6. Supply Chain Management

There is no evidence that the company requires the involvement of its procurement department in the establishment and/or oversight of its supplier base.

There is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain.

There is no evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is evidence that the company's procurement department is involved, in some capacity, in the establishment and oversight of supplier relationships. The evidence suggests that this department is the main body responsible for the establishment of new supplier relationships and oversight of the supplier base.

The company receives a score of ‘1’ because there is no evidence that the company assures itself of the procurement department’s involvement at least every three years through clearly stated means, such as an audit or other assurance process.

There is evidence that the company has formal procedures to conduct due diligence on all suppliers. There is evidence to suggest that the company is willing to review and/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence process cannot be mitigated.

However, there is no evidence that the company’s due diligence process includes, at least, checks on ultimate beneficial ownership. There is also no evidence to suggest that highest risk suppliers are subject to enhanced due diligence. In addition, although there is some evidence to suggest that due diligence is conducted periodically throughout the business relationship, the frequency of these checks is unclear; there is no evidence to suggest that due diligence is conducted at least every two years or when there is a change in the business relationship.

There is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company indicates that it requires its suppliers adhere to its Code of Business Ethics, which prohibits bribery and includes provisions for conflicts of interest, gifts and hospitality and whistleblowing. In addition, there is evidence that the company requires its suppliers to comply with a supplementary Supplier Standards of Conduct, which also addresses bribery and corruption.

However, while the company’s Supplier Standards of Conduct includes a section detailing the company’s audit rights, there is no evidence which specifically states that the company assures itself of its suppliers’ anti-bribery and corruption programme when onboarding new suppliers and/or when there is a significant change in the business relationship.

There is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place and that the substance of its anti-corruption and bribery programme and standards are included throughout the supply chain. This evidence is in the form of a set of supplier principles outlining the minimum standards of ethical behaviour expected throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption-related investigations or associated disciplinary actions relating to its suppliers.

Based on publicly available information, there is no evidence that the company requires the involvement of its procurement department in the establishment and/or oversight of its supplier base.

The company simply states that it conducts due diligence on its business partners but does not provide any further information on its due diligence procedures.

The company states that suppliers are expected to follow similar principles to those outlined in its Code of Conduct, which includes anti-bribery and corruption measures. However, the company receives a score of ‘0’ because it is not explicitly stated that suppliers are required to do so, nor is there evidence to suggest that the company takes active steps to ensure that its suppliers have adequate anti-bribery and corruption policies and procedures in place. It is not specified that assurance is conducted when onboarding new suppliers and/or when there is a significant change in the business relationship.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is evidence that the company’s procurement department is involved in the establishment and oversight of supplier relationships. However, it is not clear from publicly available information that this is the main body responsible for oversight of the company’s entire supply base, nor is there evidence that the company assures itself of the procurement department’s involvement at least every three years.

There is no publicly available evidence that the company has procedures in place to conduct anti-bribery and corruption due diligence on its suppliers.

The company’s Supplier Code of Conduct requires that its suppliers abide by anti-corruption laws and asks them to align their values and ethics to its own. In addition, it prohibits suppliers from making facilitation payments, using gifts and hospitality to gain an unfair competitive advantage, or provide ‘any improper payments of money or anything of value to government officials, political parties, candidates for public office, or other persons’.

However, it is not clear from publicly available information whether the company seeks to achieve this by requiring suppliers to develop their own policies or to abide by its Code of Conduct. There is also no public evidence regarding how the company ensures itself of its suppliers’ anti-bribery and anti-corruption policies in practice, or whether it does so when onboarding suppliers and/or whenever there is a significant change in the relationship.

There is no publicly available evidence that the company takes steps to ensure that anti-bribery and corruption standards are cascaded through its supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations or the associated disciplinary actions involving its suppliers.

There is evidence that the company requires the involvement of its procurement team in the establishment of new suppliers and that this team is ultimately responsible for providing oversight of the company's supplier base. The company states that the procurement team maintains oversight of all supplier relationships, which implies that the department is constantly involved in the company’s supplier relationships.

According to publicly available evidence, the company has procedures to conduct due diligence on all of its suppliers both at the start of the business relationship and on an ongoing basis afterwards. There is evidence that the company’s checks include verifying the beneficial ownership of each supplier and that suppliers may be subject to enhanced due diligence based on an internal risk assessment. Additionally, it is clear that supplier relationships will be subject to review and possible termination if the results of due diligence reveal significant concerns.

Based on publicly available information, there is evidence that the company contractually requires all of its suppliers to comply with the Airbus Supplier Code of Conduct which outlines the best practices in regards to ethics and compliance. This includes requirements for policies that prohibit foreign and domestic bribery, facilitation payments, and address conflict of interest, gifts and hospitality and whistleblowing. The company assures itself of its suppliers’ compliance with its code of conduct when onboarding new suppliers and for the duration of the business relationship.

The company publicly states that its suppliers are expected to cascade the ethics and compliance standards outlined in the Airbus Supplier Code of Conduct throughout their own supply chains. However, it is unclear how the company does this in practice.

Based on publicly available evidence, the company publishes some information about the number of suppliers it has identified through its risk mapping system and the number of quality alerts received. However, it does not publish any high-level results from ethical incident investigations or the related disciplinary actions.

There is no evidence that the company requires the involvement of its procurement department in the establishment and/or oversight of its supplier base.

There is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain.

There is no evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is no evidence that the company requires the involvement of its procurement department in the establishment and/or oversight of its supplier base.

There is no evidence that the company conducts due diligence on its supply chain.

There is no evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is no evidence that the company requires the involvement of its procurement department in the establishment or oversight of its supplier base.

There is no evidence that the company states that it conducts due diligence on its supply chain.

Although there is evidence that the Company Policy for Prevention applies to the company’s subcontractors, there is no evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

Based on publicly available information, there is evidence that the company's procurement department is involved in the establishment and oversight of supplier relationships, and that this department is the main body responsible for oversight of the company’s supplier base.

However, the company receives a score of ‘1’ because there is no clear evidence that the company assures itself assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means, such as an audit or other assurance process, at least every three years.

Based on publicly available information, there is some evidence that the company has procedures to conduct due diligence on all suppliers during the selection and appointment phase. The company states that it will not engage with any suppliers or subcontractors that have been involved in corrupt activity, though it is not clear whether this stems from the results of due diligence.

The company receives a score of ‘1’ because there is no evidence that due diligence includes checks on ultimate beneficial ownership, nor is there evidence to suggest that highest risk suppliers are subject to enhanced due diligence. There is also no evidence that due diligence is repeated at least every two years or in response to a change in the business relationship.

There is some evidence that the company requires its suppliers to follow similar principles to those outlined in its Ethical Principles document, which prohibits bribery.

However, the company does not clearly state that all suppliers must prohibit facilitation payments, and have policies that cover conflicts of interest, gifts and hospitality, and whistleblowing. There is also no evidence to suggest that the company takes active steps to ensure that its suppliers have adequate anti-bribery and corruption policies and procedures in place.

Based on publicly available information, there is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption-related investigations relating to its suppliers, or the associated disciplinary actions.

There is some evidence that the company’s purchasing departments are involved, in some capacity, in the establishment and oversight of its supplier relationships.

However, the company receives a score of ‘1’ because it is not clear that the procurement department is the main body responsible for oversight of the company’s supplier base. There is also no evidence that the company assures itself of the procurement department’s involvement at least every three years.

There is some evidence that the company has formal procedures to conduct due diligence on its suppliers. There is evidence that the highest risk suppliers are subject to enhanced due diligence procedures.

However, the company receives a score of ‘1’ because its publicly available information indicates that only certain types of suppliers are subject to due diligence. There is no evidence that the due diligence process includes checks on ultimate beneficial ownership, nor that due diligence is repeated at least every two years or whenever there is a change in the business relationship. There is also no evidence to suggest that the company might be willing to review supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

There is some evidence that the company requires its suppliers to comply with certain anti-bribery and corruption standards through the inclusion of contractual clauses in its purchase order terms and conditions. There is evidence that these standards prohibit bribery and facilitation payments.

The company receives a score of ‘1’ because there is no evidence that it requires suppliers to have policies and/or procedures that cover conflicts of interest, gifts and hospitality and whistleblowing. The company indicates that its due diligence includes checks on the supplier’s human resources policies and procedures, but it is not clear that this includes anti-bribery and corruption policies.

Based on publicly available information, there is no clear evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption standards are required throughout the supply chain. There is some evidence in the company’s purchase order terms and conditions that suppliers are responsible for their subcontractors, but there is no evidence that this extends to a commitment on anti-bribery and corruption standards.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations or the associated disciplinary actions relating to its suppliers.

Based on publicly available information, there is no evidence that the company requires the involvement of its procurement department in the establishment and/or oversight of its supplier base.

There is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain.

Based on publicly available evidence, there is no clear evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

Based on publicly available information, there is evidence that the company's procurement department is involved in the establishment and oversight of supplier relationships. However, the company receives a score of ‘1’ because there is no clear evidence that it assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means, such as an audit or other assurance process, at least every three years.

Based on publicly available information, there is evidence the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence when engaging and re-engaging with any suppliers. The company indicates that this due diligence process includes establishing the ultimate beneficial ownership of the supplying company. There is evidence that the highest risk suppliers are subject to enhanced due diligence and that the company might be willing to review supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated. In addition, the company indicates that it conducts such checks at the selection stage and that the business relationship is monitored on an ongoing, proportionate basis.

Based on publicly available information, there is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company states that all suppliers are expected to adhere to its anti-bribery and corruption policy or implement equivalent policies which prohibit foreign and domestic bribery and facilitation payments. In addition, the company indicates in its Supplier Code of Conduct that suppliers must adhere to procedures addressing conflicts of interest, gifts and hospitality, and whistleblowing. There is evidence that the company assures itself of this when onboarding new suppliers and on an ongoing, proportionate basis thereafter.

There is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place and that the substance of its programme and standards are included in subcontracts throughout the supply chain. The company provides a clear description of the minimum standards of anti-corruption and ethics that it expects to be observed throughout its supply chain, and indicates that it will work alongside suppliers to help to implement these standards.

There is no evidence that the company publishes any high-level data on ethical or anti-bribery and corruption investigations or disciplinary actions involving its suppliers.

There is evidence that the company's procurement department is involved, in some capacity, in the establishment and oversight of supplier relationships.

However, the company receives a score of ‘1’ because there is no clear publicly available evidence to indicate that the procurement department is the main body responsible for oversight of the company’s supplier base, nor is there evidence that the company assures itself of the procurement department’s involvement at least every three years.

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based due diligence when engaging and re-engaging with suppliers. The company indicates that it conducts this process annually or when there is a significant change in the business relationship, and states that the process includes establishing the beneficial ownership of the supplying company. There is some evidence indicating that the highest risk suppliers are subject to enhanced due diligence. There is evidence that the company might be willing to review and/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

Based on publicly available information, there is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company clearly states that all suppliers must have, at minimum, policies in place that prohibit foreign and domestic bribery, prohibit facilitation payments, as well as policies and procedures to address conflicts of interest, gifts and hospitality and whistleblowing. There is evidence that the company takes active steps to ensure this, for example by including checks on suppliers’ policies as part of the due diligence and by conducting ongoing risk assessments. The company assures itself of this when onboarding new suppliers or when there is a significant change in the business relationship.

Based on publicly available information, there is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place and that the substance of its anti-bribery and corruption programme and standards are included in sub-contracts throughout the supply chain. This evidence is in the form of a set of supplier principles that sets the minimum standards of ethical behaviour expected throughout the supply chain.

The company publishes some high-level information about its ethics enquiries and disciplinary actions involving employees and third parties, however it is not clear whether this includes suppliers. The company receives a score of ‘0’ because the data published does not provide any information on ethics enquiries, investigations launched or disciplinary actions taken as they relate to suppliers, nor does it publish a statement that it has no supplier incidents or investigations to report.

There is no evidence that the company requires the involvement of its procurement department in the establishment and/or oversight of its supplier base.

There is no evidence that the company conducts bribery and corruption-based due diligence on its suppliers.

There is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place, which cover conflicts of interest and gifts and hospitality. The company also states that suppliers must attempt to adhere to the principles outlined in its Business Ethics Code of Conduct.

However, the company receives a score of ‘1’ because it is unclear whether all suppliers are required to adhere to the company’s anti-bribery and corruption terms and conditions. Moreover, these conditions do not explicitly prohibit facilitation payments, or cover whistleblowing. There is also no evidence to suggest that the company takes steps to ensure that its suppliers have adequate anti-bribery and corruption policies and procedures in place, or whether it does so when there is a significant change in the business relationship.

There is some evidence that the company requires its suppliers’ subcontractors to observe anti-bribery and corruption legislation, but there is no evidence that it requires its suppliers to flow down the broader principles of its anti-corruption programme throughout its supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is no evidence that the institute requires the involvement of its procurement department in the establishment and oversight of its supplier base.

There is no evidence that the institute conducts anti-bribery and corruption due diligence on its supply chain.

There is evidence that the institute requires that its suppliers meet a certain standard of ethical business conduct, but the institute does not specifically refer to any of the anti-bribery and corruption measures necessary to score ‘1’.

There is no evidence that the institute takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the institute publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is evidence that the company's procurement department is involved in the establishment and management of supplier relationships, and there is some evidence that this department is responsible for oversight of the company’s supplier base.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of the procurement department’s involvement at least every three years.

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based due diligence when engaging and re-engaging with any suppliers. The company indicates that this due diligence process includes establishing the beneficial ownership of the supplying company and there is evidence that high risk suppliers are stated to be subject to enhanced due diligence.

There is evidence that this process is conducted at least every two years or when any red flags arise over the course of the supplier relationship. The evidence indicates that the company will not enter into a relationship with a supplier if red flags highlighted in the due diligence cannot be mitigated.

There is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies in place. The company states that it expects its suppliers to follow its Code of Conduct and Anti-Corruption Guidelines, which prohibit bribery and facilitation payments and address conflicts of interest, gifts and hospitality and whistleblowing. There is evidence which indicates that the company assures itself of this when onboarding new suppliers.

There is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place, and that the substance of its anti-corruption and bribery programme is required of sub-contractors throughout the supply chain. This evidence appears in the form of a clear statement and set of supplier principles that sets the minimum standards of ethical behaviour expected throughout the supply chain.

There is evidence that the company publishes high-level data from ethical incidents and investigations, and that this includes reports from and about suppliers and contractors. The data includes the number of allegations made and the number of disciplinary actions as a result of investigation findings. This data is published at regular intervals, on at least an annual basis covering cases in the past 12 months.

However, the company receives a score of ‘1’ because the data is not disaggregated to show supplier data as separate from other types of individuals, such as company employees.

There is no evidence that the company requires the involvement of its procurement department in the establishment or oversight of its supplier base.

There is evidence that the company has formal procedures to conduct due diligence on its suppliers, which includes checks on beneficial ownership. There is evidence that the company may blacklist suppliers.

However, the company receives a score of ‘1’ because there is no clear evidence that the company will not engage or potentially terminate its engagement where red flags highlighted in the due diligence process cannot be mitigated. There is also no evidence to suggest that high-risk suppliers are subject to enhanced due diligence, and the frequency of due diligence checks is unclear.

There is evidence that the company ensures that its suppliers have adequate anti-corruption policies and procedures in place, by including specific terms in its contracts. The company indicates that this assurance is conducted when onboarding new suppliers, and there is evidence that the company takes steps to assure itself of this on an ongoing basis through external independent monitors.

However, the company receives a score of ‘1’ because there is no clear evidence that all suppliers must have, at least, policies that prohibit facilitation payments or policies that cover conflicts of interest, gifts and hospitality or whistleblowing.

There is evidence that the company takes steps to ensure that the substance of its anti-corruption standards is required of sub-contractors throughout the supply chain. However, the company receives a score of ‘1’ because this is in the form of a simple statement and it is not clear how the company ensures this in practice, for example through contractual terms or provision of additional guidelines.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations or the associated disciplinary actions relating to its suppliers.

Based on publicly available information, there is evidence that the company’s procurement department is involved, in some capacity, in the establishment of supplier relationships.

However, the company receives a score of ‘1’ because it is not clear that the procurement department is the main body responsible for oversight of the company’s supplier base; for instance there is also evidence to show that the company’s Vigilance Department provides some oversight over these processes. Furthermore, there is no evidence that the company assures itself of the procurement department’s involvement at least every three years. While evidence of the use of Integrity Pacts for large value contracts has been noted, these are not explicitly related to the question.

There is evidence that the company has formal procedures to conduct due diligence on its suppliers and that suppliers are reviewed annually.

However, the company receives a score of ‘1’ because there is no evidence to suggest that highest risk suppliers are subject to enhanced due diligence. Furthermore, it is not clear whether the company might be willing to review and terminate supplier relationships in circumstances where a red flag highlighted cannot be mitigated.

There is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedure in place. There is evidence that the company ensures this in practice by stipulating certain contractual terms and by advising suppliers to have a Company Code of Conduct. This assurance is conducted when onboarding new suppliers.

However, the company receives a score of ‘1’ because there is no clear evidence that all suppliers must have, at least, policies that prohibit facilitation payments, policies that cover conflicts of interest, gift and hospitality and whistleblowing. Furthermore, it is not clear that the company assures itself of this for all suppliers.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption standards are required throughout the supply chain. Although there is evidence that the company takes steps to ensure the compliance of its suppliers, it is not clear that it applies to sub-contractors and other related entities.

There is no evidence that the company publishes data on ethical or corruption-related investigations or associated disciplinary actions involving its suppliers. The company publishes some details on its complaints and investigations related to vigilance, however this is not sufficiently clear to merit a score of ‘1’.

Based on publicly available information, there is evidence that the company requires the involvement of its procurement department in the establishment of new suppliers. The company indicates that this department is ultimately responsible for providing oversight of the company's supplier base. There is evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through an audit of the supplier management process, which is conducted on an annual basis.

Based on publicly available information, there is some evidence that the company has formal procedures to conduct due diligence on all its suppliers prior to entering into the business relationship.

However, the company receives a score of ‘1’ because it does not explicitly state that due diligence checks include establishing the ultimate beneficial ownership of the supplier. There is no evidence that the highest risk suppliers are subject to enhanced due diligence, and the frequency of these checks is unclear. In addition, there is no clear evidence to suggest that the company might be willing to terminate supplier relationships in circumstances where a red flag highlighted in the due diligence process cannot be mitigated.

Based on publicly available information, there is evidence that the company contractually requires its suppliers to comply with anti-corruption laws and have an ethics and compliance programme in place.

However, the company receives a score of ’1’ because it does not provide further information on the specific standards that are required; for example it does not explicitly state that all suppliers must have or comply with policies that prohibit bribery and facilitation payments, or procedures to cover conflicts of interest, gifts and hospitality and whistleblowing. It is also not clear that the company takes practical steps to ensure that its suppliers have adequate anti-bribery and corruption policies and procedures in place, such as an audit or assessment of the suppliers’ programme. In addition, it is not clear whether such assurance would take place only during onboarding or when there is a significant change in the business relationship.

Based on publicly available information, there is evidence that the company takes steps to ensure that the substance of its anti-corruption and bribery programme and standards are flowed down throughout the supply chain. This evidence is the form of a contractual commitment placed on suppliers and their sub-contractors.

There is evidence that the company publishes annual data on ethics-related disciplinary actions and investigations within the organisation, which includes data relating to supplier misconduct. However, the company receives a score of ‘1’ because it does not distinguish concerns and cases related to suppliers from those related to employees and other entities in the organisation.

There is evidence that the company's procurement department is involved, in some capacity, in the establishment and oversight of supplier relationships and there is evidence indicating that this department is the main body responsible for oversight of the company’s supplier base;

However, there is no evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means, such as an audit, at least every three years.

There is evidence that the company has formal procedures to conduct due diligence on its suppliers, which includes checks on ultimate beneficial ownership. There is also evidence suggesting that the company is willing to review and/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence process cannot be mitigated. The company indicates that due diligence will be undertaken at the outset and over the course of a business relationship.

However, it is unclear how frequently due diligence is refreshed, and there is no evidence to suggest that highest risk suppliers are subject to enhanced due diligence..

There is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place, by requiring all suppliers to adhere to its Supplier Code of Conduct. This policy explicitly states that all suppliers must have policies that prohibit foreign and domestic bribery and facilitation payments, as well as policies that cover conflicts of interest, gifts and hospitality, and whistleblowing.

However, it is not specified whether this assurance is conducted only when onboarding new suppliers or when there is a significant change in the business relationship.

There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. The company indicates that it expects suppliers to conduct appropriate due diligence on its subcontractors and flow down the principles of its anti-bribery and corruption policies throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption reports, investigations or the associated disciplinary actions involving its suppliers.

There is some evidence that the company has a procurement department and that this body is involved in managing the company’s supplier relationships.

However, there is no publicly available evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means, such as an audit or other assurance process, on a regular basis. In addition, it is not clear from publicly available evidence that this department is the main body responsible for establishing and onboarding all new suppliers.

There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its supply chain.

There is no clear publicly available evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard. The company states that its staff are prohibited from engaging in corrupt practices in dealings with suppliers, however there is no further publicly available evidence to indicate that the company places requirements on suppliers regarding anti-corruption.

There is no publicly available evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-corruption related reports, investigations or disciplinary actions involving its suppliers.

There is evidence that the company's procurement department, referred to as its Global Strategic Sourcing Department, is involved, in some capacity, in the establishment and oversight of supplier relationships.

However, the company does not state that the involvement of the department is required for establishing any new suppliers over a certain threshold. It is also not expressly clear that this department is the main body responsible for oversight of the company’s supplier base, nor that that the company assures itself of this department’s involvement at least every three years.

The company states that it conducts risk-based anti-corruption due diligence on third parties, which includes suppliers, and there is evidence that highest risk third parties are subject to enhanced due diligence. There is also evidence to suggest that the company might be willing to review and/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

The company receives a score of ‘1’ because it is not clear from the publicly available evidence whether all suppliers are subject to due diligence. In addition, there is no evidence to indicate that due diligence procedures include checks on ultimate beneficial ownership. The frequency with which due diligence is refreshed is also unclear.

There is some evidence that the company ensures that suppliers have adequate anti-bribery and corruption policies and procedures in place, by requiring suppliers to affirm that their own ethics and anti-corruption procedures are equivalent to the company’s. There is also evidence that the company requires its suppliers in Europe and the US to agree to comply with the company’s own Code of Business Conduct. This code contains regulations covering foreign and domestic bribery, facilitation payments, and policies that cover conflicts of interest, gifts & hospitality, and whistleblowing.

However, the company receives a score of ‘1’ because it is unclear if the company ensures these standards for all of its suppliers. It is also not clear from the evidence whether this assurance is conducted when onboarding all new suppliers and/or when there is a significant change in the business relationship.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

The company states that during the last fiscal year it had no reported incidents on supplier practices. However, it is not clear from the evidence that this information would include details of ethical, bribery or corruption related incidents, investigations or disciplinary actions.

It is noted that there is evidence that the company published a summary of the number of reports submitted to its whistleblowing line, also in the last fiscal year, which included ethics and compliance-related data. However the company does not state whether this data includes reports in relation to the company’s suppliers, and the data does not include details concerning the number of investigations or disciplinary actions.

There is no evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base.

The company does not state that it conducts due diligence on its supply chain.

There is no evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is no evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base.

There is evidence that the company conducts due diligence on its suppliers. However, the company simply states that it conducts due diligence on its suppliers, without providing any further details and therefore cannot receive a score of ‘1’.

There is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. It is explicitly stated that all suppliers must have, at minimum, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, as well as policies and procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. There is evidence to suggest that the company takes active steps to ensure that its suppliers have adequate anti-bribery and corruption policies and procedures in place.

However, the company receives a score of ‘1’ because it is unclear whether the company assures itself of this when onboarding new suppliers or when there is a significant change in the business relationship.

There is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place and that the substance of its anti-corruption and bribery programme and standards are included in subcontracts throughout the supply chain.

However, this evidence is in the form of a clear statement and it is unclear how the company does this in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is evidence that the company's procurement department is involved, in some capacity, in the establishment and oversight of supplier relationships. There is clear evidence that the company’s procurement department is the main body responsible for oversight of the company’s supplier base.

However, the company receives a score of ‘1’ because the company does not state that the involvement of the procurement department is required for establishing any new suppliers over a certain threshold. Additionally, there is no clear evidence that the company assures itself of the procurement department’s involvement at least every three years.

There is no evidence that the company conducts due diligence on its supply chain.

There is no evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is no evidence that the company requires the involvement of its procurement department in the establishment or oversight of its supplier base.

There is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain.

There is no publicly available evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.

There is no evidence that the company takes steps to ensure that anti-bribery and corruption procedures and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is evidence that the company’s procurement department is involved in the establishment and oversight of supplier relationships. It is clear that the procurement team is the main body responsible for oversight of the company’s supplier base.

However, the company receives a score of ‘1’ because there is no evidence that it assures itself of the procurement department’s appropriate involvement in this process at least every three years.

There is evidence that the company has formal procedures in place to conduct due diligence on its supply chain. The company states that this process is undertaken on an annual basis and regularly throughout the duration of the commercial relationship.

However, the company receives a score of ‘1’ because there is no evidence that this due diligence includes checks on ultimate beneficial ownership, nor that highest risk suppliers are subject to enhanced due diligence. There is also no clear evidence that the company might be willing to not engage or to terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

There is evidence that the company takes steps to ensure that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company states that, in addition to adhering to its Supplier Code of Conduct, suppliers are also contractually required to follow its Anti-Corruption Policy, which prohibits bribery, facilitation payments, payments to government officials, and contains guidance regarding gifts and hospitality.

In addition, the company indicates that suppliers must have in place policies that reflect standards in its Code of Business Conduct, which contains provisions for conflicts of interest and whistleblowing. There is evidence to suggest that the company assesses suppliers’ policies prior to engaging with them and that it repeats this assurance periodically throughout the business relationship.

There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain.

However, the company receives a score of ‘1’ because it does not provide any further information on how it ensures this in practice, for example through contractual requirements or the provision of training.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption incidents, investigations or disciplinary actions relating to its suppliers.

There is no evidence that the company requires the involvement of a centralised procurement department in the establishment and/or oversight of its supplier base.

There is evidence that the company conducts due diligence on third parties, however the company does not explicitly mention suppliers and does not provide any further details on its due diligence processes.

There is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company states that suppliers which do not already have an existing robust code of conduct must follow theirs, which prohibits bribery and facilitation payments, and covers conflicts of interests and gifts and hospitality. The company’s whistleblowing channel is also open to suppliers. The company assures itself of its suppliers’ compliance with these principles by requiring them to grant the company or an independent auditor access to documentation demonstrating this.

However, the company receives a score of ‘1’ because it is not stated that the company assures itself of this when onboarding new suppliers and/or when there is a significant change in the business relationship.

There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. Suppliers are instructed to advise their contractors to observe the standards outlined in the Code of Conduct for Third Parties.

However, the company receives a score of ‘1’ because this is a simple statement and it is unclear how the company does this in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is no evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base.

There is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain.

There is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. According to publicly available evidence, the company does this by requiring that its suppliers adopt its Code of Conduct for Suppliers and Customers, which specifically prohibits foreign and domestic bribery, gifts and conflicts of interest.

However, the company receives a score of ‘1’ because there is no evidence that suppliers must have policies in place to prohibit facilitation payments or have systems in place to allow for whistleblowing. Furthermore, it is not clear how the company ensures these standards in practice or when this process is conducted throughout the business relationship.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption-related investigations involving its suppliers, or the associated disciplinary actions.

There is publicly available evidence that the company's procurement department is involved, in some capacity, in the establishment of supplier relationships.

However, the company receives a score of ‘1’ because there is no evidence that the procurement department is the main body responsible for oversight of the company’s supplier base. There is also no evidence that the company assures itself of the procurement department’s involvement at least every three years.

Based on publicly available information, there is some evidence that the company conducts due diligence on its suppliers, which includes a review of corruption risks. There is also some evidence indicating that the company might be willing to review and/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

However, there is no evidence that the due diligence process includes checks on ultimate beneficial ownership, nor that the highest risk suppliers are subject to enhanced due diligence. There is also no clear evidence that due diligence is repeated at least every two years or whenever there is a change in the business relationship.

Based on publicly available information, there is evidence that the company requires its suppliers to abide by anti-bribery and corruption contractual terms. The company states that its suppliers are prohibited from engaging in bribery and making facilitation payments, as well as referring to conflicts of interest, gifts and hospitality and whistleblowing provisions in its commitments to suppliers.

However, there is no evidence to suggest that the company takes active steps to ensure that its suppliers have adequate anti-bribery and corruption policies and procedures in place, either when onboarding new suppliers or when there is a significant change in the business relationship. While it refers to ethical practice evaluations, it is not clear from publicly available materials what this process entails.

Based on publicly available information, there is no clear evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical, bribery or corruption-related investigations or associated disciplinary actions relating to its suppliers.

There is no publicly available evidence to indicate that the company requires the involvement of its procurement department in the establishment or oversight of its supplier base.

Based on publicly available information, there is evidence that the company has formal procedures to conduct
due diligence on its suppliers. There is also evidence that highest risk suppliers are subject to enhanced due diligence. Furthermore, there is evidence to suggest that the company might be willing to terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

However, the company indicates that due diligence is only conducted on some third parties and that checks on ultimate beneficial ownership are only performed in some instances on high risk third parties. The frequency of the due diligence is also unclear.

Based on publicly available information, there is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. It is explicitly stated that all suppliers must comply with policies that prohibit bribery and facilitation payments, as well as policies and procedures that address conflicts of interest, gifts and hospitality, and whistleblowing.

In addition, there is evidence that the company takes active steps to ensure this, for example by requiring that all suppliers follow its own anti-bribery principles and by including termination rights in its contracts with suppliers in the event of non-compliance. The company assures itself of this when onboarding new suppliers.

Based on publicly available information, there is evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain.

However, the company receives a score of ‘1’ because there is no further evidence of how the company does this in practice.

There is no publicly available evidence to indicate that the company publishes any data on ethical or anti-bribery and corruption investigations or disciplinary actions involving its suppliers.

There is some publicly available evidence that the company has a specific body responsible for the oversight of its supplier base. The company states that it has a Supply Chain Committee composed of those responsible for the supply process, and indicates that this body is responsible for making decisions in this area.

However, the company receives a score of ‘1’ because it is not clear from publicy available evidence that this Committee is the main body or department responsible for the establishment and oversight of its entire supply base, nor is there evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means at least every three years.

There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its supply chain. The company indicates that it has procedures in place to assess suppliers and map any associated risks, but it does not provide further publicly available evidence to indicate whether this includes establishing the ultimate beneficial ownership of suppliers nor is it clear that such a process is undertaken and repeated at regular intervals.

Based on publicly available information, there is evidence that the company requires that its suppliers have adequate ethics and anti-corruption standards in place by ensuring that they follow its Code of Ethics. There is evidence to indicate that this includes a ban on commercial bribery and any improper gifts or hospitality. The company also indicates that all parties must comply with relevant anti-bribery legislation.

However, the company receives a score of ‘1’ because it does not provide further publicly available information on its supplier standards to indicate that such partners must have policies in place to prohibit facilitation payments or procedures to address conflicts of interest and whistleblowing. In addition, there is no clear evidence to indicate how the company takes active steps to ensure supplier compliance in this area, whether at the start of the relationship or on a regular basis thereafter.

There is no publicly available evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption-related reports, investigations or disciplinary actions involving its suppliers.

There is evidence that the company requires the involvement of its procurement department in the establishment of new supplier relationships. This department is named as the single point of contact for all new vendors, and there is evidence that it communicates with all suppliers on anti-corruption issues on an annual basis, suggesting that they are the main body responsible for oversight of the company’s supplier base.

However, although procurement integrity is one the topics which may be discussed by the Ethics and Compliance Committee, there is no publicly available evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means, such as an audit, at least every three years.

There is some evidence that the company has formal procedures to conduct due diligence on all its suppliers, and that the company might be willing to terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

However, there is no evidence to suggest that high risk suppliers are subject to enhanced due diligence. It is also not clear from publicly available evidence whether the company repeats due diligence on its existing suppliers. There is also no evidence that due diligence includes checks on the beneficial ownership of suppliers.

There is evidence that the company ensures that all its suppliers have adequate anti-bribery and corruption policies and procedures in place. There is evidence that suppliers must have policies that prohibit foreign and domestic bribery, facilitation payments, as well as maintaining policies relating to conflicts of interest, gifts & hospitality and whistleblowing. There is evidence that the company’s procurement department is responsible for monitoring suppliers’ compliance with these policies and that the company assures itself of this on at least an annual basis.

There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain.

However, this evidence is in the form of a simple statement and it is unclear how the company ensures itself of subcontractor compliance in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations or disciplinary actions involving its suppliers.

There is no evidence that the company requires the involvement of its procurement department in the establishment and/or oversight of its supplier base.

The company states that it conducts due diligence on potential partners, but does not provide any further details on this process that would be required to score ‘1’.

There is evidence that the company sets expectations for its suppliers through its Code of Ethics. However, based on publicly available information, this code refers to general standards of ethical business conduct and does not specifically refer to any of the anti-bribery and corruption measures mentioned in score ‘1’.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is no publicly available evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base.

There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence when engaging or re-engaging with its suppliers. The company indicates that it conducts due diligence on specific business partners, but it is not clear whether this would include all suppliers or whether such partners are selected based on an assessment of their exposure to corruption risk.

There is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. There is evidence that the company takes active steps to ensure this by requiring that all suppliers follow its own anti-bribery and corruption policy.

However, the company receives a score of ‘1’ because there is no publicly available evidence that all suppliers must have policies that prohibit facilitation payments, and procedures to address conflicts of interest, gifts and hospitality and whistleblowing. There is also no clear evidence that the company assures itself of the quality of suppliers’ policies when onboarding and when there is a significant change in the business relationship.

There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. However, the company receives a score of ‘1’ because it does not provide any further information on the steps that it takes to ensure this in practice.

There is no publicly available evidence that the company publishes any data on ethical or anti-bribery and corruption reports, investigations or disciplinary actions involving its suppliers.

There is no evidence that the company requires the involvement of its procurement department in the establishment and/or oversight of its supplier base.

The company simply states that it conducts due diligence on its suppliers before entering into agreements and potentially throughout the business relationship. However, it does not provide any further details on its due diligence procedures so receives a score of ‘0’.

There is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company requires its suppliers to comply with the Supplier Code of Ethics and Business Conduct, which prohibits bribery, facilitation payments and covers conflicts of interest, gifts and hospitality, and whistleblowing.

However, the company receives a score of ‘1’ because it is unclear how the company assures itself that suppliers have such policies in place, such as by conducting assessments of supplier policies during the onboarding process and when there is a significant change in the business relationship.

There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain.

However, this evidence is in the form of a simple statement and it is unclear how the company does this in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is no clear publicly available evidence the company requires the involvement of its procurement department in the establishment of new supplier relationships and the oversight of its supplier base.

There is evidence that the company has formal procedures to conduct risk-based due diligence when engaging with suppliers. The company indicates that the highest risk suppliers are subject to enhanced due diligence. There is also evidence that the company is willing to review and terminate supplier relationships in instances where red flags highlighted during the due diligence process cannot be mitigated.

However, the company receives a score of ‘1’ because it is not clear from publicly available information how frequently it conducts these checks. There is also no clear evidence that the company includes checks on the ultimate beneficial ownership of suppliers as part of its due diligence procedure.

Based on publicly available information, there is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company indicates that all suppliers must have, at minimum, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, as well as policies and procedures to address conflicts of interest, gifts and hospitality, and whistleblowing.

There is evidence that the company takes active steps to ensure this by requiring that all suppliers follow its Supplier Code of Conduct. In addition, there is evidence that the company assures itself of this when onboarding new suppliers and periodically thereafter through the inclusion of auditing rights in its contracts with suppliers.

Based on publicly available information, there is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain.

However, the company receives a score of ‘1’ because the company does not provide further publicly available information on how it ensures this in practice, for example by adding a clause on subcontractors in contracts with suppliers or by providing training to subcontractors.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations or the associated disciplinary actions involving its suppliers.

Based on publicly available information, there is no evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base.

Based on publicly available information, there is some evidence that the company has formal procedures to conduct risk-based due diligence on suppliers, which includes checks on ownership. There is some evidence to suggest that the company might be willing to review and/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

However, the company receives a score of ‘1’ because there is no evidence that it repeats the due diligence process every two years or whenever there is a change in the business relationship. There is also no clear evidence to suggest that the highest risk suppliers are subject to enhanced due diligence.

Based on publicly available information, there is evidence that the company expects its suppliers to abide by its Code of Ethics and Conduct, and that it may include anti-corruption covenants in its written agreements with suppliers. There is also evidence that the company has a system to communicate its anti-corruption policies and expectations to suppliers.

However, the company receives a score of ‘1’ because there is no clear evidence that it takes active steps to ensure that all its suppliers have adequate anti-bribery and corruption policies in place or that they respect the Embraer Code of Ethics and Conduct.

There is no publicly available evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no clear evidence that the company publishes high-level data on its ethical or anti-corruption incidents and investigations involving its suppliers. The company publishes a statement that there were no corruption incidents in 2017 and 2018; however, there is no clear evidence that this includes cases involving suppliers.

Based on publicly available information, there is no evidence that the company requires the involvement of its procurement department in the establishment or oversight of its supplier base.

Based on publicly available information, there is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain. The company indicates that it verifies business partners against the standards set out in its Code of Conduct; however, this statement is insufficiently detailed to merit a score of ‘1’.

Based on publicly available information, there is some evidence that the company ensures that its external partners (which include suppliers) have adequate anti-bribery and corruption policies and procedures in place. There is evidence that the company takes active steps to ensure this, by requiring that all suppliers follow its own anti-bribery policies and procedures. These policies prohibit bribery and facilitation payments and include procedures to address conflicts of interest, gifts and hospitality, and whistleblowing.

However, the company receives a score of ‘1’ because there is no evidence that it takes active steps to ensure that its suppliers abide by its policies or that its suppliers have their own adequate anti-bribery and corruption policies and procedures in place.

Based on publicly available information, there is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. However, this evidence is in the form of a simple statement and it is unclear how the company does this in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers.

Based on publicly available information, there is evidence that the company's procurement department is involved in the establishment of supplier relationships and that this department is ultimately responsible for providing oversight of the company’s supplier base. Although there is evidence that the company conducts ongoing monitoring of its suppliers, there is no public evidence that the company assures itself of the procurement department’s involvement in the onboarding process itself at least every three years.

Based on publicly available information, there is some evidence indicating that the company has formal procedures to conduct due diligence on its suppliers. The company indicates that its suppliers are monitored and that annual audits are conducted on 99% of its suppliers. The company indicates that it might be willing to terminate supplier relationships in circumstances where a red flag highlighted in the due diligence process cannot be mitigated. However, it is unclear whether due diligence is also conducted whenever there is a change in the business relationship. In addition, there is no evidence that due diligence includes checks on ultimate beneficial ownership or that the highest risk suppliers are subject to enhanced due diligence.

Based on publicly available information, there is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place, and the company assures itself of this when onboarding suppliers. It is explicitly stated that all suppliers must have policies that prohibit bribery and facilitation payments as well as policies and procedures that address conflicts of interest, gifts and hospitality and whistleblowing. There is evidence that the company takes active steps to ensure this through contractual terms and by requiring suppliers to follow its Code of Conduct and Anti-Corruption Policy.

There is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place and that the substance of its anti-corruption and bribery programme and standards are included in subcontracts throughout the supply chain. This evidence is in the form of a clear statement and contractual commitments.

The company does not publish any data on ethical or anti-bribery and corruption investigations or the associated disciplinary actions relating to its suppliers.

There is evidence that the company requires the involvement of its procurement department in the establishment of new suppliers. The company indicates that this department is ultimately responsible for providing oversight of its supplier base, and there is additional evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through the use of an annual audit process.

There is evidence that the company has formal procedures to conduct risk-based due diligence when engaging and re-engaging with suppliers. There is evidence that this due diligence includes checks on ultimate beneficial ownership.

However, although the company states that suppliers undergo continuous monitoring, it is not clear from publicly available evidence that due diligence is repeated at least every two years or whenever there is a change in the business relationship. There is also no publicly available evidence that the highest risk suppliers are subject to enhanced due diligence. In addition, there is no evidence that the company might be willing to review and/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

There is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company takes active steps to ensure this by requiring that all suppliers follow its Business Conduct And Ethics Expectations For Suppliers And Contractors policy which includes provisions that prohibit bribery as well as policies related to conflicts of interest, gifts and hospitality and reporting procedures.

However, the company receives a score of ‘1’ because there is no clear evidence that its standards for suppliers include prohibiting facilitation payments or establishing a whistleblowing mechanism. In addition, although the company indicates that it conducts assurance when onboarding suppliers, there is no publicly available evidence that it repeats these checks when there is a significant change in the business relationship.

There is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place, and that the substance of its anti-corruption and bribery programme and standards are included in sub-contracts throughout the supply chain. The company publishes a clear statement on this subject, and states that it has the right to verify that its contractors and suppliers meet these expectations.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption incidents, investigations or disciplinary actions relating to its suppliers.

Based on publicly available information, there is no clear evidence that the company has a procurement department that is involved in and responsible for the establishment and/or oversight of its supplier base

The company simply states publicly that it conducts due diligence on third parties without providing any specific details regarding its due diligence process.

Based on publicly available information, there is evidence that the company requires suppliers to comply with its Global Business Standards. These standards prohibit bribery and facilitation payments and include procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. The company requires new suppliers to sign an agreement stating that they will comply with the company’s anti-bribery and corruption policies.

However, it is unclear how the company assures itself that suppliers have adequate anti-bribery and corruption procedures in place in practice. The company also does not specify that it conducts assurance when there is a significant change in the business relationship.

Based on publicly available information, there is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain.

However, this evidence is in the form of a simple statement and it is unclear how the company does this in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is evidence that the company's procurement department is the main body involved in the establishment and oversight of supplier relationships. However, the company receives a score of ‘1’ because there is no evidence that the company takes steps to assure itself of the proper functioning of this system or that the procurement department is appropriately involved in the process, such as through regular audits.

There is evidence that the company has formal procedures to conduct anti-bribery and corruption due diligence on all suppliers. There is evidence that the highest risk suppliers are subject to enhanced due diligence and the process includes checks on ultimate beneficial ownership. There is evidence that the company will not onboard a supplier, and will also terminate an existing relationship, if a red flag identified in due diligence cannot be mitigated. In addition, there is evidence that such checks on suppliers are repeated throughout the relationship, with audits conducted every one to three years depending on the level of risk and on-site assessments every one to five years.

There is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place, by stating that all suppliers must adhere to its Integrity Guide for Suppliers Contractors and Consultants. This document prohibits bribery, refers to gifts and hospitality and offers of employment, and provides details of the company’s whistleblowing line. There is evidence that the company conducts ethical evaluations of its suppliers when onboarding them, and thereafter every one to five years, although the company does not refer specifically to assessing the anti-bribery and corruption policies of suppliers.

The company receives a score of ‘1’ because it is not clear from publicly available evidence that it requires suppliers to have policies in place which prohibit facilitation payments and regulate conflicts of interest.

There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. The company states that it expects its suppliers to communicate these standards throughout the supply chain, and indicates that it conducts audits on subcontractors in sub-tiers to ensure compliance.

The company provides some data on environmental, social and governance audits of its suppliers, which includes incidents related to ethics and corruption. This data includes the number of audits conducted and the total number of findings, and there is evidence that this data is published on an annual basis.

The company receives a score of ‘1’ because there is no evidence that it clearly publishes information on the number of investigations launched and the number of disciplinary actions as a result of investigation findings for suppliers specifically.

There is no evidence that the company requires the involvement of its procurement department in the establishment or oversight of its supplier base.

There is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain.

Based on publicly available information, there is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. This includes policies prohibiting bribery, and those that manage conflicts of interest, and gifts and hospitality.

However, the company receives a score of ‘1’ because it is not clear what steps the company takes to ensure this in practice. In addition, it is not clear that the company assures itself of this for all suppliers and there is no evidence that this assurance is conducted when onboarding new suppliers and/or when there is a significant change in the business relationship. There is also no evidence that the company requires that its suppliers must have a policy on whistleblowing.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations or the associated disciplinary actions relating to its suppliers.

There is no publicly available evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base. It is not clear which entity or department is primarily responsible for supply chain management at the company.

There is some evidence that the company has a procedure to screen and conduct checks on suppliers prior to entering into a business relationship, but it is not clear what these checks include, how frequently they are conducted or whether they amount to full due diligence.

There is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies in place. The company indicates that it expects suppliers to demonstrate high ethical standards as part of its pre-selection requirements, and states in its Standards of Busines Ethics and Conduct that it expects suppliers to develop ethics programmes in line with its own values.

However, the company receives a score of ‘1’ because it is not clear whether the company takes active steps to ensure this in practice.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption incidents, investigations or disciplinary actions relating to its suppliers.

There is no evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base.

There is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain.

There is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place, which prohibit bribery and facilitation payments, and that have procedures related to conflicts of interest and gifts and hospitality. The company also states that it has the right to audit suppliers and that it assures itself on an annual basis of its suppliers’ adherence to its principles.

However, it is unclear if it conducts this assurance for all suppliers, or whether the company assures itself of this whenever there is a significant change in the business relationship. Additionally, there is no evidence that the company’s suppliers are required to have a procedure for whistleblowing.

There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain.

However, this evidence is in the form of a simple statement and it is unclear how the company does this in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers.

There is no publicly available evidence that the company requires the involvement of its procurement department in the establishment and/or oversight of its supplier base.

There is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain.

There is no evidence that the company takes steps to ensure that its suppliers have anti-bribery and corruption policies in place.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

Based on publicly available information, there is evidence that the company´s procurement department is involved in the establishment and oversight of supplier relationships. The company indicates that its Procurement Team is the main body responsible for oversight of the company’s supplier base. There is evidence that the company assures itself of the procurement department’s involvement on an annual basis.

Based on publicly available information, there is evidence that the company has formal procedures to conduct due diligence on all of its suppliers. Due diligence is conducted when engaging with new suppliers. There is evidence indicating that due diligence includes checks on the supplier’s ownership and that the company would be willing to terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated. There is some evidence indicating that the highest risk suppliers are subject to enhanced due diligence. In addition, the company’s information indicates that such checks are repeated regularly throughout the supplier relationship.

Based on publicly available information, there is evidence that the company ensures that all of its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company states that suppliers must adopt a code of conduct equivalent to its own, which covers conflicts of interest, gifts and hospitality and whistleblowing, and prohibits bribery.

In addition, the company states that the Policy for Compliance with Anti-Corruption Acts, which prohibits facilitation payment, applies to suppliers. There is evidence that the company ensures this in practice through contractual terms and assures itself of this when onboarding new suppliers and through monitoring rights in its contracts with third parties.

Based on publicly available information, there is evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. The company indicates that its suppliers ensure that their own subcontractors adhere to its anti-bribery and corruption policy through contractual requirements.

The company provides some information on its ethical investigations relating to suppliers. There is evidence that the company undertook one investigation into a supplier in 2015 which led to corrective measures, and indicates that it has not conducted further investigtaions.

The company receives a score of ‘1’ because there is no evidence that it provides further data on its investigations, nor is it clear that the information provided represents all supplier incidents and allegations.

Based on publicly available information, there is evidence that the company requires the involvement of its procurement department in the establishment of new suppliers. It is clear that this department is ultimately responsible for providing oversight of the company's supplier base. In addition, there is evidence that the company assures itself that it performs proper procedures regarding the onboarding of suppliers on an annual basis, through audits and reviews.

Based on publicly available information, there is evidence that the company has formal procedures to conduct due diligence on all suppliers, with the highest risk suppliers subject to enhanced due diligence.

However, the company receives a score of ‘1’ because it is not clear how frequently the company conducts due diligence, nor that its procedures include checks on beneficial ownership. In addition, there is no clear evidence to suggest that the company might be willing to review or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated. It is noted that the company provides additional policies which may contain more information on its approach to supply chain management, but these documents do not appear to be publicly accessible.

Based on publicly available information, there is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place, including policies that prohibit foreign and domestic bribery and facilitation payments, as well as procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. The company outlines these expectations in both its Supplier Code of Conduct and its Partner Code of Conduct.

In addition, there is evidence that the company ensures itself of partners’ anti-corruption programmes by assessing their programmes and ensuring standards are implemented where gaps are identified. The company indicates that this assurance is carried out when onboarding new suppliers and then regularly throughout the business relationship.

Based on publicly available information, there is evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. The company states that suppliers should conduct corruption due diligence on all third parties and require subcontractors to comply with policies of the same stringency as the company’s Supplier Code of Conduct.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption reports, investigations or associated disciplinary actions involving its suppliers.

There is evidence that the parent company maintains a policy stipulating the involvement of its procurement department in some capacity, in the establishment and oversight of supplier relationships throughout the corporation’s holdings. There is evidence that the parent company’s procurement department is the main body responsible for oversight of the company’s supplier base.

However, the company scores ‘1’ because there is no evidence that the company assures itself of the procurement department’s involvement at least every three years.

There is evidence that the company has formal procedures to conduct anti-corruption-based due diligence on every supplier, as stated in the publicly available group-wide procurement statement produced by its parent company. This policy indicates that a supplier may be ‘removed’ from the procurement process if found to be in breach of certain regulations or if information is found to be inaccurate.

However, the company receives a score of ‘1’ because there is no clear evidence that due diligence includes checks on, at least, ultimate beneficial ownership, nor that highest risk suppliers are subject to enhanced due diligence. There is also no evidence that the company might be willing to review and/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

There is no clear evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is evidence that the company requires the involvement of its procurement department in the establishment of new suppliers and that this department is ultimately responsible for providing oversight of the company's supplier base. There is evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed at least every three years.

There is evidence that the company has formal procedures to conduct corruption-risk based due diligence on all suppliers. There is evidence to suggest that the company might be willing to review and/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence process cannot be mitigated.

However, there is no evidence to suggest that highest risk suppliers are subject to enhanced due diligence, or that the company seeks to independently verify suppliers‘ beneficial ownership. Additionally, although there is some evidence of continuous monitoring of suppliers, there is no clear evidence that the company conducts due diligence on all suppliers at least every two years and/or when there is a change in the business relationship.

There is some evidence that the company ensures that all its suppliers have adequate anti-bribery and corruption policies and procedures in place, by way of requiring suppliers to sign an Integrity Pact at the bid stage. This agreement obliges suppliers to have adequate anti-corruption standards and policies and to abide by all anti-corruption laws and regulations.

However, there is no evidence that the company audits or reviews each supplier’s anti-corruption policies or programme. There is also no evidence that the company requires that all suppliers must have policies prohibiting facilitation payments, as well as policies which cover conflicts of interest, gifts & hospitality, and whistleblowing;
Additionally, there is no evidence as to whether this assurance is only conducted when onboarding new suppliers or also when there is a significant change in the business relationship.

There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain.

However, this evidence is in the form of a simple statement and there is no evidence of how the company would achieve this in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

Based on publicly available information, there is evidence that the company's procurement department is involved in the establishment and oversight of supplier relationships. The company states that employees must work with the Legal and Procurement Departments before appointing new suppliers, and it is clear that all agreements or purchase orders must be authorised and issued by procurement representatives.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself that the proper procurement procedures are being followed in practice, though regular audit or other means.

The company publicly states that it carries out due diligence into certain types of suppliers. The company also states that failure to comply with the its Supplier Code of Conduct could result in a termination of the business relationship.

However, the company receives a score of ‘1’ because it does not provide further publicly available details on its due diligence procedures, for example whether it aims to establish ultimate beneficial ownership of suppliers or whether it conducts enhanced due diligence on high risk suppliers. There is also no clear evidence that the company may be willing to not engage or terminate its relationship with a supplier if any red flags highlighted in the due diligence cannot be mitigated.

Based on publicly available information, there is evidence that the company requires that its suppliers adhere to ethics and anti-corruption principles and to certain compliance procedures. The company indicates that such required procedures include a clear ban on commercial bribery and training for employees, and states that staff of suppliers may use its reporting mechanisms. There is evidence that the company may take measures to assure itself of supplier compliance with its ethics and anti-corruption standards, for example through the possibility of site visits or audits of supplier facilities.

However, the company receives a score of ‘1’ because there is no publicly available evidence that its standards for suppliers include prohibiting facilitation payments and procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. It is also not clear that the company assures itself of its suppliers’ standards for all entities and on a regular basis or when there is a significant change in the business relationship.

There is evidence that the company takes steps to ensure that the standards outlined in its Supplier Code of Conduct, including anti-bribery and corruption provisions, are communicated to sub-contractors throughout the supply chain. The company indicates that all suppliers should have a management system in place which includes a clear process to communicate the standards of its Supplier Code and procedures to monitor compliance with these standards. The company states that it expects these standards from all suppliers.

There is no publicly available evidence that the company publishes data on ethics or corruption-related reports, investigations and disciplinary actions involving its suppliers.

There is evidence that the company requires the involvement of divisional procurement departments in the establishment of all new suppliers. These departments are ultimately responsible for providing oversight of the company's supplier base. There is evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed annually through internal audits. The company states that its procurement procedures are also subject to periodic external audit.

The company has formal procedures to conduct risk-based due diligence on its suppliers. The company states that due diligence checks on all suppliers include checks on ultimate beneficial ownership, and there is some evidence indicating that high risk suppliers are subject to enhanced due diligence. The company states that all suppliers undergo renewed due diligence annually.

However, the company does not commit to not engaging a supplier or terminating a supplier agreement if a red flag identified in due diligence cannot be mitigated.

There is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. It is explicitly stated that all suppliers must have, at a minimum, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, as well as policies and procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. The company encourages suppliers to develop their written policies and provides example policies and procedures on its supplier website. The company states that it carries out an assessment of suppliers’ anti-corruption programmes and procedures, and that this assurance is carried out when there is a significant change in the business relationship.

There is evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain.

However, this evidence is in the form of a simple statement and it is unclear how the company does this in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

Based on publicly available information, there is some evidence that the company's procurement department is involved, in some capacity, in the establishment of supplier relationships.

However, the company receives a score of ‘1’ as it is not clear that the procurement department is the main body responsible for oversight of the company’s supplier base. In addition, there is no evidence that the company assures itself of the procurement department’s involvement at least every three years.

There is no publicly available evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence when engaging or re-engaging with its suppliers.

There is no publicly available evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.

There is no publicly available evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption standards are required throughout the supply chain.

There is no publicly available evidence that the company publishes any data on ethical or anti-bribery and corruption investigations or the associated disciplinary actions relating to its suppliers.

There is evidence that the company has a central Procurement and Strategic Planning department, and that it involves product-specific procurement experts in the selection of suppliers. However, there is no clear evidence that this department is the main body responsible for the establishment and oversight of the company’s entire supply base. There is also no evidence that the company has procedures to assure itself of the proper functioning of its procurement procedures on a regular basis.

There is no publicly available evidence that the company conducts risk-based anti-bribery and corruption due diligence on its suppliers.

Based on publicly available information, there is some evidence that the company requires that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company indicates that such policies must cover bribery, as well as gifts and hospitality. There is evidence that the company includes contractual terms in its agreements with business partners to address these risks.

However, the company receives a score of ‘1’ because there is no publicly available evidence that all suppliers must have policies in place that prohibit facilitation payments, or procedures that address conflicts of interest and whistleblowing. It is also not clear how frequently the company assures itself of the quality of its supplier’s initiatives.

There is no publicly available evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers.

Based on publicly available information, there is some evidence to indicate that the company’s procurement department is involved in the establishment and oversight of supplier relationships.

However, there is no clear evidence that the company assures itself of the procurement department’s proper involvement in the procurement process at least every three years through clearly stated means, such as an audit or other assurance process. In addition, it is not clear from publicly available information that the procurement department is the main body responsible for oversight of the company’s supplier base.

Based on publicly available information, there is some evidence that the company has formal procedures in place to conduct due diligence on suppliers and business partners.

However, it is not clear from publicly available information that the company conducts due diligence on all suppliers. There is no evidence that the company’s due diligence procedures include checks on ultimate beneficial ownership nor that the highest risk suppliers are subject to enhanced due diligence. The frequency of the checks is also unclear and there is no clear evidence to suggest that the company might be willing to review or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

Based on publicly available information, there is no clear evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard. The company states that its compliance programme applies to relevant third party business partners but it is not clear whether this includes suppliers.

There is no publicly available evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or corruption-related reports, investigations or the associated disciplinary actions involving its suppliers.

There is some evidence that the company´s procurement department is involved in the establishment of supplier relationships.

However, the company scores ‘1’ as, based on publicly available evidence, it is not clear that the procurement department is the main body responsible for oversight of the supplier base. There is also no evidence that the involvement of the procurement department is required for establishing any new suppliers over a certain threshold. In addition, there is no evidence that the company assures itself of the procurement department’s involvement at least every three years.

There is no publicly available evidence that the company conducts risk-based anti-bribery and corruption due diligence when engaging or re-engaging with its suppliers.

There is some evidence that the company ensures that its suppliers have adequate anti-corruption policies in place. There is evidence that the company requires that supplies comply with its Supplier Code of Conduct, which prohibits bribery.

However, the company scores ‘1’ as there is no evidence that it requires suppliers to have in place policies that prohibit facilitation payments and that cover conflicts of interest, gifts and hospitality or whistleblowing. There is also no evidence that the company conducts assurance regarding its suppliers’ policies when onboarding new suppliers and when there is a significant change in the business relationship.

Based on publicly available information, there is some evidence that the company takes steps to ensure that the substance of its anti-corruption standards is required of sub-contractors throughout the supply chain. However, this evidence is in the form of a simple statement and it is unclear how the company does this in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations or associated disciplinary actions relating to its suppliers.

There is some evidence that the company has a procurement procedure in place, and that it has a central supplier management process to onboard new suppliers and exercise ongoing oversight of the company’s supply base.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it assures itself that proper processes for its procurement and supplier management system are being followed through clearly stated means, such as an audit or other assurance process, every three years.

There is evidence that the company has formal procedures in place to review and evaluate suppliers before engaging or re-engaging with them. There is evidence that these checks apply to all suppliers and that they include compliance indicators. In addition, the company indicates that its supplier management system is based on a clear assessment of risk and there is some evidence that it conducts such assessments on an annual basis. The company also indicates that it may review or terminate a supplier relationship if it does not pass the assessment process.

However, the company receives a score of ‘1’ because it is not clear from publicly available evidence that its evaluation procedures include establishing the ultimate beneficial ownership of all suppliers.

Based on publicly available information, there is evidence that the company contractually requires suppliers to comply with its Code of Ethics and Legal Compliance. This Code clearly prohibits bribery and facilitation payments, and also includes procedures related to conflicts of interest, gifts and hospitality, and whistleblowing. There is evidence that the company takes active steps to ensure this by including such considerations in its evaluation process, incorporating its Code of Ethics into contractual clauses with suppliers and by conducting periodic audits. The company also indicates that it provides training on its Code of Ethics and Legal Compliance to some international suppliers.

There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. This evidence is in the form of a contractual clause that all obligations in the agreement apply to its sub-contractors.

However, there is no further publicly available evidence to indicate how or whether the company assures itself that standards are adhered to throughout the supply chain in practices. It is also not clear whether the statement relates to obligations around contract delivery or performance, or whether this extends to ethical standards.

There is no evidence that the company publishes any high-level data on ethical or corruption-related investigations or associated disciplinary actions involving its suppliers. The company publishes some data on the reports received through its whistleblowing channel, but there is no publicly available evidence to indicate that this includes reports involving suppliers nor does the company provide disaggregated information on suppliers.

There is evidence that dedicated procurement organisations in each of the company’s business units, as well as a group-level procurement organisation, are involved in the establishment of new suppliers and also hold responsibility for overseeing and managing the company’s supplier base. The company states that it has a corporate-level supplier selection committee, used in reviewing and approving key supplier agreements. There is also evidence that the company maintains proper standards and procedures in procurement activities by way of the corporate procurement organisation providing oversight of and assurance processes for all procurement activities.

Based on publicly available information, there is no clear evidence that the company subjects suppliers to risk-based anti-bribery and corruption due diligence.

There is some evidence that the company requires its suppliers to have anti-bribery and corruption policies in place. The company includes contractual clauses on bribery and corruption in its agreements with suppliers and states that suppliers should uphold the values outlined in its own Code of Ethics.

However, in publicly available information, the company does not explicitly state that all suppliers must have, at a minimum, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, and policies that cover conflicts of interest, gifts & hospitality, and whistleblowing. There is also no evidence that the company takes active steps to ensure that its suppliers have adequate anti-bribery and corruption policies and procedures in place.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

The company does not publish any data on ethical or anti-bribery and corruption investigations relating to its suppliers.

The company publishes some information on its procurement processes, however there is no evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base.

The company indicates that it conducts “corporate social responsibility in supply chain”, but it does not provide further details of this process and there is no clear evidence to indicate that it conducts due diligence on its supply chain.

Based on publicly available information, the company states that it will perform corporate social responsibility in its supply chain. However, there is no further evidence to suggest that this statement refers to the implementation of anti-bribery and corruption policies for its suppliers.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is evidence that the company’s procurement department is involved, in some capacity, in the establishment of new suppliers and that it is the main body responsible for oversight of supplier relationships.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of the procurement department’s appropriate involvement in this process at least every three years.

There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its suppliers.

There is evidence that the company requires suppliers to have anti-bribery and corruption policies that prohibit foreign and domestic bribery, facilitation payments, as well as policies that address gifts, hospitality and whistleblowing. There is evidence that the company requires that its suppliers follow its own Code of Conduct, which includes its anti-bribery and corruption policy.

However, the company receives a score of ‘1’ because it is not clear that the company has provisions in place to ensure that suppliers adhere to these policies, nor that the company conducts assurance of its suppliers’ policies.

Based on publicly available information, there is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain.

However, the company receives a score of ‘1’ because this evidence is in the form of a simple statement and it is unclear how the company does this in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations and the associated disciplinary actions relating to its suppliers.

There is evidence that the company requires the involvement of its procurement department in the establishment of new suppliers. The company indicates that this department is ultimately responsible for providing oversight of the company's supplier base.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it assures itself of this department’s proper involvement in the procurement process, for example through audits of the system, on a regular basis or at least every three years.

There is evidence that the company has formal procedures in place to conduct due diligence on its suppliers. The company indicates that all new suppliers are screened to ensure compliance with ethical practices and all suppliers are monitored on an ongoing basis through various surveys and assessments. There is evidence that highest risk suppliers are subject to enhanced review.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that these due diligence reviews include checks on the ultimate beneficial ownership of suppliers. Although the company indicates that suppliers are monitored on an ongoing basis, it is not clear how frequently these checks are conducted during the supplier relationship. In addition, there is no clear publicly available evidence that the company might be willing to review or terminate supplier relationships if a red flag highlighted in the due diligence cannot be mitigated.

There is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company indicates that all suppliers must have, at minimum, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, as well as policies and procedures relating to gifts and hospitality. There is evidence that the company takes active steps to ensure this, for example by requiring that suppliers abide by the Code of Conduct, which includes procedures related to conflict of interest and whistleblowing. The company ensures that suppliers have adequate bribery and corruption policies when onboarding suppliers and throughout the course of the business relationship.

There is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place and that the substance of its anti-corruption and bribery programme and standards are included in subcontracts throughout the supply chain. This evidence is in the form of a clear statement, and a set of supplier principles that sets the minimum standards of ethical behaviour expected throughout the supply chain.

There is no evidence that the company publishes data on ethical or corruption-related reports investigations or disciplinary actions involving its suppliers.

There is no evidence that the company requires the involvement of its procurement department in the establishment and/or oversight of its supplier base.

There is no evidence that the company conducts due diligence on its supply chain.

There is no evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is no evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base.

Based on publicly available information, there is some evidence that the company conducts due diligence on its business partners. However, the company does not provide further information on this process and there is no evidence that due diligence specifically includes anti-bribery and corruption considerations, so the company receives a score of ‘0’.

Based on publicly available information, there is evidence that the company encourages its suppliers to act in the spirit of its Code of Conduct, which includes its anti-bribery and corruption policy.

However, there is no evidence of steps that the company takes to ensure this in practice, nor whether it assures itself of this for all its suppliers or if this assurance is conducted when onboarding new suppliers or when there is a significant change in the business relationship.

There is some evidence that the company encourages its suppliers to cascade the substance of its Code of Conduct, which includes its anti-bribery and corruption programme and standards, to sub-contractors throughout the supply chain.

However, the company receives a score of ‘1’ because this evidence is in the form of a simple statement and it is unclear what steps the company takes to ensure this in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers.

There is evidence that the company’s procurement department is responsible for establishing all new supplier relationships and for oversight of its supplier base.

However, there is no evidence that the company assures itself of the procurement department’s involvement at least every three years.

Based on publicly available information, there is some evidence that the company undertakes risk-based anti-corruption due diligence on its supply chain.

However, there is no evidence that the due diligence is repeated at least every two years, or that the company might be willing to review or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

Based on publicly available information, there is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. In its Supplier Conduct Principles, the company addresses the bribery, conflicts of interests, gifts and hospitality and whistleblowing procedures that suppliers should have in place. There is also evidence that the company takes active steps to ensure that its suppliers follow the principles, and that it assures itself of this for all new suppliers and on an ongoing basis throughout the duration of the relationship.

Based on publicly available information, there is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme is applied by sub-contractors throughout the supply chain. The company states that it ensures this by requiring audit rights and access to data for contractors throughout its supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

Based on publicly available information, there is evidence that the company’s procurement department is responsible for the establishment of supplier relationships.

However, based on public evidence, it is not clear that the procurement department is the main body responsible for oversight of the company’s supplier base. There is also no evidence that the company assures itself of the procurement department’s involvement at least every three years.

Based on publicly available information, there is evidence that the company has formal procedures to conduct due diligence on its suppliers, and that this includes checks on ownership.

However, there is no clear evidence that anti-bribery and corruption due diligence is repeated at least every two years on whenever there is a change in business relationship. There is also no evidence that the highest risk suppliers are subject to enhanced due diligence. In addition, there is no public evidence to suggest that the company might be willing to review or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

Based on publicly available information, there is evidence that the company requires its suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company’s Code of Conduct applies to business partners, which can be understood to include suppliers. The Code of Conduct includes prohibition of bribery and facilitation payments as well as policies related to conflicts of interest, gifts and hospitality and whistleblowing. The company requires suppliers to pledge to comply with the ethical rules that the company has set. There is evidence indicating that the company assures itself of this when onboarding new suppliers and periodically monitors third parties’ compliance with its anti-bribery policies.

There is no clear evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations or disciplinary actions involving its suppliers.

There is some evidence that the company’s procurement department is involved, in some capacity, in the establishment and oversight of supplier relationships.

However, there is no evidence that the involvement of the procurement department is required for establishing any new suppliers over a certain threshold. It is not clear from publicly available evidence that the procurement department is the main body responsible for oversight of the company’s supplier base. There is also no evidence that the company assures itself of the procurement department’s involvement at least every three years.

There is no evidence that the company conducts risk-based anti-bribery and corruption due diligence on its supply chain.

While there is evidence that the company requires suppliers to comply with applicable anti-corruption laws, there is nothing to suggest that it ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is evidence that the company’s procurement department oversees and manages all the company’s procurement activities, and that this body is the main body responsible for coordinating procurement activities.

However, the company receives a score of ‘1’ because there is no evidence that it assures itself that proper procedures regarding the onboarding of suppliers are followed through a clearly stated means, such as an audit, at least every three years.

There is evidence that the company has formal procedures in place to conduct risk-based anti-corruption due diligence on all third parties, which includes its suppliers. There is evidence that the company establishes ultimate beneficial ownership as part of due diligence and that it performs enhanced due diligence on any suppliers and third parties identified as high risk.

However, there is no clear evidence that the company conducts due diligence on suppliers at least every two years or when there is a significant change in the business relationship. It is also not clear from publicly available information that the company may be willing to review and or/terminate supplier relationships when red flags highlighted in the due diligence process cannot be mitigated. It is noted that the company has a separate policy detailing its due diligence procedures and requirements, but this document does not appear to be publicly available.

There is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company states that all suppliers must have policies in place that prohibit foreign and domestic bribery and facilitation payments, as well as procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. The company publishes a Supplier Code of Conduct which applies to all third parties and business partners, and indicates that all suppliers must meet, at a minimum, the standards laid out in this document. In addition, there is evidence that the company ensures this compliance at the start of the business relationship and through periodic reviews thereafter.

There is evidence that the company encourages suppliers to flow down the principles and standards outlined in its Supplier Code of Conduct to subcontractors. The company also expects its suppliers to ensure that their anti-corruption standards are maintained throughout their supply chains, for instance by performing due diligence on the third parties with which they engage.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption related reports, investigations or associated disciplinary actions involving its suppliers.

There is evidence that the company has a specialist procurement programme that oversees its supplier relationships. There is clear evidence that this department is ultimately responsible for providing oversight of the company's supplier base and that this is the main body responsible for all supplier relationships.

However, the company receives a score of ‘1’ because there is no clear evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means, such as an audit, at least every three years.

There is no publicly available evidence that the company conducts risk-based anti-bribery and corruption due diligence on its suppliers. The company indicates that it conducts due diligence on third party intermediaries, but it is not clear from publicly available information that similar standards are in place for suppliers.

There is some evidence that the company ensures that all suppliers have adequate anti-bribery and corruption policies and procedures in place. The company indicates that suppliers must adhere to its code of conduct and encourages suppliers to have anti-corruption policies which mirror those of the company’s and an equivalent ethics and anti-corruption programme.

However, the company receives a score of ‘1’ because there is no publicly available evidence that its policy provides further details of the practical measures that it takes to ensure that suppliers have robust anti-corruption programmes in place. There is also no clear evidence that the company carries out audits or assessments of its suppliers’ anti-corruption programmes, nor that it assures itself of suppliers’ adherence to anti-corruption standards and principles during the onboarding stage or on a regular basis thereafter.

There is evidence to indicate that the company expects its suppliers to conduct all business ethically and with integrity and. However, there is no clear publicly available evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of subcontractors throughout the supply chain, for example through clear audits, contractual clauses or dedicated training.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations or the associated disciplinary actions involving its suppliers.

Based on publicly available information, there is evidence that the company requires the involvement of its procurement department in the establishment of new suppliers. This department is ultimately responsible for providing oversight of the company's supplier base. The company assures itself that proper procedures regarding the onboarding of suppliers are followed through an annual audit.

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based due diligence when engaging and re-engaging with any suppliers. The due diligence process explicitly includes establishing the ultimate beneficial ownership of the supplying company. There is evidence indicating that the highest risk suppliers are stated to be subject to enhanced due diligence. This process is conducted at least every two years or when there is a significant change in the business relationship. The company indicates that supplier relationships will be subject to review, and potential termination, if any red flags highlighted in the due diligence cannot be mitigated.

Based on publicly available information, there is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. It is explicitly stated that all suppliers must have policies that prohibit bribery and facilitation payments, as well as those that address conflicts of interest, gifts and hospitality and whistleblowing. There is evidence that the company takes active steps to ensure this by requiring that all suppliers follow the anti-bribery policies and procedures of the company and the Supplier Code of Conduct. The company assures itself of this by contractually requiring this with every purchase order.

Based on publicly available information, there is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place and that the substance of its anti-corruption and bribery programme and standards are included in subcontracts throughout the supply chain. This evidence is in the form of a clear statement about the minimum standards of ethical behaviour expected throughout the supply chain, which the company enforces through its contracts with its own suppliers.

The company publishes high-level data from all ethical, bribery or corruption-related incidents and investigations involving suppliers. This includes the number of investigations launched and the number of disciplinary actions as a result of investigation findings. This data is published on an annual basis covering cases in the past 12 months.

There is evidence that the company's procurement department is involved in the establishment and oversight of supplier relationships.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that this procurement department is the main body responsible for oversight of all of supplier relationships, nor is there evidence that the company assures itself of the procurement department’s proper involvement in this process at least every three years.

There is evidence that the company has formal procedures to conduct due diligence on all of its suppliers. The company indicates that due diligence is conducted before engaging with new suppliers and is repeated when renewing the contracts.

However, the company receives a score of ‘1’ because there is no evidence that due diligence includes checks on ultimate beneficial ownership or that highest risk suppliers are subject to enhanced due diligence. There is also no evidence that due diligence is repeated at least every two years or when there is a significant change in the business relationship. Additionally, the company the company does not state that it would be willing to review or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

There is evidence that the company requires its suppliers to have adequate anti-bribery and corruption policies and procedures in place. There is evidence that the company takes active steps to ensure this, by requiring that suppliers follow its Code of Ethics and by including anti-corruption terms in its contracts.

However, the company receives a score of ‘1’ because it does not explicitly state that all suppliers must have, at least, policies that prohibit facilitation payments and policies that cover gifts & hospitality or whistleblowing. It is also unclear whether the company assures itself of its suppliers’ adherence to its policies when onboarding and when there is a significant change in the business relationship.

There is no publicly available evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations or the associated disciplinary actions relating to its suppliers.

There is evidence that the company’s Global Supply Chain Operations department is the sole authority involved in procuring goods and services, and it is clear that this department provides oversight of the company’s supply base.

However, although the company states that it has procedures for ensuring procurement professionals follow the required onboarding processes for suppliers, it does not provide further details. There is no evidence, for example, that the company conducts an audit of the onboarding process at least every three years.

There is evidence that the company has formal procedures to conduct risk-based due diligence when engaging with suppliers. This process explicitly includes establishing the ultimate beneficial ownership of the supplier. Moreover, there is evidence to suggest that the company would not be willing to proceed with a supplier relationship in circumstances where a red flag highlighted cannot be mitigated, although the company does not explicitly state it would terminate existing supplier relationships in these circumstances. The company also indicates that it undertakes enhanced due diligence on suppliers operating in high-risk jurisdictions.

However, although the company states that due diligence is periodically reassessed and updated, it is not clear that due diligence on suppliers is repeated at least every two years or whenever there is a change in the business relationship.

There is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. In its Supplier Code of Conduct, the company outlines its expectations for suppliers, including its policies prohibiting bribery and facilitation payments, as well as those covering conflicts of interest, gifts & hospitality and whistleblowing. There is evidence that the company takes active steps to ensure this by providing training materials and a self-assessment tool on its website for suppliers to benchmark their own policies and procedures, as well as by requiring suppliers to fill out a questionnaire about these topics. The company assures itself of this when onboarding new suppliers or when there is a significant change in the business relationship.

There is evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. This is in the form of contractual requirements that are flowed down through the supply chain.

The company states that it includes investigations into suppliers in its annual data on ethics contacts and investigations.

However, supplier investigations are not disaggregated from investigations involving employees.

There is no publicly available evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base. The company indicates that it has a Procurement Manual which may include more information on this subject, but this does not appear to be publicly available.

There is no publicly available evidence that the company conducts risk-based anti-bribery and corruption due diligence on its supply chain. The company states that it conducts due diligence on its vendors and indicates that this includes compliance; however there is no evidence that such checks are risk-based, nor that they specifically include an anti-bribery and corruption component.

There is evidence that the company requires that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company indicates that suppliers must comply with its Supplier Code of Conduct, which requires suppliers adopt policies that prohibit bribery and facilitation payments, as well as procedures to address conflicts of interest, gifts and hospitality, and whistleblowing.

However, the company receives a score of ‘1’ because there is no clear evidence that it assures itself of this when onboarding new suppliers and when there is a significant change in the business relationship.

There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. However, this evidence is in the form of a simple statement and it is unclear how the company does this in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption incidents, investigations or disciplinary actions relating to its suppliers.

There is evidence that the institute requires the involvement of its procurement department in the establishment of new suppliers. This department is ultimately responsible for providing oversight of the company's supplier base. However, the institute receives a score of ‘1’ because there is no evidence that it takes steps to assure itself that proper supplier onboarding procedures are followed through clearly stated means, such as an audit, at least every three years.

There is no evidence that the institute conducts anti-bribery and corruption due diligence on its supply chain.

There is some evidence that the institute ensures that its suppliers adhere to its terms and conditions, including compliance and purchasing ethics. However, the institute does not explicitly refer to anti-bribery and corruption in its terms and conditions, and does not provide any details relating to specific anti-bribery and corruption measures.

There is no evidence that the institute takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the institute publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is some evidence that the company's procurement department is involved in the establishment and oversight of supplier relationships. However, there is no clear evidence that the procurement department is the main body responsible for oversight of the company’s supplier base, nor is there evidence that the company assures itself of the procurement department’s involvement at least every three years.

There is some evidence that the company has formal procedures in place to conduct annual risk based due diligence on its suppliers. There is some evidence to indicate that the company might be willing to review or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated. However, it is not clear from publicly available information that the company’s due diligence includes checks on the beneficial ownership of suppliers.

There is some evidence that the company requires that its suppliers be aware of its Business Ethics Policy. The company indicates that it only does business with suppliers that adhere to ethical business principles. However, the company receives a score of ‘1’ because there is no evidence to indicate how the company assures itself that its suppliers to have anti-bribery and corruption policies in place that meet a high standard.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations or associated disciplinary actions involving its suppliers.

Based on publicly available information, there is evidence that the company’s procurement department is the main body responsible for oversight of the company’s supplier base. It is clear that this function is responsible for onboarding, managing and ensuring compliance of all suppliers.

However, the company receives a score of ‘1’ because there is no publicly available evidence that the company assures itself that its procurement department is appropriately functioning and involved in all supplier management at least every three years.

Based on publicly available information, there is no clear evidence that the company conducts anti-bribery and corruption due diligence on all suppliers. The company indicates that it conducts due diligence on commercial arrangements, but it does not provide any further publicly available information on its procedures. For example, there is no evidence that such checks include establishing the beneficial ownership of the supplier, nor that high risk suppliers are subject to enhanced due diligence or that such checks are undertaken frequently.

Based on publicly available information, there is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company requires suppliers to follow its Code of Conduct, Anti-Corruption Policy and other Group policies, all of which prohibit bribery and facilitation payments and address conflicts of interest, gifts & hospitality and whistleblowing. The company also indicates that suppliers may implement their own equivalent standards. There is evidence that the company conducts audits of its suppliers.

However, the company receives a score of ‘1’ because there is no clear evidence that the company conducts assurance when onboarding new suppliers and when there is a significant change in the business relationship.

Based on publicly available information, there is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. The company has procedures in place to ensure this, in the form of a contractual commitment.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption related investigations or the disciplinary actions involving its suppliers.

There is no evidence that the organisation requires the involvement of its procurement department in the establishment and oversight of its supplier base.

There is no evidence that the organisation conducts anti-bribery and corruption due diligence on its supply chain.

There is no publicly available evidence that the organisation requires its suppliers to have their own anti-bribery and corruption policies and procedures in place. The organisation’s Code of Ethics and Conduct applies to contractors; however, this refers to general standards of ethical business conduct and, with the exception of conflicts of interest, does not provide the level of detail of anti-bribery and corruption controls necessary to receive a score of ‘1’.

There is no evidence that the organisation takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the organisation publishes any data on ethical or anti-bribery and corruption-related investigations relating to its suppliers, or the associated disciplinary actions.

There is some evidence that the company’s purchasing division is involved in the oversight of its supply chain.

However, the extent the purchasing division is involved in the oversight of the supplier base is unclear. In addition, there is no evidence that the company requires the involvement of its procurement department in the establishment of its supplier base.

There is no clear evidence that the company conducts due diligence on its supply chain. The company’s Annual Report indicates that it evaluates and reviews its relationship with its suppliers periodically but it is not clear that this constitutes formal due diligence nor that such reviews take into account anti-bribery and corruption risks.

There is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company clearly states that all suppliers must have, at minimum, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, as well as policies and procedures to address gifts and hospitality and whistleblowing. There is evidence that the company takes active steps to ensure this by requesting that all suppliers follow its own anti-bribery policies and procedures and by requesting them to sign an agreement to implement CSR guidelines in their company.

However, the company receives a score of ‘1’ there is no evidence that suppliers must have policies in place covering conflicts of interest. It is also not clear that any assurance is conducted when there is a significant change in the business relationship.

There is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place and that the substance of its anti-corruption and bribery programme and standards are included in subcontracts throughout the supply chain. This evidence is in the form of a set of supplier principles that sets the minimum standards of ethical behaviour expected throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is some evidence that the company has a procurement policy, however there is no clear publicly available evidence that the company requires and ensures the involvement of its procurement department in the establishment of new supplier relationships. There is also no evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means, such as an audit or other assurance process, at least every three years.

Based on publicly available information, there is some evidence the company has formal procedures to conduct anti-corruption due diligence when engaging with third parties. However, there is no evidence that the company provides further details on its due diligence process and it is unclear whether suppliers specifically are subject to due diligence.

Based on publicly available information, there is no clear evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard. There is no clear evidence that the Group Global Code of Conduct applies to suppliers.

There is no publicly available evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes high-level results from ethics-related reports, investigations and disciplinary actions against suppliers.

There is evidence that the company's procurement department is involved, in some capacity, in the establishment and oversight of supplier relationships. Evidence indicates that this department is the main body responsible for oversight of the company’s supplier base.

However, the company receives a score of ‘1’ because it is unclear if the involvement of the procurement department is required for establishing new suppliers over a certain threshold. There is also no evidence that the company assures itself of the procurement department’s involvement at least every three years.

The company states that it will only work with suppliers that have equivalent ethical policies. However, there is insufficient evidence indicating that it conducts risk-based anti-corruption due diligence on its supply chain.

The company states that suppliers must meet a certain standard of ethical business conduct. However, it does not refer to any specific anti-bribery and corruption measures that its suppliers must have in place, such as specific policies prohibiting domestic bribery and facilitation payments, or policies covering conflicts of interest, gifts & hospitality.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

Based on publicly available information, there is evidence that the company’s procurement department is involved in the establishment and oversight of supplier relationships. The company states that a central procurement department is responsible for the onboarding and review of the supplier base, while noting that in some smaller entities this process is managed by a specific procurement or supply chain manager.

However, the company receives a score of ‘1’ because it does not provide any publicly available information to indicate that it assures itself of the procurement department’s involvement in the onboarding and management process at least every three years.

Based on publicly available information, there is evidence that the company has formal procedures in place to conduct risk-based due diligence when engaging and re-engaging with suppliers. The company indicates that the degree of due diligence is dependent on a number of factors including type, size and geographic location of the supplier, and states that various red flags and sanctions list are checked during the process. There is evidence that highest risk – termed ‘critical’ in the company’s documents – are subject to enhanced due diligence and self-assessment requirements every two years.

However, the company receives a score of ‘1’ because it does not clearly indicate that this due diligence process includes establishing the ultimate beneficial ownership of the supplying company. There is also no clear evidence to suggest that the company might review or possibly terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

Based on publicly available information, there is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company outlines these expectations in its Supplier Conduct Principles, which stipulates standards on facilitation payments, gifts and hospitality and whistleblowing. In addition, the company states that suppliers must comply with its Ethical Code of Conduct which contains similar standards covering these areas. There is evidence that the company takes active steps to ensure that these standards are being upheld, for example by requiring that all suppliers complete a self-assessment as part of the onboarding process, conducting annual reviews on a selection of companies and by cooperating with suppliers to improve their policies if necessary.

There is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption policies and procedures in place, and that the substance of its anti-bribery and corruption programme is included in sub-contracts throughout the supply chain. The company clearly indicates in its Supplier Conduct Principles that it expects suppliers to flow down these standards throughout the supply chain, and states that it performs regular audits and reviews to assure itself that these standards are upheld in practice.

Based on publicly available information, there is no evidence to indicate that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers.

The company publishes a statement in its 2019 Sustainability Report that no “negative social impacts” were recorded in relation to its supply chain; however it is not sufficiently clear that this relates to ethics and compliance, instead of other social considerations such as compliance around the environment or modern slavery.

There is evidence that the company's procurement department is involved, in some capacity, in the establishment and oversight of supplier relationships. The company says that it has an independent procurement organisation that ensures separation of decision-making with regard to suppliers and competitive bidding. The procurement department coordinates a procurement policy orientation committee where supplier lists are approved. There is evidence that the procurement department is involved in the establishment of new suppliers. The procurement director additionally chairs a committee responsible for assessing supplier risks.

However, there is no evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means, such as an audit, at least every three years.

The company has formal procedures to conduct risk-based due diligence when engaging and re-engaging with any suppliers. The due diligence process explicitly includes, at minimum, establishing the ultimate beneficial ownership of the supplying company. Highest risk suppliers are stated to be subject to enhanced due diligence. The company's due diligence procedure is accompanied by a clear statement that supplier relationships will be subject to review, and potential termination, if any red flags highlighted in the due diligence cannot be mitigated.

However, due diligence is updated at least every three years rather than every two years.

There is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company’s Supplier Code of Conduct requires suppliers to have their own policies that prohibit bribery and cover conflicts of interest and whistleblowing. Although the Supplier Code of Conduct does not explicitly refer to prohibition of facilitation payments and policies on gifts and hospitality, suppliers are separately expected to follow the company’s own integrity principles, which cover all of these areas. The company assures itself of its suppliers’ adherence to these principles when onboarding new suppliers and throughout the duration of the supplier relationship, through the inclusion of audit and termination rights in its contracts.

There is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place and that the substance of its anti-corruption and bribery programme and standards are promoted throughout the supply chain. This evidence is in the form of a clear statement, short description or set of supplier principles that sets the minimum standards of ethical behaviour expected throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is evidence that the company’s Procurement Committee is the main body that is involved in, and responsible for, oversight of supplier relationships. The company states that this committee is responsible for verifying and approving proposals to establish new suppliers, and stipulates procedures to escalate the matter if the committee cannot reach a decision. Moreover, there is evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through regular internal audit and quality assurance checks.

Although the company does not explicitly state that it conducts this type of assurance every three years, a score of ‘2’ has been awarded based on supporting evidence.

There is evidence that the company has formal procedures to conduct risk-based due diligence when engaging and re-engaging with its suppliers. The due diligence process explicitly includes establishing the ultimate beneficial ownership of the supplying company, and there is evidence that highest risk suppliers are subject to enhanced due diligence. There is evidence that this process is conducted on an ongoing basis, and when there is a significant change in the business relationship. There is also evidence that suggests that the company is willing to review and terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

There is evidence that the company requires that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company states that all of its business partners (which is understood to include suppliers) must comply with the standards outlined in its anti-corruption manual, which prohibits bribery, facilitation payments and specify procedures on conflicts of interest, gifts and whistleblowing. There is evidence that the company assures itself of this when onboarding new suppliers, by introducing anti-corruption clauses in their contracts, and on an ongoing basis, by having monitoring rights on its suppliers to ensure their continued compliance with these policies.

Although the company states that it conducts legal reviews on sub-contractors, there is no clear evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

The company publishes a statement that no supplier wrongdoing was determined during the most recent reporting year relating to violations of its Code of Business Conduct, which covers bribery and corruption. The company’s publicly available evidence indicates that this information is updated annually.

However, the company receives a score of ‘1’ because the data published does not include the number of reports received, nor investigations launched.

There is no evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base.

Based on public evidence, the company has formal procedures to conduct due diligence on its suppliers.

However, there is no evidence that the due diligence process includes checks on, at least, ultimate beneficial ownership. There is also evidence that due diligence is only conducted before engaging suppliers and the frequency of the checks is unclear. There is no evidence to suggest that the company might be willing to review and terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

Based on public information, there is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. It is explicitly stated that all suppliers must have, at a minimum, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, as well as policies and procedures to address gifts and hospitality, and whistleblowing.

However, the company does not explicitly state that all suppliers must have conflict of interest policies, it is unclear how the company ensures this in practice and there is no evidence to suggest that the company takes active steps to ensure that its suppliers have adequate anti-bribery and corruption policies and procedures in place. It is also unclear whether this assurance is conducted when onboarding new suppliers and/or when there is a significant change in the business relationship.

Based on public information, there is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain.

However, this evidence is in the form of a simple statement and it is unclear how the company does this in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is some evidence that the company has a purchasing department, which is involved, in some capacity, in the establishment and oversight of supplier relationships.

However, there are limited details available regarding the role of the purchasing department and its interaction with business units. For example, the company does not state that the involvement of the purchasing department is required for establishing any new suppliers over a certain threshold. It is not clear that the purchasing department is the main body responsible for oversight of the company’s supplier base and there is no evidence that the company assures itself of the purchasing department’s involvement at least every three years.

The company has formal procedures to conduct due diligence on its suppliers, which include checks on ultimate beneficial ownership. There is also evidence to suggest that the highest risk suppliers are subject to enhanced due diligence

However, it is unclear whether due diligence is repeated after onboarding and if so how frequently. There is also no evidence to suggest that the company might be willing to review and/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence process cannot be mitigated.

There is evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard. The company indicates that ensures this through the inclusion of anti-bribery and corruption clauses in its contracts with suppliers, and that prior to engaging suppliers it conducts an assessment of their business practices to ensure they meet its own standards.

However, the company does not explicitly state that all suppliers must have, at least, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, and/or policies that cover conflicts of interest, gifts & hospitality, or whistleblowing. Additionally, it is unclear whether the company assures itself of its suppliers’ anti-bribery and corruption policies and procedures when there is a significant change in the business relationship.

There is no publicly available evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards is required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is no publicly available evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base. The company indicates that the procedures in place for its supply chain are integrated into its wider third party processes, however there is no clear evidence that a central procurement department is the main body responsible for establishing and monitoring supplier relationships.

Based on publicly available information, there is evidence that the company has formal procedures in place to conduct risk-based due diligence when engaging and re-engaging with any suppliers. The company’s due diligence process clearly includes establishing the ultimate beneficial ownership of the supplying company, and there is evidence indicating that the highest risk suppliers are subject to enhanced due diligence.

In addition, there is evidence that the company refreshes its due diligence periodically and when there is a change in the risk profile of the supplier. There is also some evidence to suggest that the company might be willing to review or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence process cannot be mitigated.

Based on publicly available information, there is evidence that the company requires that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company clearly states that all suppliers must comply with its Supplier Standards of Business Conduct, which prohibits bribery and facilitation payments, and outlines procedures on conflicts of interest, gifts and hospitality, and whistleblowing. The company takes active steps to ensure this at the start of the relationship by including these provisions in its contractual agreements, and through a review when there is a change in the relationship with the supplier.

Based on publicly available information, there is some evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place. The company states that it conducts due diligence on lower tier subcontractors in high risk transactions and indicates that it may require the supplier to take steps to cascade anti-corruption compliance to lower tiers. In addition, the company’s Supplier Standards of Business Conduct requires that such entities conduct anti-corruption due diligence on their own sub-contracts.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption reports, investigations or disciplinary actions involving its suppliers.

There is no evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base.

There is evidence that the company has formal procedures to conduct risk-based due diligence when engaging and re-engaging with suppliers. The due diligence process explicitly includes establishing the ultimate beneficial ownership of the supplying company. The company's due diligence procedure is accompanied by a clear statement that supplier relationships will be subject to review, and potential termination, if any red flags highlighted in the due diligence cannot be mitigated.

However, the company receives a score of ‘1’ because there is no evidence that higher risk suppliers are subject to enhanced due diligence. In addition, there is no evidence that the company includes suppliers in its definition of “Intervening Third Parties” referenced in its policy.

There is evidence that the company requires that its suppliers have adequate anti-bribery and corruption policies and procedures in place. There is evidence that the company requires that all third parties must observe the company’s own Anti-corruption Policy document, which is inclusive of policies that prohibit foreign and domestic bribery, prohibit facilitation payments, as well as policies and procedures to address conflicts of interest, gifts and hospitality, and whistleblowing.

However, the company receives a score of ‘1’ because the evidence suggests that it only assures itself of this when onboarding new suppliers and there is no evidence that it does so when there is a significant change in the business relationship. In addition, although there is evidence that the company requires suppliers to sign task orders, it is unclear what the contractual obligations are under such agreements, and it is therefore unclear whether the company assures itself in practice of its suppliers’ adherence to its anti-bribery and corruption policies. Finally, there is no evidence that the company’s policies relating to intervening third parties includes suppliers in its definition.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is no publicly available evidence that the company requires and ensures the involvement of its procurement department in the establishment and oversight of its supplier base. There is some evidence that the company has a procurement policy which outlines the company’s approach to selecting and managing suppliers, but this does not assign responsibility for oversight to a specific body, department or team.

There is no evidence that the company conducts anti-bribery and corruption due diligence on its suppliers. There is some evidence that the company has a procedure for the selection of suppliers, but it is not clear that this includes due diligence and/or anti-corruption considerations.

Based on publicly available information, there is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies in place. The company states that all suppliers are requested to refrain from engaging in bribery – including through gift-giving, entertainment and political donations – however there is no mention of conflicts of interest or whistleblowing. There is also no evidence that the company takes steps to assure itself that these standards are in place when there is a significant change in the business relationship.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption-related investigations relating to its suppliers, or related disciplinary actions.

There is some evidence that the company's procurement department is responsible for oversight of the company’s supplier base.

However, in publicly available evidence the company does not does not state that the involvement of the procurement department is required for establishing any new suppliers over a certain threshold. There is also no evidence that the company assures itself of the procurement department’s involvement at least every three years.

In publicly available evidence, the company simply states that it conducts due diligence on third parties, without providing any further details.

There is some evidence that the company ensures that all its suppliers have anti-bribery and corruption policies in place. The company states that at a minimum, suppliers must adhere to its Code of Conduct and Supplier Code Of Conduct, which prohibit bribery, and include provisions addressing conflicts of interest, gifts and hospitality, and whistleblowing. There is evidence that the company monitors its suppliers and may terminate relationships if they are found to be noncompliant with its policy.

However, there is no publicly available evidence that the company conducts assurance when onboarding new suppliers or when there is a significant change in the business relationship.

There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain.

However, this evidence is in the form of a simple statement and it is unclear how the company does this in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

Based on publicly available information, there is evidence that the company’s procurement department is involved, in some capacity, in the establishment of supplier relationships.

However, there is no evidence that the involvement of the procurement department is required for establishing all new suppliers. There is no evidence that the company assures itself of the procurement department’s involvement at least every three years.

Based on publicly available information, there is evidence that the company has formal procedures to conduct due diligence on all of its suppliers. There is evidence that the due diligence process includes checks on beneficial ownership and that the highest risk suppliers are subject to enhanced due diligence. There is evidence that the company conducts due diligence when engaging or re-engaging with suppliers, and that in instances when red flags highlighted in the due diligence process cannot be mitigated it will not engage with the supplier.

Based on publicly available information, there is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies in place. There is evidence that the company requires its suppliers to sign a declaration at the outset of its relationship stating that they will not engage in bribery and unethical conduct, and there is also evidence that the company expects its suppliers to adhere to its Code of Conduct, which is inclusive of bribery, facilitation payments, conflicts of interest, gifts and hospitality and whistleblowing, or to adopt similar policies. The company states that for critical suppliers it ensures this through contractual terms.

However, the company receives a score of ‘1’ because there is no clear publicly available evidence that the company requires anti-bribery and corruption contractual terms for all of its suppliers, nor that it takes active steps to ensure compliance with these standards in practice.

Based on publicly available information, there is some evidence that the company takes steps to ensure that the substance of its ethical and compliance programme is required of sub-contractors throughout the supply chain. However, the company receives a score of ‘1’ because it is not clear how the company does this in practice.

The company makes a public statement that there were no reports, investigations or disciplinary actions relating to suppliers during the most recent reporting year.

There is no publicly available evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base.

There is some evidence to suggest that the company conducts due diligence on its supply chain, however, the company does not provide sufficient detail to receive a score of ‘1’.

There is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. Suppliers are required to comply with the company’s Contingent Worker Code of Conduct, which prohibits bribery and facilitation payments, and also includes procedures to address conflicts of interest, gifts and hospitality, and whistleblowing.

However, there is no clear evidence that the company assures itself of this when onboarding new suppliers and when there is a significant change in the business relationship.

There is evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. It ensures this by requiring that its suppliers obtain its written approval before engaging any subcontractors, and that subcontractors adhere to its Code of Conduct.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is no evidence that the company requires the involvement of its procurement department in the establishment and/or oversight of its supplier base. The company publishes some information on tenders on its website but there is no clear indication that a specific department is engaged in the oversight of supplier relationships.

There is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain.

There is no evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

Based on publicly available information, there is evidence that the company's procurement department is involved in the establishment and oversight of supplier relationships. It is clear that the procurement department is the main body responsible for oversight of the company’s supplier base.

However, the company receives a score of ‘1’ because there is no evidence that it assures itself of the procurement department’s involvement at least every three years through clearly stated means, such as an audit or other assurance process.

Based on publicly available information, there is evidence that the company conducts due diligence on all of its suppliers. This includes evidence that third parties are required to complete a due diligence questionnaire before engaging with the company, which is understood to include suppliers. There is evidence that the questionnaire includes a question regarding ultimate beneficial ownership, and that the company might be willing to review or terminate its relationship with third parties where risks identified in the due diligence cannot be mitigated.

However, there is no evidence to suggest that highest risk suppliers are subject to enhanced due diligence. Furthermore, there is no evidence that due diligence is repeated at least every two years or whenever there is a change in the business relationship.

There is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. It is explicitly stated that all suppliers must have, at minimum, policies that prohibit bribery, and cover conflicts of interest and gifts and hospitality. There is evidence that the company ensures this by requiring that its suppliers adhere to the Poongsan Business Partner Code of Conduct. There is also evidence that the company asks for evidence of anti-bribery policies as part of its Third Party Due Diligence Questionnaire, which is required when engaging with third parties. It is understood that this includes suppliers.
However, the company does not explicitly state that all suppliers must address whistleblowing. Furthermore, it is unclear whether assurance is conducted when there is a significant change in the business relationship.

Based on publicly available information, there is evidence that the company takes steps to ensure that the principles of the Poongsan Business Partner Code of Conduct is required of sub-contractors throughout the supply chain. However, this is in the form of a simple statement and it is unclear how the company does this in practice.

Although there is also evidence that the company asks for details about subcontractors and their activities in its Third Party Due Diligence Questionnaire, it is not clear whether the company uses this information to ensure that they have adequate anti-bribery and corruption programmes in place.

There is no evidence to indicate that the company publishes any data on ethical, bribery or corruption-related investigations or disciplinary actions involving its suppliers.

There is no publicly available evidence that the company requires the involvement of its procurement department in the establishment or oversight of its supplier base.

There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its supply chain.

There is no evidence that the company takes steps to ensure that its suppliers have anti-bribery and corruption policies in place that meet a high standard.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations, or the associated disciplinary actions, relating to its suppliers.

There is evidence that the company's procurement department is involved, in some capacity, in the establishment and oversight of supplier relationships.

However, there is no evidence that the company assures itself of the procurement department’s involvement at least every three years.

There is evidence that the company has formal procedures to conduct risk-based due diligence when engaging and re-engaging with its suppliers. The due diligence process explicitly includes establishing the ultimate beneficial ownership of the supplier. Highest risk suppliers are stated to be subject to enhanced due diligence.

However, there is no evidence to suggest that the company might be willing to review or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence process cannot be mitigated and due diligence is only conducted before engaging with new suppliers and is not repeated at least every two years or whenever there is a change in the business relationship.

There is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. It is explicitly stated that all suppliers must have, at a minimum, policies that prohibit bribery and facilitation payments, as well as policies and procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. There is some evidence that the company takes active steps to ensure this, by requiring suppliers to put in place policies and procedures to ensure they comply with the company’s Supplier Code of Conduct.

However, it is unclear whether the company assures itself that such policies are in place when onboarding new suppliers or when there is a significant change in the business relationship.

There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain.

However, this evidence is in the form of a simple statement and it is unclear how the company does this in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or any associated disciplinary actions.

There is no evidence that the company requires the involvement of its procurement department in the establishment or oversight of its supplier base.

There is evidence that the company has formal procedures to conduct due diligence when engaging and re-engaging with all business partners, which includes suppliers. There is evidence that the process includes obtaining ownership information for business partners, although the company does not specifically commit to establishing ultimate beneficial ownership. There is evidence that higher risk business partners are subject to enhanced due diligence and that the company states that it will not engage with a business partner if red flags highlighted in the due diligence process cannot be mitigated.

However, while the company states that the due diligence process is conducted at least every two years or when there is a significant change in the business relationship for its highest risk business partners, it is not clear how frequently the company conducts due diligence on standard suppliers, i.e. those not identified as high risk.

There is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company states that all suppliers must have, at minimum, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, as well as policies and procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. There is evidence that the company takes active steps to ensure this, for example by requiring that all suppliers follow its own anti-bribery policies and procedures. The company states that it obtains written agreements from suppliers to comply with anti-corruption laws. The company assures itself of this when onboarding new suppliers or when there is a significant change in the business relationship.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

Based on publicly available information, there is evidence that the company requires the involvement of its procurement department in the establishment of new supplier relationships and that this department is responsible for providing oversight of the company's supplier base. There is evidence indicating that the company assures itself that proper procedures regarding the onboarding of suppliers are followed on at least an annual basis.

Based on publicly available information, there is evidence the company has formal procedures to conduct risk-based due diligence when engaging and re-engaging with any suppliers. The due diligence process includes establishing the ultimate beneficial ownership of the supplying company with the highest risk suppliers subject to enhanced due diligence. The company indicates that this process is conducted at least every two years or as a result of changes in the business relationship such as contract modifications. There is evidence that the company's due diligence procedure is accompanied by a clear statement that the company will terminate or not proceed with a supplier relationship if a red flag identified in due diligence cannot be mitigated.

Based on publicly available information, there is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company states that all suppliers must adhere to, or maintain its own policies equivalent to, its Code of Conduct. There is evidence that this document prohibits domestic and foreign bribery, corrupt activity and contains procedures to manage conflicts of interest, gifts and hospitality, and whistleblowing and reporting procedures.

In addition, there is evidence that the company requires its suppliers to comply with the Code of Conduct as part of the contractual agreement. There is some evidence that the company conducts assurance when onboarding new suppliers and on an ongoing basis.

Based on publicly available information, there is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. There is evidence that the company includes a provision in its terms and conditions that none of the supplier’s subcontractors are permitted to violate any of the anti-corruption regulations, laws or policies referenced in the supplier terms and conditions.

There is evidence that the company publishes high-level data from ethical incidents and investigations, and that this includes reports from and about suppliers and contractors. The data includes the number of allegations made and the number of disciplinary actions as a result of investigation findings. This data is published at regular intervals, on at least an annual basis.

However, the company receives a score of ‘1’ because the data is not disaggregated to show supplier data as separate from other types of individuals, such as company employees.

There is evidence that the company's procurement department is involved in the establishment and oversight of supplier relationships. There is evidence that the procurement department is the main body responsible for oversight of the company’s supplier base.

However, there is no evidence that the company assures itself of the procurement department’s involvement at least every three years.

There is evidence that the company has formal procedures to conduct due diligence on all new suppliers. There is evidence that the company might be willing to review or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated. There is evidence that due diligence includes checks on ultimate beneficial ownership and that higher risk suppliers are subject to enhanced due diligence.

However, it is unclear how frequently due diligence is repeated on existing suppliers.

There is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company takes active steps to ensure this by requiring that all suppliers follow its Supplier Code of Conduct, which prohibits corruption, and refers to policies to address conflicts of interest and gifts and hospitality. There is evidence that the company assures itself of its suppliers’ adherence to this through ongoing monitoring throughout the lifecycle of the relationship.

However, there is no evidence that the company requires all suppliers to have in place policies that prohibit facilitation payments as well as procedures covering whistleblowing.

There is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place and that the substance of its anti-corruption and bribery programme and standards are included in subcontracts throughout the supply chain. This evidence is in the form of a clear statement, short description or set of supplier principles that sets the minimum standards of ethical behaviour expected throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is no evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base.

There is no evidence that the company states that it conducts due diligence on its supply chain.

There is no evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

Based on publicly available information, there is evidence that the company requires the involvement of specialist procurement teams in the establishment and oversight of its supplier base. There is also evidence that these teams are the main department involved in the establishment of all supplier relationships. There is additionally evidence that the company assures itself of proper procedures practiced by its procurement teams by way of an audit at least every three years.

There is evidence that the company has formal procedures to conduct risk-based due diligence when engaging its suppliers. The company states that the level of due diligence varies depending on the level of risk presented by the third party. In instances where red flags identified over the course of the due diligence process cannot be mitigated, the company states that it may terminate the relationship.

However, the company receives a score of ‘1’ because it is not clear whether these checks include establishing the ultimate beneficial ownership of the supplying company. There is also no evidence to indicate how frequently due diligence is undertaken and whether this is repeated at least every two years or whenever there is a change in the business relationship.

There is evidence that the company requires all of its suppliers to abide by its Global Supplier Code of Conduct, which prohibits bribery and facilitation payments, and covers conflicts of interest, gifts and hospitality, and whistleblowing. Compliance with the Global Supplier Code of Conduct is a contractual requirement although companies may also adhere to their own Code of Conduct, provided it is aligned to the same principles. The company states that it includes audit and termination rights in its contracts with suppliers to ensure their compliance.

There is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place and that the substance of its anti-corruption and bribery programme and standards is communicated throughout the supply chain. The company makes a clear statement that sub-contractors should follow the principles set out in its Supplier Code of Conduct and recommends that suppliers establish supply chain management processes to integrate the requirements of this code.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

Based on publicly available evidence, there is no evidence that the company requires the involvement of a specialised procurement department in the establishment or oversight of its supplier base.

The company states that it conducts corruption-based due diligence on its partners, contractors and third parties and intermediaries, which is understood to include suppliers. However, there is insufficient publicly available evidence as to the content and consequences of due diligence.

The company states that it ‘strongly welcomes’ third parties to adopt similar anti-corruption policies to its own. However, the company receives a score of ‘0’ because there is no evidence that the company ensures that suppliers have anti-corruption policies in place which meet a high standard.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is evidence that the company's centralised procurement department is involved, in some capacity, in the establishment and oversight of supplier relationships. However, the company receives a score of ‘1’ because there is no evidence that the involvement of the procurement department is required for establishing any new suppliers over a certain threshold. There is also no clear evidence that the company assures itself of the involvement of its procurement department in supplier relationships at least every three years.

The company states that it has formal procedures to conduct due diligence on suppliers, however it is not clear whether this includes checks on ultimate beneficial ownership. There is no publicly available evidence which shows whether due diligence is only conducted before engaging with new suppliers or if it is repeated at least every two years. There is also no evidence that the company commits to review and possibly terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

The company states that it has a separate policy entitled "Verification of counterparties in JSC "RTI”, although this document is not publicly available.

There is evidence that the company requires all suppliers to adhere to its Anti-Corruption Policy and that it includes anti-corruption clauses in contracts with suppliers. The Anti-Corruption Policy prohibits foreign and domestic bribery, facilitation payments, and contains information on whistleblowing channels open to third parties.

However, there is no publicly available evidence of the practical measures it employs to assure itself of the strength of suppliers’ anti-corruption programmes, neither at the onboarding stage of the business relationship or when there is a significant change in the business relationship. There is also no evidence that the company requires that suppliers have policies covering conflicts of interest and gifts and hospitality.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is no publicly available evidence to indicate that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base.

There is some evidence that the company conducts anti-bribery and corruption due diligence on its third parties, which includes suppliers. The company indicates that this is based on an assessment of risk, and states this due diligence process may include checks on the company’s shareholders, other affiliated legal entities and natural persons.

However, there is no publicly available evidence that this process applies to all suppliers, since the company simply refers specifically to third parties supporting sales activities. In addition, there is no evidence that it requires and conducts checks on ultimate beneficial ownership for all suppliers. There is also no publicly available evidence that the company might be willing to review and/or terminate supplier relationships in circumstances where a red flag highlighted during the due diligence process cannot be mitigated.

There is evidence that the company requires its suppliers to follow adequate anti-bribery and corruption policies and procedures. The company indicates that all suppliers must follow its ‘Code of Conduct for Business Partners of RUAG’ which clearly prohibits bribery and facilitation payments and outlines procedures for dealing with conflicts of interest, gifts and hospitality and whistleblowing. There is evidence that the company includes termination rights in its contracts with suppliers, and the company states that it reserves the right to monitor existing or new business partners for compliance with its code of conduct.

There is evidence that the company takes steps to ensure that sub-contractors in its supply chain have adequate anti-bribery and corruption programmes in place. The company indicates that it expects suppliers to communicate the substance of its ‘Code of Conduct for Business Partners of RUAG’ in subcontracts throughout the supply chain.

However, the company receives a score of ‘1’ because there is no further publicly available evidence of steps that the company ensures this in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption-related investigations or disciplinary actions relating to its suppliers.

Based on publicly available information, there is evidence that the company’s parent company (Rostec) maintains a policy stipulating the involvement of its procurement department in some capacity, in the establishment of supplier relationships throughout the corporation’s holdings.

However, the company receives a score of ‘1’ because it is not clear whether this department is the main body responsible for oversight of the company’s supplier base, nor is there evidence that the involvement of the procurement department is required for establishing any new suppliers over a certain threshold. In addition, there is no evidence that the company assures itself of the procurement department’s involvement at least every three years.

Based on publicly available information, there is no clear evidence that the company conducts risk-based anti-bribery and corruption due diligence on its suppliers.

There is evidence that the company requires counterparties with which it has business relations to support its Anti-Corruption Policy, which covers prohibitions on bribery and conflicts of interest. It is assumed that these counterparties include suppliers.

However, based on publicly available information, there is no evidence that counterparties or suppliers are expected to adopt the company’s whistleblowing or gifts and hospitality procedures. There is also no evidence that the company takes active steps to ensure that its suppliers have adequate anti-bribery and corruption policies and procedures in place.

Based on publicly available information, there is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

Based on publicly available information, there is evidence that the company requires the involvement of its procurement department in the establishment of new suppliers. The company indicates that this department is ultimately responsible for providing oversight of the company's supplier base. The company assures itself that proper procedures regarding suppliers are followed through an audit every year.

There is evidence that the company has formal procedures to conduct risk-based due diligence when engaging with all suppliers, with the highest risk suppliers being subject to enhanced due diligence. The company indicates that the due diligence process aims to establish the ownership of its suppliers. The company also states that supplier relationships will be subject to review, and potential termination, if any red flags highlighted in the due diligence process cannot be mitigated.

However, although the company states that it plans supplier audits on a priority basis each year, there is no publicly available evidence that due diligence is repeated at least every two years or when there is a significant change in the business relationship.

Based on publicly available information, there is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place which cover conflicts of interest and gifts and hospitality. The company ensures this through contractual terms and assures itself of this when onboarding new suppliers.

However, there is no publicly available evidence that the company requires its suppliers to have, at a minimum, policies that cover whistleblowing and prohibit facilitation payments.

There is evidence that the company encourages its suppliers to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain.

However, this is in the form of a simple statement and it is unclear how the company assures itself of this in practice.

There is no publicly available evidence to indicate that the company publishes any data on ethical or anti-bribery and corruption investigations or associated disciplinary actions relating to its suppliers.

There is some evidence that the company's procurement department is involved in the establishment and oversight of supplier relationships. It is clear that procurement departments, whether at group or entity levels, are the main bodies responsible for this work. It is not explicitly stated in company materials that they are involved in all supplier relationships or that their involvement is required for establishing new suppliers over a certain threshold.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of the procurement department’s involvement in this process at least every three years. It is not explicitly stated that the company’s anti-corruption certification provided by the Agency in charge of Providing Technological Information (“ADIT”), includes a review of procurement processes.

There is no evidence that the company conducts risk-based anti-bribery and corruption due diligence when engaging or re-engaging with its suppliers. The company simply states that it conducts internal and external due diligence on every business partner, which might be understood to include suppliers. It does not provide any further details on its anti-bribery and corruption due diligence procedures, such as the scope of due diligence, whether this is risk-based and how frequently due diligence is conducted.

There is some evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company states that it expects all suppliers to have policies in place that prohibit bribery and facilitation payments, as well as procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. Anti-bribery and corruption clauses are included in the company’s contracts with suppliers.

However, the company receives a score of ‘1’ because it is unclear how the company ensures this in practice. For example, it does not specify that the company assures itself of this through in-depth assessments or audits of each suppliers’ policies when onboarding new suppliers and/or when there is a significant change in the business relationship.

There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain.

However, the company receives a score of ‘1’ because this evidence is in the form of a simple statement and it is unclear how the company does this in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is no publicly available evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base.

There is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain. The company states that its Risk Oversight Committee monitors the company’s policies and practices with regard to third-party risk, but no further information on these policies and practices is publicly available.

There is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. There is evidence in its publicly available Supplier Code of Conduct that the company sets minimum anti-corruption standards and requires suppliers to have policies in place that prohibit bribery and facilitation payments, as well as procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. There is evidence that the company assures itself of this by requiring suppliers to sign the Supplier Code of Conduct at the start of the contractual relationship, and by noting that any violations could result in termination of the business relationship.

There is evidence that the company takes steps to ensure that its suppliers’ sub-contractors have adequate anti-bribery and corruption programmes in place, by detailing minimum standards expected throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers.

Based on publicly available information, there is evidence that the company requires the involvement of its procurement department in the establishment of new suppliers. This department is ultimately responsible for providing oversight of the company's supplier base. The company assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means at least every year.

Based on publicly available information, there is evidence that the company has formal procedures to conduct due diligence on all of its suppliers. There is also evidence to suggest that the highest risk suppliers are subject to enhanced due diligence. The company states that it conducts due diligence monitoring throughout the life cycle of its relationship with suppliers. There is evidence that the company might be willing to review and/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

However, the company receives a score of ‘1’ because there is no clear evidence that its due diligence includes checks on beneficial ownership and the frequency of checks on suppliers is also unclear. It is noted that the company has a document called “Third Party Legal and Ethical Compliance Due Diligence” but this does not appear to be accessible in the public domain.

Based on publicly available information, there is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company states that all suppliers must have, at minimum, policies that prohibit bribery, facilitation payments as well as policies and procedures to address conflicts of interest, gifts and hospitality and whistleblowing. There is evidence that the company takes active steps to ensure this by requiring that all suppliers follow the Supplier Code of Conduct and the company´s Code of Conduct, and there is evidence that the company assures itself of this when onboarding new suppliers.

Based on publicly available information, there is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place and that the substance of its ethics programme and standards are included in subcontracts throughout the supply chain. This evidence is in the form of a set of supplier principles that sets the minimum standards of ethical behaviour expected throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers or associated disciplinary actions.

There is some evidence that the company’s procurement department is involved, in some capacity, in the establishment and oversight of supplier relationships.

However, the company receives a score of ‘1’ because it is not clear that the procurement department is the main body responsible for oversight of the company’s supplier base and there is no evidence that the company assures itself of the procurement department’s involvement at least every three years.

Based on publicly available information, there is no clear evidence that the company conducts risk-based anti-bribery and corruption due diligence on its suppliers. The company indicates that it screens all suppliers during the onboarding process and that this screening includes ESG considerations; however there is no clear evidence that this includes anti-corruption topics, nor that suppliers are subject to different levels of due diligence based on risk.

There is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company indicates that all suppliers must have policies in place that prohibit foreign and domestic bribery, prohibit facilitation payments, as well as policies and procedures to address conflicts of interest and gifts and hospitality. There is evidence that the company takes active steps to ensure these policies are upheld.

However, the company receives a score of ‘1’ because it is not clear that the company requires its suppliers to have whistleblowing channels in place. It is also not clear whether the company assures itself of this only when onboarding new suppliers or when there is a significant change in the business relationship.

There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain, by including a principle on this in its Vendor Code of Conduct. However, the company receives a score of ‘1’ because it is not clear how the company does this in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations or the associated disciplinary actions relating to its suppliers.

There is no evidence that the company requires and ensures the involvement of its procurement department in the establishment and oversight of its supplier base.

There is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain.

There is no evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is evidence that the company's Procurement Commission is involved, in some capacity, in the establishment and oversight of supplier relationships. There is evidence that this Commission is the main body responsible for oversight of the company’s supplier base and that its involvement is required for establishing any new suppliers over a certain threshold.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of the Procurement Commission’s involvement at least every three years.

There is no evidence that the company conducts anti-corruption based due diligence on its supply chain.

There is some evidence that the company requires its suppliers to comply with its own business ethics and it states that it conducts checks on the strength of suppliers’ and other third parties’ anti-corruption procedures and policies.

However, the company does not explicitly state that all suppliers must have, at least, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, and/or policies that cover conflicts of interest, gifts & hospitality, or whistleblowing. In addition, there is no evidence that the company assures itself of this for all suppliers, or that this assurance is conducted when onboarding new suppliers and/or when there is a significant change in the business relationship.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is no evidence that the company requires the involvement of its procurement department in the establishment and/or oversight of its supplier base.

There is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain.

There is no evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is some evidence to suggest that the company's procurement department is involved, in some capacity, in the establishment and oversight of supplier relationships.

However, the company receives a score of ‘1’ because it is not clear that the procurement department is the main body responsible for oversight of the company’s supplier base. There is also no evidence that the company assures itself of the procurement department’s involvement at least every three years.

There is evidence that the company conducts due diligence on all third parties, including suppliers. The company states that it is willing to review and/or terminate a supplier relationship if a red flag highlighted during due diligence cannot be mitigated.

However, the company receives a score of ‘1’ because there is no evidence that its due diligence includes checks on ultimate beneficial ownership. In addition, there is no evidence that highest risk suppliers are subject to enhanced due diligence, and it is not clear how frequently it conducts such checks. There is no evidence that this takes place at least every two years or when there is a change in the business relationship.

There is no publicly available evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard. The company indicates that external partners must be familiar with its anti-corruption programme, but it is not clear that suppliers themselves are required to establish and implement anti-corruption procedures within their own organisations.

There is no publicly available evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations or the associated disciplinary involving its suppliers.

There is no evidence that the company requires the involvement of its procurement department in the establishment and/or oversight of its supplier base.

There is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain.

There is no evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard. The company states business associates must meet a certain standard of ethical business conduct, but does not specifically refer to a publicly available anti-bribery and corruption policy that applies specifically to suppliers.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is evidence that the company requires the involvement of its procurement department in the establishment of new suppliers. This department is ultimately responsible for providing oversight of the company's supplier base. There is evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means, such as an audit, at least every three years.

Based on publicly available information, there is evidence that the company has formal procedures to conduct due diligence on its suppliers. There is evidence to suggest that highest risk suppliers are subject to enhanced due diligence.

However, the company receives a score of ‘1’ because there is no evidence that its due diligence includes checks on the ultimate beneficial ownership of suppliers. Furthermore, there is no evidence that the company repeats due diligence at least every two years or whenever there is a change in the business relationship. There is also no evidence to suggest that the company might be willing to review or terminate supplier relationships if a red flag highlighted in the due diligence cannot be mitigated.

Based on publicly available information, there is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company states that all contracts with suppliers include the company’s anti-corruption provisions. In addition, the company requires that suppliers adhere to its Code of Conduct for Suppliers and Service Providers, which prohibits bribery and facilitation payments, and stipulates procedures to address conflicts of interest, gifts and hospitality and whistleblowing. There is evidence that the company assures itself of this when onboarding new suppliers, and includes audit rights in its contracts with suppliers to ensure their continued compliance.

Based on publicly available information, there is evidence that the company takes steps to ensure that the substance of its anti-corruption programme is required of sub-contractors throughout its supply chain. However, the company receives a score of ‘1’ because it does not provide further details on how it ensures this in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations or disciplinary actions involving its suppliers.

Based on publicly available information, there is evidence that the company's business units have specialised procurement departments which are involved, in some capacity, in the establishment and oversight of supplier relationships.

However, the company receives a score of ‘1’ because there is no evidence that its business units require the involvement of the procurement departments for establishing new suppliers over a certain threshold. It is also unclear whether these bodies are the main bodies in charge of managing the company’s supplier base and procurement activities. In addition, there is no evidence that the company assures itself of the involvement of its procurement departments at least every three years.

Based on publicly available information, there is no evidence that the company conducts risk-based anti-bribery and corruption due diligence when engaging or re-engaging with its suppliers.

Based on publicly available information, there is evidence that the company requires its suppliers to have adequate anti-bribery and corruption policies and procedures in place. There is evidence that the company requires suppliers to abide by its Code of Conduct for Suppliers and Other Business Partners, which prohibits bribery and facilitation payments and includes policies that cover conflicts of interest, gifts & hospitality and whistleblowing.

However, the company receives a score of ‘1’ because there is no evidence to suggest that the company takes active steps to ensure that its suppliers abide by its code or have adequate anti-bribery and corruption policies and procedures in place.

Based on publicly available information, there is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. However, the company receives a score of ‘1’ because this evidence is in the form of a simple statement and it is unclear how the company ensures this in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

Based on publicly available information, there is some evidence that the organisation requires the involvement of its procurement department in the establishment of new suppliers. The organisation indicates that this department is ultimately responsible for providing oversight of the company's supplier base.

However, the organisation receives a score of ‘1’ because there is no evidence that it takes steps to assure itself of the procurement department’s involvement in this process at least every three years.

There is no evidence that the organisation conducts anti-bribery and corruption due diligence on its supply chain.

Based on publicly available information, there is some evidence that the organisation ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. There is evidence that the organisation requires its suppliers, through its contracts with them, to have policies that prohibit bribery and facilitation payments, and those that cover whistleblowing.

However, the organisation receives a score of ‘1’ because it does not explicitly state that all suppliers must have policies covering conflicts of interest or gifts and hospitality. There is also no evidence that the organisation assures itself of this for all suppliers and it is not clear that this assurance is refreshed when there is a significant change in the business relationship.

There is no evidence that the organisation takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the organisation publishes any data on ethical or anti-bribery and corruption-related investigations relating to its suppliers, or the associated disciplinary actions.

There is evidence that the company requires the involvement of specialist procurement in the establishment of all new supplier relationships. The company states that these departments are ultimately responsible for providing oversight of the company's supplier base. There is also evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through regular audits of the company’s procedures at least every three years.

There is no publicly available evidence the company conducts risk-based anti-bribery and corruption due diligence when engaging or re-engaging with suppliers. The company states that its suppliers perform a self-assessment, however, there is no clear evidence that prior to engaging suppliers the company carries out due diligence or other screening checks designed to identify bribery and corruption risks.

There is evidence that the company ensures that all of its suppliers have adequate anti-bribery and corruption policies and procedures in place, including in relation to conflicts of interest, gifts and hospitality, as well as a prohibition of facilitation payments. There is evidence that the company takes active steps to ensure this by requiring that all suppliers follow its own Supplier Code of Conduct or have comparable standards in place. The company conducts assurance when onboarding new suppliers. Additionally, there is evidence that the company assures itself of its suppliers’ standards of conduct periodically throughout the business relationship. The company states that its whistleblowing channels are open to all suppliers and sub-contractors.

There is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place and that the substance of its anti-corruption and bribery programme and standards are included in sub-contracts throughout the supply chain. The company states that it ensures this commitment in practice by requiring suppliers to sign a declaration that they will adhere to the standards in the company’s Code of Conduct in all its dealings with suppliers. The company also publishes a clear anti-corruption statement that all suppliers are obliged to endorse and adhere to in their operations.

While there is evidence the company commits to investigating incidents involving suppliers, there is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

Based on publicly available information, there is some evidence that the company’s procurement department is involved in the management and oversight of its suppliers. However, the company receives a score of ‘1’ because there is no clear evidence that its procurement department is the main body responsible for oversight of its supplier base. In addition, there is no evidence that the company assures itself of the procurement department’s involvement at least every three years.

There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its supply chain. The company outlines its principles for selecting suppliers and indicates that an evaluation must be conducted prior to procurement, but it is not clear that this constitutes due diligence nor that such checks are regular and include anti-bribery and corruption considerations.

Based on publicly available information, there is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies in place. The company indicates that it takes active steps to ensure that all suppliers have adequate policies in place by including such considerations in its selection criteria and publishing details of the international standards that it expects suppliers to follow. In addition, there is evidence that the company makes its whistleblowing channel available to those employed by business partners.

However, the company receives a score of ‘1’ because there is no clear evidence that it requires suppliers to specifically have policies in place that prohibit facilitation payments and procedures to cover risks arising from conflicts of interest or gifts and hospitality. It is also not clear whether the company assures itself of this both when onboarding new suppliers and when there is a significant change in the business relationship.

There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. However, the company receives a score of ‘1’ because it does not provide further details on the steps that it takes to ensure this in practice.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations or disciplinary actions involving its suppliers. The company publishes some information on the number of suppliers that received additional guidance or were subject to the suspension of transactions on the basis of human rights and safety and environment, however there is no evidence that the company publishes data in relation to bribery and corruption concerns.

Based on publicly available information, there is evidence that the company requires that its procurement team is involved, in some capacity, in the establishment and oversight of supplier relationships.

However, it is not clear from publicly available evidence that this team is the main body responsible for oversight of the company’s supplier base. There is also no evidence that the company assures itself of the procurement department’s involvement at least every three years.

There is no evidence that the company conducts risk-based anti-bribery and corruption due diligence when engaging or re-engaging with its suppliers.

Based on publicly available information, there is evidence that the company requires its suppliers to have adequate anti-bribery and corruption policies and procedures in place, by insisting that they comply with its Supply Chain Management Code of Ethics. This document explicitly refers to the prohibition of bribery, conflicts of interest and gifts and hospitality. There is evidence that the company assures itself of this when onboarding new suppliers but not necessarily when there is a significant change in the business relationship.

However, the company scores ‘1’ as there is no evidence that it requires that all suppliers have policies that prohibit facilitation payments nor policies related to whistleblowing.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no publicly available evidence to indicate that the company publishes any data on ethical or anti-bribery and corruption investigations or associated disciplinary actions relating to its suppliers.

There is some evidence that the company's procurement department is involved, in some capacity, in the establishment and oversight of supplier relationships.

However, the company receives a score of ‘1’ as there is no evidence that the involvement of the procurement department is required for establishing any new suppliers over a certain threshold or that it is the main body responsible for oversight of the company’s supplier base. There is also no clear evidence that the company assures itself of the procurement department’s involvement at least every three years.

The company simply states that it conducts due diligence on its suppliers, without providing any further details.

The company states that its suppliers must meet a certain standard of ethical business conduct, but does not specifically refer to any of the anti-bribery and corruption measures necessary to receive a score of ‘1’.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is no publicly available evidence that the company requires the involvement of its procurement department in the establishment or oversight of its supplier base.

There is evidence that the company has formal procedures to conduct due diligence before engaging with all suppliers, and that this process includes checks on beneficial ownership. There is some evidence that the company would be willing to terminate a relationship or not engage a supplier if a red flag identified in due diligence could not be mitigated.

However, there is no evidence that high risk suppliers are subject to enhanced due diligence nor that due diligence is repeated at least every two years or when there is a change in the business relationship.

There is no evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is no clear evidence that the company requires the involvement of its procurement department in the establishment and oversight of its suppliers. The company refers to a Procurement Council body in its 2019 Annual Report, however there is no further publicly available evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base.

Based on publicly available information, there is evidence that the company conducts risk-based anti-bribery and corruption due diligence on all third parties, which can be understood to include suppliers. The company indicates that the highest risk third parties are subject to enhanced due diligence, and due diligence is repeated every two years.

However, the company receives a score of ‘1’ because there is no clear evidence that the company might be willing to review and/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated. There is also no evidence that the company’s due diligence processes include checks on the ultimate beneficial ownership of suppliers.

There is evidence that the company includes anti-bribery provisions in its contracts with all third parties, which provide for termination rights in the event of policy breaches. However, the company receives a score of ‘0’ because there is no clear evidence that it requires suppliers to have adequate anti-bribery and corruption policies in place that prohibit bribery or facilitation payments, or procedures in place covering conflicts of interest, gifts and hospitality and whistleblowing.

There is no publicly available evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption incidents, investigations or disciplinary actions relating to its suppliers.

There is evidence that the company’s procurement department is involved in the establishment and oversight of all supplier relationships. It is clear that this specialised procurement department is the main body responsible for oversight of the company’s supplier base.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of the procurement department’s involvement at least every three years.

There is evidence that the company has formal procedures in place to conduct due diligence on all counterparties, which is understood to include suppliers. The company indicates that it reviews and may terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

However, there is no evidence that due diligence includes checks on ultimate beneficial ownership, nor that highest risk suppliers are subject to enhanced due diligence. It is also not clear how frequently such checks are conducted.

There is evidence that the company expects that its contractors meet a certain standard of ethical business conduct when conducting work. The company also indicates that it includes an anti-corruption clause in its contracts with partners which prohibits bribery.

However, the company receives a score of ‘1’ because there is no evidence that all suppliers must have, at least, policies in place that prohibit facilitation payments, and procedures covering conflicts of interest, gifts & hospitality, or whistleblowing. In addition, there is no evidence that the company assures itself that suppliers meet such standards when there is a change in the business relationship.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption incidents, investigations or disciplinary actions relating to its suppliers.

The company states that it adheres to its parent company’s procurement policy, which indicates that the procurement department is involved, in some capacity, in the establishment of supplier relationships throughout the corporation’s holdings.

However, the company receives a score of ‘1’ because it is not clear whether the procurement department is the main body responsible for oversight of the company’s supplier base. There is also no evidence that the company assures itself of the procurement department’s involvement at least every three years.

There is some evidence in group-wide procurement regulations that the company conducts anti-corruption due diligence on suppliers. The company’s Anti-Corruption Policy also indicates that it conducts due diligence on all business partners and counterparties, without making specific reference to suppliers.

The company receives a score of ‘1’ because there is no publicly available evidence that the company conducts checks on ultimate beneficial ownership, or that highest risk suppliers are subject to enhanced due diligence. It is not clear that the company repeats due diligence at least every two years or whenever there is a change in the business relationship. The company’s policy also does not explicitly state that the company might be willing to review and/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

There is no clear evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard. The company states that it disseminates anti-corruption policies and standards amongst its partner organisations, but it does not indicate that this includes suppliers and there is no further evidence to indicate that the company assures itself that its suppliers meet these standards on a regular basis.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption related incidents, investigations or disciplinary actions relating to its suppliers.

There is no evidence that the company requires the involvement of its procurement department in the establishment and/or oversight of its supplier base. It is noted that in its most recently published Annual Report (2015) the company makes reference to a set of regulations on procurement, however this document is not publicly available.

There is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain.

There is no evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard. 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 evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain. 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 evidence that the company publishes any data on ethical or anti-bribery and corruption-related investigations relating to its suppliers, or the associated disciplinary actions.

There is evidence that the company's Procurement Commission is involved in the establishment and oversight of all supplier relationships. However, the company receives a score of ‘1’ because there is no publicly available evidence that it assures itself of this department’s proper involvement in the procurement process through clearly stated means, such as an audit, at least every three years.

There is evidence to suggest that the company performs checks on contractors to ensure that they have a good reputation and adequate anti-corruption programmes in placeThe company also indicates that it maintains a policy of not doing business with individuals and organisations implicated in corruption offenses.

However, it is not clear from publicly available information that the company’s due diligence processes include checks on ultimate beneficial ownership, or that high risk suppliers are subject to enhanced due diligence. It is also not clear how frequency the company conducts or refreshes this due diligence, nor is there evidence that it may review or terminate a supplier relationship where a red flag highlighted in the due diligence cannot be mitigated.

There is some evidence that the company takes steps to ensure that its contractors have adequate anti-bribery and corruption policies and procedures in place. The company indicates that it monitors counterparties’ adherence to anti-corruption policies throughout the business relationship and that it focuses on establishing business relationships with contractors who support the company’s own anti-corruption policy.

However, the company receives a score of ‘1’ because there is no clear evidence that all suppliers must have policies that prohibit foreign and domestic bribery, prohibit facilitation payments, and implement procedures to address conflicts of interest, gifts and hospitality, or whistleblowing. It is also not clear from publicly available information whether the company assures itself of this for all suppliers or whether this assurance is conducted when there is a significant change in the business relationship.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or corruption-related reports, investigations or the associated disciplinary actions involving its suppliers.

There is evidence that the company’s Procurement Commission is involved, in some capacity, in the establishment and oversight of supplier relationships. There is evidence to suggest that this department is the main body responsible for oversight of the company’s supplier base.

However, the company does not state that the involvement of the Procurement Commission is required for establishing any new suppliers over a certain threshold and there is no evidence that the company assures itself of the Procurement Commission’s involvement at least every three years.

The company simply states that it carries out checks against third parties, without specifying that these checks are conducted for suppliers, or providing any further details.

There is no evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard. The company states that it prevents and prohibits corruption in its supplier relationships, but does not specifically refer to any anti-bribery and corruption measures.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is evidence that the company requires the involvement of its procurement department in the establishment of new suppliers and that this department is responsible for providing oversight of its supplier base.

However, there is no clear publicly available evidence that the company assures itself of the procurement department’s proper involvement in the procurement process through clearly stated means, such as an audit of its internal systems, at least every three years.

There is evidence that the company has formal procedures in place to conduct risk-based due diligence when engaging and re-engaging with any suppliers. There is evidence that the highest risk suppliers are subject to enhanced due diligence and that all suppliers are screened on an annual basis.

However, the company receives a score of ‘1’ because there is no clear evidence that the due diligence process includes establishing the beneficial ownership of all suppliers. In addition, the company states in its Code of Conduct that it reserves the right to terminate third party contracts but makes no clear statement that it would do so in circumstances when a red flag highlighted in due diligence cannot be mitigated.

There is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company clearly states that all suppliers must have policies that prohibit foreign and domestic bribery and facilitation payments, as well as policies and procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. The company takes active steps to ensure this by requiring that all suppliers follow its Supplier Code of Conduct. There is evidence that the company screens suppliers annually to ensure compliance with these policies.

There is evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. This evidence is in the form of contractual commitments for all sub-contractors to maintain a code of conduct and ethics and compliance programme. It is noted that this contractual commitment relates to contracts with the United States government, the company’s primary customer. There is evidence the company also commits to flowing down the principles of its Supplier Code of Conduct.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption reports, investigations or disciplinary actions involving its suppliers.

There is no evidence that the company requires and ensures the involvement of its procurement department in the establishment and/or oversight of its supplier base. The company provides a description of good practice in procurement within its Guide to Business Conduct but this does not mention the procurement department or a central team responsible for the process.

There is no evidence that the company conducts anti-bribery and corruption due diligence on its suppliers. The company states that it will not engage with suppliers with a history of fraudulent or unethical activity, but it is not clear how the company assures itself of this.

There is evidence that the company expects certain standards of conduct from its suppliers, but there is no clear evidence that the company ensures that its suppliers have specific anti-bribery and corruption standards in place that meet a high standard. The company’s General Terms and Conditions of Purchase simply state that suppliers must comply with anti-corruption laws.

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.

There is no evidence that the company requires the involvement of its procurement department in the establishment and/or oversight of its supplier base.

There is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain.

There is no evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.

There is no evidence that the company has an anti-bribery and corruption programme, nor that it takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.