Ethics and business conduct

Chemring adopts a zero-tolerance approach to the facilitation of tax evasion, whether under UK law or under the law of any foreign country.

None of our businesses reside in countries considered as partially compliant or non-compliant according to the OECD tax transparency report and/or considered to be Offshore Financial Centres by the IMF or blacklisted or grey listed by the EU in February 2020.

Our Commercial Policy sets out the procedures required to be adopted by all businesses to ensure that appropriate commercial practices and controls are implemented, and that commercial and contractual risks are properly identified and adequately mitigated. The objectives of the policy are to ensure that customer bids and proposals are prepared, and contracts with third parties are negotiated, administered and executed, on a basis which will enable the contracting parties to satisfy their commercial and legal obligations, whilst delivering the requisite levels of return for the business and minimising potential liabilities.

Chemring recognises that our employees and businesses have an important role to play in their local communities and in supporting broader charitable activities. Our Community Investment Policy sets out our approach to employee involvement in charitable activities, and our policy on donations to charities and other not-for-profit organisations.

Chemring aims to compete vigorously but fairly in all of the markets in which we operate, and we are committed to complying with competition and anti-trust laws. The Company will not engage in anti-competitive behaviour and will not tolerate such behaviour from our employees or any third parties acting on our behalf. The Competition Law Compliance Policy provides an overview of the main competition and anti-trust laws that could affect our business, and sets out procedures and guidelines which must be followed when dealing with matters to which competition or anti-trust laws may apply.

Conflicts of interests can arise where an employee’s interests conflict with, or might appear to conflict with, those of Chemring, as a consequence of their personal relationships with customers, business partners, suppliers or competitors. Such conflicts may impair the ability of an employee to make objective and unbiaised business decisions in the interests of the Company. The Conflicts of Interest Policy sets out Chemring’s requirements in relation to the disclosure and proper management of potential conflicts of interest.

All businesses are required to maintain a Conflicts of Interest Register, a copy of which is required to be submitted with their BACM Compliance Certificate on a biannual basis.

Chemring complies fully with all export control laws applicable to the countries in which we do business. All businesses are required to maintain export control procedures to ensure that all requisite approvals are obtained for the transfer of products, services, technology and data from one country to another, and to implement systems which will detect export control violations promptly if they do occur.

Bona fide hospitality, promotional or other business expenditure which seeks to improve the image of our businesses, to better present our products and services, and to foster relationships with our customers and suppliers, is recognised as an established and important part of doing business. However, if the giving or receiving of a gift or hospitality is intended to influence the outcome of a contractual or material transaction, or to induce or reward improper behaviour on the part of the recipient, it may constitute an illegal bribe.

All employees are required to seek approval for gifts and hospitality through the Chemring Compliance Portal.

Chemring is committed to protecting its own intellectual property, such as information, processes, and technology, from infringement by others. The Company is also committed to respecting the intellectual property of others. The Intellectual Property Policy and our Code of Conduct set out standards and behaviours expected of all employees in the management of intellectual property.

The Company is committed to ensuring that any offset activity undertaken by our businesses, or on their behalf, complies fully with all applicable laws and regulations, our Code of Conduct and our Bribery Act Compliance Manual. The Offset Policy sets out the requirements for approval, resourcing and recording of offset transactions and obligations.

Chemring is committed to being transparent about how it collects and uses the personal data of employees and third parties, and to meeting its data protection obligations. Our Data Protection and Privacy Policy sets out the organisation’s commitment to data protection and the principles that will be adopted in handling and processing personal data. The policy details the ways in which we may obtain, use, hold, transfer and otherwise process personal data.

The Political Donations and Lobbying Policy provides guidelines on political and lobbying activities undertaken by our businesses and our employees, which must be in full compliance with all applicable laws and regulations, our Code of Conduct and our Bribery Act Compliance Manual.

Chemring does not make donations or contributions to any political campaign, potential candidate or any of their associated organisations.

It is an offence to deal in Chemring shares, or related securities, when in possession of “inside information” concerning the Company - this is broadly defined as information which has not yet been made public and which, if it were made public, would be likely to have a significant impact on the Company’s share price. Consequently, there are certain periods during which employees (and their immediate family) must not deal in the Company’s shares. All dealings in the Company’s shares must comply with the Share Dealing Policy.

The Company has also established procedures to ensure that information which may constitute inside information is identified and reported promptly, in order to ensure that the Company is able to release such information to the public in accordance with its legal obligations. These procedures are detailed in the Inside Information Policy.