resources representative, the Ombudsman or the Office of the General Counsel. Responsibilities of our leadership Any leader receiving a report is expected to promptly report the matter to higher management, the Ombudsman and the Office of the General Counsel and take such further action as directed. Some examples of issues that must be reported immediately include: • Non-compliance with laws and regulations’





A33(b):

Does the company have formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, or that whistleblowers are treated supportively.

References:

Public: TI notes: Non Retaliation Policy from Standards of Business Conduct: ‘Retaliation against an individual who reports a violation of law or company policy is strictly prohibited. Downgrading an employee’s performance rating, limiting an employee’s opportunities for assignments or advancement, excluding an employee from corporate or departmental functions, or any other types of retaliation must not be imposed on an employee as punishment for: • Filing or responding to a good faith complaint, or • Cooperating in an investigation. Acting in “good faith” means that you provide all of the information you have and believe you are giving a sincere and complete report. Individuals who take action against a person for making a report or participating in an investigation in good faith will be subject to disciplinary action, up to and including termination, as local law permits.’





A34:

Does the company have well-publicised resources available to all employees where help and advice can be sought on corruption-related issues?

Score:

2

Comments:

Based on public information, there is evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues. This includes trained managers, helplines, and an internal ombudsman.

References:

Public: Standards of Business Conduct, p.6: ‘Rockwell Collins has more than 20,000 employees in 27 locations, and we are committed to providing support when questions about our Standards of Business Conduct arise. Seek guidance through the following resources: Leadership Contact your direct supervisor or higher levels of leadership within your business unit or shared services organization. Our leaders are available to discuss ethical concerns or questions. They may refer you to another resource, but under most circumstances leadership should be your first point of contact. Ombudsman Corporate Ombudsman Contact the corporate Ombudsman using the Ethics Line at 1.866.224.8137 or VPN 295.7714 to get answers to your questions, seek guidance, express concerns or report suspected violations of our SBC. Rockwell Collins’ corporate Ombudsman is located in Cedar Rapids, Iowa. Non-U.S. – Regional Ombudsman Representatives Rockwell Collins has Ombudsman representatives in several different international locations. These individuals serve as local contacts about ethics and business conduct questions, and also assist the corporate Ombudsman by managing local investigations as needed. Complete contact information for the Ombudsman office and non-U.S. and regional Ombudsman representatives is available on the Contact the Ombudsman webpage and also at the back of this document.


Human Resources Contact your local Human Resources representative or the Human Resources Service Center at 1.866.295.4747 or VPN 295.HRHR with employee relations matters or issues involving employee-related concerns. Office of the General Counsel Contact the Office of the General Counsel (OGC) to obtain legal advice or assistance with interpretation of laws, regulations or company policies that address legal compliance matters. Contact information for members of the OGC is available on the OGC webpage on Rockwell Collins Online. From Standards of Business Conduct on company website Throughout the SBC, this icon is used to identify additional online resources available on our SBC website about a specific topic. This site provides several useful tools and resources throughout to help you better understand Rockwell Collins policies. These include: • Q&As • Videos • Knowledge checks • Mobile tools • Links to policies and procedures • Leader tools • Contact information The SBC website is located on our Intranet at: Rockwell Collins Online > Our Company > Ethics’





A35:

Is there a commitment to non-retaliation for bona fide reporting of corruption?

Score:

2

Comments:

Based on public information, there is evidence that the company has a clear, legally enforceable, non-retaliation policy for bona fide reporting of corruption. There is also evidence that disciplinary measures are applied to individuals breaching this policy.

References:

Public:

Company website: The Ombudsman / Ethics & Business Conduct ‘The Rockwell Collins Ombudsman Program upholds the integrity of our standards of business conduct by providing an avenue for our employees, customers, suppliers and shareowners to report suspected violations of law or our standards of business conduct, and to ask questions when faced with an ethical decision.

A comprehensive plan to communicate the Ombudsman's contact information ensures our employees and other stakeholders can easily access the Ombudsman if they have questions or concerns. Reports to the Ombudsman may be made anonymously if desired, unless prohibited by local country laws. We will maintain confidentiality to the extent permitted by law and by our company’s need to conduct a thorough investigation and take appropriate actions. Retaliation against those who report concerns or violations in good faith will not be tolerated at Rockwell Collins and is strictly prohibited by our retaliation policy.’

Standards of business Conduct:

‘Non-retaliation policy Retaliation against an individual who reports a violation of law or company policy is strictly prohibited. Downgrading an employee’s performance rating, limiting an employee’s opportunities for assignments or advancement, excluding an employee from corporate or departmental functions, or any other types of retaliation must not be imposed on an employee as punishment for: • Filing or responding to a good faith complaint, or • Cooperating in an investigation.

http://www.rockwellcollins.com/Our_Company/Ethics/~/media/Images/Pages/Our%20Company/Ethics/Ombud-Process.ashx


Acting in “good faith” means that you provide all of the information you have and believe you are giving a sincere and complete report. Individuals who take action against a person for making a report or participating in an investigation in good faith will be subject to disciplinary action, up to and including termination, as local law permits.’ http://www.rockwellcollins.com/Our_Company/Ethics/~/media/1902270829B048E58AB39A4C2AC48C8C.ashx




Information Sources:

Company website:

www.rockwellcollins.com

Standards of Business Conduct (2013):


Audit Committee Charter:

http://investor.rockwellcollins.com/files/doc_downloads/governance/Audit-Committee-Charter-4-16-14.pdf

Rockwell Collins Supplier Handbook (2014):


Guidelines on Corporate Governance (2014):


http://www.rockwellcollins.com/










Documents

FINAL ASSESSMENT ROCKWELL COLLINS - …companies.defenceindex.org/pdf/rockwellcollins.pdf · ROCKWELL COLLINS 09/09/14 HTTP:// FINAL ASSESSMENT ROCKWELL COLLINS The following pages