5. Customer Engagement

Based on publicly available information, there is evidence that the company has a policy that prohibits corporate political contributions to any parties, candidates or campaigns. The company indicates that this policy extends to any payments on its behalf, both financial and in-kind. In addition, there is evidence that the company is associated with a Political Action Committee (PAC) in the United States. The company states that its PAC is managed by the Office of Government Relations and that all relevant activities are overseen by a committee composed of senior leaders from across the U.S. business.

Since it is associated with a PAC in the United States, the company receives a score of ‘0’ in line with the scoring criteira.

The company publishes some information on its political expenditures, including a list of all membership dues paid to trade associations in the United States. However, the company receives a score of ‘0’ because there is no evidence that it publishes details of the donations made through any Political Action Committee (PAC).

It is noted that the company states that its PAC contributions are published on the United States Federal Election Commission (FEC) website, however there is no direct link on the company’s website to relevant disclosures.

There is evidence that the company has a policy and procedure covering both charitable donations and sponsorships. There is also evidence that the company discloses the causes it supports and provides summaries of its financial donations to charitable and social causes.

However, the company receives a score of ‘0’ because there is no evidence that its policy incorporates anti-corruption controls to ensure that donations and sponsorships are not used as vehicles for bribery and corruption, such as specifying criteria for donations or due diligence on recipients. There is also no evidence that the company provides full details of its charitable donations, such as the name, amount and location of each recipient entity.

There is evidence that the company has a policy on lobbying, which applies to all employees, board members and third parties engaged to work on its behalf. There is also evidence that the company’s Audit Committee, senior management and Office of Government Relations provide oversight of the company’s lobbying activities.

However, the company receives a score of ‘1’ because the company’s policy does not define responsible lobbying, and it does not mention specific standards of conduct or oversight mechanisms that apply to all lobbyists.

It is noted that the company makes reference to a policy entitled Contacts with Public Officials, but this document is not publicly available.

The company publishes some information on its lobbying topics and activities in the United States by making its quarterly federal lobbying reports publicly available via a direct link on its website.

However, the company does not provide details about its broader public policy aims or positions. The company also does not publish any information about its lobbying activities outside of the United States, nor does it indicate that it does not engage in lobbying elsewhere.

There is evidence that the company publishes summary information of its lobbying expenditure in the United States, alongside a breakdown of how the total expenditure was calculated, on an annual basis. In addition, the company’s website includes a direct link to its federal quarterly lobbing reports, which include a lobbying expenditure figure.

However, this expenditure data is not broken down into internal, external or association lobbyists and does not include an explanation of how these figures have been calculated. Furthermore, there is no evidence that the company publishes its lobbying expenditure for other jurisdictions around the world in which it conducts lobbying, nor a statement that it does not lobby outside of the United States.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality to ensure that such promotional expenses are not used as vehicles for bribery and corruption, which includes approval procedures. There is also evidence that the company specifically addresses the risks associated with gifts and hospitality given to/received from domestic and foreign public officials.

However, the company receives a score of ‘1 because it does not publicly indicate that it implements financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

It is noted that the company appears to make reference to a ‘Gifts, Meals, Entertainment and Travel’ policy which may contain more information, but this is not publicly available.

The company allows political contributions, and therefore receives a score of ‘0’.

The company does not disclose details of its political contributions on its website.

There is evidence that the company has a policy covering both charitable donations and sponsorships. It states that it conducts due diligence on recipients and refers to a group approvals process.

However, the company receives a score of ‘1’ because it is not explicitly stated that there is a requirement for senior sign-off. Also, the company does not specify criteria for donations or publish full details of its donations.

There is no evidence that the company has a policy and/or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure on its website.

There is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. This addresses the risks associated with gifts and hospitality to public officials. There is also evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process. There is also evidence that the company’s policy includes monetary limits and approval procedures.

Based on publicly available information, there is evidence that the company has a policy on corporate political donations. The company indicates that political donations, whether made directly or indirectly, are prohibited unless clearly delegated and approved in writing. In cases where donations may be authorised, the company states that they must be approved by its Vice President of Communications. In addition, there is evidence that the company is associated with a Political Action Committee (PAC) in the United States, which is overseen by a committee and board of directors.

Since the company does not prohibit political contributions and is associated with a PAC, it receives a score of ‘0’ in line with the scoring criteria.

There is no evidence that the company publishes details of political contributions made on its website.

There is evidence that the company has a policy regarding charitable donations to prevent donations being used for undue influence or corrupt intent. However, the company does not have publicly available policy regarding sponsorships; although its foundation states that it does not fund sponsorships, it is not clear whether this is a company-wide policy.

There is no evidence that the company has a publicly available policy covering responsible lobbying.

There is no evidence that the company publishes any information on its website regarding its lobbying aims, topics or activities.

There is evidence that the company provides some details on its lobbying expenditure. The company publishes a high-level figure on its lobbying costs as part of its Annual Report, which appears to indicate that the company did not incur any such costs in the most recently reported financial year.

However, the company does not publish further information to explain how this figure was calculated and there is no evidence that the company provides a breakdown of these costs by corporate entity, geography, or internal lobbyists versus external lobbyists versus association lobbying. There is also no publicly available evidence to confirm that the company has not engaged in any lobbying activities in the most recently reported financial year, either directly or indirectly, in any jurisdictions.

There is evidence that the company has a policy on gifts and hospitality, which includes financial thresholds and approval processes for different types of gift and promotional expenses. The policy addresses the risks associated with gifts and hospitality given to and/or received from government personnel, by specifying a different financial threshold and requiring that these be approved in advance by ethics and compliance. The policy also includes several examples of potential red flags around the giving and receipt of gifts and hospitality.

However, there is no evidence to confirm that gifts and hospitality above a certain threshold are recorded in a dedicated register or central database that is accessible to those responsible for oversight of the process.

There is publicly available evidence to indicate that the company has a policy on corporate political donations, where by such contributions are permitted subject to prior review and approval.

There is no evidence that the company discloses details of its political contributions.

There is evidence that the company has a policy covering both charitable donations and sponsorships. This policy specifies criteria for the type of donations and states that authorisation is required for donations over a certain threshold. Examples of charitable donations and sponsorships are mentioned on the company’s website and in the Annual Report. However, the company does not publish full details of the donations made by the company, such as the recipient, amount, country and corporate entity that made the payment. The relationship between the company’s Sponsorships, Donations and Corporate Memberships Directive and the activities of the Airbus Foundation is also unclear.

There is some publicly available evidence that the company has a policy on lobbying. This policy requires due diligence checks on lobbyists and compliance with all relevant laws, and states that lobbying is overseen jointly by the Ethics and Compliance and Government Relations teams. However, these provisions are not sufficient to constitute a responsible lobbying policy. Although the company mentions an internal Lobbyist & Special Advisors Due Diligence Directive, there is no publicly available evidence of guidelines to establish certain standards of conduct for lobbyists, beyond a broad commitment to integrity.

The company publishes a list of the topics on which it lobbies, including a description of its core positions, their importance or relevance to the company and stakeholders, and the activities it carries out. The company provides specific aims and topics for in the main jurisdictions in which it lobbies.

There is no evidence that the company publishes details of its global lobbying expenditure.

There is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. The policy addresses the risks associated with gifts and hospitality given to and received from domestic or foreign government officials. The policy also indicates that there are specific financial limits and different approval procedures for different types of promotional expenses. However, there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

There is no evidence that the company has a policy to regulate corporate political contributions.

There is no evidence that the company publishes any details of its corporate political contributions.

There is no evidence that the company has a policy and/or procedure covering both charitable donations and sponsorships.

There is no evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy on gifts or hospitality.

There is no evidence that the company has no policy on corporate political contributions.

There is no evidence that the company discloses details of its political contributions.

There is no evidence that the company has a policy and/or procedure covering both charitable donations and sponsorships.

There is no evidence that the company has a policy or procedure on lobbying.

The company does not publish any information relating to its lobbying aims, topics or activities.

The company does not provide any details about its global lobbying expenditure.

There is no evidence that the company has a policy or procedure on gifts or hospitality.

There is no evidence that the company has a policy on corporate political contributions.

There is no evidence that the company discloses details of its political contributions.

There is no evidence that the company has a policy or procedure covering charitable donations and sponsorships.

There is no evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy or procedure on gifts or hospitality.

The company publishes a clear statement that it prohibits corporate political contributions, whether made directly or indirectly. There is evidence that this applies to all employees of the company including directors, third parties, suppliers and joint venture partners.

There is evidence that the company prohibits corporate political contributions so the company is exempted from scoring on this question.

Based on publicly available information, there is evidence that the company has procedures covering both charitable donations and sponsorships. There is evidence that these include measures to ensure that donations are not used as vehicles for bribery and corruption, for example, by specifying criteria for donations and a requirement for the board to sign-off on donations. In addition, the company publishes some details of donations made on an annual basis.

However, the company receives a score of ‘1’ because it does not disclose full details of charitable donations made, such as the entity which made the donation or details of recipient organisations.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any information on its global lobbying expenditure.

Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality. There is some evidence to suggest that the company records gifts in a register.

However, the company receives a score of ‘1’ because the policy does not specify financial or proportional limits or different approval procedures for different types of promotional expenses, nor does it specifically address the risks associated with gifts and hospitality given to/received from public officials.

There is no evidence that the company has a policy on corporate political contributions.

Based on publicly available information, there is no evidence that the company has a policy to regulate corporate political contributions. The company indicates that employees engaged in political activities must receive approval from the company’s leadership, but there is no evidence that the company has a formal policy in place at corporate level.

There is no evidence that the company has a policy or procedure covering charitable donations and sponsorships, The company publishes some information on its charitable activities but does not publish any details of specific procedures for such activities to ensure that such donations are not used as vehicles for bribery or corruption. Although the company provides some information on the charitable causes it supports on its website, there is no evidence that it publishes full details of its donations – including details of the recipient, amount, country of recipient and which corporate entity made the payment – on at least an annual basis.

Based on publicly available information, there is no evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is some evidence that the company has a policy on the giving and receipt of gifts and hospitality, which specifies senior manager approval for certain proportionate gifts.

However, the company receives a score of ‘1’ because there is no evidence that the policy specifies financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no evidence that the policy addresses the risks associated with gifts and hospitality given to or received from domestic or foreign public officials. There is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.

Based on publicly available information, there is no evidence that the company has a policy or procedure to regulate corporate political contributions.

There is no evidence that the company publishes details of its political contributions.

The company discloses information on its charitable activities but receives a score of ‘0’ because there is no clear evidence that it has policies and procedures to protect against charitable donations being used as vehicles for bribery or corruption. There is no evidence that the company has procedures in place to stipulate criteria for donations or oversight mechanisms for any charitable expenditures.

There is no evidence that the company has a policy and/or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes details of its global lobbying expenditure.

There is no evidence that the company has a policy or procedure on gifts and hospitality, to ensure that such promotional expenses are not used as vehicles for corruption. The company publishes a document which states that Chinese Communist Party members will face punishment for giving and/or receiving lavish or inappropriate gifts or cash; however, the company receives a score of ‘0’ because there is no clear evidence that these principles are incorporated into the company’s own anti-corruption policies or apply to all employees across the company.

Based on publicly available information, there is evidence that the company has a policy that clearly all corporate prohibits political donations, whether made directly or indirectly. The company that this police includes both financial expenditures and in-kind donations to political parties, campaigns or candidates. There is evidence that any requests to deviate from this policy would be handled by the Group CEO, and indicates that it has not made any such donations in the past two years.

The company publishes a clear statement that it does not make political contributions, and therefore it is exempt from scoring on this question.

Based on publicly available information, there is evidence the company has a policy covering charitable donations and sponsorships, to ensure that such donations are not used as vehicles for bribery and corruption. There is evidence that these procedures include measures to ensure this, by specifying criteria for donations, procedures for senior sign-off and due diligence on donation recipients.

However, the company receives a score of ‘1’ because there is no evidence that it publishes details of its charitable donations and sponsorships made in the most recently reported financial year, such as the recipient, amount, country of recipient and which corporate entity made the payment.

Based on publicly available information, there is evidence that the company has a policy that defines lobbying and outlines certain practices which constitute legitimate lobbying activity. The company indicates that all lobbying activity undertaken by the company must receive the prior approval of the Group CEO.

However, the company receives a score of ‘1’ because there is no evidence that its policy describes certain standards of conduct or specific oversight mechanisms that apply to all types of lobbyists. The company does not publish further information on controls to prevent and reduce corruption risks in lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details of its global lobbying expenditure.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, which stipulates procedures to ensure that such promotional expenses are bona fide and not used for bribery. There is evidence that the company requires all business units to establish specific financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The company also explicitly addresses the risks associated with gifts and hospitality given to and/or received from public officials. There is evidence that all gifts and hospitality are recorded centrally and this information is held by the Group General Counsel.

Based on publicly available information, there is evidence that the company has a policy which prohibits corporate political contributions, whether by the company itself or by any other entity or individual acting on its behalf. However, there is evidence that the company has a Political Action Committee (PAC) in the United States, so the company therefore receives a score of ‘0’ as per the scoring criteria.

There is evidence to indicate that the company did not make any political contributions in 2018. Since this evidence is included in the company’s Annual Report, it is under that the data is updated on an annual basis.

However, the company receives a score of ‘0’ because it has a Political Action Committee (PAC) in the United States and there is no evidence that it publishes any information in relation to the PAC’s disbursements on its website or that it provides a direct link to its official disclosures.

Based on publicly available information, there is evidence that the company has a policy covering both charitable donations and sponsorships to ensure that such donations are not used as vehicles for bribery and corruption. There is evidence that company’s policies stipulate measures to ensure this, including sign-off procedures and a requirement to record the donation.

However, although the company publishes the total amount of contributions to charities and not-for-profit organisations made by the company in 2018, it does not publish full details of all the charitable donations made, such as details of the recipients, amounts, country of recipients and which corporate entity made the payments.

Based on publicly available information, there is evidence that the company has a policy that defines lobbying and that clearly outlines the values and behaviours that constitute ‘responsible’ lobbying. There is evidence that the company acknowledges the corruption risks associated with lobbying and it provides clear guidelines on the behaviours that are acceptable and unacceptable for individuals engaged in lobbying activities. The company’s policy applies to all employees, board members and third parties engaged in lobbying on the company’s behalf.

There is evidence that the company publishes a description of the topics on which it lobbies and the type of activities that it conducts to advance these aims. The company provides details of its core positions and their relevance to its business development plan, and there is evidence to indicate that these aims apply to the company’s lobbying activities in multiple jurisdictions around the world. The extent of the evidence provided is deemed sufficient for a score of ‘2’, though it is noted that the company appears to produce an annual report with further details on its lobbying activities which is not available in the public domain.

There is no evidence that the company publishes details about its global lobbying expenditure on its website, either directly or via a link to official filing reports.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with clear procedures designed to ensure that such promotional expenses are not used as vehicles for bribery or corruption. There is evidence that the company’s policy establishes financial limits, along with an approval procedure, for promotional expenses. The company’s policy also explicitly addresses the risks associated with gifts and hospitality given to and received from domestic and foreign public officials, by indicating that specific rules and regulations may apply. The company's policy includes a statement that all gifts and hospitality above certain thresholds are recorded in a dedicated register.

The company operates a political action committee and therefore receives a score of ‘0’.

The company discloses the political candidates that it supports. There is evidence that this information is updated annually.

There is no clear evidence that the company has a policy and/or procedure covering both charitable donations and sponsorships. The company also does not publish detailed data on its charitable contributions.

There is no evidence that the company has a policy and/or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides details about its global lobbying expenditure.

There is evidence that the company has a policy and/or procedure on the giving and receipt of gifts and hospitality. The policy covers gifts and hospitality given to and received from government officials.

However, the company receives a score of ‘1’ because the policy does not specify financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

There is no readily available evidence that the institute is able to make political contributions due to its nature as a non-profit, tax-exempt organisation in the United States of America.

There is no readily available evidence that the institute is able to make political contributions due to its nature as a non-profit, tax-exempt organisation in the United States of America.

There is no evidence that the institute has a policy or procedure to address the potential bribery and corruption risks arising from charitable donations and sponsorships. The institute publishes some information about type of organisations that it sponsors and provides an estimate figure of the amount it donates annually, but this information is insufficiently detailed to receive a score of ‘1’.

There is no evidence that the institute has a policy or procedure on lobbying.

There is no evidence that the institute publishes any information on its lobbying aims, topics or activities.

There is no evidence that the institute provides any details about its global lobbying expenditure.

There is some evidence that the institute recognises the potential risks posed by gifts and hospitality by listing it as a reporting category on the EthicsPoint portal and providing a broad definition. However, the institute receives a score of ‘0’ because there is no evidence that the company has a formal policy on the giving and receiving of gifts and hospitality to ensure that such promotional expenses are not used as vehicles for bribery and corruption.

There is evidence that the company has a policy on political contributions, which states that such donations are generally prohibited but permissible in certain circumstances with appropriate authorisation and sign-off. There is also evidence that the company is associated with a Political Action Committee (PAC) in the United States.

There is evidence that the company publishes details of its political contributions in the United States by including direct links on its website to official reporting documents and to the Open Secrets website. There is evidence that this data is updated and published on at least an annual basis. These details include the recipient and amount, and whether the contribution was made by an individual or a Political Action Committee (PAC).

There is evidence that the company has a clear policy covering both charitable donations and sponsorships, whether made directly or through corporate foundations, to ensure that such donations are not used as vehicles for bribery and corruption. There is evidence that this policy include measures to ensure this, such as specifying criteria for donations, procedures for senior sign-off, and due diligence on recipients.

However, while the company publishes some details of the company’s charitable activities, there is insufficient evidence that it publishes details of all donations as described in score ‘2’. There is also no evidence that the company updates this information on at least an annual basis.

It is noted that the company has an internal policy – Bechtel Policy 404, Corporate Contributions and Memberships – but it does not appear to be publicly accessible.

Based on publicly available information, there is evidence that the company has a policy on lobbying. There is evidence that the policy applies company-wide to all employees, board members and third parties engaged in lobbying activities on the company’s behalf. There is evidence of specific controls and oversight mechanisms that apply to all types of lobbyists, which are ensured through clear terms in all contractual agreements. The company provides guidelines on the types of behaviours that are acceptable by requiring that lobbyists abide by its Code of Conduct, Vision, Values and Covenants document, as well as all appropriate regulations.

The company publishes some information on its lobbying topics and activities in the United States by providing a direct link to its quarterly federal lobbying reports on its website. These disclosures provide high-level information on the topics on which the comany conducts lobbying activities.

However, the company receives a score of ’1’ because it does not provide details about its broader public policy aims or positions. The company also does not publish any information about its lobbying activities outside of the United States.

There is evidence that the company publishes some details of its lobbying expenditure, by providing direct links on its website to details of all of its lobbying expenditure, up to the most recently reported financial year. This expenditure data is broken down by corporate entity, geography, and internal, external and association lobbying.

However, the company receives a score of ‘1’ because the data provided only accounts for company’s lobbying activities in the United States and therefore it is not clear that this covers all of the company’s lobbying activities in all applicable jurisdictions.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality with clear procedures designed to ensure that such promotional expenses are not used as vehicles for bribery and corruption. There is evidence that the policy specifies financial and proportional limits for different types of promotional expenses and addresses the risks associated with gifts and hospitality given to public officials. There is evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.

There is no publicly available evidence that the company has a policy on corporate political contributions.

There is no evidence that the company publishes any details of its political contributions.

There is no evidence that the company has a policy or procedure covering charitable donations or sponsorships.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy on gifts or hospitality.

Based on publicly available information, there is no evidence that the company has a policy to prohibit or regulate corporate political contributions. The company’s publicly available information indicates that political contributions may be permitted in certain unspecified circumstances, and notes that such donations are not considered a CSR activity.

There is no evidence that the company publishes any details of its political contributions.

There is evidence that the company has policies and procedures covering both charitable donations and sponsorships. This policy specifies criteria for the types of causes that may receive donations and there is evidence that the company has procedures in place to monitor projects. The company also publishes full details of all charitable donations made, including details of the recipient, amount and location. The data is included in the company’s Annual Report, and is therefore updated and released on an annual basis.

However, the company receives a score of ‘1’ because there is no clear evidence that the company addresses and has specific measures in place to ensure that donations are not used as vehicles for bribery and corruption.

Based on publicly available information, there is no evidence that the company has a policy on responsible lobbying. The company states in its annual report that any businesses involved in influencing public policy must behave responsibly, however the company does not provide further details on the specific controls or oversight mechanisms in place to ensure this.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

Based on publicly available information, there is some evidence that the company addresses gifts and hospitality. The company’s policy indicates that board members and senior individuals must not solicit gifts or hospitality in order to influence business.

However, the company receives a score of ‘0’ because there is no evidence that the company’s policy addresses the potential bribery and corruption risks associated with gifts and hospitality. There is also no evidence that the company’s policy includes specific controls or measures to mitigate these risks.

The company publishes a clear statement that it does not make any political contributions under any circumstances to any party, candidate or campaign.

The company publishes a clear statement that it does not make any political contributions, and is therefore exempt from scoring on this question.

There is no evidence that the company has a policy or procedure covering charitable donations and sponsorships. There is some publicly available evidence that the company undertakes CSR activities and aims to ensure that they are conducted in an ethical manner, however this information is insufficiently detailed to receive a score of ‘1’.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no publicly available evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts. The company’s Code of Business Conduct and Ethics for Board Members and Senior Management specifies a financial limit for gifts for special events.

However, the company receives a score of ‘1’ because its policy does not address the risks associated with gifts and hospitality given to/received from domestic or foreign public officials. In addition, there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.

Based on publicly available information, there is evidence that the company has a policy on corporate political contributions. The company’s policy indicates that it may make political contributions when approved by the company’s Executive Vice President, Government Operations and other relevant senior managers from the Government Operations office. In addition, there is evidence that that the company is associated with a Political Action Committee (PAC) in the United States, which is overseen and managed by an advisory committee.

Since the company does not prohibit political donations and is associated with a PAC, it receives a score of ‘0’ in line with the scoring criteria.

The company publishes a statement that it has not made any corporate political corporate contributions to state or local candidates since 2010. The company also indicates that it has not contributed to ballot initiatives since 2011, nor to section 527 entities since 2012. In addition, the company provides a direct link to the United States Federal Election Commission website where full details of its Political Action Committee disbursements can be found.

Based on publicly available information, there is evidence that the company has a policy on charitable donations and sponsorships, which covers both financial and in-kind donations. The company states that all donations must follow ethical guidelines and must be overseen by the Law Department. There is some evidence that the company has procedures in place to conduct due diligence on recipients..

Although the company publishes some details of the recipients of its grants, the company receives a score of ‘1’ because there is no evidence that it publish full details of all donations made, such as the country and amount given to each recipient, as well as which corporate entity made the payment, for both financial and in-kind donations.

Based on publicly available information, there is evidence that the company has a policy on lobbying, which includes specific controls and oversight provisions to regulate the activities of lobbyists. The company states that it provides training on responsible lobbying behaviours and indicates that all lobbying activities are conducted in accordance with its high standards of ethical conduct. The company also states that the Government Operations department is responsible for oversight of all lobbying and political activities.

However, the company receives a score of ‘1’ because it does not provide further information on the standards and types of behaviours that constitute ‘responsible’ lobbying.

The company publishes some details of the topics on which it lobbies on its website and in more detail in the Lobbying Disclosure Reports which are available to the United States Congress and Senate. These reports are made available via a direct link on the company’s website and they include information on the specific legislation on which the company has lobbied in the United States.

However, the company receives a score of ‘1’ because it does not provide further details of its lobbying activities, such as a description of its core positions and their importance or relevance to the company and stakeholders. In addition, the information provided only relates to lobbying activities in the jurisdiction in which the company is headquartered (the United States); there is no evidence that the company discloses this information for other jurisdictions, nor does it publish a statement that it does not conduct lobbying activities outside of the United States.

The company publishes some details of its lobbying expenditure in its annual Proxy Statement, as well as in its Lobbying Disclosure Reports for the United States Congress and Senate. These reports are made available via a direct link on the company’s website and include information on total lobbying expenditure relating to activities in the United States.

However, the company receives a score of ‘1’ because it does not provide further details of its lobbying expenditure, such as a breakdown in expenditure between internal, external and association lobbying, and an explanation of how the figures in the data have been calculated. Furthermore, the information provided only relates to lobbying activities in the jurisdiction in which the company is headquartered (the United States); there is no evidence that the company discloses this information for other jurisdictions, nor does it publish a statement that it does not conduct lobbying activities outside of the United States.

There is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality, which addresses the risks associated with gifts and hospitality given to public officials. The company states that certain thresholds are in place for specific types of gifts and hospitality, and that it has a procedure in place which stipulates prior approval from the Law Department.

However, the company receives a score of ‘1’ because there is no evidence that gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process. It is noted that the company has separate policies on accepting and offering promotional expenses which may outline further control measures, but this does not appear to be publicly available.

There is evidence that the company does not make corporate contributions to support political organisations, and this policy applies company-wide to all employees. There is evidence that the company is associated with a Political Action Committee (PAC) in the United States, which is managed and overseen by a board of directors.

Since the company is associated with a PAC in the United States, it receives a score of ‘0’ in line with the scoring criteria.

There is evidence that the company publishes information on the donations made through its Political Action Committee (PAC) in the United States, by providing a direct link to the Federal Election Commission website where full details of such expenditure can be found. There is evidence that the company does not make corporate political contributions through direct expenditures.

There is some evidence that the company has policies covering charitable donations and sponsorships, which specifies criteria for donations. There is also evidence that the company discloses some summary information on its total charitable contributions, specifically those made through a related foundation.

However, the company receives a score of ‘1’ because there is no publicly available evidence that its policy has specific controls in place to reduce the risk of bribery and corruption in its charitable activities, such as procedures for senior sign-off or due diligence on recipients. There is also no publicly available evidence that the company publishes full details of its charitable contributions and sponsorships, such as details of the recipient, amount, country of recipient and which corporate entity made the payment.

There is evidence that the company has a policy and procedure on lobbying, which applies company-wide to all employees, board members and third parties engaged as lobbyists on the company’s behalf. The company's policy includes procedures to identify any conflicts of interest associated with engagements in the political process and this approach is outlined in the company’s Code of Business Ethics and Conduct which describes certain standards of conduct for all employees and third parties.

However, it is not clear from publicly available information that the company’s approach to lobbying includes further details such as specific guidelines or standards of conduct that apply to all types of lobbyists (internal, external and association) or clear oversight mechanisms to monitor activities. It is noted that the company references a separate policy document which may contain more information on its lobbying practices, but this does not appear to be publicly available.

There is evidence that the company publishes some information on its lobbying topics and activities in the United States, by making its quarterly federal lobbying reports publicly available via a direct link on its website.

However, there is no evidence that the company provides further publicly available details about its broader public policy aims or positions. There is also no evidence that the company publishes any information on the activities that it has conducted in other jurisdictions nor does it clearly state that it has not engaged in lobbying elsewhere in the most recently reported financial period.

There is evidence that the company publishes summary information of its lobbying expenditure in the United States, by making its quarterly federal lobbying reports publicly available via a direct link on its website.

However, the company receives a score of ‘1’ because there is no evidence that it provides a breakdown of its expenditure data to show costs relating to internal, external or association lobbyists. There is also no evidence that the company publishes information on its lobbying expenditure in other jurisdictions nor does it clearly state that it has not engaged in lobbying elsewhere in the most recently reported financial period.

There is evidence that the company has a policy and/or procedure on the giving and receipt of gifts and hospitality with clear procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. There is evidence that this policy has financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy also addresses the risks associated with gifts and hospitality given to and/or received from domestic and foreign public officials.

However, there is no evidence indicating that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

Based on publicly available information, there is evidence that the company has a policy that clearly prohibits corporate political contributions. The company indicates that this applies to any contributions to government officials or politicians, whether made directly or indirectly. There is evidence that this policy applies company-wide in the United States and in other jurisdictions. In addition, the company clearly states that it is not associated with a Political Action Committee (PAC) in the United States, and no publicly available evidence was identified to contradict this statement.

The company publishes a clear statement that it does not make any forms of political contributions and therefore it is exempt from scoring on this question.

Based on publicly available information, there is evidence that the company has a policy on charitable donations and sponsorships. There is evidence that this policy includes criteria for donations and specific approval procedures for donations, as well as separate financial thresholds and sign-off requirements for any donations to organisations where the recipient is associated with a company director. The company also provides some information on the charities that it supports, including the names of the organisations.

However, there is no evidence that the company’s policy includes further controls such as due diligence on recipients, nor is there evidence that the company publishes full details of its charitable donations made in the last 12 months, including details of the recipient, amount, country of recipient and which corporate entity made the payment.

There is no publicly available evidence that the company has a clear policy or procedure on lobbying. The company provides publicly available information on the regulations in the United States that it must follow when undertaking any lobbying activities, for example the disclosure of payments and avoiding improper influence on the political process; however, there is no evidence that the company outlines specific standards of conduct or oversight mechanisms to ensure that all internal, external and association lobbyists comply with these regulations.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details of its global lobbying expenditure.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with clear procedures designed to ensure that such promotional expenses are not used as vehicles for bribery. The company’s policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy also addresses the risks associated with gifts and hospitality given to and/or received from domestic and foreign public officials.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it has a procedure in place to record gifts and hospitality in a dedicated central register or database that is accessible to those responsible for oversight of the process. It is noted that the company has a separate policy covering gifts and gratuities, which may contain more information on its procedures in this area, but this document does not appear to be publicly available.

There is evidence that the company has a policy on political contributions, which states that such donations are generally prohibited. However, the company receives a score of ‘0’ because there is evidence that political donations are permissible in certain circumstances.

The company publishes details of its political contributions, and there is evidence that this data is updated and published on at least an annual basis. The company discloses that it made no political donations during the last two reporting years.

There is evidence that the company has a policy covering both charitable donations and sponsorships, whether made directly or through corporate foundations, to ensure that such donations are not used as vehicles for bribery and corruption. There is evidence that this policy includes measures to ensure this, for example, by specifying criteria for donations and procedures for senior sign-off. The company also provides limited details of specific causes that it has supported, as well as high level summary of its total charitable donations, published on an annual basis.

However, the company receives a score of ‘1’ because it does not publish a detailed breakdown of all charitable donations made, including details of the recipient, amount, country of recipient and which corporate entity made the payment.

There is evidence that the company has a policy that defines lobbying, broad enough to cover the spirit of the term as described in the guidance, and sets out the values and behaviours that constitute ‘responsible’ lobbying. There is evidence that lobbyists are required to comply with the company’s Code of Business Conduct and Anti-Corruption Policy, which set out what behaviours are acceptable in risk areas such as gifts and hospitality, undue influence and conflicts of interest. There is evidence of oversight mechanisms, including due diligence on lobbyists and provisions for senior sign off on lobbying activities. This policy applies to all employees, board members and third parties lobbying on the company’s behalf.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

There is evidence the company has a policy on the giving and receipt of gifts and hospitality with procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. There is evidence that this policy specifies financial limits and different approval procedures for different types of promotional expenses, and that it also explicitly addresses the risks associated with gifts and hospitality given to and/or received from domestic and foreign public officials. There is evidence that all gifts and hospitality worth over a certain threshold are logged in a dedicated register accessible to those responsible for oversight of the process.

There is no evidence that the company has a policy on corporate political contributions.

The company does not disclose full details of its political contributions.

There is no evidence that the company has a policy or procedure covering charitable donations or sponsorships.

There is no evidence that the company has a policy and/or procedure on lobbying.

The company does not publish any information on its lobbying aims, topics or activities.

The company does not provide any details about its global lobbying expenditure.

There is no publicly available evidence of a policy or procedure on gifts or hospitality.

The company states in its code of conduct that it does not make political contributions. This is also reflected in the company’s annual report.

The company publishes a clear statement that it does not make any political contributions, and is therefore exempt from scoring on this question.

There is some evidence that the company has a policy covering charitable donations; however, there is no evidence that the company has a policy or procedure covering also sponsorships.

There is evidence that the company has a policy covering responsible lobbying. It includes some standards of conduct and provides some guidelines on what behaviours are considered acceptable. This policy applies to all employees, board members and third parties lobbying on the company’s behalf.

However, the company receives a score of ‘1’ because it does not provide guidelines on the corruption risks associated with lobbying and it does not mention specific oversight mechanisms that apply to all types of lobbyists.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality with clear procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes some limits, along with an approval procedure. The company's policy includes a statement that all gifts and hospitality are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process. There is some evidence that the company addresses the risks associated with gifts and hospitality given to and received from domestic or foreign public officials.

There is no evidence that the company has a policy on corporate political contributions.

There is no evidence that the company discloses details of its political contributions.

There is no evidence that the company has a policy and/or procedure covering both charitable donations and sponsorships.

There is no evidence that the company has a policy and/or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

There is no evidence that the company has a policy or procedure on gifts and hospitality.

Based on publicly available information, there is no evidence that the company has a policy on corporate political contributions.

There is no evidence that the company discloses any details of its political contributions.

There is no evidence that the company has a policy on charitable donations or sponsorships, nor that it discloses details of any such donations made. The company provides some information on community projects that it supports, but it is not clear whether these are charitable donations or part of broader agreements.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no publicly available evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy or procedure on gifts and hospitality.

Based on publicly available information, there is evidence that the company has a policy on corporate political contributions. The company publishes a clear statement that the use of corporate funds or facilities for the benefit of political parties or candidates is prohibited in all jurisdictions. There is evidence that the company is associated with a Political Action Committee (PAC) in the United States.

Since the company does not prohibit political donations and is associated with a PAC, it receives a score of ‘0’ in line with the scoring criteria.

The company publishes a clear statement that it does not make corporate political contributions of any kind. However, there is no evidence that the company publishes details of the contributions made by its Political Action Committee (PAC), nor a link to its official disclosures in the United States, and therefore it receives a score of ‘0’.

There is evidence that the company has a policy on charitable donations, which stipulates criteria for donations and requirements for senior sign off on all donations. In addition, the company publishes a total figure of its donations made in the most recently reported financial year.

However, the company receives a score of ‘1’ because there is no evidence that the company publishes full details of all charitable donations made, for example the recipient, amount and country of recipient for each donation. There is evidence that the company has a separate Community Involvement Policy which may contain more information, however this does not appear to be publicly available.

Based on publicly available information, there is evidence that the company recognises the corruption risks inherent in lobbying activities. The company provides a definition of responsible lobbying and describes certain standards of conduct expected of both internal and external lobbyists. There is evidence that the company has a policy on lobbying with controls and oversight mechanisms for lobbying activities, including due diligence on lobbyists, proportionate payment scales and senior compliance officer sign off on their activities. There is evidence that that this policy applies to contracted third parties and external lobbyists.

However, the company receives a score of ‘1’ because there is no evidence that it has policies and controls in place for in-house employees and directors that might be involved in lobbying activities; the company’s publicly available information relates specifically to third party lobbyists or intermediaries. In addition, it is not clear whether the company’s procedures apply solely in the United States or to lobbying activities worldwide.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any information on its global lobbying expenditure.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, which stipulates clear procedures designed to ensure that such promotional expenses are not used for bribery. This policy establishes financial limits, along with an approval procedure, for different types of promotional expense that employees may encounter. In addition, there is evidence that the company’s policy addresses the risks associated with gifts and hospitality given to or received from domestic and foreign public officials. The company's policy includes a clear statement that all gifts and hospitality above certain thresholds are recorded in a dedicated central register.

There is evidence that the company has a policy to follow all relevant local laws regarding political contributions in different jurisdictions. In addition, there is evidence that the company has a political action committee, and therefore receives a score of ‘0’.

There is no evidence that the company discloses details of its political contributions on its website.

There is no publicly available information about the company’s policies and procedures for charitable contributions and sponsorships. For instance, the company does not indicate that it has policies and procedures in place which specify criteria for donations, procedures for senior sign-off, or due diligence on recipients. Nor does the company publish full details of all charitable donations made, including details of the recipient, amount, country of recipient and which corporate entity made the payment; this includes donations made, financial or in-kind, to corporate foundations.

There is no evidence that the company has a policy and/or procedure on lobbying. The company says that it will conduct lobbying in accordance with the law but does not provide further information on its procedures, such as the standards of conduct or specific oversight mechanisms that apply to all types of lobbyists. It also does not provide a definition of lobbying and/or responsible lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

There is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. This addresses the risks associated with gifts and hospitality given to/received from domestic or foreign public officials, for which employees must first consult with the company’s legal department.

However, the policy does not specify financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

There is evidence that the company generally prohibits corporate political contributions, however it does state that contributions may be permissible in certain circumstances, such as in support of local initiatives or referendums, providing that proper authorisation is given from individuals with legal expertise in the company. There is publicly available evidence that the company is associated with a Political Action Committee (PAC), however the company does not publish information about the PAC on its website.

There is no evidence that the company discloses details of any political contributions made, including those made under the exceptional circumstances described in its policy or those made by the Political Action Committee (PAC) with which the company is associated.

There is no evidence that the company has a policy that covers charitable donations or sponsorships. Based on publicly available information, the company does support charities and engage in sponsorships, however it is unclear whether there is a policy or procedure in place to ensure that such donations are not used as vehicles for bribery and corruption.

There is no publicly available evidence that the company has a policy on lobbying. In its Code of Conduct, the company states that its lobbying activities are governed by federal and state legislation and are overseen by the Office of the General Counsel, however it does not provide any further details of specific values, behaviours and controls that constitute ‘responsible’ lobbying.

There is no evidence that the company publishes information on its lobbying aims, topics or activities.

There is no evidence that the company provides details about its lobbying expenditure.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, which outlines and places financial limits on the different types of promotional expense that employees may encounter. The company’s policy specifically recognises the risks associated with gifts and hospitality given to public officials in the U.S. and it is clear that this applies to all employees.

However, the company receives a score of ‘1’ because there is no publicly available evidence that the company recognises the risks and has specific controls in place to cover promotional expenses given to or received from foreign public officials. There is also no evidence that all gifts and hospitality above a certain threshold are recorded in a central register that is accessible to those responsible for oversight of the process. The company appears to have a dedicated Gifts and Entertainment Policy, but this document is not publicly accessible.

Based on publicly available information, there is no evidence that the company has a policy covering corporate political contributions. The company states that employees may engage in the political process privately but does not provide further information on its approach to corporate political contributions.

There is no evidence that the company publishes details of its political contributions.

The company publishes some details of its charitable donations and sponsorships. However, based on publicly available information, there is no evidence it has clear policies or procedures in place to ensure donations are not used as vehicles for bribery and corruption, for example, by specifying criteria for donations, procedures for senior sign-off, or due diligence on recipients.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

Based on publicly available information, there is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. The policy specifies financial limits for different types of promotional expenses.

However, the company receives a score of ‘1’ because it is not clear that the company acknowledges the risks associated with giving or receiving gifts from public officials. There is also no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

Based on publicly available information, there is evidence that the company has a policy on corporate political contributions. The company indicates that it does not make any types of political contributions to parties, candidates or institutions. There is evidence that this policy applies across the company. In addition, the company states that it does not make any contributions through employee action committees.

However, there is some evidence to indicate that the company might make political contributions in certain circumstances, with the approval of the Group Compliance Officer. Since itdoes not fully prohibit political contributions, the company receives a score of ‘0’ in line with the scoring criteria.

There is no evidence that the company publishes any details of its political contributions. Although the company states that it does not make political contributions, there is some evidence to indicate that it may make such donations in certain circumstances.

Based on publicly available information, there is some evidence that the company has a policy covering donations and sponsorship. The company indicates that its policy on ‘Personal and Business Integrity’ contains more information on its approach to charitable donations, but this does not appear to be publicly available. In addition, the company publishes on some of the charitable initiatives that it supports, but there is no evidence that it publishes a comprehensive list of all donations, nor does it publish specific details such as the recipient, amount and country of recipient for each donation.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no publicly available evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no publicly available evidence that the company provides any details about its global lobbying expenditure.

Based on publicly available information, there is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. The policy addresses the risks associated with gifts and hospitality in relation to public officials.

However, there is no evidence that the company’s policy includes specific controls to address these risks, such as financial or proportional limits or different approval procedures for different types of promotional expenses. There is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process. There is evidence that the company has a policy on ‘Personal & Business Integrity’ which may contain more information on gifts and hospitality, but this does not appear to be publicly accessible.

There is no publicly available evidence to indicate that the company has a policy on corporate political contributions. The company indicates that it does not finance political parties, elected officials or candidates unless such activities are in full compliance with existing relevant laws. Since the company does not prohibit political contributions, it receives a score of ‘0’.

There is no evidence that the company publishes any details of its political contributions, nor is there evidence that it publishes a statement to indicate that it has not made any such contributions in the past 12 months.

Based on publicly available information, there is no clear evidence that the company has a policy or procedure on charitable donations and sponsorships to ensure that such expenses are not used as vehicles for bribery and corruption. The company provides some information about the charities that it supports and sponsorship programmes; however there is no clear evidence of a policy to support this, nor is there evidence that the company publishes full details of its contributions made, such as details of the recipient, amount, country of recipient and which corporate entity made the payment.

There is no publicly available evidence that the company has a clear policy or procedure on lobbying. The company publishes a statement on its website to indicate that it complies with a piece of French legislation from December 2016 that applies to lobbying activities; however, the company does not provide any further publicly available information on any specific controls, oversight mechanisms or standards of conduct that it has in place to ensure compliance.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

Based on publicly available information, there is some evidence that the company has a policy on the giving and receipt of gifts and hospitality. The company indicates that any gifts provided must be within accepted limits and states that certain types of gifts, such as offers of travel or participation in non-professional events, must be declined.

However, the company receives a score of ‘1’ because it does not provide further publicly available information on its policy to manage and handle gifts and hospitality, for example by addressing the risks associated with gifts given to or received from public officials or by establishing clear financial limits and approval procedures. In addition, there is no publicly available evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register or database that is accessible to those responsible for oversight of the process.

There is evidence that the company has a policy on political contributions to ensure that these payments are not used as vehicles for bribery and corruption. However, there is evidence that the company may make political donations when approved by the Law Department or the Company’s Vice President of Government Affairs. In addition, there is evidence that the company is associated with a Political Action Committee (PAC) in the United States.

Since the company does not prohibit political donations and is associated with a PAC, it receives a score of ‘0’ in line with the scoring criteria.

There is no evidence that the company publishes any details of its corporate political contributions or of the donations made through the Political Action Committee (PAC).

There is evidence that the company has a policy covering charitable donations, requiring the approval of the company’s legal department. The company states that it reviews charitable donations to assess whether they are associated with a foreign government official.

However, the company receives a score of ‘0’ because there is no publicly available evidence that its policy includes criteria for charitable donations, nor is there evidence that it publishes comprehensive details of the charitable donations made in the most recently reported financial year.

There is evidence that the company has a policy covering lobbying which assigns oversight of the company's lobbying activities to the Vice President of Government Affairs. Any contacts with lobbyists must be coordinated through the company's government affairs department. There is some evidence the policy applies company-wide to all employees and third parties engaged in lobbying activities on the company’s behalf, although the policy does not explicitly refer to members of the company’s board.

However, the company receives a score of ‘1’ because responsible lobbying is not clearly defined in publicly available evidence. There is also no publicly available evidence that the company has specific standards of conduct or specific oversight mechanisms that apply to all types of lobbyists, nor that specific controls or guidelines are provided.

The company publishes limited details regarding its regarding its lobbying activities.

However, it does not publish supporting details of the aims and significant topics of the lobbying activities the company carries out.

There is no evidence that the company publishes any details about its lobbying expenditure.

There is evidence that the company has a policy on the giving and receiving of gifts and hospitality with procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy also addresses the risks associated with gifts and hospitality given to and/or received from domestic and foreign public officials by specifying a lower financial value of such gratuities.

However, there is no explicit evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

There is no evidence that the company has a policy on corporate political contributions.

There is no evidence that the company discloses any details of its political contributions.

There is no evidence that the company has a policy and/or procedure covering charitable donations and sponsorships.

There is no evidence that the company has a policy and/or procedure on lobbying.

The company publishes some information on its engagement with government departments in South Africa, including with its shareholder, the Ministry of Public Enterprises, as well as the Department of Defence. However, it provides limited information on its aims in these engagement activities. The company does not publish information regarding its lobbying activities in other jurisdictions, nor an indication that it does not conduct lobbying elsewhere.

There is no evidence that the company provides details about its global lobbying expenditure.

There is no evidence that the company has a policy or procedure on gifts or hospitality.

There is no publicly available evidence that the company has a policy to regulate corporate political contributions.

There is no evidence that the company publishes any details of its corporate political contributions.

The company publishes some information about its charitable foundations, however there is no clear evidence that the company has a policy or procedure on charitable donations and sponsorships to ensure donations are not used as vehicles for bribery and corruption. There is also no evidence that the company publishes full details of its charitable contributions, such as details of the recipient, amount, country of recipient and which corporate entity made the payment.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

The company publishes some information on the subjects on which it lobbies, in particular at the European Union level. There is evidence to indicate that this information is up to date for the most recent financial year.

However, the company receives a score of ‘1’ because it does not provide further publicly available information on its core positions or aims of its lobbying activities, nor does it indicate their relevance to stakeholders. There is also no evidence that the company publishes the aims and topics of its lobbying activities at the national level or for any other relevant jurisdictions worldwide.

The company provides some details of its lobbying expenditure in the form of a total figure for the financial year 2017.

However, the company receives a score of ‘1’ because this data is not correct to the most recently reported financial year, nor does it include further details such as expenditure by corporate entity, geography, and a breakdown of internal lobbying, external lobbying and association lobbying as well as an explanation of how the figures in the data have been calculated. It is also not clear that the expenditure figure represents all jurisdictions in which the company has conducted lobbying activities.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality. The policy addresses the risks associated with gifts and hospitality given to and received from domestic or foreign public officials. The company also indicates that employees must keep written documentation of approvals for gifts and hospitality.

However, the company receives a score of ‘1’ because there is no publicly available evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process. There is also evidence that the company’s policy specifies financial or proportional limits for different types of promotional expense.

The company operates a political action committee and therefore receives a score of ‘0’.

There is no evidence that the company discloses details of its political contributions on its website.

There is no evidence that the company has a policy and/or procedure covering both charitable donations and sponsorships. The company provides some details regarding the charities it supports but it does not publish full details of all charitable contributions made.

There is evidence that the company has a policy on lobbying in its Code of Ethics and Business Conduct, which applies to all employees, board members, agents and contractors. The policy outlines some requirements for employees conducting lobbying activities on the company’s behalf.

However, it is not explicitly stated that this includes all third parties engaged in lobbying activities on the company’s behalf. Additionally, the company does not provide information on what it considers to constitute responsible lobbying nor does it publish clear guidelines on what behaviours are acceptable, or acknowledge the corruption risks associated with lobbying. While the company refers to a lobbying procedure, this is not publicly accessible.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities on its website.

There is no evidence that the company provides any details about its global lobbying expenditure on its website.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality. The policy addresses the risks associated with gifts and hospitality given to/received from public officials, and refers to proportional limits for different types of promotional expenses.

However, the company receives a score of ‘1’ because it does not specify certain financial thresholds in the policy. There is also no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

Based on publicly available information, there is evidence that the company has a policy which prohibits corporate political contributions, whether by the company itself or by any other entity or individual acting on its behalf. However, there is evidence that the company has a Political Action Committee (PAC) in the United States, so the company therefore receives a score of ‘0’ as per the scoring criteria.

The company publishes a statement that it does not make corporate political contributions.

However, the company receives a score of ‘0’ because there is evidence that it has a Political Action Committee (PAC) in the United States and there is no evidence that it publishes any information in relation to the PAC’s disbursements on its website or that it provides a direct link to its official disclosures.

Based on publicly available evidence, there is some evidence that the company has a policy on charitable donations. The company indicates that this policy includes conducting due diligence to ensure that recipients are legitimate and to avoid any risk of a donation being used to exert undue influence. In addition, there is some evidence that the company publishes high-level details of its total charitable contributions made and initiatives supported in the most recently reported financial year.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it publishes further details of its charitable donations, such as details of the recipient, amount, country of recipient and which corporate entity made the payment.

There is no publicly available evidence that the company has a policy on lobbying.

There is no publicly available evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

Based on publicly available information, there is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality with procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy indicates that the company has established financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. There is also evidence that the company’s policy clearly addresses the risks associated with gifts and hospitality given to from public officials. The company's policy includes a clear statement that all gifts and hospitality are recorded.

In addition, there is evidence that further detail relating to the company’s approval procedures and financial thresholds is available in an Approval Annex; however, this does not appear to be publicly accessible.

Based on publicly available information, there is evidence that the company has a policy which prohibits corporate political contributions, whether by the company itself or by any other entity or individual acting on its behalf. However, there is evidence that the company is associated with a Political Action Committee (PAC) in the United States, so the company therefore receives a score of ‘0’ as per the scoring criteria.

The company publishes a statement that it does not make corporate political contributions.

However, the company receives a score of ‘0’ because there is evidence that it is associated with a Political Action Committee (PAC) in the United States and there is no evidence that it publishes any information in relation to the PAC’s disbursements on its website or that it provides a direct link to its official disclosures.

There is evidence that the company has a policy for both charitable donations and sponsorships, whether made directly or indirectly through its corporate foundations, to ensure that such contributions are not used as vehicles for bribery and corruption. There is some evidence that the company’s internal procedures include measures to ensure this, for example, by requiring due diligence on recipients. The company publishes some information about the donations made through its foundations.

However, the company receives a score of ‘1’ because there is no evidence that it publishes full information about its charitable donations or sponsorships for the most recently reported financial year, such as details of the recipient, amount, country of recipient and which corporate entity made the payment.

Based on publicly available information, there is no evidence that the company has a policy or procedure covering lobbying activities.

There is no publicly available evidence that the company publishes its lobbying aims, topics or activities.

There is no publicly available evidence that the company publishes information on its lobbying expenditure.

Based on publicly available information, there is some evidence that the company has a policy on gifts and hospitality. There is evidence that the company’s policy addresses the risks associated with gifts and hospitality given to and/or received from public officials.

However, the company receives a score of ‘1’ because there is no evidence that this policy specifies financial or proportional limits or different approval procedures for different types of promotional expenses. Although there is some evidence that gifts are recorded, there is also no clear evidence that gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.

There is publicly available evidence that the company has a policy on corporate political contributions, which states that any such donations must be transparent and adhere to all relevant legal requirements. There is no evidence that the company’s policy includes specific controls or measures to ensure that political donations are not used as vehicles for bribery and corruption.

The company receives a score of ‘0’ because there is no evidence that it prohibits corporate political contributions.

There is no evidence that the company publishes any details of its political contributions.

Based on publicly available information, there is some evidence that the company has a policy covering both charitable donations and sponsorships. The company publishes a list of the organisations, social events and groups that it supports.

However, the company receives a score of ‘1’ because there is no evidence that these policies include specific measures to ensure such donations are not used as vehicles for bribery and corruption, such as criteria for donations, procedures for senior sign-off, or due diligence on recipients. There is also no evidence that the company publishes further details of its donations made, such as details of the recipient or amount, nor is there evidence that the information it does publish is updated annually.

Based on publicly available information, there is no evidence the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any information about its global lobbying expenditure.

Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality. The company’s policy acknowledges the risks associated with gifts and hospitality given to and received from public officials.

However, the company receives a score of ‘1’ because there is no evidence that all gifts and hospitality above a certain threshold are recorded in a central register accessible to those responsible for oversight of the process. There is also no evidence that the company’s policy specifies financial limits or different approval procedures for different types of promotional expenses.

There is evidence that the company permits political contributions through its political action committee and therefore receives a score of ‘0’.

Based on publicly available information, the company discloses the amount of money that it provided to its PAC. It is not clear whether this covers all corporate political contributions and the company does not disclose information about its PAC disbursements.

Based on publicly available information, there is evidence that the company has a policy and procedure covering both charitable donations and sponsorships. The company publishes some information on its sponsorships and donations, including details of the recipient and the country of the recipient; the data is updated annually. There is also evidence that these policies and procedures include measures to ensure that donations are not used as vehicles for bribery and corruption, by specifying criteria for donations and procedures for senior sign-off. However, the company does not publish full details of all charitable donations made, such as the amount of donation or which corporate entity made the payment; it is also unclear whether the information provided includes donations made, whether financial or in-kind, to corporate foundations.

Based on publicly available information, there is evidence that the company has a policy and procedure on lobbying (described as Relations with Public Administration) which sets out the values and behaviours that constitute ‘responsible’ lobbying. It provides clear guidelines on what behaviours are acceptable and unacceptable and the corruption risks associated with lobbying (e.g. gifts and hospitality, undue influence, conflicts of interest, etc.). This policy applies to all employees, board members and third parties lobbying on the company’s behalf.

The company publishes some details regarding its lobbying activities. However, there are no supporting details of the aims and significant topics or the activities that were carried out. On its website the company provides links to lobbying registers maintained by public bodies but not to its own reports specifically.

The company does not publish details about its global lobbying expenditure. On its website the company provides links to lobbying registers maintained by public bodies but not to its own reports specifically.

Based on publicly available information, there is evidence that the company has a policy and procedures on the giving and receipt of gifts and hospitality. The policy specifies different approval procedures for different types of promotional expenses and addresses the risks associated with gifts and hospitality given to/received from public officials. There is evidence that expenses in relation to gifts and hospitality have to be documented. However, based on publicly available information, there is no clear evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

Based on publicly available information, there is evidence that the company has a policy on corporate political contributions. The company’s policy indicates that it may make political contributions when approved by the company’s Senior Vice President of Government Relations and other relevant senior management and legal professionals. The company states that the board reviews its Political Activities Policy and all donations made on an annual basis. In addition, there is evidence that that the company is associated with a Political Action Committee (PAC) in the United States, which is overseen by a committee of employees from different business divisions.

Since the company does not prohibit political donations and is associated with a PAC, it receives a score of ‘0’ in line with the scoring criteria.

There is evidence that the company publishes full details of its political contributions made by the company. The company publishes a list of all corporate contributions and Political Action Committee (PAC) disbursements made in the most recently reported financial year, including details of the recipient, amount and state for each donation.

There is some evidence that the company has a policy covering charitable donations and sponsorships. The company indicates that employees must seek advice from the Government Affairs and Community Relations groups before making any contributions, and states that any donations must be properly documented.

However, the company receives a score of ‘1’ because there is no evidence that it publishes any details of its charitable donations and sponsorships made in the most recently reported financial year. In addition, the company does not provide any further information of the controls or procedures to ensure that such donations are not used as vehicles for bribery and corruption.

There is evidence that the company has a policy on lobbying. The company indicates that all political activities, including lobbying, must be reviewed and approved by the Senior Vice President of Government Relations, along with relevant senior management and legal professionals. There is evidence that the company may employ external consultants to lobby on its behalf, and that it commits to engaging in the political process responsibly.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it clearly defines responsible lobbying, nor is there evidence that its procedure includes standards of conduct for all individuals engaged in lobbying on the company’s behalf.

There is no evidence that the company publishes details of the aims and topics of its lobbying activities on its website. The company states that its lobbying reports in the United States are available on relevant federal, state and local websites, however it does not provide direct links to these sources on its own site.

There is no evidence that the company publishes any details of its lobbying expenditure on its website. The company states that its lobbying reports in the United States are available on relevant federal, state and local websites, however it does not provide direct links to these sources on its own site. The company does not publish any information about its lobbying activities in other jurisdictions, nor a statement that it does not lobby outside of the United States.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, which stipulates procedures designed to ensure that such promotional expenses are not used for bribery. The company indicates that any gifts offered must be proportionate and states that the Law Department must be notified if a government entity or official is involved.

However, the company receives a score of ‘1’ because there is no evidence that its policy specifies financial or proportional limits, nor different approval procedures, for different types of promotional expenses. In addition, there is no evidence that gifts and hospitality above a certain threshold are recorded in a dedicated central register or database that is accessible to those responsible for oversight of the process.

Based on publicly available information, there is evidence the company has a policy on political contributions. However, while donations are generally prohibited, these are stated to be permissible in certain circumstances, providing that proper authorisation is given by a senior manager. Based on the scoring criteria, the company therefore receives a score of ‘0’.

There is no evidence that the company publishes details of its political contributions.

Based on publicly available information, there is some evidence that the company has a policy on charitable donations. However, there is no evidence that the company has a policy on sponsorships, and the available information relating to its approach to charitable donations is insufficiently detailed. The company also publishes only high-level information concerning its charitable contributions.

Based on publicly available information, there is no evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with procedures to ensure that such promotional expenses are bona fide and not used for bribery. The company explicitly addresses the risks associated with gifts and hospitality given to and received from public officials.

However, the policy does not specify financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no clear evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

Based on publicly available information, there is evidence that the company has a policy on corporate political contributions. The company indicates that it may make political contributions in line with its policy and with prior approval from the Corporate Government Affairs department, a company officer or the GE counsel. There is evidence that the company has criteria in place for donations and that a dedicated board-level committee – the Governance and Public Affairs Committee – is responsible for overseeing all political spending and any associated activities. In addition, there is evidence that that the company is associated with a Political Action Committee (PAC) in the United States, which is overseen by a committee of employees from different business divisions.

Since the company does not prohibit political donations and is associated with a PAC, it receives a score of ‘0’ in line with the scoring criteria.

The company publishes a statement that it has not made any corporate political donations in the most recently reported financial year. In addition, there is evidence that the company publishes full details of the contributions made through its Political Action Committee (PAC) in the United States, by providing a link to its official disclosures. This data includes details of the recipient, amount and the name of the corporate entity that made the contribution. There is evidence that this data is updated and published on at least an annual basis.

There is evidence that the company has policies on both charitable donations and sponsorships, whether made directly or indirectly through its corporate foundation. There is evidence that any charitable donations and sponsorships must comply with a range of company policies to ensure their integrity. The company publishes details of its charitable contributions over $10,000, including the name of the recipient organisation, amount and corporate entity that made the payment.

However, the company receives a score of ‘1’ because there is no evidence that it publishes full details of all charitable donations or sponsorships made, including those under $10,000. In addition, the company does not provide further publicly available information on the specific procedures and controls in place to regulate these donations, such as procedures for senior sign-off or due diligence on recipients.

There is evidence that the company has a policy and procedures on lobbying that specify certain standards of conduct and oversight mechanisms. There is evidence that company’s Vice President of Government Affairs & Policy provides oversight and prior approval of all lobbying activities. In addition, the company indicates that it has specific policies and procedures in place to ensure that lobbying is conducted responsibly, including dedicated training for lobbyists and restrictions on gifts and hospitality. It is clear that this policy applies to both employees engaged in lobbying activities and any third party lobbyists approved by the VP of Government Affairs & Policy.

The company publishes a list of the topics on which it lobbies, including a description of its core positions, their importance or relevance to the company and stakeholders, and the activities it carries out. There is evidence that this represents lobbying activities conducted by both the company’s employees and any third parties engaged in lobbying on its behalf. In addition, it is clear that these points represent the aims and topics in all jurisdictions where the company conducts lobbying activities.

There is evidence that the company publishes its lobbying expenditure in the United States, by providing a link to its official disclosures. There is evidence that this information is correct up to the most recent quarter of the financial year.

However, the company receives a score of ‘1’ because it does not provide further details of its lobbying expenditure, to indicate details such as the corporate entity, geography, internal lobbyists/external lobbyists/association lobbying and an explanation of how the figures in the data have been calculated. Additionally, the company does not provide a clear statement regarding its lobbying expenditure outside the United States.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality with clear procedures to ensure that such expenses are not used as vehicles for bribery or corruption. The company’s policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. There is evidence the policy addresses the risks associated with gifts and hospitality given to and/or received from domestic and foreign public officials, by specifying a different financial threshold. In addition, there is evidence that gifts and hospitality are recorded in a dedicated register that is accessible to those responsible for oversight of the process.

There is no publicly available evidence that the company has a policy to regulate corporate political contributions.

There is no publicly available evidence that the company publishes any details of its political contributions.

There is no publicly available evidence that the company has a policy or procedure covering charitable donations or sponsorships.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy on gifts or hospitality.

Based on publicly available information, there is evidence that the company has a policy on corporate political contributions. The company’s policy indicates that it may make corporate political contriubtions when approved by the Senior Vice President, Planning and Development and when such donations are in the company’s business interests. There is also evidence that the company is associated with a Political Action Committee (PAC) in the United States, which is overseen by a committee of senior management employees.

Since the company does not prohibit political donations and is associated with a PAC, it receives a score of ‘0’ in line with the scoring criteria.

There is evidence that the company publishes details of its political contributions. The company publishes a total figure of all contributions made to state and local candidates for the most recently reported financial year, though it is noted that this figure is not broken down by recipient, amount and country of recipient per donation. In addition, the company provides a direct link to the United States Federal Election Commission website, where information about the donations made through its PAC may be accessed.

There is no publicly available evidence that the company has a policy on charitable donations or sponsorships. The company addresses donations to charities that are affiliated with a politician as part of its political contriubtions policy, but there is no evidence that it has a specific policy on charitable donations to address the potential bribery and corruption risks.

There is some evidence that the company has a corporate procedure on lobbying practices. The company indicates that this policy is designed to ensure compliance with all relevant laws and regulations involving government officials, as well as outlining the relevant disclosure requirements.

However, the company receives a score of ’1’ because the policy does not clearly define lobbying, nor does it outline certain standards of conduct for lobbyists. It is also not clear whether this policy applies company-wide to all employees and all third parties engaged in lobbying activities on the company’s behalf.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is evidence that the company publishes its annual lobbying expenditure, in the form of a total amount.

The company receives a score of ’1’ because this expenditure information is not broken down by corporate entity, geography, and there is no explanation of how the data has been calculated. In addition, there is no clear indication that the expenditure figure represents the United States only or all jurisdictions in which the company has conducted lobbying activities.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality. The company indicates that employees should not offer a gift that may appear to be improper, and states that only gifts that are modest in value should be accepted. Where substantial gifts are accepted, the company indicates that they must be reported to the relevant business unit’s ethics officer.

However, the company receives a score of ‘1’ because its policy does not provide further details of controls to reduce the risks arising from gifts and hospitality, such as financial or proportional limits or different approval procedures for different types of promotional expenses. In addition, the policy does not address the risks associated with gifts and hospitality given to or received from domestic or foreign public officials. There is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.

There is no publicly available evidence that the company has a policy on corporate political contributions.

There is no evidence that the company discloses any details of its political contributions.

There is no evidence that the company has a policy or procedure covering both charitable donations and sponsorships. There is evidence to suggest that that the company engages in charitable projects, but it does not provide further details regarding these activities.

There is no evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is some evidence that the company has a policy on the giving and receipt of gifts and hospitality, but this appears to apply only to the company’s suppliers, rather than its own employees.

There is no evidence that the company has a policy on corporate political contributions.

There is no evidence that the company discloses details of its political contributions.

There is no evidence that the company has a policy and/or procedure covering both charitable donations and sponsorships.

There is no publicly available evidence that the company has a policy and/or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any information on its global lobbying expenditure.

There is no publicly available evidence that the company has a policy and/or procedure on gifts or hospitality.

There is evidence that the company has a policy on corporate political contriubtions, which clearly states that such donations are prohibited. There is evidence that this policy applies to all types of contributions, whether made by the company itself or by any other entity or individual acting on the company’s behalf.

The company publishes a clear statement that it does not make any political contributions, and is therefore exempt from scoring on this question.

Based on publicly available information, there is evidence that the company has a policy and procedure covering charitable donations to ensure that such donations are not used as vehicles for corruption. The company’s policy includes clear criteria for donations and procedures for prior approval of any donations. The company publishes some details of its charitable donations, including the name and targets of each donation made for the most recently reported financial year.

However, the company receives a score of ’1’ because there is no evidence that the company publishes the amount or value of each donation made in the most recently reported financial year.

The company publishes a clear statement that it does not conduct lobbying activities. The company receives a score of ‘1’ because it is not clear from publicly available information whether this approach also applies to any lobbing activities conducted in other jurisdictions. There is no publicly available evidence that the company publishes a clear policy to regulate its lobbying activities in other jurisdictions, nor does it publish a statement to indicate that it does not lobby outside Korea.

The company publishes a clear statement that it does not conduct lobbying activities, and therefore it is exempt from scoring on this question.

The company publishes a clear statement that it does not conduct lobbying activities, and therefore it is exempt from scoring on this question.

Based on publicly available information, there is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. The company’s policy addresses the risks associated with gifts and hospitality given to public officials and that it specifies financial limits and different approval procedures for different types of promotional expenses. In addition, there is evidence that all gifts and hospitality are recorded in a dedicated central register, which is accessible to those responsible for oversight of the process.

Based on publicly available information, there is evidence that the company has a policy on corporate political contributions. The company indicates that political contributions are permissible in limited circumstances and when approved by the Vice President of HPE Corporate Affairs and reviewed by the board. The company states that it does not make any political donations where there is a risk of creating the appearance of undue influence. In addition, there is evidence that the company is associated with a Political Action Committee (PAC) in the United States.

Since the company does not prohibit political donations and is associated with a PAC, it receives a score of ‘0’ in line with the scoring criteria.

There is evidence that the company publishes full information of its corporate political contributions, including details of the recipient, amount, country of recipient and the name of the corporate entity that made the contribution. The company also publishes details of the donations made by its Political Action Committee (PAC), including the name of the candidate, state, party, office and amount donated. There is evidence that this data is updated and released on an annual basis.

Based on publicly available information, there is evidence that the company has a policy on both charitable donations and sponsorships to ensure that such expenses are not used as vehicles for bribery. The company’s policy stipulates procedures for senior sign-off on all donations and sponsorships. In addition, the company provides some information of its charitable donations and philanthropic activities, including the number of charities supported around the world.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it publishes full details of its charitable contributions and sponsorships, such as details of the recipient, amount, country of recipient and which corporate entity made the payment.

There is some evidence that the company has a policy in place to ensure that its engagement in lobbying is ethical, legal and transparent. In addition, there is evidence that the company provides clear standards of conduct and guidelines for responsible behaviour for its third parties, which clearly include lobbyists.

However, there is no publicly available evidence that the company’s approach includes oversight mechanisms for lobbyists, nor is it clear that the company’s standards of behaviour apply to all in-house, external and association lobbyists. There is also no evidence that the company provides a clear definition of responsible lobbying.

There is evidence that the company publishes some details of the aims and topics on which it conducts lobbying. The company publishes clear policy priorities for different areas of the business and provides some information on their relevance to stakeholders. In addition, there is evidence to indicate that these priorities cover multiple relevant jurisdictions and it is clear that this information is updated on an annual basis.

There is no evidence that the company publishes any details about its global lobbying expenditure. The company indicates that it has an internal document entitled ‘Reporting of Lobbying Activities’ which may contain more information on this subject, but it does not appear to be publicly accessible.

Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality with clear procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter.

In addition, the company’s policy clearly addresses the risks associated with gifts and hospitality given to and/or received from public officials, by specifying a different financial threshold. There is evidence that all gifts and hospitality above certain thresholds are recorded in a dedicated central tool that is accessible to those responsible for oversight of the process.

According to publicly available information, there is no evidence that the company has no policy on corporate political contributions.

There is no evidence that the company discloses full details of its political contributions.

There is no evidence that the company has a policy and/or procedure covering both charitable donations and sponsorships.

There is no evidence that the company has a policy and/or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

There is no publicly available evidence of a policy or procedure on gifts or hospitality.

The company publishes a clear statement that it prohibits corporate political contributions.

There is evidence that the company has a policy covering charitable donations, in order to ensure that they are free from corruption. These measures include implementing criteria for donations and senior sign off. There is evidence that the company additionally discloses certain details of its philanthropic activities.

The company publishes a commitment to engage in public policy development in adherence to all laws and regulations but publishes insufficient information to receive a score of ‘1’. There is no evidence that the company has a clear policy on responsible lobbying which goes beyond adhering to laws.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any information on its lobbying expenditure.

There is evidence that the company has a policy and procedures on the giving and receipt of gifts and hospitality, to ensure that they are bona fide and not used for corrupt purposes. The company explicitly addresses the risks associated with gifts given to, and received from, government officials. The company states that all gifts and hospitality given and received must be recorded and submitted.

However, there is no explicit evidence that these records are stored in a dedicated central repository accessible to those responsible for overseeing the policy. Although the company’s Conduct Discipline and Appeal Rules document sets financial thresholds for different kinds of gifts, this document is dated in 1984 and so it is unclear whether these financial thresholds remain relevant.

Based on publicly available information, there is evidence that the company has a policy on political contributions. The company indicates that corporate political contributions are generally prohibited, unless authorised by the Government Relations function and approved by the Senior Vice President and General Counsel specifically. The company states that it has not made any contributions since 2009, with the exception of two contributions to 501(c)(4) organisations which are publicly disclosed. In addition, there is evidence that the company is associated with a Political Action Committee (PAC) in the United States, which is subject to formal approval procedures and periodic audits.

Since the company does not prohibit political donations and is associated with a PAC, it receives a score of ‘0’ in line with the scoring criteria.

There is evidence that the company publishes details of its political contributions. The company states that it has only made two corporate political contributions since 2009, in the form of donations to 501(c)(4) organisations. For each donation, the company lists the name of the recipient organisation and the amount donated; it is also clear that both organisations are located in the United States. In addition, there is evidence that the company publishes a direct link to the U.S. Federal Election Commission (FEC), where full details of the disbursements made through its Political Action Committee (PAC) can be accessed.

Based on publicly available information, there is evidence that the company has a policy to ensure that charitable donations and sponsorships are not used as vehicles for bribery and corruption. The company states that all such contributions must follow its internal policies and indicates that all charities and proposed activities must be approved by management and the Law Department. In addition, the company states that its Integrity and Compliance department must approve any donation of over US$10,000 that may benefit a government official in a 12 month period.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it publishes full details of all charitable contributions and sponsorships made, such as details of the recipient, amount, country of recipient and which corporate entity made the payment. In addition, it is not clear that the company has procedures in place to conduct due diligence on recipients, nor does it publish information on criteria for donations.

Based on publicly available information, there is evidence that the company has a policy on lobbying. The company indicates that all lobbying activities are overseen by its Law Department, Global Compliance Department and Government Relations department. There is also evidence that the board and executive leadership receive regular reports on the company's lobbying activities.

However, there is no publicly available evidence that the company’s policy provides clear guidelines or standards of conduct that constitute responsible lobbying. It is also not clear from publicly available information that the company’s policy and its oversight mechanisms apply to all employees and individuals engaged in lobbying, including all internal, external and association lobbyists.

There is evidence that the company publishes information on its significant legislative and regulatory priorities, alongside explanations of their relevance to the company's commercial activities. The company also provides some information on the key legislation and issues on which it has lobbied on a quarterly basis, by providing a direct link to its legally mandated Lobbying Disclosure Reports in the United States.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that this represents the aims and topics of its lobbying in all jurisdictions, nor does it provide a statement to indicate that it does not engage in lobbying outside of the United States.

There is evidence that the company publishes details of its lobbying expenditure, by making its federal quarterly lobbying reports up to the most recently reported financial year available via a direct link on its website.

However, the company receives a score of ‘1’ because there is no evidence that this expenditure data is broken down into expenditure through internal, external or association lobbyists. In addition, it is not clear from publicly available information that this represents the company’s lobbying expenditure in all jurisdictions, nor does it provide a statement to indicate that it does not engage in lobbying outside of the United States.

Based on publicly available information, there is evidence that the company has a policy on gifts and hospitality to ensure that such business courtesies are not used as vehicles for corruption or bribery. The company’s policy acknowledges the risks associated with any gifts and hospitality, in particular when given or received as part of dealings with domestic and foreign government officials. In addition, there is evidence that the company’s policy sets clear financial limits for specific types of business courtesies and that senior approval may be required in some cases.

However, the company receives a score of ‘1’ because although it states that all business courtesies must be appropriately documented, there is no evidence that all gifts and entertainment given or received are recorded in a central register or database that is accessible to those responsible for oversight of the process.

The company recognises political activities as a corruption risk and has a policy governing its activities in this area. However, the company permits certain political donations and has a Political Action Committee, and therefore receives a score of ‘0’.

The company publishes some information about its political donations and therefore receives a score of ‘2’.

The company states that it has a policy regarding charitable donations, as referred to in its Code of Ethics and Business, to ensure that they are free from corruption. The company states that the recipients of its charitable donations undergo anti-corruption risk-based due diligence. The company discloses some information about the recipients of its charitable donations, but does not provide full details.

However, the company receives a score of ‘0’ because there is no evidence that it has a policy and/or procedure covering sponsorships.

The company has a policy covering responsible lobbying, and provides an overview of its expected standards of conduct comprising responsible lobbying. The company recognises lobbying as a corruption risk and outlines a number of risk mitigation procedures and oversight mechanisms, including due diligence on external lobbyists, reporting obligations, anti-corruption contractual agreements and tailored anti-corruption training for staff overseeing lobbying activities. The company also clarifies that its policy on lobbying only applies to the US because it is the only jurisdiction where it conducts lobbying activities. The policy applies to all employees and third parties.

However, the company does not clearly outline the specific corruption risks commonly associated with lobbying, such as conflicts of interest, gifts and hospitality and undue influence. Additionally, the company does not specify that its policy also applies to board members.

The company states that it does not conduct lobbying activities outside the US. The company states that it files disclosures to the United States Congress, which includes information on the topics and aims of the company’s lobbying campaigns. However, the company does not publish information on its lobbying activities on its website or in its reports. It does not provide direct links to the relevant lobbying information disclosed externally.

The company states that it does not conduct lobbying activities outside of the US. The company also states that it discloses its federal lobbying activities externally. The company, however, does not directly disclose this information on its website or in its reports.

There is evidence that the company has a policy and/or procedure on the giving and receipt of gifts and hospitality to ensure that they are not used for corrupt purposes. This explicitly states that employees should never provide or accept business courtesies from domestic or foreign officials. The company also specifies a clear financial threshold, which stipulates senior sign off.

However, while the company states that all gifts and hospitality are overseen by the company’s Compliance Office, there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or depository accessible to those with oversight responsibility.

There is no publicly available evidence that the company has a policy on corporate political contributions.

There is no publicly available evidence that the company discloses full details of its political contributions.

There is no evidence that the company has a policy and procedure covering charitable donations and sponsorships. The company publishes some information on its sponsorships and donations but it does not provide comprehensive details to indicate that this covers all sponsorships, nor is there evidence that the company has an accompanying policy or procedure in place.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no publicly available evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no publicly available evidence that the company provides any details about its global lobbying expenditure.

Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts. The company’s policy specifies financial limits for the receipt of gifts. There is evidence that gifts received are recorded in a depository that is accessible to those responsible for oversight of the process.

However, the company receives a score of ‘1’ because there is no evidence it addresses the risks associated with gifts and hospitality given to/received from public officials. There is also no evidence that the company records or specifies financial limits for the giving of gifts, nor the giving and receipt of hospitality.

There is no publicly available evidence that the company has a policy on political donations.

There is no evidence that the company publishes any details of its political contributions.

There is no publicly available evidence that the company has a policy or procedure on charitable donations and sponsorships.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy or procedure on gifts and hospitality.

There is evidence that the company has a policy on political contributions which recognises the risks associated with such expenditure and states that contributions are permissible when made in line with relevant laws. Among other procedures, the company indicates that any contributions must be consistent with its values, properly documented and approved in advance by the company’s Compliance Officer.

The company receives a score of ‘0’ since it does not prohibit political contributions in line with the scoring criteria.

There is no evidence that the company publishes any details of its political contributions.

Based on publicly available information, there is evidence that the company has a policy covering charitable donations and sponsorships. The company’s policy includes measures to ensure that donations are not used as vehicles for bribery and corruption, including a requirement for advance approval by the Compliance Officer and proper documentation of expenditure, among other controls.

However, the company receives a score of ‘1’ because there is no evidence that it publishes any details of the charitable donations and sponsorships made in the most recently reported financial year, such as the details of the recipient, amount, country of recipient and which corporate entity made the payment.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details of its global lobbying expenditure.

Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality with procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. The company’s policy clearly addresses the risks associated with gifts and hospitality given to and/or received from public officials. There is evidence that all gifts and hospitality above certain thresholds are recorded in centrally through a system that is accessible to those responsible for oversight of the process.

However, there is no publicly available evidence that the company’s policy includes financial or proportional limits or different approval procedures for different types of promotional expenses.

There is no publicly available evidence to indicate that the company has a policy on corporate political contributions.

There is no publicly available evidence to indicate that the company discloses details of its political contributions.

There is no publicly available evidence to indicate that the company has a policy or procedure covering charitable donations and sponsorships.

There is no publicly available evidence to indicate that the company has a policy or procedure on lobbying.

There is no publicly available evidence to indicate that the company publishes any information on its lobbying aims, topics or activities.

There is no publicly available evidence to indicate that the company provides details about its global lobbying expenditure.

There is no publicly available evidence to indicate that the company has a policy or procedure on gifts or hospitality.

Based on publicly available information, there is evidence that the company publishes a clear statement that it does not make corporate political contributions. The company indicates that this applies to any direct or indirect contributions in Spain or in any other jurisdictions. There is evidence that this policy applies company-wide.

The company publishes a clear statement that it does not make political contributions and therefore it is exempt from scoring on this question.

Based on publicly available information, there is evidence that the company has a policy on charitable donations and sponsorships, which outlines criteria for such donations.

However, the company receives a score of ‘1’ because there is no evidence that it publishes full details of all the charitable donations it makes, such as details of the recipient, amount, country of recipient and which corporate entity made the payment. In addition, the company does not indicate that its policy includes further controls such as procedures for senior sign-off or due diligence on recipients; the company makes reference to an internal document which provides further details on these procedures, but this does not appear to be publicly accessible.

Based on publicly available information, there is some evidence that the company has procedures on lobbying. The company indicates that employees involved in lobbying activities must abide by its Code of Ethics and Legal Compliance, which provides clear standards of conduct and acceptable behaviours.

However, the company receives a score of ‘1’ because it does not provide further publicly available information on the procedures that it has in place to ensure that lobbying is conducted responsibly, for example by outlining specific oversight mechanisms or specific standards of conduct that clearly apply to in-house, external and association lobbyists.

There is evidence that the company publishes some details of the topics on which it lobbies. The company provides details on its strategy to communicate with public bodies and indicates that its lobbying activities are primarily directed towards supporting its business interests. In addition, the company provides a direct link to the EU Transparency Register and Lobbyfacts, both of which contain records of the major topics on which the company has lobbied and its overarching goals, as well as details of any meetings with European officials.

However, the company receives a score of ‘1’ because it does not provide further publicly available information on its specific aims of its lobbying and the activities that it carries out to achieve them. Although the company provides a link to information about its EU-level lobbying activities, there is no evidence that it publishes such information on any other activities undertaken nationally or internationally in other jurisdictions.

There is some evidence that the company publishes some details of its lobbying expenditure for the most recently reported financial year. This data includes most significant associations and organisations the company has supported as part of its approach to lobbying. In addition, the company provides a direct link to the EU Transparency Register and Lobbyfacts, both of which contain records of its annual spending on lobbying at the EU-level.

However, the company receives a score of ‘1’ because it is not clear that these details represent all of the company’s expenditure on lobbying activities, including activities conducted through in-house and external lobbyists. Although the company provides a link to information about its EU-level lobbying activities and expenditure, there is no evidence that it publishes such information on any other expenditure made nationally or internationally in other jurisdictions.

Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality. The company’s policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The company’s policy also clearly addresses the risks associated with gifts and hospitality given to public officials, and there is some evidence that the Compliance Unit maintains records of all tickets for entertainment events provided by employees.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that it maintains a dedicated central register of all types of gifts and hospitality which is accessible by the Compliance Unit.

There is evidence that the company prohibits all financial contributions and donations. On the basis of other policies published by the company, which prohibit political activities on the company premises, it is understood that this includes a prohibition of political contributions.

The company publishes a clear statement that it prohibits corporate political contributions, so therefore it is exempt from scoring on this question.

The company publishes a statement that it does not make donations for any purpose with the exception of providing services that do not have material value.

The company does not meet the criteria for a score of ‘2’ as it does not provide further information on how it defines the value of services. It refers to a policy on this subject but this is not publicly available.

While the company indicates that its anti-corruption policy applies to lobbyists, in publicly available information it provides no further evidence concerning its procedures and policies on lobbying itself.

The company does not publish any information on its lobbying aims, topics or activities.

The company does not publish any details about its global lobbying expenditure.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality. This policy addresses the risks associated with gifts and hospitality given to public officials. The company’s management are required to sign an annual certification that they have not provided gifts in contravention of the company’s compliance programme.

However, based on publicly available information, there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process. The policy also does not specify financial or proportional limits or different approval procedures for different types of promotional expense. It is noted that the company has a separate policy on gifts but this does not appear to be publicly accessible.

There is no publicly available evidence that the company has a policy to regulate corporate political contributions.

There is no evidence that the company publishes any details of its corporate political contributions.

There is no evidence that the company has a policy or procedure covering charitable donations or sponsorships.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy on gifts or hospitality.

There is evidence that the the company has a policy on corporate political contributions, to ensure that such payments are not used as vehicles of bribery and corruption. There is evidence that this policy applies to all employees, officers, third parties and subsidiaries.

However, the company receives a score of ‘0’ because its policy does not prohibit corporate political contributions. It is also not clear whether the company has a Political Action Committee (PAC); there is evidence that the company had a PAC in 2017-18 but there is evidence to indicate that the PAC no longer exists.

The company publishes a high-level figure of all its political contributions made on an annual basis as part of its ESG reporting. However, the company receives a score of ‘0’ because it does not provide any further information of the donations made, such as details of the recipient, amount, country of recipient and the name of the corporate entity that made the contribution.

There is evidence that the company has a policy on charitable donations and sponsorships, to ensure that such payments are not used as vehicles for bribery and corruption. The company’s policy includes establishing the legitimacy of the donation and oversight from the Compliance Department. In addition, there is evidence that the company publishes high-level figures on its charitable donations made on an annual basis.

However, the company receives a score of ‘1’ because it does not publish full details of its charitable donations, such as details of the recipient, amount, country of recipient and which corporate entity made the payment.

There is evidence that the company has a policy on lobbying that applies company-wide to all employees, officers and third parties acting on the company’s behalf. The company’s policy provides a definition of lobbying and indicates that employees must act ethically when engaged in lobbying activities.

However, the company receives a score of ‘1’ because its policy does not provide clear standards of conduct, guidelines or oversight mechanisms that apply to in-house, external and association lobbyists.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality. There is evidence that this policy addresses the risks associated with gifts and hospitality given to and received from public officials, and it indicates that all gifts and entertainment received and given must be recorded.

However, the company receives a score of ‘1’ because its publicly available policy does not provide financial or proportional limits nor different approval procedures for different types of promotional expenses. There is also no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.

There is evidence that the company has a policy on corporate political contributions, which generally prohibits such payments but states that they are permissible in certain circumstances and in accordance with all applicable laws. There is evidence that the Government Relations department is responsible for reviewing and approving any proposed contributions. This policy applies company-wide to all employees, including those of subsidiaries. There is also evidence that the company is associated with a Political Action Committee (PAC) in the United States.

The company receives a score of ‘0’ since it does not prohibit political contributions and is associated with a PAC in the United States, as outlined in the scoring criteria.

The company publishes a statement that it did not make any political contributions in the last 12 months. The company publishes some data on its political contributions on an annual basis.

Based on publicly available information, there is some evidence that the company has a policy on charitable donations and sponsorships. There is evidence that the company specifies criteria for donations and that some donations are subject to an anti-corruption review and approval process. In addition, the company provides some high-level figures of its charitable donations and community sponsorships.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it publishes full details of its charitable contributions, such as details of the recipient, amount, country of recipient and which corporate entity made the payment. It is also not clear that the company has further procedures in place to reduce the risk of corruption, such as due diligence on recipients.

There is some evidence that the company has a procedure on lobbying to ensure compliance with all applicable laws and regulations. The company indicates that any lobbyists outside of the United States are subject to the same due diligence, approval and standards of conduct that apply to commercial intermediaries.

However, the company receives a score of ‘1’ because it does not provide further publicly available information on its procedures to ensure responsible lobbying, such as standards of conduct for lobbyists in the United States or specific oversight mechanisms for both domestic and foreign lobbying activities. There is also no clear evidence that the company’s policy addresses and applies to all internal, external and association lobbyists.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any information on its global lobbying expenditure.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with procedures designed to ensure that such promotional expenses do not pose a bribery and corruption risk. There is evidence that this policy establishes an approval procedure for the different types of promotional expense that employees may encounter, and it addresses the risks associated with gifts and hospitality given to and received from public officials. There is some evidence that the policy includes financial or proportional limits and that all gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.

There is no evidence that the company has a policy on corporate political contributions

The company does not disclose details of its political contributions.

There is no evidence that the company has a policy or procedure covering charitable donations and sponsorships.

There is no evidence that the company has a policy and/or procedure on lobbying.

The company does not publish any information on its lobbying aims, topics or activities.

The company does not provide any details about its global lobbying expenditure.

There is no publicly available evidence of a policy or procedure on gifts or hospitality.

Based on publicly available information, there is evidence that the company prohibits corporate political contributions, regardless of whether they may be permitted under local laws. However, the company receives a score of ‘0’ because there is some indication that the company may make political contributions in certain circumstances, with proper authorisation and approval.

There is no evidence that the company discloses any details of its political contributions, nor a statement that it has not made any contributions.

Based on publicly available information, there is evidence that the company makes charitable donations, referred to as ‘social contributions’. However, the company receives a score of ‘0’ because there is no evidence that it has a clear policy on charitable donations and sponsorships to ensure that such donations are not used as vehicles for bribery and corruption.

There is no evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes details about its global lobbying expenditure.

Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality. There is evidence that this policy addresses the risks associated with gifts and hospitality given to and received from domestic or foreign public officials.

However, the company receives a score of ‘1’ because it does not specify financial or proportional limits or different approval procedures for different types of promotional expenses, and there is no evidence that gifts and hospitality above a certain threshold are recorded in a dedicated register that is accessible to those responsible for oversight of the process.

Although the company indicates that it generally prohibits political contributions, there is evidence that they are permitted in certain circumstances.

There is no evidence that the company discloses details of its political contributions.

Based on publicly available information, there is evidence that the company has a policy and procedure covering both charitable donations and sponsorships. These policies include specific measures to ensure that such donations are not used as vehicles for bribery and corruption, for example by specifying criteria for donations, provisions for senior sign-off and due diligence on recipients. The company also publishes some information on the recipients of its donations, but it is not clear whether this description represents a full list of all recipients.

However, the company does not publish sufficient details on its charitable donations and sponsorships, such as the amount, country of recipient and which corporate entity made the payment.

Based on publicly available information, there is some evidence that the company has a policy on lobbying that applies to all employees and associated lobbying firms. The company states that any lobbying activities must comply with all relevant laws and regulations, and that lobbying on behalf of the company must never be used to gain an improper advantage.

However, the company’s approach does not define and control the standards of conduct required to ensure responsible lobbying. There is some evidence that the company may provide this information in an internal document, but this is not publicly available.

There is no publicly available evidence to indicate that the company publishes any information on its lobbying aims, topics or activities.

There is no publicly available evidence to indicate that the company publishes any details about its global lobbying expenditure.

Based on publicly available information, there is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. The policy specifies financial or proportional limits for different types of promotional expenses. It also addresses the risks associated with gifts and hospitality given to/received from public officials.

Although the company indicates that gifts and hospitality must be recorded in financial records, there is no evidence the company has a dedicated register or central depository that is accessible to those responsible for oversight of the process.

Based on publicly available information, the company publishes a clear statement that it prohibits corporate political contributions. There is evidence to indicate that this policy applies to donations of any kind, and that it applies to all employees and divisions across the group.

The company states that it does not make political contributions and therefore it is exempt from scoring on this question.

Based on publicly available information, there is evidence that the company has a policy covering both charitable donations and sponsorships. The company’s policy includes specific criteria and procedures for donations. However, the company receives a score of ‘1’ because there is no evidence that it publishes full details of its charitable donations, such as name, amount and country of each recipient entity.

There is evidence that the company publishes a statement to indicate that it does not engage in lobbying activities or employ lobbyists in the conduct of business, in accordance with relevant laws in Korea.

The company receives a score of ‘1’ because it is not clear from publicly available information whether this approach also applies to any lobbing activities conducted in other jurisdictions. There is no publicly available evidence that the company publishes a clear policy to regulate its lobbying activities in other jurisdictions, nor does it publish a statement to indicate that it does not lobby outside Korea.

There is evidence that the company publishes a statement to indicate that it does not engage in lobbying activities or employ lobbyists in the conduct of business, in accordance with relevant laws in Korea. Since this statement applies to the main jurisdiction in which the company operates, it is exempt from scoring on this question; though it is noted that it is not clear from publicly available information whether the company conducts lobbying in other jurisdictions outside of Korea.

There is evidence that the company publishes a statement to indicate that it does not engage in lobbying activities or employ lobbyists in the conduct of business, in accordance with relevant laws in Korea. Since this statement applies to the main jurisdiction in which the company operates, it is exempt from scoring on this question; though it is noted that it is not clear from publicly available information whether the company conducts lobbying in other jurisdictions outside of Korea.

Based on publicly available information, there is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. The policy specifies financial limits for different types of promotional expenses and it addresses the risks associated with gifts and hospitality given to public officials.

However, there is no clear publicly available evidence that all gifts and hospitality are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

There is evidence that the company permits political contributions.

The company does not disclose details of its political contributions.

There is some evidence that the company has procedures covering both charitable donations and sponsorships to ensure that such donations are not used as vehicles for bribery and corruption. However, the company does not publish further details regarding these procedures, for example, by specifying criteria for donations, requirements for senior sign-off, or due diligence on recipients.

There is no evidence the company has a policy or procedure on lobbying.

The company does not publish any information on its lobbying aims, topics or activities.

The company does not publish any information on its lobbying aims, topics or activities.

There is evidence that that the company has a procedure on the giving and receipt of gifts and hospitality. The company indicates that any expenses associated with gifts and hospitality must be entered into its financial accounts.

However, the company scores ‘1’ as there is no evidence the company’s policies or procedures specify financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no evidence the company addresses the risks associated with gifts and hospitality given to/received from domestic or foreign public officials. There is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

Based on publicly available information, there is evidence that the company has a policy on corporate political contributions. The company indicates that political contributions are generally restricted due to legal prohibitions in many jurisdictions, but where they are permitted such donations require sign-off from the Legal Department and the Government Relations Office. There is evidence that any contributions to, or in support of U.S. Federal office candidates are generally prohibited and indicates that any state or local level donations are highly regulated and must be approved in advance. There is evidence that this policy is applicable to all employees and board members, as well as those employed by the company as third parties. In addition, there is evidence that the company is associated with a Political Action Committee (PAC) in the United States, which is overseen by a committee of employees from different business divisions.

Since the company does not prohibit political donations and is associated with a PAC, it receives a score of ‘0’ in line with the scoring criteria.

There is no evidence that the company publishes any details of its corporate political contributions or Political Action Committee (PAC) disbursements for the most recently reported financial year.

There is evidence that the company has a policy and procedure on charitable donations. The company indicates that its board-level Nominating and Governance Committee reviews its charitable donations and philanthropic activities to ensure that they are consistent with the company’s ethical commitments and policies. In addition, the company publishes some information on the charitable causes it supports.

However, the company receives a score of ‘1’ because there is no evidence that it publishes full details of its charitable donations and related activities, such as the name, amount and country of each recipient as well as which corporate entity made the payment.

There is evidence that the company has a policy on lobbying which apply to all employees, directors and third parties engaged in lobbying on the company’s behalf. The company indicates that its Government Relations Office is responsible for oversight of all lobbying activities and for contracting any external lobbyists.

However, the company receives a score of ‘1’ because in publicly available evidence it does not provide details of specific oversight mechanisms or controls to regulate its lobbying activities, nor does it outline certain standards of lobbying conduct which are expected of its lobbyists. It is noted that the company has a dedicated policy on lobbying which may contain more details on these standards, but this does not appear to be publicly accessible.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities on its website. The company states that it complies with all annual lobbying disclosures required by law in the United States, however it does not provide a direct link to its disclosures nor does it provide information on its lobbying aims and activities outside the United States (if any).

There is no evidence that the company publishes any details of its global lobbying expenditure. The company states that it complies with all annual lobbying disclosures required by law in the United States, however it does not provide a direct link to its disclosures nor does it provide information on its lobbying aims and activities outside the United States (if any).

There is evidence the company has a policy regulating the giving and receipt of gifts and hospitality, to ensure that such expenses are not used as vehicles for bribery. The company’s policy also explicitly addresses the risks associated with gifts and hospitality given to and/or received from public officials.

In addition, the company indicates that it has a separate policy document which provides further procedures and establishes financial limits for different sorts of gifts and promotional expenses. There is evidence that all gift and hospitality submissions above a designated financial threshold are recorded centrally in the company’s Business Courtesy Request System.

There is evidence that the company does not make corporate contributions to support political organisations, and this policy applies company-wide to all employees. There is evidence that the company is associated with a voluntary Political Action Committee (PAC) in the United States, which is managed and overseen by a board of directors.

Since the company is associated with a PAC in the United States, it receives a score of ‘0’ in line with the scoring criteria.

There is evidence that the company publishes information on the indirect donations made through its Political Action Committee (PAC) in the United States, by providing a direct link to the Federal Election Commission website where full details of such expenditure can be found. There is evidence that the company does not make corporate political contributions through direct expenditures.

There is evidence that the company has policies and procedures regulating its charitable activities, including set criteria for donations. The company also discloses some high-level data on the total amount of money donated to charitable and philanthropic initiatives, although there is no clear evidence that this data is published annually.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it publishes further details of its charitable donations, such as details of the recipient, amount, country of recipient and which corporate entity made the payment. It is also not clear that the company’s policy includes further controls to reduce the risk of bribery and corruption, such as conducting due diligence on recipients or requiring senior approval.

There is some evidence that the company has a company-wide policy and procedures covering lobbying. However, the company receives a score of ‘1’ because the policy regarding lobbying is unclear and does not provide a general description of standards of conduct and desired behaviours that lobbyists must adhere to. No specific control mechanisms are described. It is also unclear if the company’s policies covering lobbying also apply to board members and third parties.

The company publishes details of the topics on which it lobbies in the United States, without making a clear statement on lobbying activities in other jurisdictions. The information provided is accurate up to the last quarter of the previous reporting year. Also, the company does not provide supporting details of the aims and significant topics or the activities that it has carried out in support of specific legislative acts or campaigns.

The company provides limited details of lobbying expenditure, correct up to the last reported financial year. The company receives a score of ‘1’ because it provides no clear summary of total global lobbying expenditure or a summary of its expenditures on lobbying activities within the United States. Its global lobbying expenditure or lobbying activities outside of the United States are unclear.

There is evidence that the company has a policy and procedures on the giving and receipt of gifts and hospitality, which specifically addresses risks associated with gifts and hospitality given to/received from domestic or foreign public officials.

However, the company receives a score of ‘1’ because it does not clearly specify different financial or proportional limits or different approval procedures for different types of promotional expenses. Additionally, there is no clear evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

Based on publicly available information, the company has a policy prohibiting corporate political contributions. This policy applies to all employees, board members, third parties and other entities controlled by the company. However, the company’s US subsidiary has a Political Action Committee (PAC) and therefore the company receives a score of ’0’.

In publicly available evidence the company provides a link to the contributions made by its US subsidiary’s Political Action Committee. The information provided includes details of the recipient, amount, country of recipient and the name of the corporate entity that made the contribution. There is evidence indicating that the data is updated and released on an annual basis.

Based on publicly available information, there is evidence that the company has a policy and procedure covering both charitable donations and sponsorships to ensure that they are not used as vehicles for bribery and corruption. There is evidence that these procedures include criteria for donations, due diligence on recipients, and that donations are approved by senior management.

However, while the company publishes some information on its charitable contributions on an annual basis, this is not sufficiently detailed for a score of ‘2’. The company does not publish information on the amount of its donations for each recipient nor does it state which corporate entity made the payment.

Based on publicly available information, there is evidence that the company has a policy that defines lobbying and sets out the values and behaviours that constitute ‘responsible’ lobbying. It refers to certain standards of conduct and oversight mechanisms that apply to all lobbyists. There is evidence that this policy applies to all employees, board members and third parties lobbying on the company’s behalf.

Based on publicly available evidence, the company publishes a list of the topics on which it lobbies and its aims. The company provides specific aims and topics for each of its divisions. The evidence indicates that this information is provided for every jursidiction in which the company lobbies.

Based on publicly available information, there is evidence that the company provides details of its global lobbying expenditure. The data is correct up to the most recently reported financial year. Expenditure data is broken down by corporate entity, geography, internal lobbyists v external lobbyists v association lobbying. The evidence indicates that the figure reported represents the company’s expenditure on all lobbying activities worldwide. The company provides an explanation of how the figures in the data have been calculated.

Based on publicly available information, there is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality with clear procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits for the different types of promotional expense that employees may encounter, and there is evidence of an approval procedure. The policy also explicitly addresses the risks associated with gifts and hospitality given to and received from public officials. The company's policy includes a clear statement that all gifts and hospitality above certain thresholds are recorded in a dedicated register.

The company publishes a clear statement that it prohibits any form of political donations on its behalf. There is evidence that this position applies company-wide to all employees and board members.

The company publishes a clear statement that it does not make political contriubtions, and therefore it is exempt from scoring on this question.

There is evidence that the company has a policy covering both charitable donations and sponsorships, but there is no evidence that there are procedures which include measures to ensure donations are not used as vehicles for bribery and corruption, for example, by specifying criteria for donations, procedures for senior sign-off, or due diligence on recipients. The company also does not publish sufficient detail of the donations made.

The company publishes a statement that Korean law does not permit lobbying and that it complies with all applicable laws. The company receives a score of ‘1’ because it is not clear from publicly available information whether this approach also applies to any lobbing activities conducted in other jurisdictions. There is no publicly available evidence that the company publishes a clear policy to regulate its lobbying activities in other jurisdictions, nor does it publish a statement to indicate that it does not lobby outside Korea.

The company publishes a statement that Korean law does not permit lobbying and that it complies with all applicable laws. Since this statement applies to the main jurisdiction in which the company operates, it is exempt from scoring on this question; though it is noted that it is not clear from publicly available information whether the company conducts lobbying in other jurisdictions outside of Korea.

The company publishes a statement that Korean law does not permit lobbying and that it complies with all applicable laws. Since this statement applies to the main jurisdiction in which the company operates, it is exempt from scoring on this question; though it is noted that it is not clear from publicly available information whether the company conducts lobbying in other jurisdictions outside of Korea.

There is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. The company specifies financial limits for when employees receive any kind of economic benefit, which includes gifts and hospitality. The policy also addresses the risks associated with gifts given to public officials.

However, the company receives a score of ‘1’ because the policy does not specify financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

There is evidence that the company has a policy on political contributions, which allows for donations in some circumstances in the United States. The company therefore receives a score of ‘0’.

The company publishes information on its political contributions, including details of the recipient, amount, and state of the recipient. As identified in the previous question, the company only makes corporate political contributions in the United States and through the Lockheed Martin Corporation entity, so these disclosures can be interpreted as covering all political donations made by the company. There is evidence that the data is updated on an annual basis.

There is evidence that the company has policies covering both charitable donations and sponsorships. The company’s policy on charitable contributions sets financial limits, describes the type of organisations that are eligible to receive donations, and specifies a procedure to document, review and approve donations through the Corporate Contributions Committee. Similar provisions are outlined for sponsorships under the gifts, hospitality and business courtesies policy.

However, the company does not publish details regarding the in-kind or financial charitable contributions it makes on an annual basis, including the recipient, amount, country of recipient and which corporate entity made the payment.

There is evidence that the company has a policy on lobbying which applies to all employees, board members and agents acting on the company’s behalf. The company states that it is committed to responsible lobbying, and provides some examples of what this entails. The company indicates that it has specific controls and oversight mechanisms for its lobbyists, such as conducting audits of its lobbying reporting process and evaluations of registered lobbyists on an annual basis. The company also states that all employees, board members, contractors and contract laborers are required to adhere to the company’s Code of Conduct, which outlines the corruption risks associated with lobbying, throughout the lobbying process.

The company publishes some information on its lobbying topics and activities in the United States by making its quarterly federal lobbying reports publicly available on its website.

However, the company does not provide details about its broader public policy aims or positions. The company also does not publish any information about its lobbying activities outside of the US.

The company publishes some details of its lobbying expenditure, by making its federal quarterly lobbying reports up to the most recently reported financial year available on its website.

However, this expenditure data is not broken down into internal, external or association lobbyists and does not include an explanation of how these figures have been calculated. Furthermore, the company does not publish its lobbying expenditure worldwide.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with clear procedures designed to ensure that such promotional expenses are bona fide and not used as vehicles for bribery. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy also explicitly addresses the risks associated with gifts and hospitality given to and/or received from public officials by specifying different approval procedures. There is evidence that gift and hospitality approvals are recorded in a central register accessible to those responsible for oversight of the process.

There is evidence that the company has a policy on corporate political contributions. The company’s policy indicates that it may make political contributions when approved by the company’s Corporate Legal Department and providing that such donations are not used to obtain an improper advantage. In addition, there is evidence that that the company is associated with a Political Action Committee (PAC) in the United States.

Since the company does not prohibit political donations and is associated with a PAC, it receives a score of ‘0’ in line with the scoring criteria.

There is no publicly available evidence that the company discloses any details of its corporate political contributions or the donations made through its Political Action Committee (PAC).

There is no evidence that the company has a policy or procedure on charitable donations and sponsorships. The company publishes some information on the charitable organisations that it supports, but there is no evidence that it publishes a clear policy with controls to ensure donations are not used as vehicles for bribery and corruption, nor that it publishes full details of the donations made to these organisations.

There is some evidence that the company has a policy on lobbying, in line with its policy on political contributions. The company indicates that employees must obtain prior approval from the Corporate Legal Department before engaging in lobbying.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it defines responsible lobbying, nor that its policy outlines certain standards of conduct or specific oversight mechanisms that apply to all types of lobbyists. There is also no clear publicly available evidence that the policy applies to third parties and other entities controlled by the company.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is evidence that the company has a procedure on the giving and receipt of gifts and hospitality, which stipulates procedures to ensure that such promotional expenses are not used for bribery. The company’s policy addresses the risks associated with gifts and hospitality given to and received from domestic and foreign public officials. There is also some evidence that the company has different approval procedures for different types of promotional expenses.

However, the company receives a score of ‘1’ because there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register or database that is accessible to those responsible for oversight of the process. It is noted that the company has a gifts and entertainment policy but this does not appear to be publicly available.

There is no readily available evidence that the institute is able to make political contributions due to its nature as a non-profit, tax-exempt organisation in the United States of America.

There is no readily available evidence that the institute is able to make political contributions due to its nature as a non-profit, tax-exempt organisation in the United States of America.

The institute has a policy covering charitable donations, but it is not clear whether this also includes sponsorships. Furthermore, there is no evidence that these procedures include measures to ensure donations are not used as vehicles for bribery and corruption, for example, by specifying criteria for donations, procedures for senior sign-off, or due diligence on recipients. There is no evidence that the institute discloses its donations on an annual basis.

The institute has a policy that defines lobbying, and sets out the values and behaviours that constitute ‘responsible’ lobbying. However, the institute receives a score of ‘1’ because there is no evidence that it provides further details of its lobbying controls and guidelines to ensure these standards are upheld.

There is no evidence that the institute publishes any specific information on its lobbying aims, topics or activities. The institute publishes some information on its relationships with federal, municipal and state government but this does not cover specific aims or topics.

There is no evidence that the institute provides any details about its lobbying expenditure.

There is some evidence that the institute has a policy on the acceptance of gifts and hospitality, which addresses possible bribery and corruption risks and generally prohibits the acceptance of personal gifts by MIT employees.

However, the institute receives a score of ‘1’ because there is no evidence that the policy covers the giving of gifts, nor does it specify financial or proportional limits or different approval procedures for different types of promotional expenses. It also does not address the specific risks associated with gifts and hospitality given to/received from domestic or foreign public officials. There is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

Based on publicly available information, there is evidence that the company has a policy to not make any corporate political contributions. The company indicates that this applies to both financial and in-kind donations to any political parties, organisations or individual politicians. In the United States, there is evidence that that the company is associated with a Political Action Committee (PAC).

Since the company is associated with a PAC, it receives a score of ‘0’ in line with the scoring criteria.

The company publishes a clear statement that it does not make corporate political donations. However, the company is associated with a Political Action Committee (PAC) in the United States, and there is no evidence that it discloses any information on its PAC disbursements, either directly on its website or by including a link to federal disclosures.

There is evidence that the company has a detailed policy and procedure on charitable donations and sponsorships. The company’s policy includes criteria for donations and a requirement that all donations must be properly documented. However, the company receives a score of ‘1’ because there is no evidence that it publishes full details of its charitable donations and sponsorships, such as the name, amount and country of each recipient entity.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with clear procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The company's policy includes a clear statement that all gifts and hospitality above certain thresholds are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.

However, the company receives a score of ‘1’ because there is no publicly available evidence its policy addresses the risks associated with gifts and hospitality given to or received from domestic or foreign public officials.

Based on publicly available information, there is evidence that the company publishes a clear statement that it does not make corporate political contributions. The company states that it does not make financial or in kind contributions to political parties, campaigns or organisations, and indicates that this applies to all businesses worldwide.

The company states that it does not make political contributions under any circumstances and therefore it is exempt from scoring on this question.

Based on publicly available information, there is evidence that the company has a policy on charitable donations and sponsorships to ensure that such contributions are not used as vehicles for bribery and corruption. In addition, the company’s policy includes criteria for donations and sign-off from the Group Communications Director or Group Company Secretary. The company indicates that Corporate Responsibility Committee provdies overisght of this policy.

However, the company receives a score of ’1’ because there is no evidence that it publishes full details of all charitable contribtions made, such as details of the recipient, amount, country of recipient and which corporate entity made the payment.

Based on publicly available information, there is some evidence that the company that the company has a policy on lobbying, which applies to all employees, board members and third parties engaged in lobbying activities on the company’s behalf. The company states that all lobbying activities are overseen by its legal department.

However, there is no evidence that the company publishes further information such as guidelines or standards of conduct for all types of lobbyists which would constitute a responsible approach to lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any information on its global lobbying expenditure.

Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality. This policy recognises the possible corruption and bribery risks associated with gifts and hospitality, and stipulates that employees may only accept such promotional expenses when they are of nominal value. There is evidence that all gifts and hospitality given or received are recorded in a dedicated central register that is regularly audited and accessible to those responsible for oversight of the process. Although the company does not provide financial limits for gifts and hospitality, there is sufficient evidence that only nominal gifts may be accepted, so the company receives a score of ‘2’.

There is no readily available evidence that the organisation is able to make political contributions due to its nature as a non-profit, tax-exempt organisation in the United States of America.

There is no readily available evidence that the organisation is able to make political contributions due to its nature as a non-profit, tax-exempt organisation in the United States of America.

There is no evidence that the organisation has a policy and/or procedure covering both charitable donations and sponsorships. The organisation publishes some information about its charitable activities in its Corporate Social Responsibility Report; however, this does not include full details of all charitable donations made, including details of the recipient, amount, country of recipient and which entity made the payment.

There is no evidence that the organisation has a policy and/or procedure on lobbying.

There is no evidence that the organisation publishes any information on its lobbying aims, topics or activities.

There is no evidence that the organisation provides any details about its global lobbying expenditure.

There is no publicly available evidence that the organisation has a policy or procedure on gifts or hospitality.

There is some evidence that the company has a procedure on political contributions, to ensure that these payments are not used as vehicles for bribery and corruption.

However, where political contributions are permitted, there is no evidence to suggest that the company requires authorisation from an individual with legal expertise. In addition, there is no clear evidence that this procedure applies to all employees, board members, third parties and other entities controlled by the company.

There is some evidence that the company has a procedure on political contributions, to ensure that these payments are not used as vehicles for bribery and corruption. However, there is evidence that the company may make political contributions in some circumstances.

Where political contributions are permitted, there is no evidence to suggest that the company requires authorisation from an individual with legal expertise. In addition, there is no clear evidence that this procedure applies to all employees, board members, third parties and other entities controlled by the company.

There is no publicly available evidence that the company has a policy or procedure to regulate charitable donations and sponsorships.

There is no publicly available evidence that the company has a policy and/or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy or procedure on gifts and hospitality.

Based on publicly available information, there is evidence that the company has a policy on political contributions to ensure that these payments are not used as vehicles of bribery. There is evidence that the company’s Legal Department must pre-approve political contributions and that the policy – which is a part of the Group Global Code of Conduct – applies to all employees, including board members and group companies.

However, the company receives a score of ‘0’ because it does not clearly prohibit corporate political contributions. In addition, there is evidence that the company is associated – through a local subsidiary – with a Political Action Committee (PAC) in the United States.

There is evidence that the company publishes some details of its political contributions on an annual basis. The company publishes a high-level figure of the total value of its political donations for the most recently reported financial year, and there is some evidence to indicate that there was only one major recipient, which the company names in its public reports. Although the company does not explicitly provide this information, the recipient is understood to be located in Japan.

However, the company receives a score of ‘0’ because there is no evidence that it publishes details further of the contributions made by its subsidiary’s Political Action Committee (PAC) in the United States, nor does it provide a direct link to its official disclosures of this information.

Based on publicly available information, there is evidence that the company acknowledges the risks associated with charitable donations and that it publishes some high-level information on its annual expenditure on such activities.

However, there is no publicly available evidence that it has a clear policy or procedure in place with specific controls in place to reduce the possible bribery and corruption risks associated with charitable donations and sponsorships, such as due diligence on recipients. In addition, there is no evidence that the company publishes full details of its donations including details of the recipient, amount, country of recipient and which corporate entity made the payment.

Based on publicly available information, there is some evidence that the company has a policy on lobbying. There is evidence that employees who plan to engage in lobbying activities must request approval from the Legal Department, and that the policy applies to all employees, including board members and third parties acting on the company’s behalf.

However, the company receives a score of ‘1’ because there is no evidence that the company provides clear guidelines on what behaviours or standards of conduct are acceptable. There is also no evidence that the company has clear oversight mechanisms that apply to in-house, external and association lobbyists.

Based on publicly available evidence, the company publishes some information on the topics on which it lobbies. However, there is no evidence that it publishes further details of its lobbying aims and the activities that were carried out in a relevant period. It is also not clear from publicly available information whether these aims apply to all jurisdictions in which the company lobbies, or primarily to the jurisdiction in which it is headquartered.

There is no evidence that the company publishes information on its global lobbying expenditure.

Based on publicly available information, there is evidence that the company has a policy on gifts and hospitality to prevent bribery and corruption. The company’s policy indicates that gifts must be reasonable and states that employees should avoid gifts in cash or from third parties in connection with work activities.

However, it is not clear form publicly available information that the company’s policy specifies financial or proportional limits or different approval procedures for different types of promotional expenses, nor is there evidence that it addresses the risks associated with gifts and hospitality given to or received from a domestic or foreign public official. There is also no evidence that gifts and hospitality in a dedicated central register that is accessible to those responsible for oversight of the process.

There is no evidence that the company has a policy regarding commercial political contributions.

There is no evidence that the company discloses details of its political contributions.

There is no evidence that the company has a policy or procedure covering both charitable donations and sponsorships.

There is no evidence that the company publishes a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

There is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality, which also addresses the risks associated with gifts and hospitality given to and received from domestic or foreign public officials.

The company, however, receives a score of ‘1’ because its policy does not specify financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

There is evidence that the company has a policy that prohibits support of political parties or politicians, which applies to all employees and board members within the organisation. However, the company receives a score of ‘0’ because although it prohibits corporate political contributions, there is evidence that the company is associated with a Political Action Committee (PAC) in the USA.

There is no evidence that the company publishes details of its direct or indirect political contributions on an annual basis. The company indicates that its Political Action Committee in the USA may support political parties, but there is no evidence that the company publishes any details of these donations on its own website.

There is evidence that the company has a procedure covering charitable donations and sponsorships, which includes sign-off from a three-person committee, a formal contract and certain accounting standards. There is evidence that this procedure applies to all legal entities and business units within the company.

However, the company receives a score of ‘1’ because it does not publish details of its sponsorships in sufficient detail. The company publishes percentages of its donations per sector, but there is no evidence that this data is updated on an annual basis and it does not include details such as the recipient, amount, country of recipient or which corporate entity made the payment.

Based on publicly available information, there is evidence to indicate that the company requires all lobbyists acting on its behalf to follow the standards of behaviour outlined in its Ethical Code of Conduct. There is evidence that this applies to all employees, board members and third parties engaged in lobbying on the company’s behalf.

However, the company receives a score of ‘1’ because there is no evidence that the company has a specific policy which defines lobbying and stipulates specific standards of conduct for those engaged in lobbying activities. There is no evidence that the company has specific controls or procedures in place for lobbyists, such as oversight mechanisms or other guidelines.

There is no evidence that the company publishes any information about its lobbying aims, topics or activities.

There is no evidence to indicate that the company publishes any details about its global lobbying expenditure.

Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality. The company’s policy specifies a financial limit for all promotional expenses – noting that any gifts above that level which cannot be refused should immediately be reported to a superior – and its policy also addresses the risks associated with gifts and hospitality given to/received from public officials. The company does not state that all gifts and hospitality above a certain threshold are recorded in a dedicated central register, the company’s strict and low financial threshold on promotional expenses is sufficient to merit a score of ‘2’.

The company publishes a clear statement that it does not make corporate political contributions.

There is evidence that the company has a policy and procedure covering both charitable donations and sponsorships. Both charitable activities and sponsorships undertaken on the company’s behalf must be reviewed by the Legal Department and the Head of Group Ethics, Compliance and Governance. There is evidence that due diligence is conducted on recipients and that the company specifies criteria for donations.

However, the company does not publish details of the charitable donations and sponsorships it makes.

Based on publicly available information, the company has some procedures on lobbying. The company indicates that it ensures that lobbyists acting on behalf of Naval Group conform with regulations on lobbying activities everywhere they are carried out, and in some instances complete transparency and declaration obligations.

However, lobbying is not broadly defined, the company does not outline behaviours comprising responsible lobbying practices, and there is no evidence that the policy applies company-wide to all employees, board members and third parties engaged in lobbying activities on the company’s behalf. Specific controls and guidelines for lobbying are unclear.

The company does not publish any information on its lobbying aims, topics or activities.

The company does not provide any details about its global lobbying expenditure.

There is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality with clear procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy also explicitly addresses the risks associated with gifts and hospitality given to and/or received from domestic and foreign public officials, by specifying a different financial threshold for approvals. The company's policy includes a clear statement that all gifts and hospitality above certain thresholds are recorded in the company’s compliance software. This information is reviewed by the Group Ethics, Compliance and Governance Department.

There is evidence that the company has a clear statement that it prohibits political contributions. There is evidence that corporate political contributions – whether made directly or indirectly, or whether made by the company itself or by any other entity or individual acting on the company's behalf – are prohibited under any circumstance.

The company states that it makes no political contributions and is therefore exempt from scoring on this question.

The company has a clear policy and set of procedures covering both charitable donations and sponsorships, whether made directly or through corporate foundations, to ensure that such donations are not used as vehicles for bribery and corruption. The policy stipulates measures to ensure this through procedures for senior sign-off, criteria for donations and due diligence on recipients. The company publishes details and a description of the non-profit and charitable organisations it has supported in the most recent reporting year, which is updated annually. This is accompanied by a sum total of donations made.

The company receives a score of ‘1’ because its published data on charitable donations does not include details such as a breakdown of individual sums donated to each of the organisations listed. The company also does not provide clear information on the country of each recipient organisation.

There is some evidence that the company has a policy and procedures on lobbying. This includes evidence that the company requires that due diligence is conducted on external lobbyists before hiring them, as well as during the business relationship. The company’s anti-corruption policy gives a brief description of lobbying, which emphasises the legitimacy of the activity, whilst also acknowledging the corruption risk it presents.

However the company scores ‘1’ because beyond stating that lobbying activities must adhere with laws and regulations, the policy doesn’t mention certain standards of conduct or specific oversight mechanisms that apply to lobbying activities. Additionally, the company’s policy only makes reference to external lobbyists and third parties, and does not mention internal lobbyists, or specify that the standards outlined apply to all employees and directors.

There is no evidence that the company publishes information on its lobbying aims, topics or activities.

The company states that in the most recent reporting year it did not contract any lobbying services, however this suggests that it relates to externally contracted activities only. It is therefroe not sufficiently clear that it did not conduct any lobbying activities at all, and so a score of ‘0’ applies.

There is no evidence that the company provides details about its global lobbying expenditure.

Although the company states that in the most recent reporting year it did not contract out any lobbying services, it is not sufficiently clear that it did not conduct any lobbying activities at all, and so a score of ‘0’ applies.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with clear procedures designed to ensure that such promotional expenses are not used as vehicles for bribery and corruption. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. There is evidence that the company also addresses the risks associated with gifts given to and/or received from public officials. The company's policy includes a clear statement that all gifts and hospitality above certain thresholds are recorded in a dedicated register that is accessible to the Chief Compliance Officer and Compliance Committee, who are responsible for oversight of the process.

There is evidence that the company has a policy to follow all relevant local laws and regulations when making political contributions. Since there is no evidence that the company prohibits or places controls on political donations, the company receives a score of ‘0’.

There is no evidence that the company discloses details of its political contributions.

There is no evidence that the company has a policy or procedure covering both charitable donations and sponsorships

There is no evidence that the company has a policy or procedure on lobbying.

There is no evidence to suggest that the company publishes details of the aims and topics of the lobbying activities it carries out.

There is no evidence that the company provides any details about its global lobbying expenditure.

Based on public information, there is evidence that the company has a policy on gifts and hospitality that addresses the risks associated with gifts and hospitality given to domestic and foreign public officials.

However, the policy does not specify financial or proportional limits or different approval procedures for different types of promotional expenses and there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

The company publishes a clear statement that it prohibits corporate political contributions.

The company prohibits corporate political contributions and therefore receives ‘N/A’ for this question.

There is evidence that the company has a policy and procedure covering both charitable donations and sponsorships to ensure donations are not used as vehicles for bribery and corruption.

However, the company does not publish any details of its donations.

The company has a policy and procedure that defines lobbying and sets out the values and behaviours that constitute ‘responsible’ lobbying. The company outlines certain standards of conduct and oversight mechanisms that apply to all of the company’s employees and partners. It provides clear guidelines on what behaviours are acceptable and unacceptable and on the corruption risks associated with lobbying.

The company does not publish any information on its lobbying aims, topics or activities on its website. The company states that it transmits a register of lobbying activity to the French Authority for the Transparency of Public Life, but this is not provided on the company’s website nor is there a direct link to the material.

There is evidence that the company provides limited details about its lobbying expenditure in France on the website of the French Authority for the Transparency of Public Life. However, this information is not published to its own website nor does the company provide a direct link to the relevant information.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality. This addresses the risks associated with gifts and hospitality given to and/or received from domestic and foreign public officials. The company indicates that gifts and hospitality must be recorded.

However, the policy does not specify financial or proportional limits or different approval procedures for different types of promotional expenses and there is no evidence that gifts and hospitality are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

There is evidence that the company has a policy on corporate political contributions, which indicates that such activities are restricted but permissible in certain circumstances. The company states that it has not made any political contributions since 2012, but indicates that any such donations would require board-level approval and follow all relevant laws and regulations. In addition, there is evidence that the company is associated with a Political Action Committee (PAC) in the United States, which is overseen by an executive-led committee.

Since the company does not clearly prohibit political donations and is associated with a PAC, it receives a score of ‘0’ in line with the scoring criteria.

The company publishes a clear statement that it has not made any corporate political contributions since 2012. In addition, there is evidence that details of the contributions made by the company’s Political Action Committee (ENGPAC), as well as payments made by the company to trade associations, are published on the company’s website and disclosed as required to the U.S. Federal Election Commission (FEC).

There is evidence that the company has a policy on charitable donations and sponsorships. There is evidence that these policies include measures to ensure that these payments are not used as vehicles for bribery and corruption, for example by stipulating criteria for donations and conflict of interest reviews.

However, the company receives a score of ‘1’ because there is no evidence that it publishes details of all charitable donations and sponsorships made, including details of the recipient, amount, country of recipient and which corporate entity made the payment.

Based on publicly available information, there is some evidence that the company has a procedure on lobbying. The company states that any engagement in lobbying requires prior written approval from the company’s management team, which includes its law department.

However, the company receives a score of ‘1’ because there is no clear evidence that its policy defines responsible lobbying, nor is there evidence that it stipulates certain standards of conduct or specific oversight mechanisms that apply to all types of lobbyists. In addition, it is not clear from publicly available information that its procedures apply to all employees, board members and third parties engaged in lobbying activities on the company’s behalf.

The company publishes some information on its lobbying topics and activities in the United States by making its quarterly federal lobbying reports publicly available via a direct link on its website.

However, the company does not provide further details about its broader public policy aims or positions. Although the company indicates that it does not generally engage in lobbying outside of the United States, there is no evidence that the company publishes any information on the activities that it has conducted in other jurisdictions nor does it clearly state that it has not engaged in lobbying elsewhere in the most recently reported financial period.

There is evidence that the company publishes summary information of its lobbying expenditure in the United States by making its quarterly federal lobbying reports publicly available via a direct link on its website.

However, the company receives a score of ‘1’ because this expenditure data is not broken down into internal, external or association lobbyists and does not include an explanation of how these figures have been calculated. Furthermore, although the company indicates that it does not generally engage in lobbying outside of the United States, there is no evidence that the company publishes any information on any expenditure that relates to such activities nor does it clearly state that it has not engaged in lobbying elsewhere in the most recently reported financial period.

Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with procedures designed to ensure that such promotional expenses are not used as vehicles for bribery. There is evidence that the policy places proportional limits on different types of promotional expenses. The company also states that in general employees must not offer or accept gifts and hospitality from government officials.

However, the company receives a score of ‘1’ because there is no clear evidence that all gifts and hospitality above a certain threshold are held in a dedicated central register which is accessible to those responsible for oversight of the process. The company indicates that it maintains a central register of business courtesies for non-U.S. government officials that exceed a certain limit, but it is not clear that the same requirements apply for recipients in the U.S. or outside of government.

There is evidence that the company has a policy on political contributions, which generally prohibits such donations but indicates that they may be permissible under certain circumstances. In such cases, the company states that contributions must receive authorisation from the Board of Directors. There is evidence that this policy applies to all employees, board members, third parties and other entities controlled by the company.

However, the company receives a score of ‘0’ because there is no evidence that it has a blanket prohibition on political contributions.

There is no evidence that company discloses any details of its political contributions.

There is some evidence that the company has a policy covering both charitable donations and sponsorships, whether made directly or through corporate foundations. There is evidence that the company has internal procedures in place to ensure that such donations are not used to improperly influence business decisions, such as appropriate due diligence, documentation and sign-off.

However, the company receives a score of ‘1’ because there is no evidence that it publishes any details of its charitable donations or sponsorships, such as details of the recipient, amount, country of recipient and which corporate entity made the payment.

There is no publicly available evidence that the company has a policy on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, which includes procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. The policy also explicitly addresses the risks associated with gifts and hospitality given to and/or received from domestic and foreign public officials. The company's policy includes a statement that all gifts and hospitality above certain thresholds are recorded in a dedicated register.

However, the company receives a score of ‘1’ because there is no evidence that its policy specifies financial or proportional limits, or different approval procedures for different types of promotional expenses.

There is some evidence that the company has a policy on political contributions, indicating that such donations are permitted in line with local laws and company regulations. There is no evidence that authorisation from an individual with legal expertise is required.

There is no evidence that the company publishes any details of its political contributions.

Based on publicly available information, there is evidence that the company has a procedure covering charitable donations. However, there is no evidence that this policy includes measures to ensure donations are not used as vehicles for bribery and corruption, for example, by specifying criteria for donations, procedures for senior sign-off, or due diligence on recipients. There is also no evidence that the company addresses or has measures in place to regulate sponsorships, nor is there evidence to indicate that the company does not engage in such contributions.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

The company states that it has a policy on the giving and receipt of gifts and hospitality, but it receives a score of ‘0’ because it does not make details about the contents of this policy publicly available. There is no evidence that the policy specifies financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no evidence that it addresses the risks associated with gifts and hospitality given to or received from domestic or foreign public officials, nor is there evidence that gifts and hospitality over a certain threshold are recorded in a central register that is accessible to those responsible for oversight of the process.

There is evidence that the company permits political contributions in some instances, and has a political action committee. The company therefore receives a score of ‘0’.

The company does not disclose any details of its political contributions on its website.

While the company discloses some information on its charitable contributions, there is no evidence that the company has a policy and/or procedure covering both charitable donations and sponsorships.

There is evidence that the company has a policy on lobbying, which includes guidelines on responsible lobbying activities. This policy applies company-wide to all employees, board members and third parties engaged in lobbying activities on the company’s behalf. The company provides details on certain standards of conduct comprising responsible lobbying behaviour and describes oversight mechanisms, which apply to all types of lobbyists.

The company does not publish any information on its lobbying aims, topics or activities on its website.

The company does not publish any information on its global lobbying expenditure on its website.

There is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. The policy addresses the risks associated with gifts and hospitality given to public officials. The company also states that all gifts and hospitality expenditures must be documented.

However, the company does not specify financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no evidence that all gifts and hospitality received, above a certain threshold, are recorded in a centrally held register, which is accessible to those responsible for oversight of the process. Although the company references a separate gifts and entertainment policy, it is not publicly available.

There is evidence that the company prohibits corporate political contributions or any other monetary benefit to political parties, candidates or individuals holding office. There is evidence to indicate that this policy applies across the organisation.

The company states that it makes no political contributions and is therefore exempt from scoring on this question.

Based on publicly available information, there is evidence that the company has a policy and procedure covering both charitable donations and sponsorships. There is evidence that the company specifies criteria for donations. There is also evidence that the company publishes information on its major charitable donations and sponsorships for 2018; however, it is not clear whether this represents all of the company’s donations nor whether this list is updated on an annual basis.

Based on publicly available information, there is evidence that the company has a policy and procedure on lobbying, which includes guidelines for responsible lobbying behaviour and outlines standards of conduct. There is evidence that the policy applies to all employees and board members.

However, there is no evidence that the policy mentions specific oversight mechanisms that apply to all types of lobbyists. There is evidence that the company has a document entitled “Instructions on Lobbying and Opinion Forming” which may contain further information on its policy, but this document does not appear to be publicly available.

There is evidence that the company publishes a list of the topics on which it lobbies, including a description of its core positions, their relevance to the company and stakeholders, and the activities it carries out. There is evidence to indicate that these points represent the aims and topics on which the company conducts lobbying activities across its operations. In addition, there is evidence that this list is updated regularly.

The company publishes some information on its lobbying expenditure to indicate that it has not engaged any lobbyists in the past two years and therefore it has not made any lobbying expenditure to external parties.

However, the company receives a score of ‘1’ because it does not publish full details of its global lobbying expenditure, for example the amount spent on internal lobbyists and lobbying activities. There is also no evidence that the company publishes its spending on association lobbying, nor a statement that it does not engage in such activities.

Based on publicly available information, there is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. There is evidence that the policy addresses the risks associated with gifts and hospitality given to public officials, and that it establishes financial limits for different types of gifts and hospitality. There is evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register accessible to those responsible for oversight of the process

There is evidence that the company generally prohibits political contributions, but these are permissible in certain circumstances. The company also operates a Political Action Committee.

The company does not disclose on its website any details of political contributions made by the company or its PAC.

Although the company publishes some information regarding its charitable contributions, there is no evidence that the company has a policy and/or procedure covering both charitable donations and sponsorships. There is also no evidence that the company has measures to ensure donations are not used as vehicles for bribery and corruption, for example, by specifying criteria for donations, procedures for senior sign-off, or due diligence on recipients.

Based on public information, there is some evidence that the company has a policy on lobbying. Employees must coordinate with the Legislative Affairs Department before engaging in activity which might constitute lobbying.

However, the company does not define lobbying or responsible lobbying in publicly available evidence. There is no mention of certain standards of conduct or specific oversight mechanisms that apply to all types of lobbyists. It is also unclear based on publicly available evidence whether the policy applies to third parties and other entities controlled by the company.

The company does not publish any information on its lobbying aims, topics or activities on its website.

The company does not publish any information on its global lobbying expenditure on its website.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality with procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits, along with an approval procedure for different types of expenses. The policy also explicitly addresses the risks associated with gifts and hospitality given to or received from domestic and foreign public officials.

However, there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

Based on publicly available information, there is no evidence that the company has a policy to regulate or prohibit corporate political contributions.

There is no evidence that the company publishes details of its corporate political contributions.

There is no evidence that the company has a policy or procedure covering charitable donations or sponsorships.

Based on publicly available information, there is no evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy or procedure on gifts and hospitality.

Based on publicly available information, the company prohibits all corporate political contributions. There is evidence to indicate that this statement applies to all circumstances and clearly prohibits any contributions made in the company’s name.

The company clearly states that it does not make political contributions and is therefore exempt from scoring on this question.

There is evidence that the company has a clear policy covering both charitable donations and sponsorships, to ensure that such donations are not used as vehicles for bribery and corruption. There is evidence this includes specifying criteria for donations and procedures for senior sign-off.

However, the company receives a score of ‘1 because there is no evidence that the company publishes full details of all charitable donations made, such as details of the name, amount and country of the recipient entity.

There is evidence that the company has a clear policy not to engage in any lobbying activities. There is evidence that this policy applies to all employees, board members and consultant lobbyists.

The company clearly states that it does not engage in lobbying activities and is therefore exempt from scoring on this question.

The company clearly states that it does not engage in lobbying activities and is therefore exempt from scoring on this question.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality with clear procedures designed to ensure that such promotional expenses are not used as vehicles for bribery and corruption. There is evidence that this policy establishes financial limits for the different types of promotional expense that employees may encounter. There is also evidence that the policy addresses the risks associated with gifts and hospitality given to and/or received from domestic and foreign public officials.

However, the company receives a score of ‘1’ because the approval procedures for different types of promotional expenses are not clear from the available evidence. There is also no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.

There is no publicly available evidence that the company has a policy on corporate political contributions.

There is no evidence that the company publishes any details of its political contributions.

There is no publicly available evidence that the company has a policy and/or procedure covering charitable donations or sponsorships.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy on gifts or hospitality.

The company publishes a statement that it does not make political donations.

The company indicates that it does not make political donations.

There is evidence that the company has a clear policy covering both charitable donations and sponsorships, whether made directly or through corporate foundations, to ensure that such donations are not used as vehicles for bribery and corruption. There is evidence that the policy includes measures to ensure this, for example, by specifying criteria for donations, procedures for senior sign-off, or due diligence on recipients.

The company does not publish sufficient detail concerning donations made, such as the amounts donated.

The company makes reference to an Engagement with Politicians and Political Donations Instruction Document, however this is not available on the company’s website. Therefore, there is no publicly available evidence that is sufficiently detailed in relation to the company’s policy and/or procedure on lobbying to satisfy the requirements of score '1'.

The company does not publish any information on its lobbying aims, topics or activities.

The company does not provide any details about its global lobbying expenditure.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality with clear procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy also explicitly addresses the risks associated with gifts and hospitality given to and/or received from domestic and foreign public officials, by specifying a different financial threshold. The company's policy includes a clear statement that all gifts and hospitality above certain thresholds are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

The company publishes a clear statement that it prohibits corporate political contributions, whether made directly or indirectly. Since this evidence appears in the company-wide Anti-Corruption Policy, it is understood that this applies to all employees of the company including directors, third parties, suppliers and joint venture partners.

There is evidence that the company prohibits corporate political contributions so the company is exempted from scoring on this question.

The company publishes a clear statement that it does not make charitable donations. However, the company receives a score of ‘0’ because there is no evidence that it has a policy or procedure covering sponsorships, nor does the company publish a clear statement that it does not make sponsorships.

There is evidence that the company outlines certain standards of conduct and oversight mechanisms that apply to all types of business partners, including lobbyists. The company states that it only conducts lobbying in the U.S., where it observes all the required registration and licencing conditions for lobbyists; however, there is no publicly available evidence that it has a policy that defines lobbying or responsible lobbying and that applies to all employees, board members and third parties lobbying on the company’s behalf.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is evidence that the company has a policy on the giving of gifts and hospitality to domestic and foreign public officials, with procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may give to public officials.

There is evidence that all gifts and hospitality given are recorded in a computerized system for managing business courtesies, however the company receives a score of ‘1’ because it is not explicit whether this is accessible and reviewed by those responsible for oversight of the process. Furthermore, there is no publicly available evidence that the company’s policy addresses gifts and hospitality given to individuals other than public officials, nor does it cover any procedures for the receipt of gifts and hospitality by company employees.

Based on publicly available information, there is evidence that the company has a policy on political contributions. The company states that it has not made direct corporate political donations since 2015 and does not intend to do so in the future.

However, the company scores ‘0’ because there is evidence that contributions may be permissible in certain circumstances with appropriate authorisation. There is also evidence that the company is associated with a Political Action Committee (PAC) in the United States.

The company states publicly that it has not made any corporate political contributions since 2015. In addition, there is evidence that the company publishes details of the contributions and disbursements made through its Political Action Committee (PAC) in the United States, by providing this information on its website. There is evidence that this information includes details of the recipient, amount and state of the recipient and that it is updated and released on a regular basis.

Based on publicly available information, there is evidence that the company has policies covering both charitable donations and sponsorships to ensure that they are not used for corrupt purposes. There is evidence that the company’s policies include measures to ensure proper oversight.

The company discloses some details of both its charitable contributions and sponsorship activities but receives a score of ‘1’ because it does not publish comprehensive details of these donations, including data on the amount donated, the recipient entity and the corporate entity which made the donation.

Based on publicly available information, there is evidence that the company has a policy on responsible lobbying which applies to all employees, board members and any third parties engaged in lobbying activities on the company’s behalf. The company indicates that its Public Policy and Corporate Responsibility Committee is responsible for reviewing and providing oversight of all lobbying activities. There is evidence that the company conducts due diligence on lobbyists, which are required to act in accordance with its Code of Conduct.

There is evidence that the company discloses some details about its lobbying activities, by providing a direct link to its quarterly Federal Lobbying Reports. These reports indicate the legislative topics on which the company conducts lobbying in the United States.

However, the company receives a score of ‘1’ because it does not provide details about its broader public policy aims or positions. The company also does not publish any information about its lobbying activities outside of the United States.

There is evidence that the company publishes some details of its lobbying expenditure, by providing direct links on its website to its Federal Lobbying Reports up to the most recently reported financial year. This expenditure data is broken down by corporate entity, geography, and internal, external and association lobbying.

However, the company receives a score of ‘1’ because the data provided only accounts for company’s lobbying activities in the United States and therefore it is not clear that this covers all of the company’s lobbying activities in all applicable jurisdictions.

Based on publicly available information, there is evidence that the company has policies and procedures on gifts and hospitality, which include clear procedures designed to ensure that promotional expenses are bona fide and not used for bribery. The company’s policies establish financial limits and approval procedures for the different types of promotional expense that employees may encounter.

In addition, there is evidence that the company’s policies address the risks associated with gifts and hospitality given to and/or received from domestic and foreign public officials by establishing different financial thresholds. The company indicates that all gifts and hospitality above certain thresholds are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.

There is evidence that the company permits political contributions, and therefore receives a score of ‘0’.

There is no evidence that the company discloses details of its political contributions.

There is some evidence that the company has a policy covering both charitable donations and sponsorships.

However, the company does not publish sufficient detail of the donations to receive a score of ‘2’.

There is evidence that the company has a policy on lobbying.

However, the company sores ‘1’ as there is no evidence that it defines lobbying or the practices comprising responsible lobbying. The company mentions that consultants and lobbyists are subject to high compliance standards, however, there is no evidence that the company publishes specific details of these standards or controls, or information about oversight mechanisms that apply to all types of lobbyists.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

There is some evidence that the company has a policy on the giving and receipt of gifts and hospitality to ensure they are not used for bribery. This policy refers to the risks associated with gifts and hospitality given to public officials. The policy also specifies financial or proportional limits or different approval procedures for different types of promotional expenses.

However, there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

There is no evidence that the company has a policy on corporate political contributions.

There is no evidence that the company discloses full details of its political contributions.

There is evidence that the company has a policy covering donations. However, there is no evidence that these policies include measures to ensure donations are not used as vehicles for bribery and corruption, for example, by specifying criteria for donations, procedures for senior sign-off, or due diligence on recipients.

There is no evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy or procedure on gifts or hospitality.

The company publishes a statement that it prohibits corporate political contributions, however, it indicates that it does have a Political Action Committee in the US. It therefore receives a score of ‘0’.

The company does not publish information about the recipients of the donations made by its PAC.

There is evidence that the company has a policy and procedure covering both charitable donations and sponsorships. The company’s definition of charitable contributions includes financial donations, as well as employee time and in-kind gifts, and it provides a list of legitimate reasons for making these types of contributions. There is clear evidence that the company’s policy on charitable contributions and sponsorships includes specific controls to prevent bribery and corruption, such as Ethics and Compliance Officer approval, due diligence on beneficiaries and detailed record keeping.

However, the company receives a score of ‘1’ because – despite stating in its ‘Our Group Policies’ document that it reports this information on its website – there is no publicly available evidence that the company publishes details of its global contributions.

There is evidence that the company has a policy and procedure on lobbying which applies company-wide to all employees, board members and third parties engaged in lobbying on the company’s behalf. The company recognises lobbying as a corruption risk and defines lobbying broadly and states that anyone undertaking lobbying activities on behalf of the company must first undergo risk-based due diligence and also act with honesty, integrity and transparency. There is also evidence that all lobbying activities require prior authorisation and oversight from the Government Relations team. The company indicates that it only contracts one external party for lobbying services.

However, the company receives a score of ‘1’ because it does not provide any further guidelines on the behaviours that constitute ‘responsible’ lobbying, beyond compliance with local laws, regulations and the company’s own policies.

The company publishes limited details of the topics on which it lobbies.

However, the information disclosed lacks supporting details of the aims and significant topics or the activities that were carried out.

The company does not publish any details about its global lobbying expenditure on its website.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality with clear procedures designed to ensure that such promotional expenses are not used as vehicles for bribery and corruption. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy also explicitly addresses the risks associated with gifts and hospitality given to and/or received from public officials by specifying different financial thresholds and approval procedures. The company's policy includes a clear statement that all gifts and hospitality above certain thresholds are recorded in a dedicated register or central depository that is accessible to the Ethics and Compliance team.

There is no evidence that the company has a policy or procedure covering political contributions.

There is no evidence that the company discloses details of its political contributions.

There is evidence that the company has policies covering both charitable donations and sponsorships, and that it has some procedures in place, such as a formal application process and sign-off by the Board of Directors, to ensure that such donations are not used as vehicles for bribery and corruption. The company publishes some information in its Annual Report in relation to the types of charitable causes it supports; however, there is no evidence that the company publishes details such as the amount donated to individual projects or which corporate entity made the payment.

There is no evidence that the company has a policy and/or procedure on lobbying.

There is no evidence that the company publishes information on its lobbying aims, topics or activities.

There is no evidence that the company provides details on its global lobbying expenditure.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with clear procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. The company’s publicly available policy establishes an approval procedure for the different types of promotional expense that employees may encounter and all gifts and hospitality must be recorded in a dedicated register accessible to those responsible for oversight of the process. The company states that employees should adhere to regulations governing gifts to state employees, however there is no evidence that it addresses the risks associated with gifts given to or received from foreign public officials.

It is noted that the company states in its 2017 Annual Report that it now prohibits the giving and receiving of gifts and hospitality, however there is no evidence that this has been reflected in its publicly available policies.

The company states that it is a group-wide policy that no political donations can be made in order to receive commercial gain. However, it is not sufficiently clear that the company completely prohibits political contributions in all circumstances, or what mechanisms are in place to ensure that no payments are used as vehicles for bribery and corruption.

There is no evidence that the company discloses details of its political contributions.

The company states that it has a policy that does not permit charitable and sponsorship contributions to be used as vehicles for corruption or for illegitimate purposes. However, the company receives a score of ‘0’ because there is evidence that the company does conduct charitable activity, but there is no evidence of measures to ensure that donations are not used as vehicles for bribery and corruption, for example, by specifying criteria for donations, procedures for senior sign-off, or due diligence on recipients.

There is no evidence that the company has a policy on responsible lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality. The policy specifically addresses the risks associated with gifts and hospitality given to/received from domestic or foreign public officials.

However, there is no evidence that the company specifies financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no clear evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

Based on publicly available information, there is evidence that the company has a policy on corporate political contributions. The company publishes a clear statement that it does not make any contributions to political parties. It is noted that in the Swiss political system, it is only possible to make contributions to political parties and not to individuals.

The company publishes a clear statement that it does not make any contributions to political parties and it is therefore exempt from scoring on this question.

There is evidence that the company has a policy and procedure on both charitable donations and sponsorships. This policy includes measures to ensure that donations are not used as vehicles for bribery and corruption, by specifying criteria for donations and procedures for senior sign-off.

However, the company receives a score of ‘1’ because there is no evidence that it publishes details of its charitable donations and sponsorships on an annual basis, such as details of the recipient, amount, country of recipient and which corporate entity made the payment.

There is no publicly available evidence that the company has a policy on lobbying, nor does the company publish a statement that it does not engage in such activities.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality with clear procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy clearly addresses the risks associated with gifts and hospitality given to and received from domestic and foreign public officials by requiring a different approval procedure.

In addition, the company indicates that all gifts and hospitality offerings above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.

In publicly available evidence the company states that it does not provide political donations with the aim of obtaining or maintaining a commercial advantage. However, the company receives a score of ‘0’ because the company’s statement does not make it explicitly clear that it prohibits all forms of political donations. In addition, based on publicly available information, there is no evidence of control or oversight mechanisms related to the company’s political donations, such as a requirement for approval by an individual with legal expertise.

Based on publicly available information, there is no evidence that the company discloses details of its political contributions.

Based on publicly available information, there is no evidence that the company has a policy and/or procedure covering both charitable donations and sponsorships.

Based on publicly available information, there is no evidence that the company has a policy and/or procedure on lobbying.

There is no evidence that the company publishes information on its lobbying aims, topics or activities.

There is no evidence that the company publishes details about its global lobbying expenditure.

Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. There is evidence that this policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. There is evidence that all gifts and hospitality are recorded in a dedicated register that is accessible to those responsible for oversight of the process.

However, there is no evidence that the company explicitly addresses the corruption risks associated with gifts and hospitality given to and/or received from domestic and foreign public officials and therefore it does not fulfil the criteria to score ‘2’.

The company publishes a clear statement that it does not make any contributions to political parties or activities.

There is some evidence that the company has a policy and procedure covering both charitable donations and sponsorships. The company’s policy provides details of procedures to prevent the risk of bribery and corruption, such as senior sign-off requirements and reporting obligations.

However, the company receives a score of ‘1’ because it does not publish sufficient detail of the donations made, including details of the recipient, amount, country of recipient and which corporate entity made the payment.

There is evidence that the company has a policy on lobbying, which includes a definition of lobbying. The policy mentions specific oversight mechanisms that apply to all types of lobbyists and there is evidence that this applies company-wide. The company indicates that it includes anti-bribery and compliance clauses in its contracts with lobbyists.

However, there is no evidence that the company has further guidelines that inform responsible lobbying behaviour or expected standards of conduct. Additionally, it is not clear that the lobbying policy applies to employees conducting lobbying activities on the company’s behalf.

There is no evidence that the company publishes any detailed information on its lobbying aims, topics or activities. The information it does provide is insufficient for it to receive a score of ‘1’.

There is no publicly available evidence to indicate that the company publishes any details about its global lobbying expenditure.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with clear procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy also explicitly addresses the risks associated with gifts and hospitality given to and/or received from public officials. The company's policy indicates that all gifts and hospitality are recorded. Where gifts cannot be politely refused they are held in a gift repository.

The company publishes a clear statement that it prohibits corporate political contributions.

There is evidence that the company has a clear policy and procedure covering both charitable donations and sponsorships, whether made directly or through corporate foundations. There is evidence that the company has measures in place to ensure that such expenditures are not used as vehicles for bribery and corruption. For example, the company specifies criteria for acceptable donations, conducts due diligence on recipients and outlines procedures for senior compliance officer sign-off based on financial thresholds.

However, the company receives a score of ‘1’ because it only publishes limited details on its charitable contributions and sponsorships. Although its 2018 Registration Document contains some details, it does not list the details of the recipient, amount, country of recipient and which corporate entity made the payment.

There is evidence that the company has a policy and procedure that defines lobbying and sets out the values and behaviours that constitute the spirit of ‘responsible’ lobbying. The company states that all internal and external lobbyists must comply with the standards of ethical behaviour outlined in its Code of Conduct. This policy applies to all employees and third parties lobbying on the company’s behalf, and states that breaches could result in disciplinary action or termination of contract. The company’s Responsible Lobbying Charter applies to the Safran Group, which has been understood to include all employees and board members.

The company does not publish any information on its lobbying aims, topics or activities. The company commits to complying with French law requiring it to declare lobbying activities to the French High Authority for Transparency in Public Life; however, this information is not on the company’s website. The company provides a link to the relevant law but does not provide a direct link to its own declarations.

The company does not provide any details about its global lobbying expenditure on its website. The company commits to complying with French law requiring it to declare lobbying expenditure to the French High Authority for Transparency in Public Life; however, this information is not presented on the company’s own website. The company provides a link to the relevant law but does not provide a direct link to its own declarations.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality. There is evidence that this policy explicitly addresses the risks associated with gifts and hospitality given to and/or received from domestic and foreign public officials by requiring prior authorisation from the company’s Trade Compliance Officer.

However, the company receives a score of ‘1’ because there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register that is accessible to those responsible for oversight of the process. The policy also does not specify financial or proportional limits for different types of gifts.

There is evidence that the company has a policy on political contributions, which allows for such expenditures relating to the United States political process and when they are in the interest of the company. There is evidence that corporate political contributions are overseen by the Board of Directors, the Government Affairs Office and senior company leaders, and are reviewed on an annual basis by the Risk Oversight Committee (formerly the Ethics and Corporate Responsibility Committee). Based on publicly available evidence, employees are permitted to make personal political donations with approval from Government Affairs, as well as through the company’s voluntary Political Action Committee (VPAC). The company states that the VPAC is non-partisan, chaired by a senior executive with legal expertise and governed by a committee of senior business leaders.

Since the company does not prohibit political donations and is associated with a PAC, it receives a score of ‘0’ in line with the scoring criteria.

There is no evidence that the company publishes details of its corporate political contributions on its website. In addition, the company states that VPAC, state and local political contributions are disclosed to the relevant bodies in the United States as required by law, but there is no evidence that the company provides a direct link to these disclosures.

There is no publicly available evidence that the company has a policy and/or procedure covering charitable contributions or sponsorships, nor that it publishes details of such expenditure. The publicly available Risk Oversight Committee Charter indicates that the company makes (or can make) contributions to charitable and other tax-exempt organisations, but there is no evidence of controls in place to prevent these donations from being used as vehicles for bribery and corruption.

There is some evidence that the company has a policy on lobbying. However, the company receives a score of ‘1’ because there is no evidence that it provides a clear definition of what it considers to be responsible lobbying practices, and the specific controls or guidelines to regulate lobbying are unclear. It is also not clear whether the policy on lobbying applies company-wide to all employees, board members and third parties engaged in lobbying activities on the company’s behalf.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities. The company states that it submits reports on its lobbying activities as required under the Lobbying Disclosure Act, but there is no evidence that it provides any further information on these activities. The company’s approach to lobbying in other jurisdictions is also unclear.

There is no evidence that the company publishes details of its global lobbying expenditure. The company states that it discloses its lobbying expenses for the United States as required under the Lobbying Disclosure Act, but there is no evidence that this information is proactively disclosed on the company’s website. Moreover, there is no evidence that the company provides details of its lobbying expenditure in other jurisdictions nor does it state that it does not engage in such activities outside of the United States.

There is no publicly available evidence that the company has a policy on gifts and hospitality. The publicly available Code of Conduct makes reference to a policy on the giving and receiving of gifts and hospitality, and warns against gifts that may be perceived as favourable treatment, but further details on this policy do not appear to be publicly available.

Based on publicly available information, there is evidence that the company has a policy and procedure on political contributions to ensure that these payments are not used as vehicles for bribery and corruption. The policy applies to all employees and board members across the group. The company states that its policy is to not make political donations but that such a donation would require signoff from the Board of Directors, with input from an individual with legal expertise, namely the Group General Counsel. There is also evidence that the company is associated with a Political Action Committee in the United States, which requires the signoff of a Divisional CEO with input from the company’s Divisional General Counsel.

Since the company does not prohibit political donations and is associated with a PAC, it receives a score of ‘0’ in line with the scoring criteria.

The company publishes a statement that it has not made any corporate political donations in the most recently reported financial year, and states that it intends to continue with this approach.

In addition, there is evidence that the company publishes details of the contributions and disbursements made through its Political Action Committee (PAC) in the United States, by providing links to its FEC filings and Open Secrets. There is evidence that this information includes details of the recipient, amount and state of the recipient and that it is updated and released on a regular basis.

Based on publicly available information, there is evidence that the company has a policy covering charitable donations and sponsorships. There is evidence that the company takes steps to ensure that any donations are legal, appropriate and ethical, and any donations must be signed off by a manager. In addition, the company indicates that it records all charitable donations and sponsorships in an online register.

However, the company receives a score of ‘1’ because there is no evidence that it publishes details of all charitable donations made in the past 12 months, including details of the recipient, amount, country of recipient and which corporate entity made the payment. The company mentions some donations and projects in its reporting documents, but there is no evidence that it provides a total figure or a comprehensive list of donations made to cover all of the company’s activities.

Based on publicly available information, there is evidence that the company has a policy on lobbying. The company defines lobbying and highlights the corruption risks associated with such activities, as well as identifying some guidelines for ‘responsible’ lobbying activity. In addition, there is some evidence that the company has specific controls and oversight mechanisms in place, by stipulating that all lobbying activities must be authorised by the Divisional CEO or appropriate Government Relations lead. There is evidence that this policy and procedure applies to all employees, board members and third parties lobbying on the company’s behalf.

There is no publicly available evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no publicly available evidence to indicate that the company provides any details about its global lobbying expenditure.

Based on publicly available information, there is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality with clear procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter.

In addition, the policy also clearly addresses the risks associated with gifts and hospitality given to and received from public officials. The company's policy includes a clear statement that all gifts and hospitality above certain thresholds are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.

Based on publicly available information, there is evidence that the company has a procedure to regulate political contributions, to ensure that these payments are not used as vehicles for bribery and corruption. This policy indicates that political contributions and donations are permitted, in line with the company’s approval procedure and all relevant laws. The company therefore receives a score of ‘0’.

There is no evidence that the company discloses any details of its political contributions.

There is evidence that the company has a procedure covering both charitable donations and sponsorships. The company publishes some information about the recipients of its major donations.

However, the company receives a score of ‘1’ because there is no evidence that its procedures for charitable donations include specific controls to ensure that such contributions are not used as vehicles for bribery or corruption; for example, by specifying criteria for donations, procedures for senior sign-off, or due diligence on recipients. There is also no evidence that the company publishes a full list of all charitable donations and sponsorships made in the past 12 months.

There is no publicly available evidence that the company has a policy on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

Based on publicly available information, there is evidence that the company addresses the giving and receipt of gifts and hospitality in its Code of Business Conduct.

However, the company receives a score of ‘0’ because it does not provide further details of its policy to indicate that it has procedures in place to ensure that such promotional expenses are not used as vehicles for bribery and corruption.

There is no evidence that the company has a policy on corporate political contributions.

There is no evidence that the company publishes any details of its political contributions.

There is no evidence that the company has a policy or procedure covering charitable donations or sponsorships.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy or procedure on gifts or hospitality.

There is no evidence that the company has a policy covering political contributions.

There is no evidence that the company publishes details of political contributions made by the company and its subsidiaries.

The company states that it employs oversight and control mechanisms to ensure that its charitable donations are not used for corrupt purposes, without providing any further details in publicly available evidence.

There is no evidence that the company maintains a policy regarding sponsorships to ensure that they too are not used for corrupt purposes. Furthermore, there is no evidence that the company publishes details of charitable donations made, such as the amount or details of the recipients.

There is no evidence that the company has a policy covering responsible lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its lobbying expenditure.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality. As part of this, the company explicitly addresses the risks associated with gifts and hospitality given to and received from domestic or foreign public officials.

However, the policy does not specify financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

There is no evidence that the company has a policy that prohibits, or at minimum regulates, corporate political contributions.

There is no evidence that the company discloses any details of its political contributions.

There is some evidence that the company has policies and procedures covering both charitable donations and sponsorships, but there is no evidence that these include specific controls or measures to ensure that such donations are not used as vehicles for bribery and corruption.

There is no evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy or procedure on gifts and hospitality.

There is evidence that the company has a policy on corporate political contributions, which states that such donations to political parties or movements are permitted. The company indicates that such support must not be connected to any public sector opportunity, and states that any donations must be transparent.

The company receives a score of ‘0’ because there is evidence to indicate that it does not prohibit political contributions.

There is no evidence that the company publishes any details of its political contributions.

There is some evidence that the company has a policy covering both sponsorships and charitable donations.

However, the company receives a score of ‘0’ because there is no evidence that provides specific information on the criteria or controls in place to ensure that donations are not used as vehicles for bribery and corruption. For example, there is no evidence that its controls include a measures for senior sign off on donations or due diligence on recipients. There is also no evidence that the company publishes any information on its donations made in the most recently reported financial year.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. The company states that any gifts offered must be proportionate in value and indicates that employees in high risk positions, such as sales, must not accept gifts. There is evidence that employees much report gifts to a superior in such cases.

The company receives a score of ‘1’ because it does not provide any information on further controls in place to ensure such expenses are not used as vehicles for bribery and corruption. For example, there is no evidence that it specifies financial or proportional limits or different approval procedures for different types of promotional expenses, nor does it address the risks associated with gifts and hospitality given to/received from domestic or foreign public officials. In addition, there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

There is no evidence that the company has a policy on corporate political contributions.

There is no evidence that the company discloses details of its political contributions.

There is no evidence that the company has a policy and/or procedure covering charitable donations and/or sponsorships.

There is no publicly available evidence that the company has a policy and/or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy or procedure on gifts or hospitality.

Based on publicly available information, there is evidence that the company has a policy on corporate political contributions. The company clearly states all political contributions, whether by the company itself or by any other entity or individual acting on the company's behalf, are prohibited in all circumstances.

The company publishes a clear statement that it does not make any political contributions, and therefore it is exempt from scoring on this question.

Based on publicly available information, there is evidence that the company has a policy and procedure covering charitable donations and sponsorships. There is evidence that these policies include measures to ensure that such donations are not used as vehicles for bribery and corruption. The company indicates that all contributions must be appropriately registered.

However, the company receives a score of ‘1’ because there is no evidence that it specifies criteria for donations, procedures for senior sign-off on donations or that it requires due diligence to be undertaken on recipients. There is also no evidence that the company publishes full details of all charitable donations made on an annual basis, including details of the recipient, amount, country of recipient and which corporate entity made the payment.

Based on publicly available information, there is evidence that the company has a policy on lobbying. There is evidence that the company has guidelines in place that describe responsible lobbying behaviour and outline the standards of conduct expected from lobbyists. There is also evidence that the company has specific oversight mechanisms in place. This policy applies to all employees, board members and third parties lobbying on the company’s behalf.

There is no publicly available evidence that the company publishes any information on its lobbying aims, topics or activities. The company provides some information on its memberships with trade associations and organisations, and indicates that its involvement in public affairs primarily takes place through these channels, but it does not provide further information on its aims or the topics on which it lobbies.

There is no evidence that the company publishes any details of its global lobbying expenditure.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality with clear procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy also addresses the risks associated with gifts and hospitality given to and received from domestic and foreign public officials.

In addition, the company's policy includes a clear statement that all gifts and hospitality above certain thresholds are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.

Based on publicly available information, there is evidence that the company has a policy on corporate political contributions. The company’s policy indicates that it may make political contributions when approved by individuals with legal expertise. In addition, there is evidence that that the company is associated with a Political Action Committee (PAC) in the United States.

Since the company does not prohibit political donations and is associated with a PAC, it receives a score of ‘0’ in line with the scoring criteria.

There is no evidence that the company publishes any details of its political contributions or Political Action Committee (PAC) disbursements, nor a statement that it has not made any political contributions in the last 12 months.

Based on publicly available information, there is evidence that the company has procedures governing charitable donations and sponsorships. There is evidence that the company publishes some information covering its charitable donations, including the recipients and amounts of donations in its annual Corporate Responsibility Report.

However, the company receives a score of ‘0’ because there is no clear evidence that the procedures governing charitable donations or sponsorships include measures to ensure donations are not used as vehicles for bribery and corruption. It is noted that further details may be contained in the company’s Global Anti-Corruption Compliance Policy but this document is not publicly available.

Based on publicly available information, there is no clear evidence that the company has a policy or procedure on lobbying. A summary of its Global Anti-Corruption Compliance policy refers to risk-based due diligence and oversight of lobbyists, but there is no publicly available evidence that the company has policies and controls in place to ensure that lobbying activities are conducted responsibly.

There is some evidence that the company provides information on its lobbying topics and activities, by providing a direct link to the United States House of Representatives Office of the Clerk website where its official disclosures can be found.

However, there is no evidence that the company publishes details about its broader public policy aims or positions, nor that it discloses any further information on its own website. The company also does not publish any information about its lobbying activities outside of the United States, nor a statement that it does not lobby outside of the United States.

he company provides some details of its lobbying expenditure, by providing a direct link to the United States House of Representatives Office of the Clerk website where its official disclosures can be found.

However, this expenditure data is not broken down into internal, external or association lobbyists and does not include an explanation of how these figures have been calculated. Furthermore, the company does not publish its lobbying expenditure worldwide.

Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality. There is evidence that this policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter, and also that it explicitly addresses the risks associated with gifts and hospitality given to public officials.

However, the company receives a score of ‘1’ because there is no evidence that all gifts and hospitality above certain thresholds are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

There is no readily available evidence that the institute is able to make political contributions due to its nature as a non-profit, tax-exempt organisation in the United States of America.

There is no readily available evidence that the institute is able to make political contributions due to its nature as a non-profit, tax-exempt organisation in the United States of America.

There is no evidence that the organisation has a policy or procedure covering both charitable donations and sponsorships.

There is no evidence that the organisation has a policy or procedure on lobbying.

There is no evidence that the organisation publishes any information on its lobbying aims, topics or activities.

There is no evidence that the organisation provides any details about its global lobbying expenditure.

There is no publicly available evidence that the organisation has a policy or procedure on gifts or hospitality.

The company publishes a statement that it prohibits corporate political contributions. Corporate political contributions whether by the company itself or by any other entity or individual acting on the company's behalf are prohibited under any circumstance.

The company states that it makes no political contributions and is therefore exempt from scoring on this question.

There is some evidence the company has a policy on charitable donations and sponsorships.

However, the company does not publish details of the donations made.

There is evidence that the company has a policy that defines lobbying which applies to all employees and board members, and also applies to both internal and external lobbyists. The company states that all lobbyists are contractually obliged to adhere to the same standards as outlined in the company’s Code of Conduct. There is evidence of specific controls in place regulating lobbyists’ activities, including due diligence, audit rights, anti-corruption clauses and payment subject to specific, agreed activities.

The company publishes limited details of the topics on which it lobbies through an active link to an external online register maintained by the European Union.

However, it does not publish information on the aims of its activities in the European Union. There is also no evidence that the company publishes details of the aims and topics of its lobbying activities in all jurisdictions in which the company operates.

The company publishes a summary of the costs incurred via its lobbying activities in Germany and in the European Union covering the most recent financial year.

However, the data provided does not cover the company’s lobbying activities in all jurisdictions. Additionally, the company’s dataset is lacking sufficient detail: it does not provide a breakdown of spending by corporate entity, or differentiate between internal or external lobbyists, or association lobbying expenditures.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality with procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy also explicitly addresses the risks associated with gifts and hospitality given to and/or received from domestic and foreign public officials, by specifying a different financial threshold. There is further evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register that is accessible to those responsible for oversight of the process.

Based on publicly available information, there is evidence that the company has a policy on corporate political contributions. The company indicates that its employees must not make any direct or indirect contributions to politicians or political parties; however, there is some evidence that the company may make political contributions in some circumstances to support the political process. The company states that it follows applicable laws and there is evidence that it has internal procedures to regulate donations, but these do not appear to be publicly available.

Since the company does not prohibit political donations, it receives a score of ‘0’ in line with the scoring criteria.

There is no evidence that the company publishes any details of its corporate political contributions, nor does it publish a statement that it has not made any such donations in the most recently reported financial year.

There is some evidence that the company has a policy covering both donations and sponsorships, which outlines some basic principles for its community engagement. The company states that its General Affairs Office, which reports into the CEO and COO, is responsible for authorising and overseeing all social contribution activities. In addition, the company provides some details of its charitable contributions made, including its total expenditure divided by category and information on some of its major activities.

However, the company receives a score of ‘1’ because there is no evidence that it publishes full details of its contributions made, such as details of the recipients, donation amount, country of recipient, and which corporate entity made the payment. It is also not clear that the company’s policy stipulates specific controls such as due diligence on recipients, nor that it publishes data on contributions on an annual basis.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any clear evidence on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy or procedure on gifts and hospitality, to ensure that such promotional expenses are not used as vehicles for bribery and corruption. The company indicates that directors and employees should not offer gifts or entertainment to government agencies that may be illegal or prohibited by law, but does not publish further information on the controls and measures that it has in place to reduce corruption risks in the giving or receipt of gifts and hospitality.

There is no evidence that the company has a policy on corporate political contributions. Based on publicly available information, there is evidence indicating that the company operates a Political Action Committee (‘PAC’). However, there is no evidence that the company has oversight mechanisms in place in relation to the PAC.

There is no evidence that the company discloses on its website details of any political contributions or of disbursements made through the Political Action Committee (PAC) with which it is associated.

While the company publishes some details on its sponsorship of volunteer projects, there is no publicly available evidence to indicate that the company has a policy or procedure covering both charitable donations and sponsorships.

There is no publicly available evidence to indicate that the company has a policy or procedure on lobbying.

There is no publicly available evidence to indicate that the company publishes any information on its lobbying aims, topics or activities.

There is no publicly available evidence to indicate that the company provides any details about its lobbying expenditure.

Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality. There is evidence that the policy addresses the risks involved with giving gifts to public officials, although it does not specifically mention public officials when discussing the risks associated with receiving gifts or hospitality.

The company scores ‘1’ as there is no evidence that gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process. There is also no evidence that the company’s policy specifies financial or proportional limits, or different approval procedures, for different types of promotional expenses.

There is no clear evidence that the company has a policy on corporate political contributions. The company provides some information to indicate that it does not participate in or suppor political activities, however it is not clear whether this applies to individual employees or the company as a whole, and therefore it is insufficiently clear to receive a score of ‘1’.

There is no evidence that the company publishes details of its political contributions.

There is some evidence that the company has a policy covering charitable donations and sponsorships, which includes submitting an application for approval. However, the company receives a score of ‘0’ because there is no evidence that these policies include measures to ensure donations are not used as vehicles for bribery and corruption, for example by specifying criteria for donations, procedures for senior sign-off, or due diligence on recipients.

There is no evidence that the company has a policy and/or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

There is some evidence that the company has a policy covering gifts and hospitality, which includes some financial limits on gifts employees may accept.

However, the company does not clarify whether this extends to the giving of gifts and hospitality. Additionally, the policy does not address the risks associated with gifts and hospitality given to/received from domestic or foreign public officials. Additionally, there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

There is evidence that the company has a policy to restrict political donations in order to prevent corruption. However, the company does not provide further details of its policy and it is not clear from publicly available that the company prohibits political contributions as outlined in the scoring criteria.

The company does not disclose any details of its political contributions.There is no evidence that the company publishes any details of its political contributions.

There is evidence that the company’s anti-corruption programme includes restrictions on charitable donations but it provides no further detail in publicly available evidence. There is no evidence that the company has a policy on sponsorships.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is evidence that the company has a policy and procedures on the giving and receipt of gifts and hospitality. This policy includes a financial threshold, which is set by law, although the company does not disclose the specific amount. There is evidence that the company addresses the risks associated with gifts and hospitality given to public officials.

The company requires employees to notify the Commissioner of the Commission for Anti-Corruption Risk Assessment in writing about gifts given and received. However, the company receives a score of ‘1’ because there is no publicly available evidence that this information is recorded in a dedicated register that is accessible to the Commissioner.

Based on publicly available information, there is evidence that the company has a policy on corporate political contributions. The company publishes a clear statement that it does not make political contriubtions, and there is evidence that this applies to the company as a whole and its subsidiaries. In addition, there is evidence that that the company is associated with a Political Action Committee (PAC) in the United States.

Since the company does not prohibit political donations and is associated with a PAC, it receives a score of ‘0’ in line with the scoring criteria.

The company publishes a clear statement that it does not make corporate political contributions of any kind. However, there is no evidence that the company publishes details of the contributions made by its Political Action Committee (PAC), nor a link to its official disclosures in the United States, and therefore it receives a score of ‘0’.

Based on publicly available information, there is evidence that the company has a policy covering charitable donations. However, there is no clear evidence that the company has a policy covering sponsorships, nor that its policy on donations includes specific controls to ensure that they are not used for bribery. There is also no evidence that the company publishes any details about the charitable contributions made in the most recently reported financial year.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its lobbying expenditure.

Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality. The company’s policy specifies financial limits for gifts and addresses the risks associated with gifts given to and received from public officials by indicating that they are not permitted. The company states that all gifts and hospitality above a certain threshold are recorded in central registers for each of its business units, which are accessible to those responsible for oversight of the process.

The company publishes a clear statement that it does not make any corporate political contributions under any circumstances to any party, candidate or campaign.

The company publishes a clear statement that it does not make any political contributions, and is therefore exempt from scoring on this question.

There is evidence that the company recognises charitable donations and sponsorships as possible corruption risks and that it has a policy in place to cover such activities. The company publishes some information about the projects that it supports in its Annual Reports, however it does not provide full details of each donation such as the recipient, amount donated and country of recipient. The company indicates that further details of controls and criteria to ensure that such donations are not used as vehciles for bribery and corruption can be found in a separate document, which does not appear to be publicly available.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes details about its global lobbying expenditure.

There is evidence that the company has a policy on gifts and hospitality which establishes a financial threshold on offering gifts and addresses the risks associated with gifts and hospitality given to/received from domestic or foreign state officials.

However, there is no evidence that all gifts and hospitality submissions are recorded in a dedicated central register or database that is accessible to those responsible for oversight of the process. It is noted that the company makes reference to a separate gifts and hospitality policy, but this document does not appear to be publicly available.

There is no publicly available evidence that the company has a policy to regulate or prohibit corporate political contributions.

There is no evidence that the company publishes details of its political contributions, nor does it provide a clear statement that it makes no such donations.

There is no publicly available evidence that the company has a policy on charitable donations or sponsorships. There is evidence that the company mentions charitable donations in its anti-corruption policy, but it does not provide any further information on measures to ensure that such expenses are not used as vehicles for bribery and corruption.

There is no publicly available evidence that the company has a policy and/or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy on gifts and hospitality. There is evidence that the company mentions gifts and hospitality in its anti-corruption policy, but it does not provide any further information on measures to ensure that such expenses are not used as vehicles for bribery and corruption.

There is no publicly available evidence that the company has a policy covering corporate political contributions.

There is no evidence that the company discloses any details of its political contributions.

There is no evidence that the company has a policy and/or procedure covering charitable donations or sponsorships. The Anti-Corruption Charter of Russian Business contains some limited information on this subject, but it is not sufficiently clear that the company has integrated this into its own anti-bribery and corruption framework, so this evidence is not considered in the assessment.

There is no publicly available evidence that the company has a policy and/or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy on gifts and hospitality.

The company publishes a clear statement that it does not provide any form of contribution to political parties, candidates or campaigns. There is evidence that this policy applies company-wide to all employees.

The company publishes a clear statement that it does not make political contribtions and therefore it is exempt from scoring on this question.

There is evidence that the company has a policy covering charitable donations and sponsorships. The company’s policy includes a list of the types of projects that it prioritises. The company also publishes some details of charitable donations made and there is some evidence it indicate that it updates data on an annual basis, including details of the recipients of its contributions and data outlining general spending on broad areas of charitable activity and sponsorships. There is evidence that this includes spending made by both the company and the wider group.

However, it clear from publicly available information that the company’s policies on charitable donations and sponsorships include specific measures to ensure that such expenses are not used as vehicles for bribery and corruption, such as senior sign-off or conducting due diligence on recipients. In addition, there is no evidence that the company publishes the amount donated to each recipient.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with clear anti-bribery and corruption procedures. The company’s policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees encounter. There is evidence to indicate that gifts and hospitality above certain thresholds are recorded in a dedicated central system that is accessible to those responsible for oversight of the process.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it addresses the risks associated with gifts and hospitality given to, or received from, domestic and foreign public officials, for example by specifying a different financial threshold or approval procedure.

The company publishes a clear statement that it does not make corporate political contributions.

Based on publicly available information, there is some indication that the company makes charitable donations and sponsorships. However, there is insufficient evidence in relation to whether the company has a policy and/or procedure covering charitable donations and sponsorships to ensure that they are not used as vehicles for bribery and corruption.

There is no evidence that the company has a policy and/or procedure on lobbying.

The company publishes insufficient information on its lobbying aims, topics or activities.

The company discloses its donations to some interest groups which have conducted lobbying on the company’s behalf, however this is insufficiently detailed to merit a score of ‘1’.

There is evidence that the company has a policy in relation to the receipt of gifts, which is applicable to board members only. However, this only addresses the receiving of gifts and does not mention the company’s policy on giving of gifts and hospitality. Furthermore, there is no evidence to indicate that the company has clear controls in place which apply to the company’s employees to counter the bribery and corruption risks posed by gifts and hospitality, such as approval procedures, or a dedicated register. As a result, the publicly available evidence is insufficient to receive a score of ‘1’.

The company publishes a clear statement that it does not make corporate political contributions. The company prohibits any donations to political parties, candidates or for other political purposes, and indicates that this policy applies to all employees, agents or third parties acting on its behalf.

There is also evidence that the company has a policy to adhere to all relevant laws governing the operation of Political Action Committees (PAC) in the United States; however there is no readily available evidence in the public domain to indicate that the company is associated with a PAC or that it has been associated with a PAC in the most recently reported financial year.

The company states that it does not make political contributions and therefore it is exempt from scoring on this question.

There is evidence that the company has a policy on both charitable donations and sponsorships. The company’s policy specifies measures to ensure that such expenses are not used as vehicles for bribery and corruption, including criteria for donations, procedures for senior sign-off and due diligence requirements on recipients. In addition, the company indicates that it did not make any donations over $10,000 during 2019.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it publishes full details of all charitable donations made in the most recently reported financial year, such as details of the recipient, amount, country of recipient and which corporate entity made the payment.

There is evidence that the company has a policy and procedures to regulate its lobbying activities. The company also refers to standards of conduct that apply to lobbyists working on its behalf.

However, the company receives a score of ‘1’ because there is no clear evidence that the company’s policies on lobbying apply company-wide to all employees, board members and third parties engaged in lobbying activities on the company’s behalf. There is no publicly available evidence concerning specific controls or guidelines for lobbying behaviour; the company states that it has an internal lobbying policy, which outlines the values and behaviours that constitute responsible lobbying, but this does not appear to be publicly available.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities on its website. The company states that its federal lobbying disclosures are available on the United States House of Representatives website and provides a direct link; however disclosures from the company itself, which include all of its lobbying activities, could not be identified through a public search.

There is no evidence that the company publishes information on its global lobbying expenditure on its website. The company states that its federal lobbying disclosures are available on the United States House of Representatives website and provides a direct link; however disclosures from the company itself, which include all of its lobbying activities, could not be identified through a public search.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits, along with a specific approval procedure, for the different types of promotional expense. The company’s policy also clearly addresses the risks associated with gifts and hospitality given to and/or received from domestic and foreign public officials, and provides different financial thresholds for gifts given and received from such parties.

In addition, there is evidence that all gift and hospitality disclosures are required to be logged in a register accessible to those responsible for oversight of the process.

There is some evidence that the company has a policy on corporate political contribution. The company’s policy indicates that it does not make political contributions in the United States in line with local regulations, but states that it may make political donations in other countries where permitted and subject to prior approval. Although there is evidence that any donations must be properly documented and recorded, there is no evidence that approval must be given from an individual with legal expertise. The company also states that it does not currently make donations through a Political Action Committee but indicates that it may in the future.

There is no evidence that the company publishes any details of its political contributions.

There is no evidence that the company has a policy or procedure covering charitable donations and sponsorships, despite evidence that it engages in such activities. The company provides some information on the types of charitable initiatives that it supports on its website, but does not disclose specific details such as the recipient, amount, country of recipient, or which corporate entity made the payment.

There is some evidence that the company has controls in place to regulate lobbying activities by requiring employees to comply with all relevant laws. There is some indication that the company’s legal counsel has oversight of lobbying activities but this is not clear.

The company receives a score of ‘0’ because there is no evidence that it publicly defines lobbying, nor that it outlines what it considers to be responsible lobbying principles. Additionally, the company’s policy is unclear and does not mention standards of conduct or specific oversight mechanisms that apply to all types of lobbyists. The company does not outline any controls or guidelines. It is also not clear whether this policy applies to board members and third parties engaged in lobbying activities on the company’s behalf.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities. The company states that it will express its views to governments on subjects that might affect the company’s welfare, but provides no further information on the topics that this may include.

There is no evidence that the company provides any details about its global lobbying expenditure.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality to ensure that such promotional expenses are bona fide and not used for bribery. The company’s policy indicates that employees should generally refuse gifts and hospitality, and specifically states that the giving and receipt of promotional expenses to/from government officials is not permitted under any circumstances.

However, the company receives a score of ‘1’ because it does not specify financial limits or approval procedures for different types of gifts and hospitality. There is also no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.

There is no publicly available evidence that the company has a policy on corporate political contributions.

There is no evidence that the company discloses details of its political contributions.

There is no evidence that the company has a policy or procedure covering both charitable donations and sponsorships.

There is no evidence that the company has a policy and/or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy or procedure on gifts or hospitality.