Triumph Group, Inc.

Based on public information, there is no readily available evidence that the company has published a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company. TI notes one minor statement from CEO Jeffrey D. Frisby which is insufficiently strong.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer or Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the Chief Executive Officer demonstrates 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.

Based on public information, there is no readily available evidence that the company publishes a statement of values or principles representing high standards of business conduct. While the company does list integrity as one of its core values, it is not used in reference to ethical business conduct, but rather meeting customer demands. Only one sentence on the company website references integrity with character and ethical values. To score higher the company should provide a detailed explanation of its values that represent high standards of business conduct, and demonstrate why they matter to the organisation.

Based on public information, there is no readily available evidence that the company belongs to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption.

Based on public information, there is evidence that the Audit Committee has overall corporate responsibility for the company’s ethics and anti-corruption agenda. The Committee’s responsibilities include reviewing policies and procedures designed to promote compliance.

Based on public information, there is some evidence that the company has appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda. While General Counsel John B. Wright, II reports to the Board on the Company’s compliance with the terms of its Code of Business Conduct, it is unclear if this responsibility involves implementing the entire ethics and anti-corruption agenda. The company therefore scores 1. To score higher, the company would need to provide evidence that clearly states which individual has responsibility for implementing its ethics and anti-corruption agenda.

Based on public information, there is evidence that the company’s Audit Committee regularly reports to the Board on the implementation and effectiveness of the company’s ethics and compliance programs. In addition, the Nominating and Corporate Governance Committee Charter reviews and assesses the Company’s Code of Business Conduct annually.

Based on public information, there is no readily available evidence of a formal, clear, written plan on which the review of the ethics and anti-corruption agenda by the Board or senior management is based, nor evidence of improvement plans being implemented when issues are identified.

Based on public information, there is no readily available evidence that the company has a formal process for review and where appropriate updates its policies and practices in response to actual or alleged instances of corruption.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide.

Based on public information, there is no readily available evidence that the company has 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.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing agents.

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.

Based on public information, there is no readily available evidence that the company makes 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.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is no readily available evidence that the company has an anti-corruption policy that prohibits corruption in its various forms. The company only states their compliance with the FCPA, or other laws when operating in different jurisdictions. To score higher the company must have a policy that prohibits the giving and receiving of bribes, and that is explicit on the various forms corruptions can take.

Based on public information, there is no readily available evidence that the company’s anti-corruption policy is explicitly one of zero tolerance. However, the company has a zero tolerance policy of violations of the Code of Business Ethics and Conduct, as shown by its explicit stance on disciplinary procedures in the event of a violation by any employee or director. The company therefore scores 1.

Based on public information, there is evidence that the company has an anti-corruption policy easily accessible to Board members and employees. The Code of Business Conduct is available on the company website and any changes to it are brought to the attention of all employees, officers and directors. However, the Code of Business Conduct is only available in English and evidence suggests the company operates in multiple countries worldwide. The company therefore scores 1.

Based on public information, there is evidence that the company’s anti-corruption policy is somewhat understandable and clear to Board members and employees. However, the language in some sections of the Code of Business Conduct is assessed to be dense and lacks clarity. The company therefore scores 1. To score higher the company could simplify the Code of Business Conduct by using clearer language.

Based on public information, there is evidence that the Code of Business Conduct explicitly applies to all employees and members of the Board.

Based on public information, there is evidence that the company has a detailed policy on potential conflicts of interest. Located in the Code of Business Conduct it applies to all employees and board members. A definition of a conflict of interest is provided, along with several examples.

Based on public information, there is evidence of a company policy for the giving and receipt of gifts. It is minimal in description, restricting gift exchange that aims to induce decisions, may be seen as inappropriate or contravenes applicable laws. Employees and directors are encouraged to consult the General Counsel if they have any questions regarding whether any gift is inappropriate or inconsistent with the Code of Business Conduct. The company therefore scores 1. To score higher the company must set upper limits for gift exchange or senior authorisation and broaden the policy beyond US law.

Based on public information, there is evidence of a company policy for the giving and receipt of hospitality. It is minimal in description, restricting hospitality exchange that aims to induce decisions, may be seen as inappropriate or contravenes applicable laws. Employees and directors are encouraged to consult the General Counsel if they have any questions regarding whether any hospitality is inappropriate or inconsistent with the Code of Business Conduct. The company therefore scores 1. To score higher the company must set upper limits for gift exchange or senior authorisation and broaden the policy beyond US law.

Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments.

Based on public information, there is some evidence that the company regulates political contributions, in order to prevent undue influence or other corrupt intent. The company therefore scores 1. However, it is not clear that the company discloses all political contributions.

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, or discloses the issues on which the company lobbies. Despite the Code of Business Conduct stating that all employees and directors should conduct relationships with public officials and political condidates in compliance with all applicable laws, rules and regulations, TI feels this is insufficient in this case.

Based on public information, there is no readily available evidence that the company prohibits or regulates charitable contributions, in order to prevent undue influence or other corrupt intent.

Based on public information, there is no readily available evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda. The Code of Business Conduct is assessed to lack clarity, with few scenarios to assist employees with understanding the rules and regulations. To score higher the company would need to provide written guidance that contains scenarios or case studies, to ensure that any areas of uncertainty are fully explained.

Based on public information, there is no readily available evidence that the company has a training programme that explicitly covers anti-corruption.

Based on public information, there is no readily available evidence that anti-corruption training is provided in all countries where the company operates or has company sites.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board.

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

Based on public information, there is evidence that the company has a process by which employees declare conflicts of interest. Employees must disclose promptly to the General Counsel the facts and circumstances of potential or actual conflicts of interest. Alternatively employees can consult with their manager before entering into transactions or associations where the potential for conflict of interest exists.

Based on public information, there is evidence that the company is explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities.

Based on public information, there is evidence that employees can report concerns or instances of suspected corrupt activity using multiple, well-publicised channels. A Corporate Governance Hotline is publicised in the Code of Business Conduct and on the company website, but the number is only displayed on the latter. The hotline is available 24/7, operated by an independent paty and allows employees to report concerns anonymously. Alternatively, employees may contact the General Counsel by mail, email or phone, with contact details offered in the Code of Business Conduct.

Based on public information, there is evidence that across geographies, all employees have access to more than one reporting channel. These channels include the General Counsel and the Corporate Governance Hotline.

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.

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 consulting with managers, supervisors or the General Counsel, with the contact details of the General Counsel provided in the Code of Business Conduct.

Based on public information, there is evidence that there is a commitment to non-retaliation for bona fide reporting of corruption. However, there is no readily available evidence that disciplinary measures are applied to employees who breach this policy. The company therefore scores 1.