1. Leadership and Organisational Control

There is evidence that the company has a publicly stated anti-corruption commitment, which details the company's stance against bribery and corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's leadership.

There is evidence that the company publishes a comprehensive anti-bribery and corruption policy which specifically prohibits bribery, payments to public officials, commercial bribery and facilitation payments. There is evidence that this policy applies to all employees and board members as described in (a) and (b) in the question.

Based on publicly available information, there is evidence that a designated board committee – the Audit Committee – is ultimately responsible for oversight of the company's anti-bribery and corruption programme. The Audit Committee’s role includes reviewing reports from management on the company’s risk assessment procedure and receiving reports on investigations.

However, the company receives a score of ‘1’ because there is no clear publicly available evidence that the Audit Committee receives reports on the overall performance of the company’s anti-bribery and corruption programme, nor that it has the authority to require that changes to the programme are made as a result of reviews.

Based on publicly available information, there is evidence that the company's Chief Compliance Officer and the General Counsel are jointly responsible for implementing and managing the company's anti-bribery and corruption programme.

However, the company receives a score of ‘1’ because, although there is evidence of reporting activities between these persons and the Audit Committee, this appears to mostly relate to the presentations of risk assessments, rather than the status of the anti-bribery and corruption programme more broadly.

There is no evidence that the company makes a public commitment to ethical or anti-bribery and corruption standards.

There is no evidence that the company publishes an anti-bribery and corruption or ethics and compliance policy.

There is no evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.

There is no evidence that a specific managerial-level employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

There is evidence that the company’s Code of Business Ethics outlines the company's stance against bribery and corruption. It is clear that the Code of Business Ethics was authorised and endorsed by the company's leadership in the form of an introductory message signed by Chief Executive Officer. However, this message does not specifically mention anti-bribery and corruption and therefore a score of ‘1’ applies.

There is evidence that the company publishes an anti-bribery and corruption policy as part of its Code of Business Ethics, which applies to all employees, directors, as well as the staff and leadership of the company’s wider corporate group. There is evidence that the policy explicitly prohibits bribery.

However, the company receives a score of ‘1‘ because there is no evidence that the policy also prohibits facilitation payments or payments to public officials.

There is evidence that a designated board committee – the Audit Committee – is ultimately responsible for oversight of the company's compliance programme and Code of Business Ethics, which includes the company’s anti-bribery and corruption policy.

However, there is no clear evidence that this committee engages in formal oversight functions such as reviewing reports from management on the company’s anti-bribery and corruption programme’s performance, or the results of internal and external audits, or that it has the authority to require that changes are made.

There is evidence that a designated senior executive – the Chief Compliance Officer – has ultimate responsibility for managing the company's compliance and ethics programme, which is understood to include the company’s anti-bribery and corruption programme.

However, there is no evidence that this individual has a direct reporting line to the board or board committee that provides oversight of the anti-bribery and corruption programme.

The company’s Code of Conduct, which includes sections addressing its anti-bribery and corruption commitments, is endorsed by the CEO.

However, the company receives a ‘1’ because the CEO does not specifically mention anti-bribery and corruption in their statement.

The company publishes an explicit anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees, including in subsidiaries, and board members.

There is evidence that the board and designated board committees, namely the Audit Committee and Nominating/ Governance Committee, oversee the company's anti-bribery and corruption programme.

However, the company receives a score of ‘1’ because it does not provide any further information regarding what reporting is made to these committees and how oversight is exercised in practice. Also, whilst the company refers briefly to a Global Ethics & Compliance Committee, this appears to be a managerial-level committee.

There is evidence that a designated senior executive, the Chief Ethics and Compliance Officer, has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme.

However, the company receives a score of ‘1’ because further information on their role, seniority, responsibilities and reporting lines is not provided in public materials. Additionally, the company’s Chief Operating Officer and Chief Legal Officer head the company’s Global Ethics Committee and it is not clear whether they report on the company’s anti-bribery and corruption programme to the board or designated board committees.

There is evidence that the company has a publicly stated commitment to anti-bribery and corruption, which outlines the company’s stance against all forms of bribery and corruption within the organisation. It is clear that this commitment is endorsed and authorised by the company’s senior leadership.

The company publishes a clear anti-bribery and corruption policy, which makes specifically prohibits bribery, payments to public officials, commercial bribery and facilitation payments. This policy clearly applies to all employees and board members as described in (a) and (b) in the question.

Based on publicly available information, the company’s Board of Directors and Audit Committee are the bodies that provide oversight of the anti-bribery and corruption programme. There is evidence that their responsibilities include reviewing reports from management on the programme’s performance, along with the results of audits, and there is evidence that it has the authority to require that any necessary changes are made.

There is evidence that the company has an Ethics and Compliance Team which manages its anti-bribery and corruption programme. The Executive Director of this team reports to the Board of Directors and Audit Committee on a quarterly basis regarding the activities of the programme. In addition, there is evidence of reporting and feedback activities between this individual as part of the company’s reporting stricture.

Based on publicly available information, company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's CEO.

The company publishes a comprehensive Anti-Corruption Policy and supporting Code of Conduct, both of which specifically define and prohibit bribery, payments to public officials, commercial bribery and facilitation payments. Both policies clearly apply to all employees and board members as described in (a) and (b) above, regardless of their location, responsibilities or seniority.

There is evidence that the company has a designated board committee – the Ethics and Compliance Committee – that is ultimately responsible for oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from management on the programme’s performance and ensuring that required changes are made.

There is evidence that a designated senior executive – the Ethics and Compliance Officer – has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the board committee that provides oversight of the anti-bribery and corruption programme, and there is evidence that the company’s reporting structure allows the Ethics and Compliance Officer to report and feedback to the board directors (through the General Counsel).

There is no evidence that the company makes a public commitment to ethical or anti-bribery and corruption standards.

There is no publicly available evidence that the company publishes an anti-bribery and corruption policy.

There is no publicly available evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.

There is no evidence that a specific senior employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

There is no evidence that the company publishes a commitment to ethical or anti-bribery and corruption standards that is authorised and endorsed by the senior leadership. The company mentions ‘integrity’ as one of its core values, but this is insufficient to score ‘1’.

There is no evidence that the company publishes an anti-bribery and corruption policy.

There is no evidence that the company has a designated board committee or individual board member responsible for anti-bribery and corruption.

There is no evidence that a specific managerial-level employee has ultimate responsibility for implementing and managing an anti-bribery and corruption programme.

The company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company’s leadership.

The company publishes an explicit anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery and commercial bribery. This policy clearly applies to all employees, including staff and leadership of subsidiaries and other controlled entities as well as all board members, including non-executive directors.

However, the policy does not specify that it includes a prohibition of facilitation payments.

There is evidence that a designated board committee oversees the company's anti-bribery and corruption programme.

However, there is no evidence to suggest that it engages in formal oversight functions, such as reviewing reports from management or the results of internal and external audits.

There is no evidence that a specific managerial-level employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

There is evidence that the company’s Chairman and CEO publicly endorses the company’s 2018 Sustainability Report, which includes a commitment to anti-bribery and corruption. However, the company scores ‘1’ because this statement does not directly include a commitment to anti-bribery and corruption.

There is evidence that the company publishes an anti-bribery and corruption policy which applies to all groups as specified in (a) and (b) in the question. This policy explicitly prohibits bribery and payments to public officials.

However, the company receives a score of ‘1’ because this policy does not explicitly prohibit facilitation payments.

Based on publicly available information, there is evidence that the company’s board is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from management on the programme’s performance. There is evidence that the board has the authority to require that changes are made. The company also has a managerial-level committee, the Ethical Principles Committee, which is responsible for the design and measurement of the programme.

Based on publicly available information, there is no evidence that a designated senior executive or managerial-level employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

There is evidence that the company makes a general commitment to ethical standards. However, there is no evidence that the company directly addresses anti-bribery and corruption in this commitment, nor is there evidence that this statement is authorised or supported by a senior figure within the organisation.

Based on publicly available information, there is no evidence that the company has a comprehensive anti-bribery and corruption policy that applies to all employees. The company indicates that it has a Code of Conduct as well as specific anti-corruption and whistleblowing policies, however these policies do not appear to be available in the public domain.

There is some evidence that the company’s board and a board-level committee – the Audit and Risk Management Committee – oversee the company’s compliance programme. There is evidence to suggest that the bodies engage in formal oversight functions, such as reviewing reports from management.

However, the company scores ‘1’ because there is no publicly available evidence to indicate that this includes oversight of its anti-bribery and corruption activities specifically. There is also no evidence that either the board or the Audit and Risk Management Committee reviews the results of internal and external audits of the anti-bribery and corruption programme.

There is no evidence that a specific senior individual or managerial-level employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

There is some evidence that the company publishes a general commitment to anti-corruption and ethical standards, however the company receives a score of ‘1’ because there is no evidence that this statement is authorised or supported by a senior figure within the organisation.

Based on publicly available information, there is no evidence that the company publishes a clear anti-corruption policy that applies to all employees and directors within the organisation. The company states that it operates according to principles of honesty and integrity and publishes an document outlining the disciplinary measures that may result from acts of corruption from the Chinese Communist Party, but there is no evidence that the company itself has a comprehensive anti-corruption policy in place.

There is no clear evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.

The company publishes working regulations produced by the Chinese Communist Party which state that the company’s party group is responsible for conducting anti-corruption activities within the company. However, there is no indication that this group has formal oversight functions or that it maintains a reporting line to the company’s board of directors.

There is some evidence that one of the company’s senior executives has a role involving corporate ethics, according to its 2016 Social Responsibility Report, however the company does not provide any further information on the individual’s role or responsibilities in relation to anti-corruption. In addition, the company refers to a different individual on its website with the same title but similarly provides no further information on the individual’s duties.

Since the information provided is limited and there is no clear evidence that the company has an anti-corruption programme or management system, the company receives a score of ‘0’. There is also no indication that the individuals responsible for corporate ethics have a direct reporting line to the company’s board of directors.

There is evidence that the company publishes statements from both the CEO and Chairman of the Board that outline a commitment to integrity and high ethical standards. In addition, the company indicates that its CEO has personally endorsed the Code of Conduct, but there is no direct evidence of this in practice. The company receives a score of ‘1’ because there is no evidence that the company’s senior leadership publish a statement outlining its commitment to anti-bribery and corruption within the organisation.

There is evidence that the company publishes an anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and there is evidence to indicate that it also applies to board members and directors.

Based on publicly available information, there is evidence that the board, through its Audit and Risk Committee, is responsible for oversight of the company's ethics programme. There is evidence that the committee’s oversight responsibilities include reviewing reports from management on the programme’s performance, and it is clear that the committee has the authority to require that any necessary changes to the programme are made.

Based on publicly available information, there is evidence that the company’s CEO is ultimately responsible for the management and implementation of the anti-bribery and corruption programme, with daily operational responsibility delegated to the Sector Chief Executives and Managing Directors. The CEO has a direct reporting line to the board and there is evidence of reporting and feedback activities between the CEO and the board, as well as to the Audit and Risk Committee.

There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of corruption within the organisation. There is clear evidence that this commitment was authorised and endorsed by the company's CEO.

There is evidence that the company publishes a clear anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members as described in (a) and (b) in the question.

Based on publicly available information, there is evidence that a designated board committee – the Corporate Responsibility Committee – is ultimately responsible for oversight of the company's anti-bribery and corruption programme. There is evidence that this includes reviewing reports from management on the programme’s performance, along with the results of audits, and it is clear that the committee has the authority to ensure that required changes are made.

Based on publicly available information, there is evidence that a designated senior executive has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. There is evidence that this person has a direct reporting line to the board committee that provides oversight of the anti-bribery and corruption programme. There is also evidence of reporting and feedback activities between this person and the board committee as part of the company’s reporting structure.

The company’s leadership endorses its Business Ethics Code of Conduct, which outlines its anti-bribery and corruption commitment.

However, the company receives a ‘1’ because its leadership does not explicitly mention bribery and corruption in their statement.

The company publishes an explicit anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials and commercial bribery. This policy applies to all employees and board members, including those of subsidiaries and controlled entities.

However, the company receives a score of ‘1’ because its policy makes no specific reference to facilitation payments. It is also unclear whether the company’s policies apply to non-executive and independent directors.

There is evidence that the company’s Nominating/Corporate Governance Committee oversees the company's anti-bribery and corruption programme, contained within the company’s ethics and compliance programme. The company states that the committee provides oversight of the programme.

However, the company receives a score of ‘1’ because there is no clear evidence that the committee reviews reports from management or the results of internal and external audits relating to the company’s anti-bribery and corruption policies and procedures. There is also no clear evidence that the committee has the authority to require that changes are made.

There is no evidence that the company has a specific managerial-level employee who holds ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

The institute has a publicly stated commitment to 'integrity' and 'high ethical standards' but does not explicitly mention anti-bribery and corruption. There is no direct evidence that this statement is authorised and supported by the institute’s leadership.

There is no publicly available evidence that the institute has an anti-bribery and corruption policy. The institute appears to have a Code of Business Conduct and Ethics, however this document is not publicly accessible so it is not possible to determine whether this covers anti-bribery and corruption.

There is no evidence that the institute has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.

There is no evidence that a specific managerial-level employee has ultimate responsibility for implementing and managing the institute’s anti-bribery and corruption programme.

There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which details the company’s stance against any form of bribery or corruption and is endorsed by the President and Chief Operating Officer. Although the statement does not specifically mention bribery and corruption, its position appears as part of the Anti-Corruption Compliance Guidelines and so is sufficient to receive a score of ‘2’.

There is evidence that the company publishes an anti-bribery and corruption policy which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery and facilitation payments. This policy clearly applies to all employees and board members as described in (a) and (b) in the question.

Based on publicly available information, there is evidence that a designated board committee – the Audit Committee – is ultimately responsible for oversight of the company's ethics and compliance programme, which is understood to incorporate anti-bribery and corruption. There is evidence that this includes reviewing reports from management on the programme’s performance, along with the results of internal and external audits.

Based on publicly available information, there is evidence that a designated senior executive – the Chief Ethics and Compliance Officer – has ultimate responsibility for implementing and managing the company's ethics and compliance programme, which is understood to incorporate anti-bribery and corruption. It is clear that this person has a direct reporting line to the Audit Committee, which provides oversight of the ethics and compliance programme. There is evidence of reporting activities between this person and the Audit Committee.

There is no evidence the company makes a public commitment to ethical or anti-bribery and corruption standards.

There is no evidence that the company has or publishes an anti-bribery and corruption policy for its employees.

There is no evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.

There is no evidence that a specific senior individual or managerial-level employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

There is evidence that the company makes a public commitment to ethical business conduct, and there is evidence that this commitment is supported by the Chairman and Managing Director. However, the company receives a score of ‘1’ because this commitment does not explicitly detail the company’s stance against anti-bribery and corruption.

There is no evidence that the company publishes an anti-bribery and corruption policy. The company’s website describes high-level procedures to ensure integrity and reduce the opportunities for corruption, however there is no evidence that the company publishes a clear anti-corruption policy for all employees that defines and prohibits bribery, payments to public officials, commercial bribery, and facilitation payments.

There is no evidence that the company has a dedicated board committee or department responsible for oversight of the company’s anti-bribery and corruption programme. The company indicates that it has a Chief Vigilance Officer responsible for ensuring compliance across the organisation, but there is no evidence that this individual is part of a wider risk or ethics committee which can review and implement changes to the company’s programme.

The company also states that its activities are monitored by the Central Vigilance Commission, a department within the Indian government responsible for ensuring compliance in businesses.

Based on publicly available information, there is evidence that a managerial-level individual – the Chief Vigilance Officer – has been assigned ultimate responsibility for managing the company’s anti-corruption activities.

However, the company receives a score of ‘1’ because it is not clear whether this person is a senior executive and there is no evidence that this person has a direct reporting line to the board.

There is evidence that the company has a publicly stated anti-corruption commitment, which details the company’s stance against corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company’s leadership.

There is evidence that the company publishes various anti-corruption policies: a Vigilance Manual; Principles and Policies of Business Responsibility; and a Code of Business Conduct and Ethics for Board Members and Senior Management. The Vigilance Manual specifies prohibition of bribery and payments to public officials and applies to all employees. The Principles and Policies of Business Responsibility specifies commercial bribery with regards to employees. The Code of Business Conduct and Ethics for Board Members and Senior Management, in which reference is made to corruption and ethics, applies to all board members, including non-executive directors.

However, the company receives a score of ‘1’ because there is no evidence that any of the policies or codes specifically address or prohibit facilitation payments.

There is evidence that a designated board committee – the Corporate Level Vigilance Committee – is ultimately responsible for oversight of the company’s anti-bribery and corruption programme.

However, the company receives a score of ‘1’ because there is no clear evidence that this committee engages in formal oversight functions, such as reviewing reports from management or the results of internal and external audits.

Based on publicly available information, there is evidence that a managerial-level individual – the Chief Vigilance Officer – has been assigned ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme. The Chief Vigilance Officer also serves as the Committee Secretary to the Corporate Level Vigilance Committee which provides oversight of the anti-bribery and corruption programme.

However, the company receives a score of ‘1’ because there is evidence to indicate that this individual is a senior executive.

There is evidence that the company publishes a clear anti-bribery and corruption commitment, which details its stance against any form of bribery and corruption within the organisation. There is evidence that this commitment was directly authorised and endorsed by the company’s senior leadership.

There is evidence that the company publishes an anti-bribery and corruption policy, which specifically prohibits commercial bribery and directly addresses facilitation payments. This policy applies to all employees and board members as described in (a) and (b) in the question.

However, the company receives a score of ‘1’ because there is no publicly available evidence that its anti-bribery and corruption policy prohibits payments to public officials.

Based on publicly available information, there is evidence that a designated board committee – the Audit Committee – is ultimately responsible for oversight of the company's ethics and compliance programme, which includes anti-bribery and corruption. The company indicates that this body is responsible for reviewing reports from management on the performance of the ethics and compliance programme and ensuring that required changes are made. The Audit Committee also reports at least annually to the board on the implementation and effectiveness of programme.

There is evidence that a designated senior individual – the Senior Vice President of the Office of Internal Governance and Administration – has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. The company indicates that this individual has a direct reporting line to the Audit Committee which provides oversight of the ethics and compliance programme. There is evidence of reporting and feedback activities between this person and the Audit Committee as part of the company’s reporting structure.

There is evidence that the company’s Chief Executive Officer makes a statement in support of ethical business conduct, and endorses the company’s Code of Business Ethics and Conduct. This document contains the company’s zero-tolerance stance toward bribery and corruption.

However, the company receives a score of ‘1’ because the public statement from its leadership does not specifically mention and address bribery and corruption.

There is evidence that the company publishes a clear anti-bribery and corruption policy, which prohibits bribery, payments to public officials, commercial bribery and facilitation payments. This policy explicitly applies to all employees and directors, including those of subsidiaries and other controlled entities.

There is evidence that the board level Audit Committee is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from management on the programme’s performance, along with the results of internal and external audits.

There is evidence that a designated senior executive has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to a board committee that provides oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this person and the board committee.

There is evidence that the company has a publicly stated anti-bribery and corruption statement, contained in the company’s Standards of Ethics and Business Conduct. It is clear that this commitment is endorsed by the company’s CEO, who states that the company and all its employees must share a commitment to ethical and honest business practices. However, the company receives a score of ‘1’ because there is no evidence that the company’s leadership directly addresses the organisation’s stance against bribery and corruption.

There is evidence that the company publishes an anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials and commercial bribery. In addition, there is evidence that this policy applies to all employees and board members as described in (a) and (b) in the question.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it has a policy to address or prohibit facilitation payments.

There is evidence that the Culture, Character, Integrity and Ethics Committee of the Board of Directors is ultimately responsible for oversight of the company's anti-bribery and corruption programme. The company indicates that the Committee’s responsibilities include reviewing reports from management on the programme’s performance, along with the results of internal and external audits, and there is evidence that it had the authority to require that any necessary changes are made.

There is evidence that a designated senior executive – the General Counsel – has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. There is evidence that this person has a direct reporting line to the board committee that provides oversight of the anti-bribery and corruption programme. In addition, there is evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure; for example, attendance or participation at board-level committee meetings.

The company’s Code of Business Conduct details the company's stance against bribery and corruption. It is clear that the Code of Business Conduct was authorised and endorsed by the company's leadership in the form of an introductory message from the President and Chief Executive Officer.

However, this message does not specifically mention anti-bribery and corruption and therefore a score of ‘1’ applies.

The company publishes a clear anti-bribery and corruption policy, which specifically defines and prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members as described in (a) and (b) in the question.

There is evidence that a board level committee - the company’s Governance Committee - provides oversight of the company's anti-bribery and corruption programme. There is evidence that this committee’s responsibilities include reviewing reports from management on the programme’s performance and reviewing policies.

However, the company receives a score of ‘1’ because it is not clear from publicly available evidence whether the Governance Committee reviews the results of internal and external audits of the anti-bribery and corruption programme, or that it has the authority to require that changes are made.

There is evidence that a designated senior executive - the General Counsel, Chief Compliance Officer and Corporate Secretary - has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the Governance Committee which provides oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure

There is no evidence of a commitment to ethical or anti-bribery and corruption standards.

The company does not publish an anti-bribery and corruption or ethics and compliance policy.

There is no evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.

There is no evidence that a specific senior individual has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

The company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. This commitment is included in the company’s Code of Conduct, which is in turn authorised and endorsed by the company's leadership.

However, the company’s leadership does not explicitly mention anti-bribery and corruption in its statement and the company can therefore not receive a score of ‘2’.

There is evidence that the company publishes an explicit anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members, regardless of their seniority, and across all subsidiaries and controlled entities.

There is evidence that a designated board committee is ultimately responsible for the oversight of the company's anti-bribery and corruption programme.

However, the company receives a score of ‘1’ because there is no evidence to suggest that it engages in formal oversight functions, such as reviewing reports from management or the results of internal and external audits.

There is some evidence to suggest that a designated senior executive has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. There is evidence that this person has a direct reporting line to the board committee that provides oversight of the anti-bribery and corruption programme. There is some evidence of reporting and feedback activities between this person and the board.

There is no evidence that the company has a commitment to ethical or anti-bribery and corruption standards.

There is no evidence that the company publishes an anti-corruption policy which applies to all employees.

There is no clear evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.

There is no evidence that the company has a specific managerial-level employee with ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

There is some evidence that the company has a publicly stated commitment against corruption as part of its group-wide integrity standards. However, the company receives a score of ‘1’ because it is not clear that the company’s commitment is authorised and endorsed by the company’s leadership.

Based on publicly available information, there is no evidence that the company has an anti-corruption policy. The company’s website lists integrity and anti-corruption as core values, but there is no indication that the company has and publishes a comprehensive anti-bribery and corruption policy that applies to all employees and board members.

There is no evidence that the company has an anti-corruption policy or programme, nor that a designated board committee or an individual board member is responsible for the company’s anti-bribery and corruption activities.

There is no evidence that the company publishes an anti-corruption policy, nor that a specific managerial-level employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. There is evidence that this commitment is authorised and endorsed by the company's senior leadership, through a direct statement from the Chief Executive Officer.

There is evidence that the company publishes a clear anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. It is clear that this policy applies to all employees and board members, including non-executive directors, as well as to the staff and leadership of subsidiaries and other controlled entities.

There is evidence that two board level committees provide oversight of the company’s anti-corruption programme: the Business Ethics and Compliance Committee, consisting of senior executives, and the Audit Committee, composed of members of the board. There is also evidence that the Audit Committee engages in formal oversight activities, including reviewing reports from management on the programme’s performance, and that it has the authority to require that any necessary changes to the programme are made.

There is evidence that the company’s General Counsel, a senior executive, has ultimate responsibility for implementing and managing its anti-bribery and corruption programme. The company states that the General Counsel has a direct reporting line to the board, and there is evidence of reporting and feedback activities between the General Counsel and the board as part of the company’s reporting structure.

The company’s Code of Business Conduct outlines its commitment to anti-bribery and corruption, however, the statement endorsed by the company’s leadership makes only a general commitment to integrity and high ethical standards.

There is evidence that the company sets out an anti-bribery and corruption policy in its Code of Business Conduct which includes a prohibition on bribery, payments to public officials, commercial bribery and facilitation payments. The Code of Business Conduct applies to all employees.

However, it is not clear that the policy applies to all board members, including non-executive directors.

There is evidence that a designated board committee, the Ethics and Corporate Responsibility Committee, is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. Although the Ethics and Corporate Responsibility Committee Charter does not explicitly mention oversight of anti-bribery and corruption, its remit includes reviewing compliance with the company’s Code of Conduct, which sets out its anti-bribery and corruption policy. This committee receives reports from the Chief Ethics and Compliance Officer and/or General Counsel and makes recommendations to the board regarding the enhancement of the company’s policies and activities. The company’s Audit and Compliance Committee is responsible for reviewing the results of internal and external audits.

There is evidence that a designated senior executive has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. They oversee the implementation of the Code of Conduct and measures relating to the anti-corruption programme. There is evidence that they provide regular reporting to the Ethics and Corporate Responsibility Committee on the effectiveness of the company’s anti-corruption programme.

There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which is reflected in its Code of Conduct. This is endorsed by the company's leadership in the form of an introductory message from the Chairman and Chief Executive Officer. However, the company receives a score of ‘1’ because this message does not explicitly mention anti-corruption or bribery.

There is evidence that the company publishes an anti-bribery and corruption policy, which makes explicit reference to the prohibition of bribery, payments to public officials and commercial bribery. This policy clearly applies to all employees and board members as described in (a) and (b) in the question. However, the company receives a score of ‘1’ because there policy does not make specific reference to facilitation payments.

There is no evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme. The company has a Committee on Directors and Governance but there is no publicly available evidence that specifically states that this committee’s responsibilities include oversight of the anti-bribery and corruption programme.

There is no evidence that a specific executive or managerial-level employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

There is evidence that the company’s CEO makes a public statement in support of the company’s ethics programme and promotes a commitment to ‘transparent business practice’ and ‘high ethical standards’.

However, the company receives a score of ‘1’ because the CEO’s public statement does not explicitly address or promote the company’s stance against bribery and corruption. There is evidence that in 2015 the company’s leadership explicitly endorsed its commitment to anti-bribery and corruption, however there is no evidence of a more recent statement to reaffirm this position.

There is evidence that the company publishes an anti-bribery and corruption policy, and that this policy applies to all employees and board members as described in (a) and (b) above.

However, the company receives a score of ‘1’ because there is no evidence that its publicly available policy extends beyond a general commitment to comply with anti-bribery laws. There is no evidence that the company specifically addresses and prohibits payments to public officials, commercial bribery or facilitation payments.

Based on publicly available information, there is evidence that the company’s Audit Committee is ultimately responsible for the oversight of its anti-corruption programme. There is evidence that this includes reviewing reports from management on investigations and the performance of the company’s ethics programme.

Based on publicly available information, there is evidence that a managerial-level individual, the Head of Corporate Auditing & Consulting Division, has ultimate responsibility for managing the company's anti-corruption programme. There is evidence that this individual has a direct reporting line to the Audit Committee and there is evidence of feedback activities between this person and the Audit Committee as part of the company’s reporting structure.

However, the company receives a score of ‘1’ because there is no evidence that the individual heading the Corporate Auditing & Consulting Division is a senior executive. It is also noted that, based on publicly available information, there is evidence that the development of ethics training and policies appears to fall under the remit of a different department: Compliance & Legal Support.

Based on publicly available information, there is evidence that the company makes a general commitment to responsible business that is endorsed by its Chief Executive Officer.

However, there is no evidence that this commitment makes direct reference to the company’s stance against bribery and corruption within the organisation, and therefore the company receives a score of ‘0’.

Based on publicly available information, there is evidence that the company publishes an anti-bribery and corruption policy which specifically prohibits bribery, payments to public officials, commercial bribery and facilitation payments. The policy applies to all employees, including staff and leadership of subsidiaries and other controlled entities.

Based on publicly available information, there is evidence that a designated board committee, the Audit & Risk Committee is ultimately responsible for the oversight of the company's compliance programme. This includes reviewing reports from management and the results of external audits.

Based on publicly available information, there is evidence that a designated senior executive has ultimate responsibility for managing the company's compliance programme. It is clear that this person has a direct reporting line to the board and the board committee that provides oversight of the compliance programme. There is evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure.

The company would do well to clarify the extent to which the CFO is responsible for implementing and managing the anti-bribery and corruption programme, or whether these responsibilities lie with the Group Compliance Officer.

There is evidence that the company has a publicly stated anti-corruption commitment, which details the company's stance against any form of corruption within the organisation, which is understood to include bribery. It is clear that this commitment was authorised and endorsed by the company's leadership.

There is some evidence that the company has an Ethical Charter and Code of Ethics, both of which it indicates apply to all employees. These policies outline the company’s zero tolerance position on corruption and commit to complying with all relevant anti-bribery laws.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that its policies specifically prohibit payments to public officials and facilitation payments. It is also not clear whether the Code of Ethics applies to all board members, including non-executive members.

Based on publicly available information, there is evidence that the company’s Ethics Department is responsible for evaluating and monitoring all anti-corruption policies and processes. The company indicates that this department reports directly to the Chairman-Chief Executive Officer and the board of directors. In addition, there is evidence that the Ethics Department’s responsibilities include formal oversight functions such as reviewing the functioning of the programme and conducting risk mapping exercises. It is clear that this department is the main body responsible for the company’s anti-corruption measures and that it has the authority to require that any necessary changes to the programme are made.

There is some evidence that a senior individual – the Senior Vice President Ethics and Compliance – has responsibility for implementing and managing the company's anti-bribery and corruption programme.

However, the company receives a score of ‘1’ because there is no clear publicly available evidence that this individual as a direct reporting line to the Ethics Department, which oversees of the anti-corruption programme, nor is there evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure. It is also not clear that this individual or position is a senior executive.

The company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. This commitment is clearly endorsed by its Chairman and CEO.

The company publishes an explicit anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members as described in (a) and (b) above.

There is evidence that the company's Ethics and Compliance Committee is responsible for overseeing the company's anti-corruption, ethics and integrity programme. The committee reviews reports from management on the programme's performance alongside the results of internal audits. There is also evidence that the committee ensures that necessary changes are made to the company's ethics and compliance programme. It reports at least annually to the company’s leadership.

There is evidence that a designated senior executive, the General Counsel, has ultimate responsibility for implementing and managing the company's ethics and compliance programme. The General Counsel chairs the Ethics and Compliance Committee, which provides reporting to the company’s leadership on at least an annual basis.

The company has a publicly stated commitment to 'integrity' and 'high ethical standards'. However, there is no evidence that this statement is directly authorised or supported by the company leadership and it does not explicitly refer to anti-bribery and corruption.

The company has a Code of Ethics which applies to directors and employees. However, the code is not available on the company’s website. The company provides a summary of its Code of Ethics and outlines some standards that it establishes, but these summaries do not specifically mention tackling bribery or corruption.

There is evidence that a designated board committee – the Social & Ethics Committee – oversees the company's ethics and anti-bribery and corruption activities. However, the company receives a score of ‘1’ because there is no evidence to suggest that it engages in formal oversight functions, such as reviewing reports from management. The Audit Committee reviews reports from auditors although it is unclear if this specifically includes reviewing reports on the anti-bribery and corruption programme.

There is no evidence that a specific managerial-level employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme. There is evidence that the company has a Risk and Compliance Manager but it is not explicitly stated that this individual’s remit includes implementing and managing the company’s anti-bribery and corruption activities.

There is evidence that the company publishes a clear statement the outlines its commitment against all forms of bribery and corruption. It is clear that this statement is directly supported and endorsed by members of the company’s executive leadership.

There is evidence that the company publishes an anti-bribery and corruption policy which specifically prohibits bribery and commercial bribery. There is evidence that this policy applies to all employees and board members of the company.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that the company prohibits facilitation payments or payments to public officials.

There is evidence that a designated board committee – the Compliance Committee – is responsible for oversight of the company's anti-bribery and corruption programme. There is evidence that the Compliance Committee and the board engage in formal oversight functions including reviewing reports from management on the programme’s performance and it has the authority to require that any necessary changes are made. There is further evidence indicating that the Compliance Committee reviews audits of the company’s anti-corruption compliance programme.

There is evidence that a designated senior executive, the Corporate Compliance Officer, has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the board, and there is evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure.

The company has a publicly stated anti-corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's leadership.

The company has an anti-corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials and commercial bribery. The policy applies to all company employees and board members.

However, the company’s anti-corruption policy does not make reference to facilitation payments and it is not explicitly clear that the policy applies to non-executive directors as well as the staff and leadership of subsidiaries and other controlled entities within the policy.

There is evidence that a designated board committee, the Business Ethics and Compliance Committee, is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from management on the programme’s performance and ensuring that required changes are made. The company’s Audit Committee receives a quarterly briefing on internal and external audits of the company’s ethics and compliance programme.

There is evidence that a designated senior executive has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the designated board committee that provides oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure.

There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. It is clear that this commitment is authorised and endorsed by the company’s President and Chief Executive Officer.

There is evidence that the company publishes an anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that this policy applies to all employees and board members as described in (a) and (b) in the question.

There is evidence that the board and the Audit Committee are ultimately responsible for providing oversight of the company’s anti-bribery and corruption programme. There is evidence to suggest that these bodies engage in formal oversight functions, such as reviewing reports from management, and that they have the authority to require that any necessary changes to the programme are made.

Based on publicly available information, there is evidence that a senior executive, the Chief Compliance Officer, has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. The company indicates that this individual has a direct reporting line to the board and periodically reports findings on the effectiveness of the company’s anti-bribery and corruption programme to both the board and Audit Committee.

There is evidence that the company makes a public commitment to anti-corruption through provisions in its Anti-Corruption Policy. There is evidence that this policy as a whole is authorised and endorsed by the company’s Managing Director. In addition, there is also evidence that its parent company – CSG Holding – makes a commitment to ethical standards and that this commitment is supported by the CEO.

The company receives a score of ‘1’ because there is no evidence that the company, or its parent company, publishes a specific or direct commitment to anti-bribery and corruption from its senior leadership, in addition to an endorsement of the anti-corruption policy overall.

Based on publicly available information, there is evidence that the company has an explicit anti-corruption and bribery policy, which specifically prohibits bribery, facilitation payments and payments to public officials. The policy clearly applies to employees and board members as described in (a) and (b) in the question.

Based on publicly available information, there is evidence that the board of directors of the company’s parent company is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. There is evidence that the board oversees the Compliance Department, which is responsible for the implementation of the programme.

However, the company receives a score of ‘1’ because there is no clear publicly available evidence to suggest that the board engages in formal oversight functions, such as reviewing reports from management or the results of audits.

Based on publicly available information, there is no evidence that a specific managerial-level employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme. The company indicates that the Group’s Compliance Department as a whole manages the programme but there is no evidence that there is a specific individual with ultimate responsibility for anti-bribery and corruption.

There is evidence that the company has a publicly stated anti-corruption commitment which details the company's stance against corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's CEO.

There is evidence that the company publishes an Anti-Corruption Policy and a Code of Conduct. The Anti-Corruption Policy makes specific reference to prohibition of bribery, payments to public officials, commercial bribery and facilitation payments and applies to all employees as specified in (a) and (b) above. The Code of Conduct applies to all groups as specified in (a) and (b), and makes specific reference to prohibition of bribery and payments to public officials.

There is evidence that the board and the Sustainability Committee are ultimately responsible for the oversight of the company's anti-bribery and corruption programme. There is evidence to suggest that they engage in formal oversight functions, such as reviewing reports from management on the programme’s performance, and ensuring that required changes are made.

Based on publicly available information, there is evidence the company has established an Anti-Corruption Function, which manages and implements the company’s anti-corruption policy and has a direct reporting line to the Board of Directors. However, there is no clear publicly available evidence that a specific senior employee or executive has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

There is evidence that the company publishes a clear anti-bribery and corruption commitment, which details its stance against any form of bribery or corruption within the organisation. There is evidence that this commitment was directly authorised and endorsed by the company’s Chief Executive Officer.

There is evidence that the company has an anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials and commercial bribery. There is evidence that this policy applies to all employees and board members as described in (a) and (b) in the question. The company publishes two Codes of Conduct which cover ethical risks, anti-bribery and corruption – one for employees and one for members of the board.

Although the company states that facilitation payments are prohibited, there is evidence that these are permissible in some circumstances, providing that they follow certain procedures and are allowed under applicable laws. Since these exceptions appear to encompass more than an imminent threat to physical security, the company receives a score of ‘1’.

There is evidence that the company’s board-level Audit Committee is responsible for providing oversight of its compliance and ethics programme, which is understood to include anti-bribery and corruption initiatives. The company indicates that the committee’s responsibilities include reviewing reports from management on the programme’s performance, along with the results of internal and external audits, and there is evidence that the committee has the authority to require that any necessary changes to the programme are made.

There is evidence that a senior individual – the Chief Compliance Officer – has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. The company indicates that this individual has a direct reporting line to the board and board committee that provides oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure.

The company publishes a clear statement on its anti-bribery and corruption commitment, which details the company’s stance against any form of bribery or corruption within the organisation. There is evidence that this commitment was authorised and endorsed by the company’s leadership.

The company publishes an anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members as described in (a) and (b) in the question.

Based on publicly available information, there is evidence that a designated board committee, the Risk Management and Compliance Committee, is ultimately responsible for oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from management on the programme’s performance. There is evidence that the committee has the authority to require that changes are made.

Based on publicly available information, there is evidence that a designated senior executive, the Chief Risk Management & Compliance Officer, has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the Risk Management and Compliance Committee which provides oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this person and the committee as part of the company’s reporting structure.

There is evidence that the company’s Code of Conduct, which outlines its stance against bribery and corruption, is authorised and endorsed by the board and the Chief Executive Officer. However, the company receives a score of ‘1’ because there is no evidence that the company’s leadership makes a direct commitment to anti-bribery and corruption.

There is evidence that the company has an anti-bribery and corruption policy as part of its Code of Conduct. The company’s policy clearly prohibits bribery, payments to public officials, commercial bribery and facilitation payments. There is evidence that this policy applies to all employees and board members, including non-executive directors, as well as the staff and leadership of subsidiaries and other controlled entities.

There is evidence that a designated board committee – the Audit Committee – is responsible for providing oversight of the company’s anti-corruption programme. There is evidence that the Audit Committee’s oversight responsibilities include reviewing reports from management on the programme’s performance, along with the results of audits, and there is evidence that it has the authority to ensure that any required changes are made.

There is evidence that the General Counsel has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the board, as well as to the board-level Audit Committee responsible for oversight of such activities. There is evidence of reporting and feedback activities between the General Counsel and the board as part of the company’s reporting structure.

There is evidence that the company has a publicly stated commitment to 'integrity' and 'high ethical standards', but it does not explicitly mention anti-bribery and corruption. There is no clear evidence that this statement is endorsed or authorised by the company’s leadership and it only appears in its supplier code of conduct.

There is no publicly available company has or publishes an anti-bribery and corruption policy for its employees.

There is no evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.

There is no evidence that a specific senior individual or managerial-level employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

Based on publicly available information, there is evidence that the company has a publicly stated commitment to anti-bribery and corruption as part of its Standards of Business Ethics and Conduct, which is endoresd by the chairman and CEO.

However, the company receives a score of ‘1’ because the statement from the company’s leadership does not explicitly mention and stand against bribery or corruption.

There is evidence that the company publishes an anti-bribery and corruption policy, which applies to all employees and executives within the organisation.

However, the company receives a score of ‘1‘ because there is no clear evidence that this policy prohibits facilitation payments and it is not clear that the policy applies to non-executive directors.

There is evidence that the company’s board-level Audit Committee provides oversight of the anti-bribery and corruption programme as part of its oversight of the company’s Business Ethics and Conduct Program. There is evidence that this Committee engages in formal oversight functions such as monitoring the programme’s implementation and meeting with auditors.

However, the company receives a score of ‘1’ because there is no evidence that the Committee reviews reports on anti-bribery and corruption performance specifically, nor is there clear evidence that it has the authority to require that changes to the programme are made when necessary.

There is some evidence that the company has an ethics officer responsible for managing reviewing, investigating and addressing issues related to the company’s Standards of Business Ethics and Conduct, which includes anti-bribery and corruption. There is evidence that this individual has a direct reporting line to the Audit Committee, which in turn presents its findings to the board.

However, the company receives a score of ‘1’ because there is no evidence that this individual holds a senior or managerial level position within the organisation.

There is no evidence that the company has a publicly stated anti-bribery and corruption commitment, which is authorised and endorsed by the company’s leadership. The company mentions bribery and corruption as behaviours that will not be tolerated but this is indirect and not supported by a senior leadership figure.

There is evidence that the company has an anti-corruption policy, which prohibits bribery and applies to all employees and board members.

However, the policy does not explicitly prohibit payments to public officials or facilitation payments. It is also unclear whether the policy applies to the staff and leadership of subsidiaries and other controlled entities. While the company states that more detail on its ethical commitments can be found in the GKN Aerospace Code and Policies, this document is not publicly accessible.

There is no evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.

There is no evidence that a specific managerial-level employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

There is no evidence that the company publishes a commitment to ethical or anti-bribery and corruption standards.

There is no evidence that the company publishes an anti-bribery and corruption policy.

There is no evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.

There is no evidence that a senior executive or specific managerial-level employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

There is evidence that the company publishes a clear statement on its anti-bribery and corruption commitment, which details the company’s stance against any form of bribery or corruption within the organisation. There is evidence that this commitment was authorised and endorsed by the company’s leadership.

The company publishes a clear anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members as described in (a) and (b) in the question.

Based on publicly available information, there is evidence that the board-level Compliance Committee provides oversight of the company’s anti-bribery and corruption programme. There is evidence that the committee reviews reports from management and the results of internal and external audits, and that it has the authority to require that any necessary changes to the programme are made.

Based on publicly available information, there is evidence that a designated senior executive – the Compliance Officer – has ultimate responsibility for implementing the company’s anti-corruption program. This person has a direct reporting line to the board and the Compliance Committee. There is evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure.

There is evidence that the company publishes a statement in support of ethical conduct and integrity, which is authorised and endorsed by the company’s President and CEO. However, the company receives a score of ‘1’ because this publicly available statement does not directly mention or address the company’s commitment to anti-bribery and corruption.

There is evidence that the company publishes an anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. This policy applies to all employees and board members as described in (a) and (b) in the question.

Based on publicly available information, there is evidence that the board-level Audit Committee is ultimately responsible for oversight of the company’s anti-bribery and corruption programme. This includes reviewing reports from management on the programme’s performance and the results of audits. In addition, there is evidence that the Audit Committee has the authority to require that any necessary changes to the programme are made.

Based on publicly available information, there is evidence that a designated senior executive – the Chief Ethics and Compliance Officer – has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this individual has a direct reporting line to the board-level Audit Committee which provides oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this person and the Audit Committee.

There is no clear evidence that the company has a public commitment to ethical or anti-bribery and corruption standards.

There is no evidence that the company publishes an anti-bribery and corruption policy.

There is no evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.

There is no evidence that a specific managerial-level employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

There is evidence that the company publishes statements against corruption and in support of ethical business practices, which are endorsed by senior figures other than the company leadership. Publicly available statements made by the company’s leadership are indirect in nature.

There is evidence that the company has anti-bribery and corruption policies which apply to all employees, including those working for subdiaries and other controlled entities, as well as executive and non-executive directors. There is evidence that these policies explicitly prohibit bribery and commercial bribery.

However, there is no evidence that the company's policies prohibit facilitation payments or payments to public officials.

There is evidence that the company’s board of directors and its audit commitee provide oversight of its anti-corruption programme.

There is evidence that the company’s Chief Vigilance Officer has responsibility for implementing and managing all anti-corruption activities at the company. There is evidence of reporting and feedback activities between the Chief Vigilance Officer and the company’s Chairman of the Board of Directors.

However, evidence suggests that the Chief Vigilance Officer is not a senior executive.

There is evidence that the company has a publicly stated commitment to integrity, compliance and high ethical standards which is authorised and endorsed by the company’s Chairman and CEO, Darius Adamczyk. This commitment appears at the start of the company’s Code of Business Conduct, which addresses bribery and improper payments as a specific risk. The company receives a score of ‘1’ because there is no evidence that the company’s senior leadership makes a clear and direct statement on anti-bribery and corruption.

Based on publicly available information, there is evidence that the company has a Code of Business Conduct which prohibits bribery, commercial bribery and improper payments to public officials. The company also publishes highlights of its Anti-Corruption Policy, which prohibits facilitation payments. There is evidence that the Code of Business Conduct applies to all employees and directors of the company, while the Anti-Corruption Policy applies to all employees, including those employed by subsidiaries and other controlled entities.

There is evidence that the company's Corporate Governance and Responsibility Committee is accountable to the board for oversight of the Code of Business Conduct, which outlines the company’s anti-bribery and corruption stance and wider compliance programme. This committee's functions include monitoring and reviewing reports on adherence to the code of conduct and the performance of the compliance programme.

In addition, there is evidence that both the Corporate Governance and Responsibility Committee and the Audit Committee engage in formal oversight functions relating to compliance with ethics and integrity, including reviewing audits and formal reports on the company’s compliance activities. There is evidence that these bodies have the authority to require that any necessary changes to the programme are made.

There is some evidence to indicate that a specific managerial-level individual – the Vice President Global Compliance – has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

However, the company receives a score of ‘1’ because it is not clear that this individual is a senior executive, nor is there evidence of clear reporting and feedback between this individual and the board.

The company publishes an explicit anti-corruption message which is endorsed by its CEO.

There is evidence that the company has an anti-corruption policy which prohibits bribery, commercial bribery, facilitation payments and payments to government officials. Evidence indicates that this policy applies to all employees and directors of the company, as well as all employees and leadership of subsidiaries and other controlled entities.

There is evidence that the board and the audit committee are ultimately responsible for the oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from management on the programme’s performance, along with the results of internal and external audits, and ensuring that required changes are made.

There is clear evidence that a designated senior executive has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the board. There is evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure.

There is evidence that the company has a publicly stated commitment to ethics. However, the company receives a score of ‘0’ because there is no evidence that this commitment is not authorised or supported by a senior figure. The company’s statement also does not make specific reference to anti-bribery and corruption.

There is evidence that the company has ethical guidelines for its employees that includes a compliance manual on fair trade, which refers to some of the risk areas related to bribery and corruption. However, the company receives a score of ‘0’ because this document does not make explicit reference to anti-bribery and corruption, and there is no evidence that any of the company’s other publicly available information outlines anti-bribery and corruption policies for its employees or board members.

There is evidence that a designated board committee – the Ethics Committee – oversees the company's compliance programme. However, there is no evidence to suggest that the compliance programme includes a focus on bribery and corruption. In addition, there is no clear evidence that the committee engages in formal oversight functions such as reviewing reports from management or the results of internal and external audits of an anti-bribery and corruption programme.

Based on publicly available information, there is no evidence that a senior individual is ultimately responsible for implementing and managing the company’s anti-bribery and corruption programme. Although there is evidence that the company has a Compliance Officer, there is no publicly available evidence to suggest that their responsibilities include oversight of anti-bribery and corruption.

There is evidence that the company has a publicly stated commitment to integrity and high ethical standards which is endorsed by the company’s President and CEO. The publicly available statement directly refers to addressing the challenge of bribery of foreign public officials, and there is evidence that this text appears at the start of the company’s Code of Conduct, which includes an anti-bribery commitment.

There is evidence that the company publishes a Code of Conduct that applies to all employees of the group. The company’s policy clearly prohibits bribery and payments to public officials.

However, the company receives a score of ‘1’ because there is no evidence that it prohibits facilitation payments, nor is it clear that the policy applies to board members.

Based on publicly available information, there is evidence that the company’s Compliance Committee maintains responsibility for the company’s anti-bribery and corruption programme. There is evidence that the Compliance Committee is chaired by a senior executive and has a direct reporting line to the board, which holds ultimate accountability.

However, the company receives a score of ‘1’ because there is no clear publicly available evidence that this committee sits at board level, nor is it clear that the committee’s responsibilities include reviewing reports from management on the programme’s performance.

Based on publicly available information, there is evidence that a designated senior executive – the Chief Compliance Officer – has ultimate responsibility for implementing and managing the company’s compliance programme. There is evidence that the Chief Compliance Officer has a direct reporting line to the board, and there is evidence of reporting and feedback activities between this person and the board as part of the company’s structure.

There is no publicly available evidence that the company makes a publicly stated commitment to ethical or anti-bribery and corruption standards, nor is there clear evidence that its anti-corruption policy is endorsed by its senior leadership.

There is evidence that the company publishes an anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery and facilitation payments. This policy clearly applies to all employees and board members as described in (a) and (b) in the question.

Based on publicly available information, there is evidence that the board of directors is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. The company indicates that the board’s responsibilities include reviewing reports from management on the programme’s performance and there is evidence that the board has the authority to require that changes are made.

Based on publicly available information, there is evidence that a designated senior executive has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the board which provides oversight of the anti-bribery and corruption programme and there is evidence of reporting and feedback activities between this person and the board.

There is no evidence of a publicly stated anti-bribery and corruption commitment, which is authorised by the company’s leadership.

While there is some evidence that the company adopts Integrity Pacts in its procurement processes, there is no evidence that the company has an anti-bribery and corruption policy.

There is no evidence that the company has a designated board committee or individual board member responsible for an anti-bribery and corruption programme.

Based on publicly available information, there is evidence that a managerial-level individual has been assigned ultimate responsibility for managing vigilance at the company. However, there is no clear publicly available evidence that the role of this individual includes implementing and managing an anti-corruption programme.

There is evidence that the company’s CEO publicly endorses the company’s Code of Ethics and Compliance, which includes its anti-bribery and corruption policy. However, the company scores ‘1’ as this statement does not directly mention or support the company’s anti-bribery and corruption stance.

There is evidence that the company publishes an anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. This policy applies to all employees and board members as described in (a) and (b) in the question.

Based on publicly available information, there is evidence that a designated board committee – the Audit and Compliance Committee – is ultimately responsible for oversight of the company’s anti-bribery and corruption programme. There is evidence that the committee is engaged in formal oversight functions and it is clear that this committee has the authority to require that any necessary changes to the programme are made.

Based on publicly available information, there is evidence that the company has a designated Compliance Officer responsible for implementing and managing the company's anti-bribery and corruption programme. However, it is not clear from publicly available information whether this individual is a senior executive or whether they have a direct reporting line to the board committee that provides oversight of the anti-bribery and corruption programme.

There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's leadership.

There is evidence that the company publishes an anti-bribery and corruption policy, which makes specific reference to bribery and payments to foreign public officials. This policy clearly applies to all employees and board members as described in (a) and (b) above.

However, the company does not explicitly prohibit facilitation payments or commercial bribery.

There is evidence that the board is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from the company’s Compliance Officer on the programme’s performance and ensuring that required changes are made.

There is evidence that a designated senior executive, the Compliance Officer, has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that the Compliance Officer has a direct reporting line to the board. There is evidence of reporting and feedback activities between the Compliance Officer and the board as part of the company’s reporting structure.

There is no evidence that the company makes any publicly available commitment to ethical or anti-bribery and corruption standards.

There is no evidence that the company has or publishes an anti-bribery and corruption policy for its employees.

There is no evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.

There is no evidence that a specific senior individual or managerial-level employee has responsibility for implementing and managing the company’s anti-bribery and corruption programme.

There is evidence that the company has a publicly stated anti-bribery and corruption commitment. There is clear evidence that this commitment was authorised and endorsed by the company's President and Chief Executive Officer.

There is clear evidence that the company has an anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence this policy applies to all employees and board members.

There is evidence that the company’s Corporate CSR Committee is responsible for overseeing the company’s Code of Conduct and therefore the company’s anti-bribery and corruption policy. There is evidence that this committee is chaired by the President, who is a member of the board of directors. The company indicates that this committee is responsible for monitoring the achievement levels and status of the company’s compliance programme.

Based on publicly available information, there is evidence that the President of the company, who is also the chair of the Corporate CSR Committee, has ultimate responsibility for overseeing all aspects of the company’s compliance structure, which includes its anti-bribery and corruption programme. Although the company does not explicitly state that the President is responsible for implementing and managing the its compliance activities, the company’s annual report indicates that the Corporate CSR committee is tasked with monitoring and implementation, so this is deemed sufficient for a score of ‘2’.

There is evidence that the company has a publicly stated anti-bribery and corruption statement that is endorsed by its leadership. There is evidence that this statement is published in the company’s Code of Business Conduct, which contains its anti-bribery and corruption policy.

However, the company receives a score of ‘1’ because there is no publicly available evidence that its senior leadership directly addresses and supports the company’s stance against corruption.

There is evidence that the company publishes an anti-bribery and corruption policy, which makes specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that this policy clearly applies to all employees and board members as described in (a) and (b) above.

There is evidence that a board committee is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from management on the programme’s performance, along with the results of internal and external audits, and has the authority to ensure that required changes are made.

There is clear evidence that a designated senior executive has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the board or board committee that provides oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure.

There is no evidence that the company has a public commitment to anti-bribery and corruption that is authorised and endorsed by its senior leadership. The company has a publicly stated commitment to 'integrity' but does not explicitly mention anti-bribery and corruption, and there is no direct evidence that this statement is supported by a senior figure.

There is no evidence that the company publishes an anti-bribery and corruption policy.

There is no evidence that the company has a designated board committee or individual board member responsible for anti-bribery and corruption.

There is no evidence that a specific managerial-level employee has ultimate responsibility for implementing and managing an anti-bribery and corruption programme.

Based on public evidence, the company has a publicly stated commitment to integrity in its Code of Conduct, which includes its anti-bribery and corruption policy. The Code of Conduct is endorsed by the company’s CEO. However, the company receives a score of ‘1’ because this statement does not specifically make reference to anti-bribery and corruption.

Based on publicly available information, there is evidence that the company publishes a comprehensive anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery and facilitation payments. This policy applies to all employees and board members.

Based on publicly available information, there is evidence that a designated board committee oversees the company’s anti-bribery and corruption programme and engages in formal oversight functions. There is evidence that the Compliance Committee supervises the company’s compliance and ethics activities and that it has the authority to require that any necessary changes are made.

Based on publicly available information, there is evidence that a designated senior executive has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the board/board committee that provides oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure.

There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which details the company’s stance against any form of bribery or corruption within the organisation. It is clear that this commitment is authorised and endorsed by the company’s President and CEO.

Based on publicly available information, there is evidence that the company publishes an Anti-Corruption Guide and a Code of Ethics and Business Conduct, both of which specifically prohibit bribery, payments to public officials, commercial bribery and facilitation payments. These policies apply to all employees and board members.

There is some evidence that the Board of Directors provides oversight of the company’s anti-corruption and compliance programme, including for example by adopting the Code of Ethics and Business Conduct. The company has an Ethics Committee appointed by the Board, which is responsible for promoting high ethical standards.

However, although there is some evidence that the board reviews the results of internal audits, it is not sufficiently clear that the scope of these audits include the company’s anti-bribery and corruption programme. There is also no clear evidence that the board or a board committee receives reports from management on the programme’s performance and ensures that required changes are made.

There is clear evidence that a designated senior executive has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the board committee that provides oversight of the anti-bribery and corruption programme. There is evidence of feedback activities between this person and the board as part of the company’s reporting structure.

There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's CEO.

There is evidence that the company publishes an explicit anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members.

Based on publicly available information, there is evidence that the board is ultimately responsible for the oversight of the company's ethics and compliance programme. This includes reviewing reports from management on the programme’s performance along with the results of audits, and there is evidence that the board has the authority to require that any necessary changes are made.

There is evidence that a designated senior executive, the company’s Chief Ethics and Compliance Officer, has ultimate responsibility for implementing and managing the company's ethics and compliance programme. It is clear this person has a direct reporting line to the board, which provides oversight of the programme.

There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company’s CEO.

The company publishes an explicit anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members.

Based on publicly available information, there is some evidence that the board of directors is responsible for the company’s anti-bribery and corruption programme.

However, there is no evidence to suggest that it engages in formal oversight functions, such as reviewing reports from management or the results of internal and external audits.

While the company refers to a local compliance officer in its Ethics Charter, there is no further public information concerning the role, responsibilities or seniority of this individual. There is insufficient evidence that a specific managerial-level employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

The company publishes a clear statement in support of high ethical standards and integrity, which is signed by its Chairman and CEO. This commitment appears in the company’s Code of Conduct, which contains the company’s anti-corruption policy that applies all employees within the organisation.

There is evidence that the company publishes a Code of Conduct, which explicitly prohibits bribery, payments to public officials, commercial bribery and facilitation payments. The company indicates that its policy applies to all employees and board members as described in (a) and (b) in the question.

There is evidence that a designated board committee – the Nominating and Governance Committee – is responsible for providing oversight of the company’s anti-bribery and corruption programme. There is evidence that the committee’s responsibilities include reviewing reports from management on the programme’s performance and it is clear that it has the authority to require that changes are made.

There is evidence that a designated senior executive – the company’s VP and Corporate Ethics Officer, also referred to as the Director of Ethics and Compliance – has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person is at executive level and has a direct reporting line to the board through interaction with the Nomination and Governance Committee, which provides oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure, through attendance at meetings of the Nomination and Corporate Governance Committee.

There is evidence that the company’s Chairman and CEO makes a public statement in support of high ethical standards. There is clear evidence that this individual supports and endorses the company’s Code of Conduct, which contains the company’s policy to prohibit all forms of bribery and corruption within the organisation.

There is evidence that the company publishes a clear anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and directors, and there is evidence to indicate that this extends to all individuals as listed in (a) and (b) in the question.

There is evidence that the company’s Ethics and Corporate Responsibility Committee is ultimately responsible for oversight of the anti-bribery and corruption programme. There is clear evidence that this committee engages in formal oversight functions, including reviewing reports from management and audits, and that it has the authority to require that any necessary changes to the programme are made.

There is evidence that the company’s Chief Ethics and Compliance Officer is responsible for managing its anti-bribery, corruption and ethics programme. It is clear that this individual has a direct reporting line to the Ethics and Corporate Responsibility Committee, which provides oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between the Chief Ethics and Compliance Officer and the board as part of the company’s reporting structure.

There is evidence that the company has a publicly stated anti-bribery and corruption commitment which details the company's stance against any form of bribery or corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's Chairman.

Based on publicly available information, there is evidence that the company has an explicit anti-bribery and corruption policy, which makes reference to the prohibition of bribery, payments to public officials, commercial bribery and facilitation payments. This policy clearly applies to all employees and board members as described in (a) and (b) above.

Based on publicly available information, there is evidence that the board is ultimately responsible for the oversight of the company’s anti-corruption programme. The company has established a Control and Risk Committee which comprises several board members and provides direct reporting on the anti-corruption programme to the board. There is also evidence that the board engages in formal and direct oversight functions, including reviewing reports from management along with the results of internal and external audits.

Based on publicly available information, the Chairman of the Board has ultimate responsibility for overseeing the implementation of the company's anti-bribery and corruption programme. An anti-corruption unit is responsible for management and implementation, reporting to the Chairman and the Group General Counsel.

There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's leadership.

There is evidence that the company publishes a clear anti-bribery and corruption policy which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery and facilitation payments. This policy clearly applies to all employees and board members as described in (a) and (b) in the question.

There is no clear evidence to suggest that a designated board committee or individual board member is responsible for the company’s anti-bribery and corruption programme. There is some evidence to indicate that the Legal Affair & Chief Compliance Officer is responsible for the compliance programme, however it is not clear whether this individual is a senior executive or board member, nor that this individual has ultimate responsibility for overseeing the programme.

There is evidence that the Legal Affairs & Chief Compliance Officer has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the CEO and board of directors, which provides oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this individual and the board twice a year as part of the company’s reporting structure.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that this individual is a senior executive.

The company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's leadership.

The company publishes an explicit anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members, regardless of their seniority, as well as the staff and leadership of subsidiaries and other controlled entities.

There is evidence that a board committee – the Nominating and Corporate Governance Committee – is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. The committee receives reports from the Senior Vice President Internal Audit, Ethics & Sustainability regarding the company’s ethics and business conduct programme. In addition, as part of the company’s anti-corruption policies, the Senior Vice President, Ethics and Enterprise Assurance reports significant audit matters to the Audit Committee of the board.

There is evidence that a senior executive, the Senior Vice President Ethics and Enterprise Assurance, has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme. This position has a direct reporting line to the Chairman, President and CEO, executive leadership team and the Nominating and Corporate Governance Committee and Audit Committee of the board. The Senior Vice President Ethics and Enterprise Assurance provides frequent summary reports on the company’s ethics programme to board members and responds to their feedback.

There is evidence that the company publishes a Standards of Ethics and Business Conduct which outlines its stance against bribery and corruption. It is clear that this document was authorised and endorsed by the company's leadership, though an introductory message from the company’s President and CEO and executive team.

However, the company receives a score of ‘1’ because the statement from the company’s leadership does not directly address or mention the organisation’s stance against bribery and corruption.

There is evidence that the company publishes an anti-bribery and corruption policy which specifically prohibits bribery, payments to public officials and commercial bribery. There is evidence that this policy applies to all employees and board members of the company as listed in (a) and (b) in the question.

However, the company receives a score of ‘1’ because there is no publicly available evidence it prohibits facilitation payments.

There is evidence that a designated board committee – the Audit Committee – oversees the company's ethics and compliance programme. The company indicates that this includes reviewing reports from management on the programme’s performance. In addition, there is evidence that Audit Committee has the authority to require that updates and changes to the programme are made when necessary.

There is evidence that the General Counsel and Chief Compliance Officer have been assigned responsibility managing the company’s ethics and compliance programme. There is evidence that these individuals have a direct reporting line to the board-level Audit Committee, which is responsible for providing oversight of the programme.

However, the company receives a score of ‘1’ because there is no clear evidence of reporting and feedback activities between these individuals and the board as part of its reporting structure.

The institute has a publicly stated commitment to adhere to relevant legislation concerning anti-bribery and corruption, such as the U.S. Foreign Corrupt Practices Act. However, further details are not publicly available and it is not clear whether this statement is endorsed by a senior figure. The Lincoln Laboratory, the federally funded research and development centre through which MIT undertakes work for the U.S. Department of Defense, likewise does not publish a separate statement regarding anti-bribery and corruption authorised by a senior figure.

There is evidence that the Lincoln Laboratory has a code of conduct, which applies to all personnel, including board members. However, this code of conduct makes no reference to anti-bribery and corruption; rather it states that employees must contribute to an ethical atmosphere and comply with laws and regulations.

There is evidence that the Risk and Audit Committee is responsible for the oversight of the institution’s compliance programme. However, this is only evident from simple statements that do not offer details into oversight functions, such as reviewing reports from management or the results of internal and external audits. There is no publicly available information about whether the committee specifically oversees anti-corruption efforts, nor whether it specifically oversees the Lincoln Laboratory.

There is evidence that the institution has assigned responsibility for implementing and managing its compliance programme to several managerial-level employees. However, anti-bribery and corruption is not mentioned explicitly as a part of the compliance programme. Additionally, there is no evidence of reporting and feedback activities between these individuals and the board as part of the institution’s reporting structure, for example through attendance or participation at board-level committee meetings.

There is evidence that the company has a publicly stated anti-bribery and corruption statement, which outlines its stance against any form of bribery or corruption within the organisation. It is clear that this statement is authorised and endorsed by the company’s CEO.

There is evidence that the company publishes an anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. The company’s policy applies to everyone within the company including those at subsidiaries and controlled entities.

There is evidence that the company has a executive-level committee – the Business Ethics Committee (BEC) – that is ultimately responsible for the oversight of the company’s anti-bribery and corruption programme. This includes reviewing reports on the programme’s performance, along with the results of internal audits, and there is evidence that it has the authority to require that any necessary changes are made.

There is evidence that a designated senior executive – the Group Director Business Ethics & Corporate Responsibility, also referred to as the Group Compliance Officer – has ultimate responsibility for implementing and managing the anti-bribery and corruption programme. This individual has a direct reporting line to the Business Ethics Committee. There is evidence of reporting and feedback activities between this person and the committee as part of the company’s reporting structure, through the attendance and participation at committee meetings on at least a quarterly basis.

There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's CEO.

There is evidence that the company publishes a clear anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that this policy clearly applies to all employees and board members as listed in (a) and (b) in the question.

Based on publicly available information, there is evidence that a designated board committee – the Corporate Responsibility Committee – is responsible for oversight of the company´s anti-bribery and corruption programme. There is evidence to indicate that the committee’s role includes reviewing reports from management on the programme’s performance, and that it has the authority to require that any necessary changes to the programme are made.

Based on publicly available information, there is evidence that the Group Company Secretary has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme. There is evidence of reporting activity between this individual and the board as part of the company´s reporting structure. The company indicates that the Group Company Secretary acts as the secretary of the Corporate Responsibility Committee, which reports on its activities to the Board after each meeting.

There is no evidence that the organisation has a publicly stated commitment to anti-bribery and corruption that is authorised by its leadership. The organisation makes a publicly stated commitment to high standards of ethical conduct but there is no specific mention of anti-bribery and corruption, nor is there evidence that this commitment is supported by a senior figure.

There is no publicly available evidence that the organisation has an anti-bribery and corruption policy. The organisation makes a general commitment to upholding ethical values but there is no specific mention of policies or procedures to prevent bribery and corruption.

There is no evidence that the organisation has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.

There is no evidence that a specific managerial-level employee has ultimate responsibility for implementing and managing the organisation’s anti-bribery and corruption programme.

There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's leadership.

There is evidence that the company publishes an anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. It is clear from publicly available information that this policy applies to all employees and board members.

There is some evidence that the company has a designated board committee that oversees all compliance activities, which is understood to include the anti-bribery and corruption programme. The company’s publicly available evidence indicates that the board discusses the results of activities in the previous fiscal year and responds to legal amendments.

However, the company receives a score of ‘1’ because there is no clear evidence to suggest that it engages in formal oversight functions, such as reviewing the results of internal and external audits.

There is evidence that a managerial-level individual has been assigned ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme, which is understood to be a part of its compliance activities.

However, the company receives a score of ‘1’ because there is no evidence to indicate that the individual is a senior executive. In addition, there is no evidence that this individual has an explicit direct reporting line to the board committee that provides oversight of the anti-bribery and corruption programme.

There is evidence that the company’s Group Global Code of Conduct outlines the company's stance against bribery and corruption. There is evidence that this document was authorised and endorsed by the company's leadership in the form of an introductory message from the company’s President and CEO. However, the company receives a score of ‘1’ because there is no evidence that the senior leadership directly mentions or addresses the company’s stance against all forms of bribery and corruption within the organisation.

There is evidence that the company has a clear anti-bribery and corruption policy as part of its Group Global Code of Conduct, which specifically prohibits bribery, payments to public officials, commercial bribery and facilitation payments. There is evidence that this policy applies to all employees and board members as described in (a) and (b) in the question.

There is evidence that the Board of Directors – through the Compliance Committee – is ultimately responsible for oversight of the company's compliance programme, which includes the anti-bribery and corruption programme. In addition, there is evidence that the board engages in formal oversight functions, such as reviewing reports and updated from management, and due to the seniority of the body there is evidence to indicate that it has the authority to require that any necessary changes to the programme are made.

Based on publicly available information, there is some evidence that the company’s General Counsel and Executive Vice President is responsible for implementing and managing the company’s compliance programme in their role as Chair of the Compliance Committee. There is some evidence to indicate that this individual, through the Compliance Committee, has a reporting line to the President and CEO.

However, the company receives a score of ‘1’ because there is no evidence that the individual has a direct reporting line to the body that provides oversight of the compliance programme, which according to publicly available evidence is the Board of Directors. There is also no clear publicly available evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure; for example, attendance or participation at board-level committee meetings.

There is evidence that the company’s CEO makes a commitment to integrity and high ethical standards in business conduct. The CEO also endorses the company’s Statement of Business Ethics, which prohibits bribery and corruption and makes a commitment to comply with anti-bribery laws.

However, the company’s senior leadership does not specifically mention corruption and bribery.

The company publishes outlines of its anti-bribery and corruption policies, contained in its Statement of Business Ethics. This policy, which prohibits bribery, commercial bribery and payments to public officials, explicitly applies to all employees and board members.

However, the policy does not extend beyond a general commitment to comply with anti-bribery laws and regulations, and does not specifically prohibit facilitation payments. Additionally, the company does not specify whether the policy also applies to employees and the leadership of subsidiaries and other controlled entities.

There is evidence that the board and its Audit Committee is ultimately responsible for the oversight of the company's anti-bribery and corruption programme.

However, the company receives a score of ‚1‘ because there is insufficient evidence to suggest that the board or its committees engage in formal oversight functions of the anti-corruption programme, such as reviewing reports from management and ensuring that required changes are implemented.

There is no evidence that the company has a specific managerial-level employee who holds ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

There is evidence that the company has a publicly stated anti-bribery and corruption commitment that outlines the company’s stance against any form of bribery or corruption within the organisation. There is clear evidence that this commitment was authorised and endorsed by the company’s leadership.

There is evidence that the company publishes a clear anti-bribery and corruption policy, which specifically prohibits bribery, commercial bribery and facilitation payments. The company notes that although facilitation payments are generally prohibited, they may be permissible in certain exceptional circumstances where there is a perceived threat to life, safety or health. There is evidence that this policy applies to all employees and directors as described in (a) and (b) above.

Based on publicly available information, there is evidence that the Board of Directors has ultimate responsibility for the oversight of the company’s anti-bribery and corruption programme. In addition, there is evidence that the company has an independent Ethics and Integrity Council that receives regular updates from the Chief Compliance Officer and has the mandate to make recommendations on ethics and anti-corruption directly to the board. The company indicates that the Board of Directors is involved in reviewing reports on the performance of the compliance programme through an annual review and evaluation process, and there is evidence that it has the authority to require that changes are made, if necessary.

There is evidence that a designated senior executive – the Chief Compliance Officer (CCO) – has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme. There is evidence that this individual has a direct reporting line to the Board of Directors, which provides oversight of the company’s anti-bribery and corruption programme. The company also states that the CCO has a direct reporting line to the Chief Executive Officer (CEO), who is ultimately accountable for the company’s compliance activities. There is evidence that the CCO engages in reporting and feedback activities with both the Board of Directors and the CEO on a regular basis, as part of the company’s reporting structure.

The company has a publicly stated anti-corruption commitment, which details the company's stance against any form of corruption within the organisation, including bribery. It is clear that this commitment is authorised and endorsed by the company's leadership.

The company publishes an explicit anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees regardless of their seniority and all members of a management executive committee and it applies to all entities controlled by the group.

There is evidence that the Compensation, Appointments, Ethics and CSR Committee, which is a designated board committee, is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. It receives reports on the results of the company’s compliance programme from the Group Ethics and Social Responsibility Committee (CERSE), a managerial level committee which is tasked with the implementation of the anti-bribery and corruption programme. This includes reporting against an action plan on ethics and corporate social responsibility. In addition, the Audit, Accounts and Risks Committee, a board-level committee, receives annual reporting on the results of the company’s compliance programme.

There is evidence that a designated senior executive, the Director of Group Ethics, Compliance and Governance, has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. This individual is the Head of the Group Ethics, Compliance and Governance and chairs the Group Ethics and Social Responsibility Committee (CERSE), which presents an action plan to the Chairman and CEO and also reports on its activities to the Appointments, Ethics and CSR Committee.

There is no evidence that the company publishes a commitment to ethical or anti-bribery and corruption standards that is authorised and endorsed by the company’s leadership. Although the company’s Code of Business Conduct reflects a commitment to high business standards, this is not supported by a public statement from the company’s leadership and therefore the company receives a score of ‘0’.

There is evidence that the company publishes a clear anti-bribery and corruption policy, which specifically defines and prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and directors as listed in the question.

Based on publicly available information, there is evidence that the board is ultimately responsible for oversight of the company's anti-bribery and corruption programme. There is evidence that this includes reviewing reports from management on the programme’s performance, including the results of internal audits, and that the board has the authority to require that changes are made.

Based on publicly available information, there is evidence that a designated senior executive – the Chief Compliance Officer – has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the board, which provides oversight of the company’s anti-bribery and corruption programme. There is also evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure.

Based on public evidence, the company has a publicly stated anti-bribery corruption statement, which is endorsed by its leadership.

However, this statement is weak, indirect and unspecific, and makes only a general commitment to comply with anti-bribery principles.

Based on public evidence, the company publishes an explicit anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery and payments to public officials. This policy clearly applies to all employees and board members, regardless of their seniority.

However, the company does not refer to commercial bribery or facilitation payments.

Based on public information, there is evidence that the board or a designated board committee oversees the company's anti-bribery and corruption programme. There is evidence to suggest that it engages in formal oversight functions, such as reviewing reports from management or the results of internal and external audits.

Based on public information, there is no clear evidence that a managerial-level individual has been assigned ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme.

In its Ethics Charter, the company has a publicly stated commitment to ‘integrity’ and ‘high ethical standards’ which is authorised and endorsed by the company’s leadership.

However, the statement does not explicitly refer to anti-bribery and corruption.

There is evidence that the company publishes an explicit anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members as described in (a) and (b) above, regardless of their seniority.

There is no publicly available evidence that the company has a designated board committee or individual board member responsible for oversight of its anti-corruption programme. On its website the company refers to an Ethics and Compliance Committee which meets biannually and ‘ensures the proper implementation of the anti-corruption program’. However, it is not stated that this is a board-level committee and its membership and mandate are not clear from publicly available materials.

There is evidence that a designated senior executive, the Group Compliance Officer, has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the chair of the board.

However, there is no evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure; for example, through attendance or participation at board-level committee meetings.

There is evidence that the company publishes a clear commitment to ethics and integrity, which is endorsed and authorised by its CEO and President. This commitment appears in the company’s Standards of Business Conduct, which contains its anti-corruption policy, as well as on a dedicated webpage about anti-corruption compliance.

There is evidence that the company publishes a clear anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that this policy applies to all employees and board members as described in (a) and (b) in the question.

Based on publicly available information, there is evidence that a designated board committee – the Audit Committee – is ultimately responsible for oversight of the company's anti-bribery and corruption programme. There is evidence that its responsibilities include reviewing audits and reports from management on the programme’s performance, and it is clear that this committee has authority to require that changes are made.

There is evidence that a designated senior executive – the Chief Compliance Officer – has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. There is evidence that this person has a direct reporting line to the Audit Committee, which provides oversight of the anti-bribery and corruption programme. In addition, there is evidence of reporting and feedback activities between this person and the Audit Committee as part of the company’s reporting structure.

Based on publicly available evidence, the company publishes a Code of Ethics and Conduct, which includes an anti-bribery and corruption commitment and policy, and is authorised by the company’s leadership. However, the leadership statement itself relates to ethics and integrity instead of directly referring to anti-bribery and corruption, so the company receives a score of ‘1’.

Based on publicly available evidence, the company publishes an explicit anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that this policy applies to all employees and board members.

There is some evidence that the Board of Directors oversees the company's anti-bribery and corruption programme. However, there is no evidence that it engages in formal oversight functions, such as reviewing reports from management or receiving the results of audits.

There is some evidence that a designated senior executive – the Chairman and CEO – has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme, through the Compliance Office. There is some evidence of a reporting line between this individual and the Board of Directors, which is responsible for oversight of the programme. However, the company receives a score of ‘1’ because the level of involvement of the Chairman and CEO in the day-to-day management of the programme is insufficiently clear and evidence of reporting activities is lacking.

There is evidence that the company has a publicly stated anti-bribery and corruption statement. However, the company receives a score of ‘1’ because this statement does not directly mention anti-bribery and corruption. The company makes a general commitment, authorised and supported by the President of the company, to participate in the voluntary initiative the United Nations Global Compact (UNGC).

Based on publicly available information, there is evidence that the company has an anti-bribery and corruption policy as part of its Code of Conduct. However, the company receives a score of ‘1’ because it does not make specific reference to facilitation payments and it is not clear that the policy applies to board members.

Based on publicly available information, there is evidence that the Board of Directors and the CSR division oversee the Code of Conduct, which includes the company’s anti-bribery and corruption policy. However, there is no evidence to suggest that the Board engages in formal oversight functions, such as reviewing reports from management or results of informal and external audits.

There is also evidence that the company has a Risk Management Committee and a Compliance Committee. However, it is unclear whether either of these bodies provide oversight of the company's anti-bribery and corruption programme specifically.

There is no publicly available evidence that a specific senior executive or managerial-level employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme. The company has a Chief Compliance Officer, however it is not stated that his/her remit includes implementing and managing the company’s anti-bribery and corruption programme.

The company’s Code of Conduct details the company's stance against bribery and corruption. It is clear that the Code of Conduct was authorised and endorsed by the company's leadership.

However, the company’s leadership does not specifically mention anti-bribery and corruption and therefore a score of ‘1’ applies.

The company publishes an explicit anti-bribery and corruption policy which makes specific reference to the prohibition of bribery of all types, payments to public officials and facilitation payments. This policy clearly applies to all employees and board members.

There is evidence that the Audit Committee of the board of directors provides oversight of the company’s anti-bribery and corruption programme. This includes reviewing reports from management on the programme’s performance, and there is evidence that the designated board committee has the authority to require that changes are made.

There is evidence that a designated senior executive, the Vice President and Chief Ethics and Compliance Officer, has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the Audit Committee. There is evidence of reporting and feedback activities between this person and the Audit Committee as part of the company’s reporting structure.

There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. There is evidence that this commitment is authorised and endorsed by the company's leadership.

The company publishes an explicit anti-bribery and corruption policy, the Ethical Code of Conduct, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery and facilitation payments. There is evidence that this policy applies to all employees and board members as described in (a) and (b) in the question.

Based on publicly available information, there is evidence that a designated board committee, the Audit Committee, is ultimately responsible for the oversight of the company's ethics and compliance programme. There is evidence that this includes reviewing reports from management on the programme’s performance.

Based on publicly available information, there is evidence that a designated senior executive – the General Counsel and Chief Compliance Officer – has ultimate responsibility for implementing and managing the company's ethics and compliance programme. There is evidence that this person has a direct reporting line to the board and the Audit Committee and there is evidence of reporting between this person and the board and Audit Committee as part of the company’s reporting structure.

The company’s code of conduct details the company's stance against bribery and corruption. It is clear that this document was authorised and endorsed by the company's leadership.

However, the messages from leadership do not specifically mention anti-bribery and corruption and therefore a score of ‘1’ applies.

The company publishes an anti-bribery and corruption policy which makes specific reference to the prohibition of bribery, payments to public officials and commercial bribery. There is evidence that this policy applies to all employees and board members of the company.

However, the company scores ‘1’ as there is no evidence its policy prohibits facilitation payments. The company’s policy also does not extend beyond a general commitment to comply with anti-bribery laws.

There is evidence that a designated board committee, the Audit Committee, is ultimately responsible for the oversight of the company's ethics programme. This includes reviewing reports from management on the programme’s performance on at least an annual basis.

However, the company scores ‘1’ as there is insufficient publicly available evidence that the Audit Committee reviews audits of the company’s ethics programme specifically. The Audit Committee Charter also does not refer to anti-bribery and corruption directly.

There is evidence that a designated senior executive, the Chief Ethics and Compliance Officer, has ultimate responsibility for implementing and managing the company's ethics programme. It is clear that this person has a direct reporting line to the Audit Committee which provides oversight of the company’s ethics programme. There is evidence of reporting and feedback activities between this person and the Audit Committee as part of the company’s reporting structure.

There is no evidence that the company publishes a commitment to ethical or anti-bribery and corruption standards.

There is no evidence that the company publishes an anti-bribery and corruption or ethics and compliance policy.

There is no evidence that the company has an anti-bribery and corruption programme, nor that a designated board committee or individual board member is responsible for oversight of such activities.

There is no evidence that the company has an anti-bribery and corruption programme, nor that a specific senior executive or managerial-level employee has ultimate responsibility for implementing and managing such activities.

There is evidence that the company publishes a clear statement on its anti-bribery commitment, which details the company's stance against any form of bribery within the organisation. It is clear that this commitment was authorised and endorsed by the company's leadership.

The company publishes an anti-bribery and corruption policy, which specifically defines and prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that the company’s policy applies to both employees and board members.

However, the company receives a score of ‘1’ because it is not clear from publicly available evidence that the policy applies to those employed by subsidiaries and other controlled entities.

Based on publicly available information, there is some evidence that a designated board committee – the Audit Committee – oversees the company's compliance programme, which is understood to incorporate the company’s anti-corruption programme. There is evidence to suggest that this committee engages in formal oversight functions such as reviewing reports from management and that it has the authority to require that any necessary changes to the programme are made.

Based on publicly available information, there is evidence that a designated senior executive – the Compliance Officer – has ultimate responsibility for implementing and managing the company's compliance programme, which is understood to include the company’s anti-corruption programme. There is evidence that this person has a direct reporting line to the board of directors and board committee that provides oversight of the programme.

There is no evidence that the company makes a public commitment to ethical or anti-bribery and corruption standards.

There is no publicly available evidence that the company has an anti-bribery and corruption policy.

There is no evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.

There is no evidence that a specific senior individual or managerial-level employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

The company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's leadership.

The company publishes an explicit anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members as described in (a) and (b) above, regardless of their seniority.

There is evidence that a designated board committee, the Risk and CSR Committee, is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from management on the programme’s performance, along with the results of internal audits, and has authority to ensure that required changes are made.

There is evidence that a senior executive at the company, the Chief Ethics Officer and Company Secretary, has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. This individual has a direct reporting line to the board, and there is evidence of reporting and feedback activities between this person and the board, such as attendance or participation at board-level committees. In addition, the company states that its CEO has primary responsibility for the application of the anti-bribery and corruption programme, and that the Chief Ethics Officer reports to the CEO.

There is evidence that the company publishes a clear statement on its anti-bribery and corruption commitment, which details the company’s stance against any form of bribery or corruption within the organisation. There is evidence that this commitment was authorised and endorsed by the company’s leadership.

There is evidence that the company publishes a clear anti-bribery and corruption policy, which specifically defines and prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that this policy applies to all employees and directors.

There is evidence that the board oversees the company's anti-bribery and corruption programme. There is evidence that this includes reviewing reports from management on the programme’s performance, along with the results of internal audits. However, the company receives a score of ‘1’ because there is no evidence to suggest that the board has the authority to require that changes are made. While there is some indication that the company has an Anti-Corruption Committee, the evidence suggests that this is not a board-level committee.

There is evidence that a designated senior executive – in this case the Compliance Officer – has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. The company indicates that this person has a direct reporting line to the board. There is evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure, both through the CEO and the General Counsel.

There is evidence that the company publishes a clear statement on its anti-bribery and corruption commitment, which details the company’s stance against any form of bribery or corruption within the organisation. There is evidence that this commitment was authorised and endorsed by the company’s leadership.

The company publishes a clear anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members as described in (a) and (b) in the question.

Based on publicly available information, there is evidence that a designated board committee – the Public Policy and Corporate Responsibility Committee – is responsible for oversight of the company's anti-bribery and corruption programme. There is evidence that the Committee’s oversight function includes reviewing reports from management on the programme’s performance and the results of internal audits, and there is evidence that the committee has the authority to require that changes are made.

Based on publicly available information, there is evidence that a designated senior executive – the company’s Chief Ethics and Compliance Officer – has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the Public Policy and Corporate Responsibility Committee, which oversees the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between the Chief Ethics and Compliance Officer and this committee.

There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. It is clear that this commitment was authorised and endorsed by the Company's Leadership.

There is evidence that the company publishes an anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. The policy applies to anyone acting on behalf of the company, which is interpreted to include employees of subsidiary companies as well as board members and non-executive directors.

There is evidence that a designated board committee, the Audit Committee of the Supervisory Board, is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. There is evidence indicating that this includes reviewing reports from management on the programme’s performance, along with the results of audits, and has the authority to ensure that required changes are made.

There is evidence that a designated senior executive, the Chief Compliance Officer, has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the board. There is evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure.

The company has a publicly stated commitment to 'integrity' and 'high ethical standards' but does not explicitly mention anti-bribery and corruption. There is no evidence that this commitment is endorsed by senior leadership.

The company simply makes a general commitment to upholding ‘ethical values’ without specific mention of tackling bribery and corruption. This commitment does not refer to different categories of employees.

There is no evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.

There is no evidence that the company has a specific managerial-level employee with ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

The company has a publicly stated commitment to high ethical principles, which is reflected in statements from the chief executive and general counsel.

However, the company receives a score of ‘1’ because these statements do not specifically mention anti-bribery and corruption.

The company publishes a clear anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that this policy applies to all employees and directors of the company, as well as the staff and leadership of subsidiaries and other controlled entities.

There is evidence that a designated board committee – the Safety, Ethics and Sustainability Committee – is responsible for oversight of the company’s anti-bribery and corruption programme. According to publicly available documents, this includes reviewing reports from management on the programme’s performance. Although the company does not explicitly mention that this committee reviews the results of internal and external audits of its anti-bribery and corruption programme, the company receives a score of ‘2’ due to significant evidence that it reviews reports on the implementation and progress of ethics policies.

There is evidence that a managerial-level individual – the Head of Ethics and Compliance – has been assigned ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. This individual has a clear reporting line to the board and there is further evidence of reporting and feedback activities between the Head of Ethics and Compliance and the board as part of the company’s reporting structure.

However, the company receives a score of ‘1’ because the Head of Ethics and Compliance is not a senior executive.

The company has a publicly stated anti-corruption commitment, within its Anti-Corruption Policy, which details the company's stance against any form of bribery or corruption within the organisation. There is evidence that this policy was authorised and endorsed by the Company's Leadership.

There is evidence that the company has an Anti-Corruption Policy, which clearly applies to employees of all levels of seniority and board members, including non-executive directors. There is evidence that the company’s policy specifically prohibits bribery and commercial bribery.

The company receives a score of ‘1’ because neither this policy, nor any other publicly available evidence, makes specific reference to the prohibition of payments to public officials or facilitation payments.

There is evidence that the General Director, who is a member of the Supervisory Board, is ultimately responsible for oversight of the company's anti-bribery and corruption programme, and that anti-corruption issues are discussed during board meetings. According to publicly available evidence, the General Director receives reports from the Commission for Corporate Conduct and Conflicts of Interest Resolution, which is chaired by the company’s Deputy General Director. However, based on publicly available information, it is not clear whether responsibility for reviewing the results of internal and external audits, and ensuring that required changes are made, is held at the level of Supervisory Board.

There is evidence that a designated senior executive (the Deputy General Director) is responsible for implementing and managing the company's anti-bribery and corruption programme. There is evidence that this person has a direct reporting line to the General Director, who provides oversight of the anti-bribery and corruption programme, and that feedback activities take place.

The company states that it is committed to conducting business to high ethical standards and preventing corruption in all of its operations. However, there is no evidence that the company publishes an explicit anti-bribery and corruption statement which is clearly endorsed by a member of the company’s senior leadership.

The company publishes an Anti-Corruption Policy, as well as a Code of Ethics. Together these documents make specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that the company’s anti-bribery and corruption policies apply to all employees and board members as described in (a) and (b) above, regardless of their seniority.

There is evidence that a designated board committee (the Ethics and Control Committee) is responsible for oversight of the company's anti-bribery and corruption programme. There is evidence that the committee’s responsibilities include reviewing reports from management on the programme’s performance, along with the results of internal and external audits, and recommending that required changes are made.

The company states that its General Director is responsible for managing its anti-corruption programme. However, the company receives a score of ‘1’ because there is no evidence as to how this individual interacts with the Ethics and Control Committee, which provides oversight of the company’s anti-corruption programme. There is no clear evidence of reporting and feedback activities between the two parties.

There is evidence that the company has a publicly stated commitment to anti-bribery and corruption, which details the company's stance against any form of bribery or corruption within the organisation. It is clear that this commitment is authorised and endorsed by the company's CEO and General Counsel.

There is evidence that the company publishes a formal and clearly stated anti-bribery and corruption policy, which specifically prohibits bribery, commercial bribery, payments to public officials, and facilitation payments. The policy clearly applies to all employees and board members as described in (a) and (b) in the question.

There is evidence that the Audit Committee and Board of Directors are ultimately responsible for providing oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from management on the programme’s performance, along with the results of internal and external audits, and there is evidence that these bodies have the authority to required that changes to the programme are made.

There is evidence that a designated senior executive has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the board and the Audit Committee, which jointly provide oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure.

There is evidence that the company has an anti-corruption policy, which was signed off by the company’s General Director at the time. However, the company scores ‘1’, because while there is evidence that the company’s anti-corruption policy is approved by its leadership, there is no evidence that the company publishes a clear statement or message made by an appropriate senior figure either promoting its anti-corruption policy or against corruption in general.

There is evidence that the company has an anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, commercial bribery and payments to public officials. However, the company receives a score of ‘1’ because there is no clear evidence that the policy applies to board members or non-executive directors. Based on publicly available information, the company’s policy also does not explicitly prohibit facilitation payments.

There is evidence that the company’s Audit Committee oversees the company’s anti-bribery and corruption programme. However, based on publicly available information, there is insufficient evidence to suggest that it engages in formal oversight functions, such as reviewing reports from management on the programme’s performance.

Based on publicly available information, there is evidence that a designated senior executive, the Deputy Chief Security Officer, has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. However, the company receives a score of ‘1’ because there is no clear evidence that this individual has a direct reporting line to the company’s board of directors.

There is evidence that the company has a publicly stated anti-corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's leadership.

There is evidence that the company publishes an anti-bribery and corruption policy which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. The company states that the policy applies to all employees and directors, and there is further evidence that it also applies to all employees and the leadership of the company’s wider corporate group.

Based on publicly available information, there is evidence that the company has a designated board committee – the Audit Committee – that is ultimately responsible for the oversight of the company's ethics programme. This includes reviewing reports from management on the programme’s performance, along with the results of audits and ensuring that required changes are made.

Based on publicly available information, there is evidence that a designated senior executive – the General Counsel – has ultimate responsibility for implementing and managing the company's ethics programme. It is clear that this person has a direct reporting line to the board committee that provides oversight of the ethics programme. There is evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure.

The company has a publicly stated anti-corruption commitment, which details the company's stance against any form of corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's leadership.

The company publishes a Code of Conduct, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that this Code applies to all of those employed across the group, including subsidiaries and joint ventures.

The company’s anti-bribery and corruption programme is overseen by the Compliance, Ethics and Anti-Fraud Committee, which is a management-level committee. There is no evidence to suggest that any other committee at board level has oversight of the company’s anti-bribery and corruption programme, or that an individual board member is responsible for overseeing the programme.

There is evidence that a managerial-level individual has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. The company states that the Group Compliance Officer is responsible for leading the company’s risk prevention programme and is a member of the Compliance, Ethics and Anti-Fraud Committee.

However, the company receives a score of ‘1’ because there is no publicly available evidence that this individual has a direct reporting line to the board or a designated board committee. Although the Group Compliance Officer is a member of the Compliance, Ethics and Anti-Fraud Committee, this is a managerial committee and not a board-level committee.

There is evidence that the company publishes a Code of Conduct containing a public statement from its CEO emphasising the company’s commitment to 'integrity' and high ethical standards.

However, the company receives a score of ‘1’ because there is no evidence that the CEO’s statement directly mentions or addresses its stance against bribery and corruption within the organisation. In addition, the Code of Conduct contains a general directive to avoid bribery and corruption and comply with anti-corruption laws, rather than a clear and proactive stance against corruption.

There is evidence that the company’s Code of Conduct prohibits involvement in corruption and that this applies to all employees and board members.

The company receives a score of ‘1’ because there is no publicly available evidence that the company clearly prohibits bribery, payments to public officials, commercial bribery and/or facilitation payments. It is also not clear whether the company’s stance applies to subsidiaries and other controlled entities.

There is evidence that a designated board committee – the Risk Oversight Committee – is ultimately responsible for the oversight of the company's ethics and compliance programme, which includes anti-bribery and corruption. There is also evidence that the Committee has the authority to require that any necessary changes to the programme are made.

However, the company receives a score of ‘1’ because there is no clear evidence that the committee’s responsibilities include monitoring and reviewing reports from management on the programme’s performance.

There is no clear evidence that a senior executive or managerial-level employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption policy or programme. There is evidence that the Chair of the Risk Oversight Committee is responsible for leading the group in monitoring and overseeing the company’s ethics and compliance activities, but it is not clear who is responsible for the day-to-day implementation and management of the programme.

The company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. There is clear evidence that this commitment was authorised and endorsed by the company's leadership.

The company publishes a clear anti-bribery and corruption policy and accompanying business ethics codes, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members as described in (a) and (b) in the question.

Based on publicly available information, there is evidence that the company has a designated board committee that is ultimately responsible for the oversight of the company's ethics programme. There is evidence that this includes reviewing reports from management on the programme’s performance, and the company indicates that this committee has authority to require that changes are made.

Based on publicly available information, there is evidence that a designated senior executive has ultimate responsibility for implementing and managing the company's ethics programme. The company indicates that this person has a direct reporting line to the board committee that provides oversight of the ethics programme. There is evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure.

Based on publicly available information, there is evidence that the company makes a general commitment to anti-bribery and corruption. However, the company receives a score of ‘0’ because there is no evidence that this commitment is directly authorised or supported by its leadership.

Based on publicly available information, there is evidence that the company publishes an anti-bribery and corruption policy that specifically prohibits bribery, payments to public officials and facilitation payments. There is evidence that this policy applies to all employees across the organisation.

However, the company receives a score of ‘1’ because there is no clear evidence that the policy addresses and covers commercial bribery. It is also not clear from publicly available information whether the policy applies to board members.

There is evidence that a designated board committee – the Risk and Sustainability Committee – provides oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from management on the programme’s performance and there is evidence that this committee has the authority to require changes are made.

There is evidence that a designated senior executive has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. There is evidence that this person has a direct reporting line to the board or board committee that provides oversight of the anti-bribery and corruption programme.

There is no evidence that the company makes a public commitment to ethical or anti-bribery and corruption standards.

There is no evidence that the company publishes an anti-bribery and corruption or ethics and compliance policy.

There is no evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.

There is no evidence that a specific senior individual has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

The company publishes an Anti-Corruption Policy which demonstrates the company's commitment to anti-bribery and corruption, but there is evidence that this is authorised by senior figures other than the Company Leadership.

There is evidence that the company publishes an Anti-Corruption policy, which applies to all employees and managing directors, as well as the staff and leadership of all subsidiaries and other controlled entities. The company’s policy explicitly prohibits bribery, commercial bribery and payments to public officials.

The company receives a score of ‘1’ because there is no evidence that the company specifically prohibits facilitation payments, nor is there evidence that its Anti-corruption policy explicitly applies to non-executive directors of the company.

Based on publicly available evidence, the General Director, who is a member of the Board of Directors, oversees the company’s anti-bribery and corruption programme. However, there is no evidence to suggest that the General Director engages in formal oversight functions, such as reviewing reports from management or the results of internal and external audits.

There is evidence that a managerial-level individual, the Head of the company’s Department of Internal Control, has been assigned responsibility for implementing and managing the company's anti-bribery and corruption programme, but he is not a senior executive. There is some evidence that this individual has a reporting line to the General Director, who provides oversight of the anti-bribery and corruption programme.

The company publishes a general commitment to high ethical principles, but there is no evidence that the company makes a public anti-bribery and corruption commitment that is authorised and endorsed by its senior leadership.

There is no evidence that the company has a comprehensive anti-bribery and corruption policy. The company publishes some information about its internal controls and its commitment to adhere to high ethical standards, but there is no evidence that it has a specific an anti-bribery and corruption policy.

There is no evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.

There is no evidence that a specific managerial-level employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

There is evidence that the company publishes a general anti-bribery and corruption commitment as part of its Code of Ethics. The Code of Ethics is endorsed by the company’s CEO. However, the company receives a score of ‘1’ because the statement from the CEO does not specifically mention and address the company’s stance against bribery and corruption, referring instead to integrity and highest ethical standards.

There is evidence that the company publishes an anti-bribery and corruption policy as part of its Code of Ethics. There is evidence that this policy clearly prohibits bribery and facilitation payments. This policy applies to all staff and board members, as well as the staff and leadership of its wider corporate group.

However, the company receives a score of ‘1’ because there is no clear evidence that its anti-corruption policy prohibits commercial bribery and payments to public officials.

There is some publicly available evidence that the company’s Executive Board is responsible for oversight of its anti-bribery and corruption programme. However, the company receives a score of ‘1’ because there is no further evidence to suggest that it engages in formal oversight functions or that it has the authority to require that changes are made.

There is evidence that a managerial-level individual has been assigned ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. However, the company receives a score of ‘1’ because it is not clear that this individual is a senior executive and there is no clear evidence that they have a direct reporting line to the company’s board of directors.

There is evidence that the company has a publicly stated commitment to anti-bribery and corruption, however there is no evidence that this statement is authorised and endorsed by the a senior leadership figure.

The company publishes some anti-bribery and corruption guidance on its website, but it does not provide further details of specific controls that would constitute a comprehensive anti-bribery and corruption policy. Although the company states that it prohibits bribery and corruption, it does not address payments to public officials or facilitation payments, nor does it indicate that it applies to all employees and board members.

There is no evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.

There is no evidence that a specific senior executive or managerial-level employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

Based on publicly available information, there is evidence that the company has a publicly stated anti-corruption commitment which details its stance against corruption and bribery within the organisation. It is clear that this commitment was authorised and endorsed by the company's leadership.

Based on publicly available information, there is evidence that the company publishes a clear anti-bribery and corruption policy that prohibits bribery, facilitation payments, payments to public officials and commercial bribery. The company indicates that its policy applies to all groups as specified in (a) and (b) in the question.

There is evidence that the board is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. The company also indicates that an Ethics Committee provides oversight of certain anti-corruption activities, with a direct reporting line to the board. There is evidence that the board’s responsibilities include reviewing reports from management on the programme’s performance, along with the results of internal and external audits, and there is evidence that it has the authority to require that any necessary changes are made.

Based on publicly available information, there is evidence that a managerial-level individual – the Head of CSR & Compliance – has been assigned ultimate responsibility for implementing and managing the company's anti-corruption compliance programme. It is clear that this person has a direct reporting line to the board.

However, the company receives a score of ‘1’ because there is no evidence to indicate that the Head of CSR & Compliance is a senior executive.

There is evidence that the company’s Chief Executive Officer makes a public statement in support of the company’s ethics and compliance programme. However, the company receives a score of ‘1’ because there is no evidence that the CEO’s public statement directly addresses and mentions the company’s stance against bribery and corruption.

There is evidence that the company publishes an anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that this policy applies to all employees and board members as described in (a) and (b) in the question.

Based on publicly available information, there is evidence that the company’s Audit Committee, a designated board committee, is responsible for oversight of the company’s ethics and compliance programme. There is evidence that this includes reviewing reports from management on the programme’s performance and that the committee has authority to require that changes are made.

The company also states that its Ethics & Compliance steering committee provides oversight of the ethics and compliance programme. There is evidence that the committee is comprised of senior managers and is chaired by the Executive Vice President, General Counsel and Chief Compliance Officer of Textron, who also reports to the Audit Committee.

Based on publicly available information, there is evidence that a designated senior executive – the Executive Vice President, General Counsel and Chief Compliance Officer - has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. There is evidence that this person has a direct reporting line to the Audit Committee, which provides oversight of the anti-bribery and corruption programme. There is also evidence of reporting and feedback activities between this person and the Audit Committee as part of the company’s reporting structure.

The organisation has a publicly stated commitment to ethics and integrity, which is indirectly supported by the company’s leadership as part of the Corporate Social Responsibility Report. The organisation receives a score of ‘0’ because this statement is indirect and does not explicitly mention anti-bribery and corruption.

There is no publicly available evidence that the organisation has an anti-bribery and corruption policy.

There is no evidence that the organisation has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.

There is no evidence that a specific managerial-level employee has ultimate responsibility for implementing and managing the organisation’s anti-bribery and corruption programme.

The company has a publicly stated anti-bribery and corruption commitment, which details its stance against any form of bribery or corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company’s executive board.

The company publishes an anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members as described in (a) and (b) above.

There is evidence that the company’s board, with assistance from two designated board committees, the Audit Committee and the Executive Board Department for Compliance and Legal, is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from management on the programme’s performance, along with the results of internal and external audits, and ensuring that required changes are made.

There is evidence that a designated senior executive – the Chief Compliance Officer – has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme and that this person has a direct reporting line to the Executive Board member responsible for Legal & Compliance. There is evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure through participation in Board and Audit Committee meetings. This person is also responsible for a larger network of compliance managers and officers in different Group companies and business divisions.

There is evidence that the company has an anti-corruption statement authorised by its senior leadership. However, the company receives a score of ‘1’ because this statement represents a general commitment to comply with anti-bribery laws and principles. The company’s anti-bribery policy sits within its ‘Standards of Conduct’; however, there is no clear or direct evidence that the Standards of Conduct are endorsed by its leadership.

There is evidence that the company has an anti-bribery and corruption policy, which specifically prohibits bribery, illegitimate payments to public officials, commercial bribery and facilitation payments. There is evidence that this policy applies to all employees and directors across all of the Group’s companies.

There is no publicly available evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme. The company indicates that it has a Risk Compliance Committee, which is chaired by the Chief Risk Compliance Management Officer, however it is not clear that this level sits at board-level or whether it is overseen by the board of directors.

There is evidence that the company’s Chief Risk Compliance Management Officer has ultimate responsibility for implementing and managing the company’s compliance programme, which includes anti-bribery and corruption. There is evidence that this individual is a senior executive and that he/she has a direct reporting line to the President and Chief Operating Officer.

The company publishes a Code of Business Conduct which details the company's stance against bribery and corruption. There is evidence that the Code of Business Conduct was authorised and endorsed by the company's leadership in the form of an introductory message from the President and Chief Executive Officer. However, this message does not specifically mention anti-bribery and corruption and therefore a score of ‘1’ applies.

There is evidence that the company publishes a Code of Business Conduct, which makes specific reference to the prohibition of bribery, payments to public officials and commercial bribery. The policy states that it applies to all directors and all employees, including staff and leadership of subsidiaries.

However, the company scores ‘1’ as there is no evidence it prohibits facilitation payments.

There is evidence that a designated board committee, the Audit Committee, oversees the company's ethics and compliance programme, and that this includes reviewing reports from management on the programme’s performance.

However, the company scores ‘1’ as there is insufficient publicly available evidence that the Audit Committee reviews audits of the company’s ethics and compliance programme specifically. The Audit Committee Charter also does not refer to anti-bribery and corruption directly.

There is some evidence that the General Counsel has been assigned responsibility for reporting to the board on the company’s compliance with the Code of Business Conduct. However, there is insufficient evidence that the General Counsel, or an alternative managerial-level employee, has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

The company publishes a statement endorsed by its leadership that commits to ethical business conduct and principles, but it does not explicitly mention anti-bribery and corruption.

The company publishes an anti-bribery and corruption policy, which applies to managers and employees.

However, there is no evidence that the policy prohibits payments to public officials and facilitation payments. Additionally, there is no evidence that the company’s policy applies to staff and leadership of subsidiaries and other controlled entities, or that the policy applies to all board members, including non-executive directors.

There is no evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.

There is no evidence that a specific managerial-level employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

There is evidence that the company’s General Director makes a clear endorsement of the company’s anti-corruption programme, which supports a zero tolerance stance against all forms of corruption within the organisation.

There is evidence that the company publishes an anti-bribery and corruption policy, which applies to all of the company’s employees and members of senior management. There is evidence the policy prohibits all forms of commercial bribery.

However, there is no evidence the company’s policy applies to the staff and leadership of subsidiaries and other controlled entities, nor does it explicitly apply to all of the company’s board members. There is also no evidence the company’s policy explicitly prohibits facilitation payments or payments to public officials.

There is evidence that the company has a commission, the Commission for Corruption Risk Assessment, which oversees the company’s anti-bribery and corruption programme along with the General Director. This includes reviewing reports from management and implementing changes. The company states that this Commission submits reports to the General Director, a member of the company’s board of directors. There is evidence that the General Director subsequently ensures that proposed changes are implemented to the company’s anti-corruption programme.

There is evidence that a named manager, the Commissioner of the company’s Commission for Corruption Risk Assessment, is responsible for managing and implementing the company’s anti-corruption programme. It is clear that this individual has a reporting line to the General Director, the company’s most senior executive and a member of the board of directors.

Based on publicly available information, there is evidence that the company’s leadership endorses the company’s Statement on Ethics and Business Conduct, which outlines the company’s zero tolerance stance toward bribery and corruption. The company receives the score of ‘1’ because its leadership statement does not directly mention bribery and corruption.

Based on publicly available information, there is evidence that the company publishes a clear anti-bribery and corruption policy, which specifically prohibits bribery, commercial bribery and facilitation payments. The policy applies to directors and all employees as described in (a) and (b) in the question.

Based on publicly available information, there is evidence that responsibility for oversight of the company’s anti-bribery and corruption programme sits at board level. Both the company’s Ethics Overview Committee and the board itself engage in formal oversight functions such as reviewing reports from management on the programme’s performance, along with the results of audits, and there is evidence that these entities have the authority to require that changes are made.

Based on publicly available information, there is evidence that a designated senior executive, the Group Company Secretary and General Counsel, has ultimate responsibility for implementing and managing the company´s anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the Ethics Overview Committee and the board, both of which provide oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure.

There is no evidence that the company has a publicly stated anti-bribery and corruption commitment that is authorised and endorsed by its senior leadership. The company indicates that it does not tolerate corruption in its corporate policies, however this is not accompanied by a statement or similar indication of support from its leadership.

There is evidence that the company publishes an anti-bribery and corruption policy and accompanying ethics polices which outline the company’s commitment to anti-corruption laws and clearly prohibit bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that the company’s policies apply to all employees, including employees of subsidiaries, third parties and joint ventures.

The company receives a score of ‘1’ because there is no clear evidence that the company’s policies on anti-corruption apply to board members or senior leadership, including non-executive directors.

Based on publicly available information, there is some evidence to indicate that the Commission on Corporate Ethics and Conflict of Interest Regulation provides oversight of the company’s anti-bribery and corruption programme. However, the company receives a score of ‘0’ because the responsibilities of the Commission are not clear and there is no evidence that this body is represented at board level or that it has the authority to require that changes to the programme are made.

There is evidence that the company’s President has primary responsibility for implementing and managing the company’s anti-bribery and corruption programme. Since the President sits on the Board of Directors, it is understood that this individual has a direct reporting line to the board on any issues relating to anti-corruption.

However, the company receives a score of ‘1’ because there is no clear evidence of reporting and feedback activities between the President and the board in relation to anti-bribery and corruption.

The company publishes a statement that it has a zero-tolerance approach to all forms of corruption, which forms part of its Anti-Corruption Policy and has been signed off by the company’s General Director. Since there is evidence that he General Director is the most senior figure within the organisation, the company receives a score of ‘2’.

There is evidence that the company publishes an Anti-Corruption Policy which prohibits bribery and corruption. The company’s policy states that it applies to all the company’s staff and all employees of subsidiaries and companies under the company’s control.

However, the company receives a score of ‘1’ because there is no evidence that the company’s policy specifically prohibits facilitation payments or payments to state officials, and while it includes a definition of commercial bribery, it is not entirely clear that this practice is prohibited. Furthermore, there is no clear evidence that the policy applies to all board members, including non-executive directors.

There is some evidence that the Audit Committee of the Board of Directors is responsible for oversight of the company’s anti-corruption programme. However, the company receives a score of ‘1’ because there is no indication that the committee’s oversight responsibilities include formal oversight functions such as reviewing reports from management or the results of audits.

There is some evidence in the company’s Anti-Corruption Policy that the Deputy Managing Director of Security has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. There is some indication that this individual, alongside other managers engaged in managing and implementing the anti-corruption programme, has a direct reporting line to General Director of the company.

However, the company receives a score of ‘1’ because it is not clear whether this individual is a senior executive, nor whether this individual is the main individual responsible for implementing aspects of the anti-bribery and corruption programme.

There is evidence that the company makes a general anti-bribery and corruption commitment. However, there is no evidence that it is authorised or supported by a senior figure, and therefore the company receives a score of ‘0’.

It is noted that although the company publishes a copy of the Anti-Corruption Charter of Russian Business on its website, there is no evidence that the company has incorporated the principles of the charter into its wider anti-bribery and corruption framework. This Charter is therefore not considered as evidence for this assessment.

Based on publicly available information, there is no evidence that the company publishes an anti-corruption policy that goes beyond compliance with anti-bribery laws and which explicitly applies to all employees and board members of the company.

There is evidence that the company has a Commission on “compliance with the requirements for the official conduct of employees and the settlement of the conflict of interests”, which is responsible for the company’s anti-corruption programme. This body includes at least one member of the company’s board of directors. However the company receives a score of ‘1’ because there is no clear evidence that this body performs oversight functions, such as reviewing reports from management or audit results.

There is evidence that the company’s Deputy General Director is responsible for anti-corruption activities within the organisation. However, despite this individual being a member of the board, there is no evidence of reporting and feedback activities between this individual and the board of directors.

It is also noted that the list of members of the executive management team published on the company’s website mentions four individuals with the title ‘Deputy General Director’, despite company documents referring primarily to one named individual in relation to this role.

There is no publicly available evidence that the company publishes an anti-bribery and corruption commitment that is endorsed by its senior leadership. The company has an anti-corruption policy which is approved by its President, however there is no evidence that this individual makes a direct statement endorsing the company’s commitment to anti-corruption within the organisation.

There is evidence that the company publishes an Anti-Corruption Policy and Code of Conduct, both of which prohibit bribery, payments to public officials and commercial bribery. There is evidence that these policies apply to all employees in the company.

The company receives a score of ‘1’ because there is no evidence that either of the policies address and prohibit facilitation payments, nor is it clear that they apply to all directors, including non-executive directors.

There is some evidence that the company’s Anti-Corruption Commission provides oversight of the company's anti-bribery and corruption programme. However, the status of the Commission in relation to the rest of the company’s corporate structure is not clear, and there is no clear evidence that it engages in formal oversight functions or that it has the authority to require that changes to the programme are made.

There is evidence that a designated senior-executive – the Vice President for Security – has been assigned ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. There is evidence to indicate that this individual is also the Chairperson of the Anti-Corruption Commission, and this committee has a direct reporting line to the company’s President.

The company states that employees must commit to maintaining high ethical standards in their professional conduct, without mentioning bribery or corruption, and this statement is not authorised or endorsed by the company's leadership.

The company does not publish an anti-bribery and corruption policy. The company states that employees must behave ethically, without specifically mentioning bribery and corruption. Although the company references a Code of Corporate Ethics and an Anti-Corruption Policy, these documents are not publicly available.

The company states that the Board of Directors and the Audit Committee provide oversight of the company's anti-bribery and corruption programme. There is evidence that both the Board and the Audit Committee engage in formal oversight functions, such as reviewing the results of audits and risk assessments.

There is no evidence that a specific senior individual has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

There is evidence that the company has a publicly stated commitment to high ethical standards and integrity as part of its Code of Conduct, which details the company's stance against any form of bribery or corruption. This commitment, and the Code of Conduct itself, is clearly authorised and endorsed by the company's President and Chief Executive Officer.

There is evidence that the company publishes a clear anti-bribery and corruption policy and Code of Conduct, both of which specifically prohibit bribery, payments to public officials, commercial bribery, and facilitation payments. The company’s policies clearly apply to all employees and board members as described in (a) and (b) in the question.

There is evidence that a designated board committee – the Audit Committee – is ultimately responsible for oversight of the company's anti-bribery and corruption programme. There is evidence indicating that this includes reviewing reports from management on the programme’s performance along with the results of audits, and there is evidence that it has the authority to require that any necessary changes to the programme are made.

There is evidence that that a designated senior executive – the General Counsel – has ultimate responsibility for the company’s anti-corruption programme. There is evidence that the General Counsel has a direct reporting line to the Audit Committee, which provides oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this person and the Audit Committee as part of the company’s reporting structure.

There is evidence that the company has a publicly stated commitment to 'integrity' and 'high ethical standards' which is supported and endorsed by the Chairman and CEO. Although this statement does not explicitly mention anti-bribery and corruption, it forms part of the company’s wider code of conduct, which outlines the company’s commitment to anti-bribery and corruption.

There is evidence that the company’s Guide to Business Conduct provides details on its anti-bribery and corruption policy. There is evidence that it prohibits payments to public officials and that the policy applies to all employees.

However, the company receives a score of ‘1’ because its policy does not specifically refer to commercial bribery and it does not extend beyond a general commitment to comply with anti-bribery legislation. Although the company describes facilitation payments, it does not clearly refer to them by name and does not prohibit them. In addition, the company does not clearly indicate that its anti-bribery and corruption policy applies to board members, or the staff and leadership of subsidiaries and other controlled entities. There is some indication that the company has an additional anti-corruption document, however this does not appear to be not publicly accessible.

There is no evidence that the company has a designated board committee or individual board member responsible for anti-bribery and corruption. There is some indication that the company has a managerial-level Ethics Committee, which reports to the Vice-President of Human Resources, Chief Financial Officer, and General Counsel. It is not clear that the Ethics Committee reports to the board or a designated board committee.

There is evidence that the company has an Ethics Committee that reports to the Vice-President of Human Resources, Chief Financial Officer, and General Counsel. However, it is not clear whether any of these individuals, or any other managerial-level individual, is ultimately responsible for implementing and managing the company's anti-bribery and corruption programme.

There is no evidence that the company makes a commitment to ethical or anti-bribery and corruption standards.

There is no publicly available evidence that the company publishes an anti-bribery and corruption policy.

There is no evidence that the company has an anti-bribery and corruption programme, nor that a designated board committee or individual board member is responsible for its oversight.

There is no evidence that the company has an anti-bribery and corruption programme, nor that a specific managerial-level employee has ultimate responsibility for implementing and managing it.