3. Support to Employees

Based on publicly available information, there is evidence that the company provides training that outlines the principles of its anti-bribery and corruption policy, which covers the whistleblowing options available to employees. There is evidence that the company provides this training to all employees across all divisions and countries of operation and in all appropriate languages. The company states that employees must repeat the training on an annual basis.

Based on publicly available information, there is evidence that the company tailors its anti-bribery and corruption training programme to the different levels of risk facing employees in different roles. The company makes specific reference to the categories of employee referred to in the question. There is evidence that employees working in high risk positions are required to refresh their training on at least an annual basis.

Based on publicly available information, there is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme on an annual basis. There is evidence that the results of such reviews are used to update the programme.

However, the company receives a score of ’1’ because it does not provide any publicly available information to indicate how it measures effectiveness, and therefore it is unclear how the company does this in practice.

There is no publicly available evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

Based on publicly available information, there is some evidence that the company encourages employees to act ethically, even when it results in a loss of business for the company.

However, the company receives a score of ‘1’ because there is no clear evidence that the company assures itself of its employees’ confidence in this statement through anonymised surveys or other clearly stated means.

There is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, which explicitly applies to all employees across the organisation, including those engaged by the group as third parties, suppliers and joint venture partners.

However, the company receives a score of ‘1’ because there is no evi

There is no evidence that the company provides anti-bribery and corruption training to its employees.

There is no evidence that the company provides tailored anti-bribery and corruption training for employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of an anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

There is no publicly available evidence that the company has a policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is no evidence that the company provides either whistleblowing or advice channels for its employees to ask questions and raise concerns about suspected bribery or corruption.

There is evidence that the company provides ethics and compliance training for all employees, which is understood to include its anti-bribery and corruption policy. The company indicates that employees must undertake and refresh this training on an annual basis.

However, the company receives a score of ‘1’ because there is no clear evidence that this training applies to employees in all countries and regions of operation or in all appropriate languages. There is also no clear publicly available evidence that this training covers the whistleblowing options available to employees.

There is evidence that the company provides tailored anti-bribery and corruption training to employees in high risk positions. However, it is not clear from the available evidence that employees in high risk positions are required to undertake and refresh their training on at least an annual basis. There is also no evidence that the company provides tailored anti-bribery and corruption training to middle management or board members.

There is evidence that the company measures and reviews the effectiveness of its ethics and compliance training and communication programme, which includes anti-corruption training. There is evidence that the company has a system to do this, for example through staff surveys and monitoring the use of ethics and compliance resources, and that the company monitors the number of personnel trained and completion rates. There is evidence that the company uses the results of such reviews to update the company's ethics and compliance communications and training programme.

The company receives a score of ‘1’ because it is unclear whether the company conducts a full review of its ethics and compliance communications and training programme at least every three years.

There is some evidence that the company’s incentive schemes for employees incorporate ethical and anti-bribery and corruption principles. The company indicates that employees must complete its ethics and compliance training in order to be eligible for any annual rewards.

However, there is no evidence to suggest that incentives are designed to reward behaviour in line with the company’s ethical values as identified through performance appraisals or conduct in the workplace. In addition, it is not clear whether financial rewards must be proportionate to the employee’s salary in the case of high risk employees, such as sales roles.

There is evidence that the company commits to support employees to “make good decisions” and “do the right thing” when faced with ethical dilemmas in the workplace. However, there is no clear evidence that the company clearly commits to support or protect employees who refuse to act unethically, even where such actions result in a loss to the company, nor that it assures itself of employees’ confidence in this commitment.

There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. This policy applies to all employees across the organisation, including those engaged by the group as third parties and suppliers. There is evidence that the company commits to assure itself of its employees’ confidence in this commitment through periodic anonymised surveys.

There is evidence that the company provides multiple channels for its employees to report instances of suspected corrupt activity and seek advice on its anti-bribery and corruption programme. There is evidence that channels are sufficiently varied to allow the employee to raise concerns across the management chain and externally to an independently-operated helpline. These channels allow for confidential and, wherever possible, anonymous reporting. There is evidence that the channels are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners, and in all relevant languages.

There is evidence that the company provides training for its employees which outlines the basic principles of the anti-bribery and corruption policy, including the whistleblowing options available. The training is available in 15 languages. There is evidence that all employees are required to complete anti-corruption training on an annual basis.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme.

However, these measures appear to be simplistic and are limited to completion rates and annual certifications of employees’ adherence to the Code of Conduct. There is also no evidence that results are used to update specific parts of the company’s anti-bribery and corruption communications training programme.

There is some evidence that the company’s incentive schemes incorporate ethical and anti-bribery and corruption principles. Supervisors are advised to consider an employee’s commitment to ethical conduct during the performance evaluation process, although the company does not provide further details on how this is assessed.

The company receives a score of ‘1’ because there is no evidence that the company’s executive compensation practices also factor in ethical behaviour.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

In its Code of Conduct and Anti-Corruption Policy, the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, which explicitly applies to all employees across the organisation, including those employed by the group as third parties and joint venture partners.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and to relevant external bodies. These channels allow for confidential and, wherever possible, anonymous reporting. They are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties. There is evidence that the company’s whistleblowing lines are available in all languages.

There is evidence that the company requires its employees to undertake training on anti-bribery and corruption, which it provides in English since it only operates in the United States. The company indicates that employees are required to undertake refresher trainings on a periodic basis.

However, there is no evidence that employees must undertake and refresh their training on anti-corruption at least every three years. The company also does not clearly indicate that the training includes information on the whistleblowing options available to employees.

There is evidence that the company provides tailored ethics and compliance training for board members and employees in higher risk roles on an annual basis. However, there is no publicly available evidence that the company provides tailored training for employees in middle management positions.

There is evidence that the company has implemented several measures for reviewing the effectiveness of its anti-bribery and corruption communications and training programme. Such measures include a monthly leadership ethics scorecard, a bi-monthly ethics poll and participation in the Defence Industry Benchmark survey on a bi-annual basis. The company’s Executive Ethics Committee reviews trends and employee survey results. The company also gathers data on a quarterly basis from its whistleblowing channel and has developed metrics which allow the company to identify potential risk areas and opportunities for improvement.

There is no public evidence to suggest that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles.

While the company promotes a ‘speaking up’ culture and has a non-retaliation policy, it does not explicitly state that it will support and protect employees who refuse to act unethically, even when it might result in a loss of business.

There is evidence that the company has a clear policy that it will not tolerate retaliation against whistleblowers and employees who report bribery and corruption incidents. The policy applies to all employees and third parties engaged by the company, or anyone on its behalf. There is evidence that the company assures itself of its employees’ trust in this commitment through surveys to assess general awareness of its ethics and compliance programme, as well as through the usage data of its whistleblowing channel.

There is evidence that the company provides multiple channels for its employees to report instances of suspected corrupt activity and seek advice on its anti-bribery and corruption programme. The company indicates that these channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an external helpline managed by a third party. These channels allow for confidential and, wherever possible, anonymous reporting. They are available and accessible in English to all employees in the United States, where the company operates, and is also accessible to third parties employed by the group.

There is evidence that the company provides both face-to-face and online anti-corruption training to all employees across all divisions and geographies, in four different languages. The company requires its employees to undertake Ethics and Compliance training, including on Anti-Bribery and Corruption, at least once a year.

There is evidence that the company provides tailored anti-bribery and corruption training to employees based on their job role, location and level of risk. There is evidence that this includes employees in high risk employees and board members. However, there is insufficient evidence that the company provides training to employees covered in (b) above, and it is not clear that training for employees in high-risk positions is refreshed on at least an annual basis.

Based on publicly available information, the company’s board of directors receives an update on ethics and compliance training on an annual basis. The Annual Report also contains some high-level information on the anti-bribery and corruption e-training provided to employees, in the form of completion rates. However, there is no evidence to indicate that the company measures or reviews the effectiveness of its anti-bribery and corruption communications or training programme beyond completion rates. According to the Annual Report, the company issued questionnaires to its affiliates in 2018 to check that internal procedures were adequate and to ensure that anti-corruption messaged had been communicated, but this is not sufficient to receive a score of ‘2’.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

Based on publicly available information, there is no clear evidence that the company commits to supporting employees who refuse to act unethically where such actions may result in a loss of business or other disadvantage to the company.

Based on publicly available information, the company has a clear policy of non-retaliation against whistleblowers and employees who report suspected bribery and corruption incidents. This commitment provides a clear definition of actions that may constitute retaliation and is repeated in several different documents that are made available to all employees. Additionally, there is evidence that this policy extends to suppliers, affiliates and third parties who may wish to report suspected bribery and corruption. However, there is no evidence that the company assures itself of its employees’ confidence in the commitment of non-retaliation through surveys, usage data or other clearly stated means.

According to publicly available information, the company offers multiple channels for employees, suppliers and third parties to report instances of suspected bribery or corruption or seek advice. Channels are sufficiently varied to allow employees to raise concerns across the management chain and across divisions – including to an external independent provider – as well as being accessible to employees in all jurisdictions in which the company operates and in all relevant languages. There is evidence that these channels allow for confidential and, where possible, anonymous reporting of concerns.

There is no publicly available evidence that the company provides anti-bribery and corruption training to its employees.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company publicly commits to support or protect employees who refuse to act unethically.

There is no evidence that the company has a publicly available policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is no evidence that the company provides whistleblowing or advice channels for its employees to raise concerns or seek advice about anti-bribery and corruption.

There is no evidence that the company provides anti-bribery and corruption training to all employees.

There is no evidence that the company provides tailored anti-bribery and corruption training for employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of an anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

There is no evidence that the company has a publicly available policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is no evidence that the company has either whistleblowing or advice channels.

There is no evidence that the company provides anti-bribery and corruption training to all employees.

There is no evidence that the company provides anti-bribery and corruption training to all employees, nor that it tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

The company’s approach to incentives is unclear to the extent that it cannot satisfy the requirements of score ‘1’.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

There is some evidence to suggest that the company has a policy of non-retaliation against individuals who report bribery and corruption incidents, however, the policy does not explicitly refer to both whistleblowers and employees who report bribery and corruption incidents, and does not apply company-wide.

There is evidence that the company has a whistleblowing channel.

However, there is no evidence that the company has an advice channel, there are no explicitly anonymous or confidential channels, the company only offers internally operated channels, and the channels are not explicitly available to all employees in any country of operation, or in multiple languages, or to any employees of third parties, suppliers or joint venture partners.

Based on publicly available information, there is evidence that the company provides a training module that outlines the basic principles of its anti-bribery and corruption policy to its employees.

However, the company receives a score of ‘1’ because it is not clear whether this also includes an explanation of the whistleblowing options available to employees. It is also not clear how frequently training is provided, and whether it is provided across all divisions, all countries and regions of operation, or in all appropriate languages.

Based on publicly available information, there is no evidence that the company provides tailored anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

Based on publicly available information, there is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications and training programme.

Based on publicly available information, there is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no publicly available evidence that the company makes a specific commitment to support and protect employees who refuse to act unethically, even when it might result in a loss of business.

Based on publicly available information, there is evidence that the company has a policy of non-retaliation against all employees who report bribery and corruption incidents. There is some evidence to suggest that this commitment extends to third parties engaged by the company.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

Based on publicly available information, there is evidence that the company provides multiple whistleblowing channels for its employees, which allow for anonymous reporting.

However, the company receives a score of ‘1’ because there is no evidence that the company offers a channel operated by an independent third party to allow external reporting, or is there clear evidence that the company also offers advice channels. Additionally, the company does not explicitly state that its channels are available to all employees in any country of operation, or in multiple languages, or to employees of third parties, suppliers or joint venture partners.

Based on publicly available information, there is no evidence that the company provides anti-bribery and corruption training to its employees.

There is no evidence that the company provides tailored anti-bribery and corruption training to its employees based on an assessment of their role and exposure to corruption risk.

Based on publicly available information, there is no evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption communications or training programme.

Based on publicly available information, there is some evidence that the company’s renumeration structures incorporate ethical principles. The company states that it emphasises ethics when recognising employee performance and indicates that individual employees may also lose rewards in cases of misconduct.

However, the company receives a score of ‘1’ because there is no clear evidence that it has a specific approach for employees in high risk positions, such as those in sales roles. There is also no evidence that financial rewards must be proportionate to the employee’s salary in the case of high risk employees.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

There is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is evidence that this applies to all employees across the organisation, including those employed by the group as third parties, such as suppliers and contractors.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. The company indicates that these channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an independent body through a third party-operated channel. The company’s channels allow for confidential and anonymous reporting, and there is evidence that these channels are open to all employees as well as third parties, including suppliers.

The company receives a score of ‘1’ because there is no evidence these channels are available in multiple languages, nor that the channels are may be accessed by employees and third parties in any country of operation.

There is evidence that the company provides a training module on the basic principles of the anti-bribery and corruption policy. However, the company receives a score of ‘1’ because is not clear that anti-corruption training is delivered to employees in all divisions, all countries of operation and in all appropriate languages. There is also no clear evidence to indicate how frequently training is conducted.

There is no evidence that the company provides tailored anti-bribery and corruption training to its employees based on an assessment of their role and exposure to corruption risk. There is some evidence that company representatives give occasional seminars on business ethics, including anti-corruption, to selected managers, however there is no evidence to indicate that these events constitute a training programme for all relevant individuals across the organisation.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company makes a public commitment to support or protect employees who refuse to act unethically.

There is no evidence that the company has a publicly available policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is evidence that the company provides whistleblowing and advice channels that allow for anonymous reporting. However, the company receives a score of ‘1’ because it only offers internally operated channels. In addition, the company makes no explicit statement that its whistleblowing and advice channels are available to all employees in any country of operation, or in multiple languages, or to any employees of third parties, suppliers or joint venture partners.

Based on publicly available information, there is some evidence the company provides training for all employees that outlines the basic principles of the company’s Anti-Bribery and Corruption Policy and Code of Conduct, both of which include information on the whistleblowing options available. There is evidence that all employees across all across all divisions worldwide are required to undertake an online training module.

However, the company receives a score of ‘1’ because it is not clear how frequently employees are required to undertake and refresh their training on anti-bribery and corruption. There is also no clear evidence that the company provides training in all appropriate languages.

There is some evidence that the company provides tailored anti-bribery and corruption training for employees in certain positions, based on an assessment of their role and exposure to corruption risk. The company indicates that it provides training for employees in high risk positions, which may include those in marketing, contracting, procurement or client-facing roles.

However, the company receives a score of ‘1’ because there is no evidence that it provides tailored anti-corruption training to middle management and board members. In addition, there is no evidence that employees in high risk positions must refresh their anti-corruption training on at least an annual basis.

There is no publicly available evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption communications or training programme.

There is no publicly available evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles. The company publishes some information on its performance-based incentives for senior executives, but there is no evidence that this includes ethical factors nor that it applies to general employees.

There is no clear evidence that the company publicly commits to support or protect employees who refuse to act unethically. The company indicates that employees should seek advice on its ethics programme and states that it will support employees who raise concerns, but it is not clear that the company encourages employees to refuse to act unethically even where such actions may result in a loss of business.

Based on publicly available information, there is evidence the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption concerns. The company indicates that this policy applies to all employees across the organisation, including those employed by the group as third parties, such as suppliers and joint venture partners.

However, the company receives a score of ‘1’ because there is no evidence that it assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

Based on publicly available information, there is evidence that the company provides multiple channels for its employees to report instances of suspected corrupt activity and seek advice on its anti-bribery and corruption programme. The company indicates that these channels are sufficiently varied to allow the employee to raise concerns across the management chain, as well as externally to an independent third party. These channels allow for confidential and anonymous reporting and are available and accessible to all employees in all jurisdictions where the company operates. There is evidence indicating that the company’s whistleblowing channels are available to third parties, including suppliers and joint venture partners.

There is evidence that the company provides training to its employees on the basic principles of its Code of Conduct, which includes scenario-based anti-bribery and corruption issues and covers the whistleblowing options available to employees. There is evidence that training is provided to all employees across all divisions and regions of operation, and in all appropriate languages. The company indicates that employees must refresh their training on the anti-bribery and corruption programme annually.

There is evidence that the company provides tailored training on its anti-bribery and corruption programme for employees in certain positions, with specific reference to all three categories of individuals referred to in the question. There is evidence that all employees, including those in high risk roles such as import and export, receive annual ethics training.

Based on publicly available information, there is evidence that the company reviews and measures the effectiveness of its anti-bribery and corruption communications and training programme. There is evidence that the company has a system for doing this through employee surveys, face-to-face interviews and by monitoring the number of compliance enquiries. The company commits to conducting and reviewing these measures on an ongoing basis. There is evidence that the results of such reviews are used to update specific parts of the company's anti-bribery and corruption communications and training programme.

Based on publicly available information, there is evidence that the company’s incentive schemes incorporate ethical and anti-bribery and corruption principles. The company states that it incentivises employees based on ‘how’ they achieve these goals, which is assessed as part of performance reviews throughout the year. There is evidence that the company’s incentive schemes are based on the achievement of 75% financial and 25% non-financial targets, with a focus on integrity. The company also indicates that employees in its defence businesses are excluded from any sales-based incentives.

There is some evidence that the company commits to support and protect employees to act ethically and ‘do the right thing’ when conducting business. However, the company receives a score of ‘1’ because there is no evidence that it assures itself of its employees’ confidence in this statement through anonymised surveys or other clearly stated means.

Based on publicly available information, there is evidence that the company promotes a policy of non-retaliation against anyone who reports apparent misconduct, which includes whistleblowers and employees who report bribery and corruption incidents across the organisation. There is also evidence that this applies to those employed by the group as third parties, suppliers and joint venture partners. There is some evidence that the company assures itself of its employees’ confidence in this commitment by monitoring usage data for its whistleblowing channels.

There is evidence that the company provides multiple channels for its employees to report instances of suspected corrupt activity in the organisation and to seek advice on the company's anti-bribery and corruption programme. The company indicates that these channels can be confidential and anonymous, and are sufficiently varied to allow the employee to raise concerns across the management chain or to an external ethics hotline provider if necessary. There is evidence that the company’s channels are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners, and in all relevant languages.

The company states that all employees are required to undertake a compliance verification process, which includes an understanding of the company’s anti-corruption and anti-bribery policies. However, it is not clearly stated that employees are required to undertake training on the company’s anti-corruption programme.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk. Although the company states that managers and select employees are required to verify understanding of all of the company’s business conduct, it is not explicitly clear that this constitutes training.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically, even when it might result in a loss of business.

The company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, which applies to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners.

However, the company receives a score of ‘1’ because there is no evidence that it assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company has multiple whistleblowing and advice channels, some of which allow for anonymous and confidential reporting. The company also provides channels and resources for employees to receive advice related to anti-corruption and ethics and there is evidence that the company’s channels are available to all employees in all countries of operation, in all relevant languages. There is also evidence that the company maintains a reporting and advice channel for use by third parties.

However, the company receives a score of ‘1’ because it is unclear whether the company has an externally operated whistleblowing or advice channel.

There is no evidence that the institute provides anti-bribery and corruption training to all employees.

There is no evidence that the institute tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the institute measures or reviews the effectiveness of its anti-bribery and corruption communications and training programme.

There is no evidence that the institute’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is some evidence that the institute aims to promote an ethical culture in the workplace, however it does provide sufficiently clear evidence that it will support and protect employees who refuse to act unethically, even where it might result in a disadvantage or loss of business. There is also no evidence that the company takes steps to assure itself of employees’ belief in this commitment through surveys or other means.

There is evidence that the institute promotes a policy of non-retaliation against whistleblowers and employees who report compliance incidents. However, the institute receives a score of ‘0’ because it is not clear whether this policy applies to all employees across the organisation, including those employed by the group as third parties, suppliers and/or joint venture partners.

There is evidence that the institute provides several channels through which to report instances of suspected corrupt activity and seek advice on its Code of Business Conduct and Ethics. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an independent third party, through the provision of an externally-operated hotline. These channels allow for confidential and, wherever possible, anonymous reporting. This platform is available and accessible to employees in any jurisdiction through the online reporting system or international telephone service, and there is evidence that reports can be made in all relevant languages.

There is evidence that the company provides training on anti-bribery and corruption. There is evidence that the company provides this training to all employees across all divisions and countries of operation and in all appropriate languages. The company states that employees are required to undertake refresher courses every two years.

Based on publicly available information, there is evidence that employees in certain positions receive different and tailored training on anti-bribery and corruption. The company makes specific reference to all three categories of employee referred to in the question – employees in high risk positions, middle management and board members – and indicates that training requirements are defined according to the level of risk of their specific job assignment. There is evidence that employees in high-risk positions receive tailored training on an annual basis.

There is evidence that the company measures and reviews the effectiveness of its ethics and compliance communications and personnel training programme. There is evidence that the company has a system to do this, for example through staff surveys.

However, the company receives a score of ‘1’ because it is not from the evidence that the company specifically measures the effectiveness of its anti-bribery and corruption training, or whether the results are used to update specific parts of the company's anti-bribery and corruption communications and training programme. There is also no clear evidence that the company conducts a full review of its anti-bribery and corruption communications and training programme at least every three years.

Based on publicly available information, there is some evidence that the company incorporates integrity and accountability as measures in its annual employee performance reviews. The company indicates that such reviews are based on its ‘Vision, Values and Covenants’, which makes specific reference to ethics and integrity, and are designed to promote ethical behaviour while discouraging corrupt practices.

However, the company receives a score of ‘1’ because it does not provide further information on how such assessments impact on the company’s bonus or reward schemes. There is also no clear evidence to indicate that, where financial rewards are part of incentive schemes, there are procedures in place to ensure that they are proportionate to the base salary in the case of high risk employees.

There is publicly available evidence that the company commits to support and protect any employee who refuses to act unethically, in keeping with the company’s anti-corruption commitments, even where such actions result in a loss of business or another disadvantage to the company. There is evidence that the company assures itself of its employees' confidence in this commitment through anonymised surveys.

Based on publicly available information, there is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is evidence that this policy applies to all employees across the organisation, including those engaged by the group as third parties and suppliers. The company commits to assure itself of its employees’ confidence in this commitment through surveys and other measures.

There is evidence that the company has multiple channels for employees to report instances of suspected corrupt activity and seek advice on the company's ethics and compliance programme. There is evidence that these channels are sufficiently varied to allow employees to raise concerns across the management chain, as well as through an external service provider. There is evidence that these channels allow for confidential and anonymous reporting and that they are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners, and in all relevant languages.

There is no publicly available evidence that the company provides anti-bribery and corruption training to its employees.

There is no evidence that the company provides tailored anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

There is no evidence that the company has a publicly available policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is no publicly available evidence that the company provides whistleblowing or advice channels for its employees.

Based on publicly available information, there is evidence that the company’s Human Resources and Vigilance departments organise training programmes. However, the company receives a score of ‘0’ because there is no clear evidence that this training covers anti-bribery and corruption, nor that it applies to all employees across the organisation.

There is no evidence that the company provides tailored anti-bribery and corruption training to its employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

Based on publicly available information, there is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles. The company provides some information on it annual incentive schemes and remuneration policy for employees and directors, however the information published indicates that such incentives are based on financial and performance-based targets, with no evidence of ethical targets.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

There is evidence that the company has a policy of non-retaliation against any permanent employees who report bribery and corruption incidents. However, the company receives a score of ‘0’ because there is no evidence that the policy applies to all employees across the organisation, including those employed by the group as third parties, and suppliers.

There is evidence that the company provides a whistleblowing channel for its employees to report allegations or incidents of bribery and corruption, and there is evidence that reports can be confidential. The company states that employees may raise concerns through the channel in multiple relevant languages.

However, the company receives a score of ‘1’ because there is no evidence that it offers an external channels operated by an independent third party. There is also no evidence that the company’s reporting channels can also be used to seek advice or ask questions about the its anti-bribery and corruption programme, nor is there evidence that its system allows for anonymous reporting. Furthermore, there is no evidence to suggest that the company’s whistleblowing channel is available to employees of third parties or suppliers.

Based on publicly available information, there is evidence that the company provides vigilance training for all employees. However, the company receives a score of ‘1’ because there is no clear evidence that this training covers anti-bribery and corruption, and the company also does not provide further information on how frequently employees are required to undertake this training.

Based on publicly available information, there is some evidence that employees in certain positions receive different or tailored anti-bribery and corruption training. However, the company receives a score of ‘1’ because it does not make specific reference to all three categories of employee referred to in the question. There is also no evidence that training for employees in high risk positions is refreshed on at least an annual basis.

There is no publicly available evidence that the company measures or reviews the efficacy of its anti-corruption communications or training programme.

There is no publicly available evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to protect and support any employee who refuses to act unethically, including in cases where such actions may result in a loss of business or another disadvantage to the company. There is some evidence that the company accepts business loss arisen as a consequence of a bona-fide commercial/operational decision, however this doesn’t specifically relate to anti-bribery and corruption or supporting employees to do the right thing.

There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents which explicitly applies to all employees across the organisation, including those employed by the group as third parties and suppliers. This is understood to also apply to employees of joint ventures, although they are not specifically mentioned in the list of stakeholders.

The company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data or other clearly stated means.

Based on publicly available information, there is evidence that the company has some whistleblowing and advice channels which are confidential. The company states that these channels are available to all employees in any country of operation and to any employees of third parties, suppliers and joint venture partners.

However, the company receives a score of ‘1’ because there is no evidence that it offers externally operated reporting channels and there is no clear evidence that the channels are available in multiple relevant languages.

Based on publicly available information, there is evidence that the company provides training for its employees that outlines the principles of the anti-bribery and corruption policy, including the whistleblowing options available. There is evidence that the company provides this training to all employees in all business divisions and in multiple languages. The company indicates that employees are required to undertake this training on an annual basis.

Based on publicly available information, there is evidence that the company provides tailored training on anti-bribery and corruption to employees in different positions based on their role and exposure to corruption risk. The company indicates that managers receive tailored training on anti-corruption and compliance, and states that employees receive individual training plans based on the type of work they perform. In addition, there is evidence that board members receive annual training on corporate governance and the company’s policies and procedures, which is understood to include ethics and compliance. The company indicates that all employees are required to update their training on an annual basis.

There is evidence that the company reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme on an annual basis. The company states that it does this through staff surveys and feedback from subject matter experts. There is evidence indicating that the results of such reviews are used to update specific parts of the company's anti-bribery and corruption communications and training programme.

There is some evidence that the company’s incentive schemes for employees incorporate ethical and anti-corruption principles. The company indicates that integrity considered as a factor in individual performance reviews, and that these reviews inform the company’s annual employee incentive calculations.

However, the company receives a score of ‘1’ because there is no further publicly available description of how the company achieves this in practice. For example, it is not clear whether incentives focus on the achievement of both financial and non-financial targets, nor is there evidence that such rewards must be proportionate to the base salary, especially in the case of high risk employees.

There is evidence that the company commits to support and protect employees who refuse to act unethically, even when it might result in a loss of business. There is evidence that the company assures itself of employees’ confidence in this statement on a regular basis through confidential surveys.

There is evidence that the company promotes a policy of non-retaliation against both employees and third parties who report allegations of bribery and corruption. There is evidence that the company assures itself of employees’ confidence in this commitment on a regular basis through confidential surveys.

Based on publicly available information, there is evidence that the company provides multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. There is evidence that these channels are sufficiently varied to allow employees to raise concerns across the management chain and to an external party through an independently-operated hotline. The company states that these channels allow for confidential and, wherever possible, anonymous reporting.

In addition, the company indicates that its channels are available and accessible to all employees in all jurisdictions where it operates, including those employed by the group as third parties, suppliers and business partners. The company’s Code of Conduct has been translated into multiple languages, and therefore it is understood that the its reporting channels are available in multiple languages.

There is evidence that the company provides training for all employees, which outlines the basic principles of its anti-bribery and corruption programme.

However, there is no clear publicly available evidence that the company’s training specifically includes the whistleblowing options available to employees. It is also not clear from publicly available information that it provides this training to all employees in all divisions, countries and regions of operation and in all appropriate languages.

There is evidence that the company provides tailored anti-bribery and corruption training for employees in high risk positions based on their exposure to possible corruption risk.

However, there is no clear public available evidence that the company provides tailored anti-corruption training to those in middle management positions and to board members, nor is there clear evidence that employees in high risk positions specifically must undertake and refresh their tailored training on at least an annual basis.

There is evidence that the company reviews its anti-bribery and corruption communications and personnel training programme, the results of which are used to update specific parts of the company's anti-bribery and corruption communications and training programme.

However, it is unclear whether reviews of the training programme are carried out on at least an annual basis.

There is no publicly available evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is publicly available evidence that the company commits to support employees who raise concerns, make ethical decisions and refuse to act unethically, even when situations are difficult in the conduct of business.

However, there is no publicly evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

The company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, which explicitly applies to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners.

However, there is no publicly evidence evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company provides both whistleblowing and advice channels for its employees to report concerns and seek advice on its anti-corruption programme. The company clearly indicates that these channels allow for both confidential and anonymous reporting. In addition, there is evidence that the company operates both internal reporting mechanisms as well as an external whistleblowing service operated by an independent third party. There is also evidence indicating that these channels are available to all employees in any country of operation, in multiple languages, and to any employees of third parties, suppliers and joint venture partners.

Based on publicly available information, there is evidence that the company provides annual training on its Standards of Ethics and Business Conduct, which includes the company’s anti-corruption policy and whistleblowing options available to employees. The company indicates that this training applies to all employees and states that staff must certify their understanding of the Standards on an annual basis. The company does not state that it provides training in multiple languages, however there is no clear evidence that it operates in jurisdictions where training could not be provided in English.

There is no publicly available evidence that the company provides tailored anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is evidence that the company measures and reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme. The company indicates that the Culture, Character, Integrity and Ethics Committee is responsible for reviewing implementation and effectiveness, and there is evidence that the findings of such reviews are used to update elements of anti-corruption training programme.

However, company receives a score of ‘1’ because it does not provide further publicly available information on the way in which it measures effectiveness, for example through staff surveys, specific audits or training completion rates. In addition, it is not clear that the company makes use of these mechanisms on an annual basis, nor is there evidence that it undertakes a full review of the programme every three years.

There is no publicly available evidence that the company’s incentive schemes for employees are designed to incorporate ethical or anti-bribery and corruption principles.

There is no publicly available evidence that the company commits to support or protect employees who refuse to act unethically.

There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is evidence that this policy applies to all employees, directors and consultants across the organisation.

However, there is no publicly available evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company provides multiple channels for its employees to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. There is evidence that these channels are sufficiently varied to allow the employee to raise concerns across the management chain and externally through an independently operated hotline. The company indicates that its channels allow for confidential and, wherever possible, anonymous reporting.

In addition, there is evidence to indicate that the company’s whistleblowing hotline is available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties and suppliers. There is also evidence that the channels are available in multiple languages.

There is evidence that the company provides a training module to all employees that outlines the basic principles of its anti-bribery and corruption programme, including the whistleblowing options available to employees. There is also evidence indicating that the company provides this training in all company locations worldwide.

The company receives a score of ‘1’ because although the company states that employees must undertake refresher anti-corruption training periodically, there is no evidence that employees must do this at least every three years. There is also no evidence that training is delivered in all appropriate languages.

The company states that employees in certain high-risk positions receive different or tailored anti-bribery and corruption training.

However, there is no evidence that this includes middle management or board members. There is also no evidence that the company updates its training for those in high-risk positions at least annually.

There is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme.

However, the company receives a score of ‘1’ because the measures are limited to completion rates, and there is no evidence that the results of reviews are used to update specific parts of the company’s anti-bribery and corruption communications training programme. There is also no evidence that the company assures itself of the quality of its anti-corruption training on at least an annual basis.

While there is evidence that the company’s incentive schemes are designed to discourage excessive risk-taking, there is no publicly available evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is evidence to suggest that any employee who refuses to act unethically, in keeping with the company’s anti-corruption commitments, will be protected and supported, even where such actions result in a loss of business or another disadvantage to the company.

However, there is no evidence that the company assures itself of its employees’ confidence in this statement through anonymised surveys or other clearly stated means.

There is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents that applies to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. The evidence indicates that the channels are sufficiently varied to allow employees to raise concerns across the management chain, as well as through an external channel operated by an independent third party. There is evidence that these channels allow for confidential and, wherever possible, anonymous reporting, and that they are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners, and in several languages.

There is no evidence that the company provides anti-bribery and corruption training to its employees.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

The company does not have a publicly available policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is no evidence that the company has either whistleblowing or advice channels.

There is evidence that the company provides a training module that outlines the basic principles of its anti-bribery and corruption policy, including the whistleblowing options available to employees.

However, the company receives a score of ‘1’ because there is no evidence that the training is systematically provided to all employees across all divisions, all countries and regions of operation or in all appropriate languages.

There is evidence that the company tailors its anti-bribery and corruption training to employees in certain positions based on an assessment of their role and exposure to corruption risk. The company states that managers, and employees working in certain positions, including sales and procurement, receive anti-bribery and corruption training tailored to their role.

However, the company receives a score of ‘1’ because it does not mention board members nor does it specify that employees in high-risk positions are required to undertake refresher trainings on at least an annual basis.

There is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme. The company suggests that reviews are used to improve specific parts of its training programme. There is evidence that the company reviews its training on a half-yearly basis as part of its operational assurance process.

There is evidence that the company’s incentive schemes incorporate ethical and anti-bribery and corruption principles. There is evidence to suggest that incentives are designed to minimise compliance risks arising from target-based incentives, and that objectives include compliance principles.

However, the company receives a score of ‘1’ because this is insufficiently detailed and where financial rewards are part of the company’s incentive schemes, it is not clear that these must be proportionate to the employee’s salary in the case of high risk employees, such as sales roles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents that explicitly applies to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and to relevant external bodies. These channels allow for confidential and, wherever possible, anonymous reporting. They are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners. There is evidence that reporting can be done in all languages relevant to the jurisdictions in which it operates.

There is no evidence that the company provides anti-bribery and corruption training to all employees.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

There is no evidence that the company has a publicly available policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is no evidence that the company has either whistleblowing or advice channels.

Based on publicly available information, there is no evidence that the company provides anti-bribery and corruption training to all employees.

Based on publicly available information, there is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk. There is some indication that the company recognises the different corruption risks facing employees in different positions, but it is not clear that it provides training to employees to counter these risks.

There is no evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

Based on publicly available information, there is no evidence that the company has a policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is no publicly available evidence that the company provides whistleblowing or advice channels for employees to report suspected incidents of corruption or seek advice on the company’s anti-bribery and corruption activities.

There is evidence that the company provides training for its employees that outlines the principles of the anti-bribery and corruption policy and code of conduct, which include whistleblowing options available. The company states that all employees must undertake this anti-corruption training, along with a refresher course on an annual basis. The company states that it offers training in all necessary languages and there is evidence that the company delivers this training online, which is understood to indicate that it is available to all employees across the company’s operations.

There is some evidence that the company provides tailored anti-bribery and corruption training to employees in different positions based on their role and exposure to corruption risk. There is evidence that the company provides tailored training to employees in high risk positions and to board members, who must undertake this training on an annual basis.

However, the company receives a score of ‘1’ because there is no clear evidence that it provides tailored anti-corruption training to employees in middle management positions. There is also no evidence that those in high risk positions are required to refresh their training on this subject on an annual basis.

There is some evidence that the company measures and reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme. There is evidence that the company does this through monitoring training completion rates on an annual basis.

However, the company receives a score of ‘1’ because there is no publicly available evidence that the company takes additional steps to measure the effectiveness of its initiatives, for example by conducting staff surveys, audits or undertaking face-to-face conversations. There is also no clear evidence that such reviews are used to update and enhance specific elements of the company’s anti-bribery and corruption training programme.

There is evidence that the company’s incentive schemes for employees incorporate ethical and anti-bribery and corruption principles. The company indicates that its annual employee performance reviews are designed to recognise employees that demonstrate ethical behaviours by promoting a focus on ‘how’ they achieved their objectives, in addition to the objectives themselves.

However, the company receives a score of ‘1’ because there is no evidence to indicate that certain restrictions on incentives are applied to employees in high risk roles, such as ensuring that financial rewards are proportionate to the employee’s salary.

There is some evidence that the company encourages and supports employees who choose to act ethically or speak out against unethical conduct.

However, there is no evidence that the company clearly commits to support and protect employees who choose to act ethically, when doing so may result in a loss of business. There is also no evidence that the company assures itself of its employees’ confidence in this statement through anonymised surveys or other clearly stated means.

There is evidence that the company has a clearly stated policy of non-retaliation against whistleblowers and those who report ethics and corruption-related concerns. There is evidence that this commitment extends to employees of third parties engaged by company, including suppliers and joint venture partners.

However, the company receives a score of ‘1’ because there is no evidence that it assures itself of its employees’ confidence in its non-retaliation commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company provides multiple channels for its employees to report instances of suspected corrupt activity and seek advice on its anti-bribery and corruption programme. There is evidence that these channels are sufficiently varied to allow employees to raise concerns across the management chain and to an external party through an independently-operated hotline. The company’s channels also allow for confidential and, wherever possible, anonymous reporting.

In addition, there is evidence that the company’s reporting channels are available in all relevant languages and are available and accessible to all employees in all jurisdictions where the company operates, including to those employed by the group as third parties, suppliers and joint venture partners.

There is evidence that the company provides a training module that outlines the basic principles of its anti-bribery and corruption policy, including the whistleblowing options available to employees.

However, the company receives a score of ‘1’ because it is unclear how frequently training is conducted and whether training is provided in all appropriate languages.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk. The Code of Business Conduct indicates that employees interacting with customers receive training on the company’s ethical standards. However, it is not clear that this is tailored to employees in high risk positions, nor how frequently this is conducted. There is also no evidence of tailored training for middle management or board members.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme. The company does not provide information on any data it collects on its communications and personnel training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company makes an explicit commitment to protect employees who refuse to act unethically, even when it might result in a loss of business.

There is evidence that the company, in its Code of Conduct, promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. The Code of Conduct applies to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and to relevant external bodies. These channels allow for confidential and anonymous reporting. They are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners, and in all relevant languages.

There is evidence that the company provides training to its employees on the Code of Conduct, which includes the company’s anti-bribery and corruption policy and the whistleblowing options available to employees. The company states that this training is provided on an annual basis to all employees across the organisation.

However, the company receives a score of ‘1’ because it is not clear that training is provided to all employees across all divisions and regions of operation or in all appropriate languages. Although the company states that the Code of Conduct is available to employees in all divisions and regions, it is not clear from publicly available evidence that this applies to training.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk. Although the company provides a dedicated Code of Conduct for board members, this document does not mention a requirement to undergo training on anti-bribery and corruption.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically. The company states its intention to create an ethical workplace but does not provide sufficiently clear evidence that it will support and protect those who refuse to act unethically, even where it might result in a disadvantage or loss of business.

There is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is evidence that this policy applies to employees and representatives associated with the company, which is understood to include third parties and those employed by joint ventures.

However, the company receives a score of ‘0’ because it is not clear whether this Code applies to those engaged by the group as suppliers, and there is no mention of non-retaliation in the Code of Conduct for Suppliers and Customers. There is also no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an independent third party, through an externally-operated hotline. These channels allow for confidential and, wherever possible, anonymous reporting. There is evidence that the EthicsPoint hotline is available to all employees in all jurisdictions – including those employed by the group as third parties, suppliers and joint venture partners – and in all relevant languages.

Based on publicly available information, there is some evidence that the company systematically provides training to its employees, outlining its anti-corruption policy and the whistleblowing options available to them. The training is provided to all employees. The company states that employees at different levels receive some version of ethics training on a monthly and quarterly basis.

However, the company receives a score of ‘1’ because there is no clear evidence to indicate that all employees are required to undertake and refresh their training on anti-bribery and corruption at least every three years. The company indicates that some employees may be required to refresh their training on ethics, but it is not clear which employees this includes nor which the topics that might be covered. There is also no clear evidence that the company provides training in all appropriate languages for employees of subsidiaries or offices in other countries.

Based on publicly available information, there is some evidence that certain employees in certain positions receive different or tailored anti-bribery and corruption training. The company makes reference to employees in high risk positions and management employees.

However, the company receives a score of ‘1’ because there is no evidence that board members receive tailored training. The company also does not specify whether training for employees in high risk positions is refreshed on at least an annual basis.

Based on publicly available information, there is no clear evidence that the company reviews its anti-bribery and corruption communications and training programme. Although the company states that it hosts an ethics conference to obtain employee feedback, it is not clear whether this includes a review of its anti-bribery and corruption communications and training activities.

Based on publicly available evidence, there is some evidence that the company’s incentive schemes for employees incorporate ethical and anti-bribery and corruption principles. There is evidence indicating that performance evaluations take account of compliance with the company’s ethics policies.

However, the company provides limited public information on how it incentivises ethical conduct. There is also no evidence that financial incentives must be proportionate to the employee’s base salary in the case of high-risk roles, such as sales.

Based on publicly available information, there is no evidence that the company commits to support or protect employees who refuse to act unethically.

Based on publicly available information, there is evidence that the company has a policy of non-retaliation against whistleblowers who report bribery and corruption incidents. There is evidence indicating that this policy applies to both employees of the company and those outside of the company.

However, there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

Based on publicly available information, there is evidence that the company has whistleblowing and advice channels that allow anonymous reporting and are accessible to all employees. There is also evidence that the whistleblowing channel is accessible to external parties and is available in multiple languages.

However, the evidence indicates that the company only offers internally operated whistleblowing channels and does not provide any external channels operated by an independent third party. There is also no clear evidence to indicate that the available channels allow for confidential reporting, nor that they are available to the employees of suppliers and joint venture partners.

Based on publicly available information, there is evidence that the company provides a training module that
outlines the basic principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees. The evidence suggests that the training is systematically provided to all employees across all divisions and all countries regions of operation.

However, the company receives a score of ‘1’ because it is not clear how frequently all employees receive training.

Based on publicly available information, there is evidence that the company states that employees in certain positions receive tailored anti-bribery and corruption training. The company indicates that employees in high risk positions – including those who deal with agents, customers and suppliers – receive training bi-annually.

However, the company receives a score of ‘1’ because there is no evidence that it provides tailored anti-corruption training to its middle management and board members.

Based on publicly available information, there is evidence that the company measures the efficacy of its compliance programme via an employee engagement survey. However, it is not clear that the company measures or reviews
the efficacy of its anti-bribery and corruption communications or training programme.

There is no publicly available evidence to indicate that the company's incentive schemes incorporate ethical or anti-bribery and corruption principles.

Based on publicly available information, there is evidence that the company commits to support and protect employees who refuse to act unethically.

However, the company does not specify that it will support employees even where such actions result in a loss of business to the company. There is also no evidence it assures itself of employee’s confidence in this.

Based on publicly available information, there is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents that explicitly applies to all employees across the organization, including those employed by the group as third parties, suppliers and joint venture partners.

However, there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

Based on publicly available information, there is evidence that the company has whistleblowing and advice channels. The channels are confidential, there are both externally and internally operated channels and both whistleblowing and advice channels. The channels are explicitly available to any employees of third parties, suppliers or joint venture partners.

However, there is no clear evidence that the company’s channels are available in multiple languages.

There is evidence that the company provides training sessions on the basic principles of the anti-bribery and corruption policy to employees and managers who are most exposed to corruption risk.

However, there is no clear evidence that the company provides such training to all employees across all divisions, all countries regions of operation or in all appropriate languages. In addition, the company does not provide further publicly available information regarding the content of its training so it is not clear whether these sessions cover the whistleblowing options available to employees. It is also unclear how frequently employees must undertake or refresh their training in this area.

There is some evidence that the company provides tailored anti-corruption training to certain employees based on an assessment of their role and exposure to corruption risk. The company indicates that it provides such training to managers and those most exposed to possible corruption and influence-peddling.

However, there is no publicly available evidence that the company provides tailored anti-corruption training to board members. It is also not clear how frequently employees in high risk positions must undertake and refresh their training in this area.

There is no publicly available evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption communications or training programme. The company indicates that it has a system in place to evaluate its internal controls, however it is not clear from publicly available information that this specifically includes measuring effectiveness nor that it covers the company’s anti-corruption training and communications initiatives.

There is no publicly available evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles. The company provides some details on its compensation policy in its Annual Report, however there is no evidence that it includes clear information on how it incentivises employees to promote ethical behaviour and discourage corrupt practices.

There is no publicly available evidence that the company commits to support or protect employees who refuse to act unethically.

There is some evidence that the company has a policy of non-retaliation against whistleblowers, in line with relevant national legislation, and that this policy applies to all employees and those employed by subsidiaries.

However, there is no publicly available evidence that this commitment extends beyond whistleblowers to any employees who report bribery and corruption-related allegations and incidents through other channels. In addition, there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys or other clearly stated means.

There is some evidence that the company has an internal alert procedure to allow employees to report incidents or possible breaches of its Anti-Corruption Code. The company indicates that this system is open to outside employees, including temporary staff and those working for subsidiaries or third parties.

However, the company receives a score of ‘1’ because it does not provide further publicly available information on its whistleblowing and reporting mechanisms. There is no evidence that the company provides an external reporting mechanism, for example a channel operated by an independent third party, nor is there evidence that the company’s alert system allows for anonymous or confidential reporting. In addition, it is not clear from publicly available information that these channels are available to all employees in all countries of operation, or in multiple languages.

There is evidence that the company provides training on its Code of Business Conduct, which outlines the principles of the company’s anti-bribery and corruption policy, including the whistleblowing options available to employees. There is evidence that the company provides this training to all employees across all divisions and countries of operation, and in all appropriate languages. There is evidence that employees are required to undertake refresher courses on the anti-bribery and corruption programme on an annual basis.

There is evidence that the company tailors its anti-bribery and corruption training programme to the different levels of risk facing employees in different roles, with specific reference to senior executives, as well as senior, middle and lower management, and those engaged in international business. There is evidence that all employees are expected to undertake anti-corruption and ethics training annually. There is also evidence that employees working in high risk positions, namely those involved in international business, are required to refresh their training in this area on at least an annual basis.

There is evidence that the company reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme. There is evidence that the company has a system to do this, via annual audits and interviews with randomly selected employees designed to assess employees’ knowledge and memory of the content of training sessions. The company also states that it monitors training completion rates. The Ethics and Compliance Committee reviews the company’s training and communications programme on a quarterly basis and there is evidence to suggest the results are used to specific parts of the company’s anti-bribery and corruption communications training programme.

There is no publicly available evidence to determine whether the company's incentive schemes are designed to discourage corrupt practices.

There is evidence that the company will protect employees who refuse to act unethically to gain business.

However, there is no publicly available evidence that the company assures itself of employees’ confidence in this commitment such as through anonymised surveys or clearly stated means.

There is evidence the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. This policy explicitly applies to all employees across the organisation, including those engaged by the group as third parties, sub-contractors, suppliers and joint venture partners. There is evidence the company assures itself of its employees’ confidence in this commitment through employee questionnaires. The company additionally monitors the statistics and usage of its whistleblowing telephone and email service.

The company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. Channels are sufficiently varied to allow the employee to raise concerns across the management chain to a supervisor, Ethics Officer, or one of several internal departments, as well as to external bodies through an ethics helpline managed by a third party. There is evidence that the company's reporting channels allow for confidential and, wherever possible, anonymous reporting. It is also clear that the company’s ethics reporting helpline is available to all employees – including sub-contractors, representatives, agents or other third parties – in all jurisdictions; while the company’s Code of Ethics and Standards of Business Conduct, which outlines all the company's whistleblowing options, is available in six languages.

There is some evidence that the company provides its employees with training on anti-bribery and corruption. The company states that prevention of corruption is included as part of its induction programme. However, the company receives a score of ‘1’ because it is unclear whether training is refreshed throughout employment or whether training is systematically provided to all employees across all divisions, all countries regions of operation or in all appropriate languages.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles. The company mentions some information on its remuneration strategy, but there is no evidence that this includes a consideration of anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

There is no evidence that the company has a policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is evidence that the company provides an externally operated whistleblowing channel to allow employees and external stakeholders to report bribery or corruption allegations. However, the company receives a score of ‘1’ because it is not clear that these channels can be used to seek advice on the company’s anti-bribery and corruption activities, nor does it state that reports can be made anonymously and are treated confidentially. It is not explicitly clear that the channel is available to all employees in any country of operation, or in multiple languages, or to any employees of third parties, suppliers or joint venture partners.

There is evidence that the company provides training for its employees that outlines the principles of the anti-bribery and corruption policy, including the whistleblowing options available. There is evidence that the company provides this training to all employees across all divisions and countries of operation, and in all appropriate languages. The company states that employees are required to undertake refresher courses or modules on the anti-bribery and corruption programme at least every three years.

There is evidence that the company provides tailored anti-bribery and corruption training based on the different levels of risk facing employees in different roles. The company makes specific reference to employees in high risk positions, middle management positions and board members. There is evidence that employees working in high risk positions, such as those in sales and purchasing, are required to refresh their training in this area on at least an annual basis.

There is evidence that the company measures the effectiveness of its anti-bribery and corruption communications and personnel training programme. The company indicates that it has a system in place to do this, by tracking participation rates, obtaining participant feedback and face-to-face conversations. There is evidence that the company conducts this assurance on a continuous basis with the results used to update specific parts of the company’s anti-bribery and corruption communications training programme.

However, the company receives a score of ‘1’ because there is no clear publicly available evidence that the company undertakes a formal review of the whole programme at least every three years.

There is some evidence that the company’s incentive schemes for employees are designed in such a way to promote ethical behaviour and discourage corrupt practices. There is evidence that any financial rewards included in the company’s incentive schemes must be proportionate to the employee’s salary in the case of high risk employees. The company also states that such provisions are included in employment contracts and that it may reduce or eliminate bonuses in situations where employees are found to have violated its compliance procedures. It is noted that, beyond contractual requirements, the company does not provide additional information on how it incentivises ethical behaviour on a continuous basis, for example through performance appraisals or evaluations.

There is evidence that the company commits to protecting and supporting any employee who refuses to act unlawfully, in keeping with the company’s anti-corruption commitments, even where such actions result in a loss of business or another disadvantage to the company.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this statement through anonymised surveys or other clearly stated means.

There is evidence the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is evidence that this policy applies to all employees across the organisation as well as those engaged by the group as third parties, including suppliers and joint venture partners.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company provides multiple channels for its employees to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. There is evidence that these channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an independent external ombundsman. These channels allow for confidential and anonymous reporting. In addition, the company indicates that its reporting channels are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners. The company also indicates that employees may submit reports in multiple languages, and that it has procedure in place to translate such reports as soon as possible.

There is evidence that the company provides a training module that outlines the basic principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees, which is refreshed on an annual basis.

However, the company receives a score of ‘1’ because it is not clear whether this training is provided in all the company’s countries of operation and in all appropriate languages.

There is some evidence that the company provides tailored anti-bribery and corruption training to employees in different roles. For instance, the company states that employees that are more exposed to corruption risk receive additional training on anti-corruption legislation, which is refreshed annually.

However, the company receives a score of ‘1’ because there is no evidence that it conducts tailored training for middle management and board members.

There is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme. However, these measures appear to be too simplistic to receive a score of ‘1’ and are limited to maintaining records of completion. There is also no evidence that the company assures itself of this on at least an annual basis nor that the results are used to update specific parts of the company’s anti-bribery and corruption communications training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

The company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. This applies to all employees across the organisation.

However, the company does not explicitly refer to employees employed by the group as third parties, suppliers and joint venture partners. There is also no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

The company has multiple whistleblowing and advice channels which allow for anonymous and confidential reporting. These channels are sufficiently varied to allow the employee to raise concerns across the management chain and to relevant external bodies. They are available and accessible to all employees in all jurisdictions where the company operates, and in all relevant languages.

However, the company receives a score of ‘1’ because it is not explicitly stated that the whistleblowing and advice channels are also available to those employed by the group as third parties and joint venture partners.

There is evidence that the company provides training on a periodic basis that outlines the principles of its anti-bribery and corruption policy, including the whistleblowing options available to employees. The company indicates that it provides this training to all employees, across all divisions and countries of operation. In addition, there is evidence that the company provided training on anti-corruption and ethics in the most recently reported financial year and that it aims to provide training all employees every two years.

Based on publicly available information, there is some evidence that the company provides different or tailored anti-bribery and corruption training to employees based on their roles. The company indicates that employees in certain professional functions receive dedicated anti-bribery and corruption training on a periodic basis.

However, it is not clear from publicly available information that the company provides tailored anti-bribery and corruption training to middle management and board members, to account for the specific risks that they might face. It is also not clear from publicly available information whether employees in professional functions include all employees in high risk positions nor is it clear that such individuals must refresh their specific training on at least an annual basis.

There is some evidence that the company measures the effectiveness of its anti-bribery training and communications programme. The company provides data on the percentage of employees trained on anti-corruption in the most recently reported financial year, and there is also some evidence that the company may hold in-person sessions to reinforce understanding of its policies.

However, there is no publicly available evidence that the company has further procedures in place to measure and review the effectiveness of its anti-corruption training and communications programme specifically, for example by conducting staff surveys or targeted audits of these aspects of its programme at least every three years.

Based on publicly available information, there is no evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles.

There is no publicly available evidence that the company commits to support or protect employees who refuse to act unethically. The company indicates that employees who report incidents are protected and that it will not proceed with a third party transaction where concerns are identified, however it is not clear from publicly available information that the company commits to support employees to make ethical decisions in their responsibilities, even when this might result in a loss of business.

There is publicly available evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, which clearly applies to all employees across the organisation. There is evidence that the company makes this commitment in its Anti-Bribery and Corruption Compliance Policy, which also applies to third parties acting on the company’s behalf.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means. Although there is evidence that the company conducts employee engagement surveys, it is not clear from publicly available information that this survey addresses employees’ understanding and belief in the company’s non-retaliation policy.

Based on publicly available information, there is evidence the company provides multiple channels for employees to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. There is evidence that these channels are sufficiently varied to allow the employee to raise concerns across the management chain. The company indicates that these channels allow for confidential and, wherever possible, anonymous reporting. In addition, there is evidence that whistleblowing channels are available and accessible to all employees, in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that it offers an external reporting channel for employees to report incidents outside the management chain, for example through a channel operated by an independent third party.

Based on publicly available information, there is evidence that the company provides a training module on the basic principles of its anti-bribery and corruption policy to all employees.

However, the company receives a score of ‘1’ because it not clear how frequently the company conducts or provides this training. There is also no clear evidence that training is provided to all employees across all divisions, all countries of operation and in all appropriate languages.

Based on publicly available information, there is evidence that the company provides tailored anti-corruption training to employees in high risk positions, senior management staff and board members. However, the company receives a score of ‘1’ because it is not clear how frequently these employees are required to refresh their training.

Based on publicly available information, there is some evidence that the company monitors and records its educational materials, attendance at training sessions and certifications of compliance, and that it conducts staff surveys in relation to employee engagement with Ethics and Compliance.

However, the company receives a score of ‘1’ because it is not clear how frequently it conducts such reviews. There is also no clear evidence that the results are used to update specific parts of the company's anti-bribery and corruption communications and training programme.

There is no publicly available evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

Based on publicly available information, there is no evidence that the company commits to support and protect employees who refuse to act unethically.

Based on publicly available information, there is evidence that the company has a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is evidence to indicate that this policy applies to all employees across the organisation, including those engaged by the group as third parties.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data or other means.

There is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. There is evidence that these channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an external channel managed by an independent third party. There is evidence that these channels allow for confidential and, wherever possible, anonymous reporting.

The company indicates that channels are available and accessible to all stakeholders, including all employees in all jurisdictions where the company operates and those employed by the group as third parties, as well as in all relevant languages.

Based on publicly available information, there is some evidence that the company provides a training module that outlines the basic principles of its anti-bribery and corruption policy. The company indicates that it provides this training to employees when they join the company.

However, the company receives a score of ‘1’ because there is no evidence that training is systematically provided to all employees across all divisions, all countries and regions of operation and in all appropriate languages. It is also unclear how frequently employees receive this training, nor is there clear evidence that training includes an outline of the whistleblowing options available to employees.

There is no publicly available evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to risk.

There is no publicly available evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme. The company indicates that it conducts annual audits to determine the effectiveness of its anti-corruption programme, but there is no evidence that it specifically measures the effectiveness of its training and communications as part of this process.

Based on publicly available information, there is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

Based on publicly available information, there is no clear evidence that the company commits to support or protect employees who refuse to act unethically.

Based on publicly available information, there is some evidence that the company has a policy of non-retaliation against whistleblowers and employees who report bribery and corruption incidents. There is evidence that this commitment extends to third parties.

However, the company receives a score of ‘1’ because there is no evidence that it assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

Based on publicly available information, there is evidence that the company provides multiple channels for its employees to report instances of suspected corrupt activity. There is evidence that employees may report concerns anonymously, and the company indicates that these channels are open to third parties.

However, the company receives a score of ‘1’ because there is no evidence that the company provides an external reporting channel operated by an independent third party, nor is it clear that the channels provided could be used to seek advice about the company’s anti-corruption programme. There is also no publicly available evidence that reports are treated confidentially. In addition, there is no clear evidence that these channels are available to all employees in any country of operation, or in multiple languages.

Based on publicly available information, there is evidence that the company provides a training module that outlines the basic principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees. There is evidence that the training is conducted annually and is provided systematically to all employees across all divisions and in all countries and regions of operation. There is evidence to suggest that training is provided in all appropriate languages. However, while the company states it conducts periodic refresher training, there is no clear evidence that employees are required to undertake refresher courses at least every three years.

The company states that employees in certain positions receive different anti-bribery and corruption training and makes specific reference to employees in high risk positions and middle management. However, there is no evidence that board members receive tailored training on the company’s anti-bribery and corruption programme. There is also no clear evidence that training for employees in high risk positions is refreshed on at least an annual basis.

Based on publicly available information, there is evidence that the company reviews its anti-bribery and corruption communications and personnel training programme through staff questionnaires. The company also publishes information on the number of personnel trained on an annual basis. The board receives an annual report regarding the company’s training activities. There is evidence indicating that the results are used to update specific parts of the company's anti-bribery and corruption communications and training programme.

Based on publicly available information, there is evidence that the company’s incentive schemes incorporate ethical and anti-bribery and corruption principles. An employee’s commitment to the company’s objectives on anti-corruption is one of the elements considered when awarding variable renumeration. However, there is no evidence that in the case of high risk employees, such as sales roles, financial rewards must be proportionate to the employee’s salary.

The company clearly states that any employee who refuses to act unethically, in keeping with the company’s anti-corruption commitments, will be protected and supported even where such actions result in disadvantages to the company. Although the company indicates that it carries out surveys of its employees, it is unclear whether these include a question relating to employees’ trust in this commitment.

Based on publicly available information, there is evidence that the company promotes a policy of non-retaliation against both whistleblowers and company employees who report bribery and corruption incidents. There is evidence this commitment extends to third parties, although the company does not refer to those engaged by the company as suppliers and joint venture partners specifically. There is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data or other clearly stated means.

Based on publicly available information, there is evidence that the company has external and internal whistleblowing and advice channels that are confidential and allow for anonymous reporting. The channels are explicitly available to all employees in any country of operation and to third parties. There is evidence that the channels are provided in multiple languages.

There is evidence that the company provides training on anti-bribery and corruption to all of its employees, which outlines the principles of its policy and the whistleblowing options available to employees. The company indicates that it provides training for all its employees worldwide, which is understood to include providing training to all divisions and in all appropriate languages. In addition to periodic training on ethics and compliance, there is evidence that employees must review and certify their understanding of the company’s Code of Business Conduct and Ethics, and the anti-corruption principles therein, on an annual basis.

There is evidence that the company provides tailored anti-bribery and corruption training to employees in different roles based on their role and exposure to corruption risk. The company indicates that it provides fact-to-face training for certain employees and all directors, and indicates that middle management receive targeted training on handling and escalating employee concerns and incidents. In addition, the company states that in 2018 it provided an update to its board of directors about the international compliance risks, including anti-corruption risks, facing the company.

However, the company receives a score of ‘1’ because there is no evidence to indicate that employees in high risk positions must refresh their training on at least an annual basis.

Based on publicly available information, there is evidence that the company reviews the effectiveness of its anti-bribery and corruption communications and training programme. The company indicates that it undertakes such reviews on an annual basis using incident reporting data and employee surveys, as well as by making adjustments based on business needs. There is evidence that the company uses these reviews to update specific elements of its anti-corruption training and communications programme.

There is some evidence that the company’s incentive schemes are designed to promote its compliance programme and adherence with all relevant regulations and policies. The company indicates that the Compliance and Ethics Committee is responsible for designing and implementing such systems. In addition, there is evidence that the Organisation and Compensation Committee is responsible for ensuring that executive compensation aligns with the company’s values.

However, the company receives a score of ‘1’ because further details on how the company’s incentive schemes are designed to promote ethical behaviour and discourage corrupt practices are not made publicly available. It is not clear that the incorporation of ethical values into incentives applies to all employees in addition to executives, nor is it clear whether such incentives include both financial and non-financial components.

There is evidence that the company commits to support and protect any employee who refuses to give or receive bribes, even where such actions may result in a loss of business. There is evidence that the company assures itself of its employees’ confidence in this commitment through employee surveys.

There is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. The company clearly indicates that this policy applies to all employees across the organisation, including those employed by the group as third parties, suppliers and other partners. There is evidence that the company assures itself of its employees’ confidence in this commitment through employee surveys.

There is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. There is evidence that these channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an external body through an independently-operated hotline. The company indicates that these channels allow for confidential and, wherever possible, anonymous reporting. There is evidence that channels are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners, and in all relevant languages.

Based on publicly available information, there is evidence that the company provides a training module that outlines the basic principles of its anti-bribery and corruption policy, including the whistleblowing options available to employees. There is evidence that training is provided to all employees across all divisions, all countries/regions of operation and in all appropriate languages. There is evidence that the training is held annually.

Based on publicly available information, there is evidence that the company provides tailored anti-bribery and corruption training to employees in different roles, including managers, employees in high-risk positions such as public sector business and sales, and executives. There is evidence to suggest that the training is held on at least an annual basis.

The company states publicly that it reviews its anti-bribery and corruption communications and personnel training programme on an annual basis. The company tracks training completion rates.

However, it is unclear how the company reviews the programme in practice. It is also unclear whether the results are used to update specific parts of the company's anti-bribery and corruption communications and training programme.

Based on publicly available information, there is no clear evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

Based on publicly available information, there is no evidence that the company commits to support or protect employees who refuse to act unethically, even when it might result in a loss of business.

Based on publicly available information, the company promotes a policy of non-retaliation against both whistle-blowers and employees who report bribery and corruption incidents, which explicitly applies to all employees across the organisation. There is evidence indicating that the company’s whistleblowing line is open to third parties and that its policy on non-retaliation extends to these parties. There is evidence that the company assures itself of its employees’ confidence in this commitment by tracking usage data from its whistleblowing line.

Based on publicly available information, there is evidence the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and to relevant external bodies. These channels allow for confidential and, wherever possible, anonymous reporting. They are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, and in all relevant languages.

There is evidence that the company provides training for its employees that outlines the basic principles of its anti-bribery and corruption policy, as well as providing details of the whistleblowing options available. There is evidence that the company provides this training to all employees across all divisions and countries of operation, and in all appropriate languages. The company indicates that all employees receive this training during the onboarding process.

Although the company states that employees receive clear communications on anti-corruption in annual and quarterly meetings, there is no publicly available evidence that employees are required to refresh their training on the company’s anti-bribery and corruption programme and whistleblowing options on a regular basis or every three years.

There is evidence that the company provides tailored training on its anti-bribery and corruption programme to employees based on the different levels of risk facing those in different roles. There is evidence that the company provides tailored training to employees in high risk positions, as well as for middle management and board members. The company indicates that all categories of employees must refresh their training regularly or at least annually, and states that middle management must certify their understanding of the Code of Conduct on an annual basis.

There is evidence that the company measures and reviews the effectiveness of its anti-corruption training programme. There is evidence that the company has a system in place to do this, through an annual employee survey and regular monitoring and assessments of the programme. The company indicates that it undertakes such reviews on at least an annual basis, and there is evidence that the results are used to update specific parts of its anti-bribery and corruption communications and training programme.

Based on publicly available information, there is evidence that the company’s incentive schemes for employees incorporate anti-bribery and corruption principles. The company indicates that where employees receive performance-based pay, such incentives are calculated based on performance appraisals which include a qualitative assessment of the employee’s behaviours in line with the company’s Code of Conduct. The company states that per deal incentives are uncommon but that where such incentives are provided they are designed to discourage corrupt practices.

The company receives a score of ‘1’ because there is no clear evidence that it adjusts its incentive schemes to account for employees in high risk positions and ensures that incentives are proportionate to the employee’s base salary in such cases.

There is evidence that the company publicly commits to protect and support any employee who refuses to act unethically, in keeping with the company’s anti-corruption commitments, even where such actions may result in a loss of business or another disadvantage to the company. There is evidence that the company assures itself of its employees' confidence in this commitment through anonymised surveys.

There is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, including those engaged by the group as third parties, suppliers and joint venture partners. There is evidence that the company seeks to assure itself of its employees’ confidence in the commitment through monitoring the usage statistics of whistleblowing channels and employee surveys.

There is evidence that the company provides both whistleblowing and advice channels for its employees to report concerns and seek advice on its anti-bribery and corruption programme. There is evidence these channels allow for confidential and anonymous reporting. The company indicates that these channels are available to all employees in all locations and in multiple languages, including those engaged as third parties, suppliers and joint venture partners.

However, the company receives a score of ‘1’ because there is no evidence that it provides an external channel for employees to report concerns or incidents, such as an independently-operated hotline.

There is no publicly available evidence that the company provides anti-bribery and corruption training to its employees.

There is no evidence that the company provides tailored anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company publicly commits to support or protect employees who refuse to act unethically.

There is no evidence that the company has a publicly available policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is no publicly available evidence that the company provides either whistleblowing or advice channels for its employees.

There is evidence that the company provides an ethical training module for its employees, which outlines the basic principles of its anti-bribery and corruption policy, including the whistleblowing options available. There is some evidence that such training is mandatory for all employees and that it is provided every two years.

However, the company receives a score of ‘1‘ because there is no clear evidence that this training is provided to employees across all divisions, in all countries or regions of operation and in all appropriate languages. Moreover, it is not clear whether the requirement to complete the training every two years is targeted or whether it applies to all employees across the company.

There is some evidence that the company provides tailored ethics training to its directors at the start of their employment. There is evidence to indicate that this ethics training includes anti-bribery and corruption.

However, the company receives a score of ‘1‘ because there is no evidence that it provides tailored anti-bribery and corruption training to middle management or employees in high risk positions.

There is no evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

Based on publicly available information, there is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report ethical incidents of any kind. This policy applies to all employees across the organisation, including those engaged by the group as third parties, suppliers and joint venture partners. There is evidence that the company assures itself of its employees’ confidence in this commitment by monitoring the usage statistics.

There is evidence that the company provides multiple channels for its employees to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. The company indicates that these channels are sufficiently varied to allow the employee to raise concerns across the management chain and externally through an independently-operated hotline. These channels allow for confidential and, wherever possible, anonymous reporting. There is evidence that the company’s whistleblowing channels are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners, and in all relevant languages.

There is evidence that the company provides training on the GKN Aerospace Code and Values to all employees. However, the company receives a score of ‘0’ because it is unclear whether this includes the company’s policies on anti-bribery and corruption and the company does not otherwise explicitly state that it conducts training on anti-bribery and corruption.

There is no evidence that the company provides different or tailored anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

There is no publicly available evidence that the company has policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is evidence that the company has an external whistleblowing hotline, which is available to all employees in all relevant languages and allows for anonymous and confidential reporting.

However, there is no evidence that the company provides other reporting options, including advice channels for employees to ask questions about the company’s anti-bribery and corruption policy or activities. Moreover, there is no clear evidence that the external channel is available to employees of third parties, suppliers or joint venture partners.

There is no evidence that the company provides anti-bribery and corruption training to all of its employees.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures and reviews the efficacy of its anti-bribery and corruption training programme.

There is no evidence that the company’s incentive schemes for employees incorporate anti-bribery or corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

There is no evidence that the company has a publicly available policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is no evidence that the company provides whistleblowing or advice channels for its employees.

Based on publicly available information, there is evidence that the company provides training to its employees that outlines the principles of the anti-bribery and corruption policy, including the whistleblowing options available. There is evidence that the company provides this training to all employees across all divisions and countries of operation and in all appropriate languages. The company states that employees are required to undertake refresher courses or modules on the anti-bribery and corruption programme at least every three years.

Based on publicly available information, there is evidence that the company tailors its anti-bribery and corruption training programme to the different levels of risk facing employees in different roles, with specific reference to the categories of employee listed in the question. There is evidence that employees working in high risk positions, such as those in sales and government relations, are required to refresh their training in this area on an annual basis.

Based on publicly available information, there is evidence that the company reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme. There is evidence that the company has a system in place for doing this, in the form of staff surveys and employee tests. The company assures itself of this on an annual basis and there is evidence indicating that the results are used to update specific parts of the company's anti-bribery and corruption communications and training program.

Based on publicly available information, there is evidence that the company’s incentive schemes incorporate ethical and anti-bribery and corruption principles. There is evidence to suggest that incentives are designed to reward behaviour in line with the company’s ethical values. There is evidence that the policy applies to high-risk employees, such as sales roles.

There is evidence that the company commits to protecting and supporting employees who refuse to act unethically, even where such actions result in a loss of business or another disadvantage to the company. There is evidence that the company conducts surveys to understand employee perceptions and confidence in its Compliance Program generally. However, based on publicly available information, there is no clear evidence that the company assures itself of its employee’s confidence in this commitment specifically.

Based on publicly available information, there is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. The company’s policy clearly applies to all employees across the company, including those engaged by the group as third parties, suppliers and joint venture partners.

However, although there is evidence that the company measures its employees’ confidence in its company’s compliance programme generally, there is no clear evidence that the company specifically assures itself of its employees’ confidence in this commitment through surveys, usage data or other clearly stated means.

Based on publicly available information, there is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. The company indicates that these channels are sufficiently varied to allow the employee to raise concerns across the management chain and to external parties through an independently-operated hotline. These channels allow for confidential and, wherever possible, anonymous reporting. There is evidence that these channels are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners, and in multiple languages.

Based on publicly available information, there is evidence that the company provides training to all employees that outlines the principles of its anti-bribery and corruption policy, including the whistleblowing options available. The company states that it provides training in all appropriate languages and that employees are required to take an anti-corruption refresher course annually.

Based on publicly available information, there is evidence that the company provides tailored anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk. The company indicates that it provides tailored training to employees in high-risk positions, as well as senior business leaders which can be understood to include middle management.

However, the company receives a score of ‘1’ because there is no publicly available evidence that board members receive tailored anti-corruption training. It is also unclear whether tailored training for employees in high-risk positions is updated on at least an annual basis.

Based on publicly available information, there is evidence the company reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme annually. There is evidence that the company has a system to do this, using data from compliance-related reviews. It is clear that the results of such reviews are used to update specific parts of the company's anti-bribery and corruption communications and training programme.

There is no publicly available evidence that the company’s incentive schemes employees incorporate ethical or anti-bribery and corruption principles.

Based on publicly available information, there is evidence that the company will support employees who refuse to act unethically, even when it might result in a loss in business.

However, the company receives a score of ‘1’ because there is no evidence that it assures itself of its employees’ confidence in this statement through anonymised surveys or other clearly stated means.

Based on publicly available information, there is evidence the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is evidence that this policy applies to all employees across the organisation, including business partners.

However, the company receives a score of ‘1’ because there is no evidence that it assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

Based on publicly available information, there is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on its anti-bribery and corruption programme. The company indicates that channels are sufficiently varied to allow employees to raise concerns across the management chain, as well as through an external channel operated by an independent third party. These channels allow for confidential and, wherever possible, anonymous reporting.

In addition, there is evidence that these are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, and in all relevant languages.

There is no evidence that the company provides anti-bribery and corruption training to all employees.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

The company states that employees and third parties reporting incidents via its hotline reporting service will not be subject to retaliation or sanction.

However, the company receives a score of ‘1’ as there is no evidence that it assures itself of employees’ confidence in this commitment through surveys, usage data or other means.

There is evidence that the company operates whistleblowing channels which allow for anonymous and confidential reporting. There is also evidence that these reporting channels – including a phone line, email address, postal address and the ethics hotline – are available to all third parties, which is understood to include joint ventures and subsidiaries.

However, the company receives a score of ‘1’, as it is unclear based on publicly available information whether any of the options are operated by independent third parties, and there is no evidence that these reporting channels can be used by employees to obtain advice on the ethics and anti-corruption policies or issues.

There is evidence that the company provides a training module that outlines the basic principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees.

However, the company receives a score of ‘1’ because it is unclear how frequently employees must undertake refresher training and whether this is at least every two years. The company also does not expressly state in publcly available information that all employees across its operations and countries of operation must complete training, and that it is available in all relevant languages.

There is some evidence indicating that the company provides tailored anti-bribery and corruption training to employees identified as filling high risk positions, as well as executives and board members.

However, there is no evidence that training is provided for middle management or that the training for these groups is refreshed annually.

There is insufficient evidence that the company measures and reviews the effectiveness of its anti-bribery and corruption and communications training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company makes a public commitment to support and protect those who refuse to act unethically in situations which result in lost business for the company.

There is evidence that the company operates whistleblowing and incident reporting channels, which are open to all employees, as well as third parties, contractors and joint venture partners. There is evidence that these channels allow for confidential reporting.

However, evidence indicates that the company only offers internally operated channels that do not allow for anonymous reporting. It is also unclear if the company also operates advice channels. There is no evidence that the company’s reporting channels are available in all countries of operation and in multiple languages.

There is evidence that the company operates whistleblowing and incident reporting channels, which are open to all employees, as well as third parties, contractors and joint venture partners. These channels allow for confidential reporting.

However, evidence indicates that the company only offers internally operated channels that do not allow for anonymous reporting. It is also unclear if the company also operates advice channels. There is no evidence that the company’s reporting channels are available in all countries of operation and in multiple languages.

Based on publicly available information, there is evidence that the company provides training on its anti-bribery and corruption policies. There is evidence that this training includes information on the company’s whistleblowing channels and that it applies to all employees.

However, the company receives a score of ‘1’ because it is not clear how frequently employees must undertake anti-corruption training; it is not clear that all employees must refresh their training in this area every three years. It is also not clear from publicly available information that the company provides anti-corruption training to those in all countries of operation and in all relevant languages.

There is no publicly available evidence that the company provides tailored anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk. The company indicates that managers and executives must certify their adherence to the Code of Business Conduct on an annual basis, but it is not clear from publicly available information that these categories of employees receive any additional or tailored anti-corruption training.

There is no publicly available evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption communications or training programme.

There is no publicly available evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles.

There is no publicly available evidence that the company commits to support employees who refuse to act unethically.

Based on publicly available information, there is evidence that the company promotes a clear policy of non-retaliation against any employee who reports bribery and corruption incidents.

However, the company receives a score of ‘1’ because there is no clear evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means. In addition, it is not clear that the policy of non-retaliation applies to all third parties, suppliers and joint venture partners engaged by the company who may use its reporting channels.

There is evidence that the company provides multiple channels for employees to report instances of suspected corruption and seek advice on its anti-bribery and corruption programme. These channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an external channel operated by an independent third party. There is evidence that these channels allow for confidential and, wherever possible, anonymous reporting.

In addition, the company indicates that its reporting channels are available to employees across all operations and jurisdictions, as well as to all suppliers and third parties, and that the company’s whistleblowing service is available in all relevant languages.

There is evidence that the company provides a training module that outlines the basic principles of its anti-bribery and corruption policy, including the company’s whistleblowing and reporting options. This training is mandatory for all employees and must be completed annually. The company also states that training is provided in all appropriate languages.

Evidence suggests that the company tailors its anti-bribery and corruption training programme to the different levels of risk facing employees in different roles, with specific reference to the categories of employee referred to in the question. There is evidence that employees working in high risk positions, including those in sales and government relations are required to refresh their training in this area on at least an annual basis.

The company states that it regularly reviews and measures the effectiveness of its anti-corruption training and communications programme, in line with any regulatory changes, industry best practice and any identified trends. The company states that it also employs external parties to assess its training programme.

However, there is no evidence that the company uses KPIs, scenario tests or employee surveys or other clearly stated means to measure the effectiveness of its training. It is also unclear whether reviews are used to modify specific parts of the training programme or how frequently the company reviews its training programme.

There is evidence that the company’s incentive schemes incorporate ethical and anti-bribery and corruption principles. According to publicly available information, with the exception of certain hourly employees, all employees have Annual Performance Agreements which have a compliance element included as a component of their financial remuneration. This agreement involves an evaluation of whether or not employees’ actions are in line with company values. The company also states that it accounts for incentives as a corruption risk for those in high risk positions such as sales by not including incentives linked directly to sales generated.

There is evidence that any employee who refuses to act unethically, in keeping with the company’s ethical and anti-bribery and corruption values and policy, will be protected and supported even where such actions result in a loss of business or another disadvantage to the company. The company states that it assures itself of its employees' confidence in this commitment through surveys on the company’s whistleblowing and reporting channels.

There is evidence that any employee who refuses to act unethically, in keeping with the company’s ethical and anti-bribery and corruption values and policy, will be protected and supported even where such actions result in a loss of business or another disadvantage to the company. The company states that it assures itself of its employees' confidence in this commitment through surveys on the company’s whistleblowing and reporting channels.

The company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. These channels, which include an externally operated hotline, are sufficiently varied to allow employees to raise concerns across the management chain and to relevant external bodies. These channels allow for confidential and anonymous reporting, and are available in multiple languages. The company states that all its reporting and whistleblowing options are available to all third parties, including suppliers and joint venture partners.

Based on publicly available information, there is evidence that the company provides training for its employees that outlines the basic principles of its anti-bribery and corruption policy.

However, the company receives a score of ‘1’ because there is no clear evidence that the training is provided to all employees across all divisions, all countries of operation or in all appropriate languages. There is also no clear indication that the training includes an outline of the whistleblowing options available to employees.

Based on publicly available information, there is some evidence that the company provides tailored training to employees based on their roles and exposure to corruption risks. The company indicates that it provides tailored training to senior executives and line managers, as well as to participants overseas.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it provides tailored training for employees in high risk positions, nor that employees in such positions must refresh their training on an annual basis.

There is some evidence that the company measures and reviews the effectiveness of its anti-bribery and corruption training and communications programme. The company publishes data on the number of personnel who received compliance training on an annual basis, and indicates that it conducts internal surveys to assess the quality of its internal initiatives in areas such as compliance.

However, the company receives a score of ‘1’ because it does not publish further information on the way in which it measures effectiveness of its anti-corruption initiatives specifically, for example through regular dedicated staff surveys or specific audits.

Based on publicly available information, there is some evidence that the company’s incentive schemes for employees incorporate ethical and anti-corruption principles. The company indicates that its performance evaluations for employees include integrity and trust as a category and that this is a factor in personnel development.

However, the company receives a score of ‘1’ because there is no further publicly available information on how its approach to employee incentives is designed to promote ethical behaviour while discouraging corrupt practices. There is no evidence that the company’s approach considers different risks relating to high risk employees.

Based on publicly available information, there is no clear evidence that the company commits to support or protect employees who refuse to act unethically.

Based on publicly available information, there is evidence that the company has a policy of non-retaliation against whistleblowers and those who report bribery and corruption concerns. This statement appears in the company’s Code of Conduct which applies to all employees across the organisation.

However, the company receives a score of ‘1’ because there is no clear evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means. It is also not clear whether this policy applies to those employed by the group as third parties, suppliers and joint venture partners.

Based on publicly available information, there is evidence that the company has multiple whistleblowing and advice channels. There is evidence that these channels are sufficiently varied to allow employees to raise concerns across the management chain and externally, through an independently operated hotline. The company also indicates that its channels allow for confidential and anonymous reporting.

However, the company receives a score of ‘1’ because there is no clear evidence that these channels are available to all employees in any country of operation, in multiple languages, or to the employees of third parties, suppliers or joint venture partners. The company indicates that its hotline may only extend to certain countries of operation.

There is evidence that the company provides training for its employees that outlines the basic principles of the anti-bribery and corruption policy, including the whistleblowing options available. The company indicates that this training is provided on an annual basis to employees in certain positions or departments.

However, there is no clear publicly available evidence that the company provides training to all employees across all divisions, all countries of operation and in all appropriate languages on a regular basis.

There is evidence that the company provides specific compliance and anti-corruption training to employees in certain positions depending on their role and department. The company indicates that it provides such training to employees in high-risk positions, such as in the marketing division, as well as to middle management and to senior officers in certain departments.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that employees in high risk positions must undertake and refresh their compliance training on an annual basis.

Based on publicly available information, there is no evidence that the company reviews the effectiveness of its anti-bribery and corruption communications and training programme. The company indicates that the Compliance Officer is responsible for conducting checks on the programme to ensure proper implementation, but it is not clear that this includes measures of effectiveness or that the results of such checks are directly used to update specific parts of the company’s anti-corruption training and communications programme.

There is no publicly available evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles.

There is no publicly available evidence that the company commits to support employees who refuse to act unethically.

Based on publicly available information, there is evidence the company has a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. This policy applies to all employees and there is evidence to indicate that it extends to those employed by the group as third parties.

However, the company receives a score of ‘1’ because there is no evidence that it assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

Based on publicly available information, there is evidence the company provides an internal whistleblowing line for its employees to report incidents or allegations of bribery and corruption. The company indicates that its channel allows for confidential reporting. There is evidence that the whistleblowing line is open and accessible to business partners of the company.

However, it is not clear from publicly available information that the company provides employees with an external reporting channel operated by an independent third party, nor is it clear that the internal channel may be used to seek advice on the anti-corruption programme. In addition, it is not clear whether the company’s whistleblowing line is available to all employees in any country of operation or in multiple relevant languages.

There is no publicly available evidence to indicate that the company provides anti-bribery and corruption training to all employees.

There is no publicly available evidence to indicate that the company provides anti-bribery and corruption training to all employees.

There is no publicly available evidence to indicate that the company measures or reviews the efficacy of an anti-bribery and corruption communications or training programme.

Based on publicly available information, there is no evidence that the company´s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no publicly available evidence to indicate that the company commits to support or protect employees who refuse to act unethically, even when it might result in a loss of business.

There is no evidence the company has a publicly available policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

On its website the company publishes a statement indicating that the Central Vigilance Commission, a government agency, is responsible for investigating allegations of corruption at state-owned companies. There is evidence indicating the agency acts as an external whistleblowing channel for employees and third parties.

However, the company scores ‘1’ as there is no evidence that it offers internally operated or explicitly anonymous channels, nor that it offers an external channel operated by an independent third party.

Based on publicly available information, there is evidence that the company provides training for employees that that outlines the basic principles of its anti-bribery and corruption policy. There is some indication that this also includes the whistleblowing options available to employees, as part of the Code of Ethics. There is evidence to suggest that trainings are provided to all employees across all divisions and all countries of operation. Although the company does not explicitly state that employees must undertake and refresh their training regularly, there is publicly available evidence to suggest that the company provides training to the majority of its staff on an annual basis.

There is evidence that the company provides tailored anti-corruption training for employees based on their role and exposure to corruption risk. The company indicates that it provides tailored training to board members and those in management positions, as well as stating that employees in technical positions and those working in the defence and security market receive specific training on the rules of conduct related to that field.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that employees in high risk positions must refresh their training on at least an annual basis. The company indicates that it will provide training in the next year but it is not clear whether this applies to the same employees or new employees receiving the training for the first time.

Based on publicly available information, there is evidence to indicate that the company reviews its compliance communications and personnel training programme. The company clearly measures and publishes information on its training completion rates and whistle-blower reports received. In addition, there is evidence that the company conducted a review of its compliance programme in 2019 which resulted in updates to its training procedures.

However, the company receives a score of ‘1’ because it does not publish further details on how it measures and reviews the effectiveness of its communications or training beyond tracking completion rates. Although the company indicates that it reviewed these processes in 2019, there is no clear evidence that the company conducts a full review of its anti-corruption training and communications programme on a regular basis, at least every three years.

There is no clear evidence that the company incentive schemes for employees incorporate ethical or anti-corruption principles.

For some employees, the company indicates that it has a variable remuneration system which is proportionate and based on their contribution towards the objectives of the company. For executive directors, the company indicates that it has procedures in place to recover any variable compensation that may have been improper or miscalculated. However, there is no evidence that the company’s approach to incentives for all employees incorporates ethical principles, by incentivising employees based on ‘how’ they achieve their goals through tool such as performance appraisals.

Based on publicly available information, there is no evidence that the company publishes a clear commitment to support or protect employees who refuse to act unethically.

There is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption concerns. There is evidence that this applies to all employees across the organisation. In addition, there is evidence to indicate that the company’s whistleblowing channel is open to third parties and business partners, so this commitment is understood to extend to the employees of these entities.

However, there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

Based on publicly available information, there is evidence that the company provides a whistleblowing channel for its employees that allows for confidential and, where possible, anonymous reporting. The company indicates that these channels are accessible in all relevant countries of operation and available to those employed by its business partners, including suppliers.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it provides an external reporting channel operated by an independent third party. It is also not clear that the company’s channels may be used to ask questions and seek advice on the anti-corruption programme, in addition to reporting allegations or incidents.

There is evidence that the company provides a training module that outlines the basic principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees. The company provides this training to all employees across all divisions of operation. All employees are required to refresh the training every two years.

However, the company does not state that it provides training in all appropriate languages or in all countries of operation.

There is evidence that the company provides tailored anti-bribery and corruption training to employees in different roles based on their exposure to corruption risk, including employees in middle management and high risk positions. These employees are required to refresh their training on an annual basis.

However, the company does not make reference to tailored training for board members.

There is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme.

However, the measures appear to be limited to tracking the number of personnel trained and completion rates on an annual basis. Based on publicly available information, there is no evidence that the results are used to update specific parts of the company’s anti-bribery and corruption communications training programme.

Based on publicly available information, there is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

Based on publicly available information, there is no clear evidence that the company commits to support or protect employees who refuse to act unethically, even when it might result in a loss of business.

The company promotes a policy of non-retaliation against whistleblowers and employees who report bribery and corruption incidents. The company operates a public complaints line, which it can be inferred is open to individuals employed by the groups as third parties, suppliers and joint venture partners.

However, based on publicly available information, there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

Based on publicly available evidence, the company has some whistleblowing and advice channels for employees to report instances of suspected corrupt activity and obtain advice on compliance matters. The company also operates a public complaints line, which it can be inferred is open to individuals employed by the groups as third parties, suppliers and joint venture partners. The company also states that, as a state owned body, reports can be submitted in various languages to a state-level agency with the remit to investigate corruption at state owned enterprises. The company states that whistleblowing reports may be submitted anonymously.

However, the company does not explicitly refer to confidential channels and the company only offers internally operated channels. There is also no evidence that company’s reporting channels are available in all relevant languages.

There is no publicly available evidence that the company provides anti-bribery and corruption training to its employees.

There is no evidence that the company provides tailored anti-bribery and corruption training for its employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company publicly commits to support or protect employees who refuse to act unethically.

There is no evidence that the company has a publicly stated policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is no publicly available evidence that the company provides either whistleblowing or advice channels for its employees.

Based on publicly available information, there is evidence that the company provides training to its employees that outlines the principles of its anti-bribery and corruption policy. The company indicates that this training applies to any employees involved in overseas business, and states that the training is provided in Japan on an annual basis.

The company receives a score of ‘1’ because it is not clear that anti-bribery and corruption training is provided to all employees across all divisions, countries and regions of operation or in all appropriate languages. The company indicates that one of its divisions in the United States provided training for all its employees, however there is no evidence that this applies group-wide to all employees in all divisions.

There is some evidence that the company provides anti-bribery and corruption training specifically for employees involved in overseas business. However, the company receives a score of ‘0’ because it is not clear whether this training is based on an assessment of their role or exposure to corruption risk, nor is it clear that other employees in middle management or on the board receive tailored anti-bribery and corruption training.

Based on publicly available information, there is evidence that the company measures and reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme. The company indicates that it conducts awareness surveys to measure understanding of compliance initiatives among both its employees and its executives. There is also evidence that the results of these surveys are used to update specific parts of the company’s initiatives.

However, the company receives a score of ‘1’ because there is evidence to indicate that such surveys are conducted every 3-4 years instead of on an annual basis. There is no evidence that, in addition to regular survey-related updates to the programme, the company also conducts a full review of its initiatives every three years.

There is no publicly available evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles. The company provides some information on its compensation system for directors and supervisory board members, but there is no evidence that this includes measures to promote ethical behaviour and discourage corrupt practices.

Based on publicly available information, there is no clear evidence that the company commits to support or protect employees who refuse to act unethically. The company indicates that all reports will be taken seriously and acted upon, but does not encourage employees to speak up even when such actions might result in a loss of business or other advantage.

There is evidence that the company promotes a policy of non-retaliation against whistleblowers, which applies to all employees across the organisation, including those employed by the company as third parties.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

Based on publicly available information, there is evidence that the company provides whistleblowing and advice channels for its employees to raise concerns. The company indicates that employees can report concerns confidentially, and there is some indication that its whistleblowing channels are open to third parties and temporary staff. There is also some evidence that the company provides an external reporting system in the form of an independent lawyer, to whom employees may anonymously report violations of the compliance programme.

However, the company receives a score of ‘1’ because it is not clear that these channels are available to all employees in all countries of operation and in all relevant languages. The company also does not clearly indicate that its channels allow for anonymous reporting, nor is it clear that the channels are available to suppliers or joint venture partners.

There is evidence that the company provides training on its Code of Business Conduct, which includes the anti-bribery and corruption programme. The company states that this training is provided in all relevant languages and locations. There is evidence that all employees are required to undertake this training on an annual basis.

Based on publicly available information, there is evidence that the company provides specific anti-bribery and corruption training to certain employees based on their roles and exposure to corruption risk. The company indicates that board members must complete annual ethics training and states that employees in critical or high risk or with significant authority must certify their ethics and compliance understanding on an annual basis. As part of its definition of high risk roles, there is evidence that the company identifies employees in government relations, accounting, finance and internal audit, business development, sales and those dealing with high-risk intermediaries.

There is some evidence that the company measures and reviews the effectiveness of its anti-bribery and corruption communications and training programme. There is evidence that the Director of Business Conduct is responsible for this process, which includes reviewing survey questions and responses. The company indicates that the results of such reviews are used to update specific parts of its anti-bribery and corruption programme. There is evidence that such reviews are conducted on an continuous basis with a full assessment questionnaire on an annual basis.

There is evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles. The company publishes a statement to indicate that it considers ethical conduct and compliance with the Code of Business Conduct as factors in annual performance reviews, which determine employee incentive compensation.

However, the company receives a score of ‘1’ because it does not provide further publicly available information on the way in which it structures its incentives, for example by indicating that financial rewards must be proportionate to the employee’s salary for those in high risk departments or roles.

Based on publicly available information, there is evidence that the company commits to support and protect employees who refuse to act unethically, even where such actions may result in a loss of business or other disadvantage.

However, the company receives a score of ‘1’ because there is no publicly available evidence that the company assures itself of its employees' confidence in this commitment through anonymised surveys or other clearly stated means on a regular basis.

There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. The company indicates that its policy applies to all employees across the organisation, including those employed by the group as third parties. In addition, there is evidence that the Director of Business Conduct conducts periodic reviews of the company’s systems to ensure employees understand and have confidence in its non-retaliation commitment.

There is evidence that the company provides multiple channels for its employees to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. The company indicates that these channels are sufficiently varied to allow employees to raise concerns across the management chain and externally through a reporting channel operated by an independent third party. The company states that the channels allow for confidential and, wherever possible, anonymous reporting.

In addition, there is evidence that these channels are accessible to all employees in all jurisdictions where the company operates and are available in multiple languages. Since it is possible for anyone to make a report via the Ethics Point website, it is understood that the channels are available to third parties, suppliers and joint venture partners.

There is no evidence that the company provides anti-bribery and corruption training to all employees.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of an anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

The company does not have a publicly available policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is no evidence that the company has either whistleblowing or advice channels.

Based on publicly available information, there is evidence that the company provides a training module that outlines the basic principles of its anti-bribery and corruption policy. The company indicates that this training is provided on an annual basis.

However, there is no evidence that the training is systematically provided to all employees across all divisions, all country regions of operation or in all appropriate languages or that the training includes whistleblowing options available to employees.

Based on publicly available information, there is some evidence that the company tailors its compliance training to certain employees. However, the company does not make specific reference to all three categories of employee referred to in the question and there is no evidence that the training is refreshed at least on an annual basis.

There is no evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles. The company publishes some information about its remuneration system, but there is no evidence that anti-bribery and corruption considerations factor into this, nor that it applies to all employees across the organisation.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

Based on publicly available information, there is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is clear evidence that this policy applies to all employees across the organisation.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means. It is also not clear that the policy applies to third parties, suppliers and joint venture partners.

Based on publicly available information, there is evidence the company has whistleblowing and advice channels that are available to all employees in all countries of operations and in all appropriate languages. There is evidence that the company provides both internally- and externally-operated channels.

However, it is not clear that the channels are not available to employees of third parties, suppliers or joint venture partners. Furthermore, these channels are not explicitly stated to be anonymous or confidential.

Based on publicly available information, the company provides a training module that outlines the principles of its anti-bribery and corruption policy that includes the whistleblowing options available to employees. There is evidence that employees receive basic online training on the Code of Ethics, as well as classroom training for all new employees and new line managers. There is evidence that training is provided to all employees in all divisions and geographies, and in all appropriate languages. There is evidence that employees are required to refresh their training at least every three years.

Based on publicly available information, there is evidence that employees in certain positions receive specialised or tailored anti-bribery and corruption training. The company states that risk-exposed personnel, managers and market representatives, and board members receive specific training. In addition, the company states that the annual training plan is risk- based, and updated to include new laws and requirements. There is evidence that high-risk positions are required to undertake refresher training on an annual basis.

There is publicly available evidence that the company takes steps to assure itself of the effectiveness of its anti-bribery and corruption communications and training programme. Information suggests that the company assures itself of this annually, and that the results of its reviews are used to update specific parts of the company’s anti-bribery and corruption communications and training programme.

There is no publicly available evidence to indicate that the company’s incentive schemes incorporate ethical or anti-corruption principles.

There is evidence that the company commits to support or protect employees who refuse to act unethically.

However, there is no evidence that the company assures itself of its employees’ confidence in this statement through anonymised surveys or other clearly stated means.

There is evidence that the company has a clear policy of non-retaliation against both whistleblowers and employees who report concerns.

However, the company receives a score of ‘1’ as it does not explicitly commit to assure itself of its employees’ confidence in this commitment through surveys or other clearly stated means.

There is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company’s anti-bribery and corruption programme, including through a dedicated whistleblowing channel. These channels allow for anonymous and confidential reporting, and are sufficiently varied to allow employees to raise concerns across the management team. There is also evidence that the channels are available and accessible to employees in multiple jurisdictions, in all relevant languages (Norwegian and English), including those employed by the group as suppliers or other external parties.

Based on publicly available information, there is evidence that the company provides an annual training module that outlines the basic principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees. There is evidence that the training is provided to all employees in all relevant divisions and jurisdictions.

Based on publicly available information, there is evidence that the company tailors its anti-bribery and corruption training programme to the different levels of risk facing employees in different roles, with specific reference to the categories of employees referred to in the question. There is evidence that employees working in high risk positions are required to refresh their training on at least an annual basis.

Based on publicly available information, there is evidence that the company reviews its anti-bribery and corruption communications and personnel training programme through staff surveys. There is also evidence indicating that the company conducts reviews on an annual basis and that the results are used to update the company's anti-bribery and corruption programme.

There is some evidence that the company’s incentive schemes for employees incorporate ethical principles. The company indicates that it incentivises its employees to comply with its ethics programme and report violations of its ethics policies.

However, in publicly available evidence, the company provides limited details on how it rewards this behavior or structures its incentives. It is also unclear whether the company uses financial rewards in high risk departments to incentivise sales and, if so, whether these rewards must be proportionate to the employee’s salary.

The company makes a public commitment to protecting whistleblowers even when it might result in a loss of business. However, there is no evidence that the company assures itself of its employees’ confidence in this statement through anonymised surveys or other clearly stated means.

Based on publicly available information, there is evidence that the company has a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is evidence indicating that this commitment extends to business partners of the company.

However, there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data or other clearly stated means.

Based on publicly available information, there is evidence that the company has whistleblowing and advice channels, including anonymous and confidential channels. The channels are available to all employees and there is evidence indicating that they are also open to business partners of the company.

There is no publicly available evidence that the company provides anti-bribery and corruption training to all of its employees.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no publicly available evidence that the company commits to support or protect employees who refuse to act unethically, even when this might result in a loss of business.

There is evidence the company has a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, which applies to all employees across the organisation. There is also evidence the company’s whistleblowing channels are open to third parties engaged by the group.

However, the company scores ‘1’ as there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company has multiple whistleblowing and advice channels, which are open to all employees. There is also evidence the company’s whistleblowing channels are open to third parties. There is some evidence that whistleblowing complaints may be handled confidentially.

However, the company scores ‘1’ as the evidence suggests the company only offers internally operated channels and does not explicitly offer anonymous channels. There is also no publicly available evidence that the channels are available in all relevant languages.

There is evidence that all employees must complete anti-corruption focused training and that this training programme covers the company’s Code of Conduct, which includes the whistleblowing options available to employees. The company states that all employees complete training on joining the company and periodically thereafter.

However, the company receives a score of ‘1’ because it is not clear from publicly available evidence that anti-corruption training for employees is provided across all of its operations and geographies, and in all relevant languages.

There is some evidence the company provides targeted anti-corruption training to certain employees based on an their specific role and exposure to corruption risk.

However, the company receives a score of ‘1’ because it does not provide further publicly available information to indicate that this includes all three categories of employee as identified in (a), (b) and (c) in the question. In addition, thile the company states that this training is provided periodically, there is no evidence that employees in high risk positions specifically must refresh their anti-corruption training on at least an annual basis.

There is evidence that the company’s anti-corruption communications and training programme is subject to regular review and that, along with all elements of the anti-corruption programme, it is updated when gaps or possible improvements are identified. The company indicates that it monitors these processes on an ongoing basis, with a full review at least every two years.

The company receives a score of ‘1’ because it does not provide further publicly available evidence of how it measures the effectiveness of its anti-corruption communications and personnel training programme, for example by conducting staff surveys or other awareness activities.

There is no publicly available evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles.

There is evidence that the company commits to support and protect employees to speak up and “do the right thing”, and never compromise its values in order to achieve business objectives. This commitment appears in the form of a clear statement from the Chairman and CEO, and its commitment to ethical business conduct is reiterated throughout its anti-corruption materials.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it assures itself of its employees’ confidence in this commitment through anonymised surveys or other clearly stated means.

There is evidence the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, as outlined in the company’s Code of Conduct. There is evidence that this commitment extends to all third parties, which are also able to access the company’s whistleblowing line. There is evidence that company assures itself of employees’ confidence in this commitment by monitoring usage statistics from its reporting line. It is noted that the company does not publish high-level usage data on its reporting line.

There is evidence that the company provides both whistleblowing and advice channels for its employees to report concerns and seek advice on its anti-bribery and corruption programme. The company states that reports and questions may be submitted confidentially and anonymously. There is evidence that its channels are sufficiently varied to allow employees to raise concerns across the management chain and to an external body through an independently-operated ethics hotline.

In addition, the company indicates that its channels are available to all employees and external parties, such as suppliers, joint venture partners and other third parties, as well as in multiple languages and in all relevant geographies across its operations.

There is evidence that the company provides training that outlines the principles of the Code of Conduct and anti-corruption policy, including the whistleblowing options available to employees. The company states that employees are required to undertake refresher anti-corruption training every year.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is evidence that the company reviews its anti-corruption training programme on an annual basis, and that it uses the results of such reviews to update the programme where necessary. The company indicates that it measures training completion rates.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it has further procedures in place to measure and review the effectiveness of its anti-corruption training and communications programme specifically, for example by conducting staff surveys or targeted audits of these aspects of its programme at least every three years.

There is no publicly available evidence that the company’s incentive schemes for employees incorporate ethical or anti-corruption principles to promote behaviour in line with the company’s values. The company provides some publicly available information on its compensation structures for incentives, which includes a portion of an annual incentive based on adherence to the company’s ethics principles; however it is not clear from publicly available information that the company adopts a similar approach to incentives for all employees.

There is no evidence that the company publicly commits to support and protect employees who refuse to act unethically in situations which result in a loss of business for the company.

There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is evidence that this non-retaliation policy extends to all employees, including those engaged by the group as third parties, suppliers and joint venture partners.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that it commits to assure itself of employees’ confidence in its non-retaliation commitment through surveys or other clearly stated means. This could include monitoring the usage statistics of whistleblowing channels across different parts of the organisation or conducting independent anonymised employee surveys.

There is evidence that the company provides multiple channels for its employees to report instances of suspected corrupt activity and seek advice on its anti-bribery and corruption programme. The company indicates that these channels are sufficiently varied to allow the employee to raise concerns across the management chain and to a third party operated whistleblowing service. These channels are available in relevant foreign languages and additionally allow for confidential and, wherever possible, anonymous reporting.

In addition, there is evidence that the company’s reporting channels are available to all employees in all jurisdictions where the company operates, and there is nothing to suggest that the reporting channels are not available for third parties and joint ventures. There is clear evidence that the company’s reporting channels are available to suppliers.

Based on publicly available information, there is evidence that the company provides training that outlines the principles of its anti-bribery and corruption policy, including the whistleblowing options available to employees. The company provides this training to all employees across all divisions and countries of operation and in all appropriate languages. The company states that employees are required to undertake training on the anti-bribery and corruption programme at least every three years.

Based on publicly available information, there is evidence that employees in certain positions receive different anti-bribery and corruption training. The company makes specific reference to all three categories of employees. The company indicates that training frequency is based on a differentiation of risk, and that training is refreshed on either a one-year or three-year basis depending on the risk exposure of the employee.

Based on publicly available information, there is evidence that the company reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme. There is evidence that the company has a system to do this through an anonymized employee survey conducted annually. It is clear that the results of these reviews are then used to update specific parts of the company's anti-bribery and corruption communications and training programme, with a review of the programme taking place at least every three years.

Based on publicly available information, there is evidence indicating that the company’s incentive schemes are designed in such a way that they simultaneously promote ethical behaviour and discourage corrupt practices. The company incentivises ethical conduct through its performance and development management and leadership frameworks. There is evidence that financial rewards included in the company’s incentive schemes must be proportionate to salaries for all employees. There is evidence indicating that the policy applies to employees in sales roles.

Based on publicly available information, the company clearly states that any employee who refuses to act unethically, in keeping with the company’s ethical and anti-bribery and corruption values and policy, will be protected and supported even where such actions result in a loss of business or another disadvantage to the company. There is evidence that the company assures itself of its employees' confidence in this commitment through annual anonymised surveys.

Based on publicly available information, there is evidence that the company promotes a policy of non-retaliation against all whistleblowers and employees who report bribery and corruption incidents, including those employed by the group as third parties. The company commits to assure itself of its employees’ confidence in this commitment through annual anonymised surveys.

Based on publicly available information, the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and to a relevant external body. These channels allow for confidential and anonymous reporting. They are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners, and in all relevant languages.

There is evidence that the company provides a training module that outlines the basic principles of the anti-corruption policy. The company indicates that this training is provided to all employees across all divisions, all countries and regions of operation, and in all relevant languages on an annual basis.

However, the company receives a score of ‘1’ because there is no publicly available evidence that the training includes the whistleblowing options available to employees.

There is evidence that the company tailors its anti-corruption training programme to the different levels of risk facing employees in different roles, with specific reference to all categories of employee referred to in the question. There is evidence that employees working in high risk positions are required to refresh their training in this area on at least an annual basis.

There is some evidence that the company reviews its anti-corruption communications and personnel training programme.

However, the company receives a score of ‘1’ because it is not clear if the company reviews the effectiveness of the programme on at least an annual basis, or whether the results are used to update specific parts of the company's anti-corruption communications and training programme.

There is some evidence in the company’s Code of Ethics that it applies fair measures to evaluate the abilities and performances of its employees and rewards them accordingly. However, the company does not provide further details on its approach to indicate that incentives for employees incorporate ethical principles.

There is evidence that the company commits to protect and support employees who refuse to act unethically. However, it is not clear from publicly available information that this statement extends to situations where such actions result in a loss to the company and there is no evidence that the company assures itself of employees’ confidence in this statement through anonymised surveys or other clearly stated means.

There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents that explicitly applies to all employees across the organisation, including those employed by the group as third parties and suppliers.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data or other clearly stated means.

There is evidence that the company has whistleblowing and advice channels, and that whistleblowing channels are anonymous and confidential. The channels are explicitly available to all employees in any country of operation and to any employees of third parties, suppliers and joint ventures.

However, the company receives a score of ‘1’ because it only offers internally operated channels and it is not explicitly state that the channels are available in multiple languages.

There is evidence that the company provides training on its anti-bribery and corruption policy, which forms part of its broader Ethics Awareness and Business Conduct Compliance Training. It is clear that this covers the whistleblowing options available to employees. The company provides this training to all employees across all divisions and countries of operation, and in all appropriate languages. Employees are required to undertake and refresh this training on an annual basis.

There is evidence that employees in certain positions receive additional, tailored anti-bribery and corruption training on an annual basis. The company states that these positions include middle management and employees in high-risk positions, for example based on geographical location. There is also evidence that board members and the executive leadership team are required to undertake tailored annual ethics training.

There is evidence that the company reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme. The company states that it does this by conducting staff surveys and audits of the programme, collecting data on training completion rates and the number of inquiries received, and discussions with subject matter experts. The company conducts these reviews on an annual basis and it is clear that the results of such reviews are used to update specific parts of the company’s anti-bribery and corruption communications and training programme.

There is evidence that the company’s incentive schemes incorporate ethical and anti-bribery and corruption principles. Adherence with the company’s ethical principles is included in annual performance assessments for all employees, which, in turn, are a factor in determining employee compensation.

However, the company does not indicate that incentives must be proportionate to the employee’s salary in the case of high risk employees, such as sales roles.

The company clearly states that any employee who refuses to act unethically will be protected and supported even where such actions result in a loss of business or another disadvantage to the company. There is evidence that the company assures itself of its employees' confidence in this commitment through confidential surveys.

The company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is evidence that this policy applies to all employees and third parties with whom the company does business. The company assures itself of its employees’ confidence in this commitment through surveys.

The company has multiple internal advice channels and a whistleblowing line to seek advice on the company's anti-bribery and corruption programme and report instances of suspected corrupt activity. These channels are available to all employees in all countries of operation, as well as to third parties with whom the company does business. All the channels allow for confidential and anonymous reporting. The company also makes information available to its employees concerning an external hotline operated by the US Department of Defence.

There is no publicly available evidence that the company provides anti-bribery and corruption training to its employees.

There is no publicly available evidence that the company provides anti-bribery and corruption training to its employees, nor that it tailors its anti-bribery and corruption training to certain employees based on an assessment of their role and exposure to corruption risk.

There is no publicly available evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption communications or training programme.

There is no publicly available evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles. The company provides some information on its executive compensation programme, but there is no evidence that it provides information on its incentive structures for employees.

There is no publicly available evidence that the company commits to support or protect employees who refuse to act unethically.

There is evidence the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. The company’s policy explicitly applies to all employees across the organisation. There is also evidence that the company’s whistleblowing line is open to third parties, including those employed by suppliers.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company provides multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. The company indicates that these channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an external party through an independently-operated channel. These channels allow for confidential and anonymous reporting and are accessible to all employees in all jurisdictions where the company operates. In addition, there is also evidence to indicate that the company’s whistleblowing line is open to third parties including suppliers and available in relevant languages.

There is evidence that the Lincoln Laboratory provides training on the Code of Conduct to all of its new employees. However, there is no evidence that the Code of Conduct includes anti-bribery and corruption principles.

There is no evidence that the institute tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the institute measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the institute’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the institute commits to support or protect employees who refuse to act unethically.

The institute promotes a clear policy of non-retaliation against both whistleblowers and employees. However, the institute’s reporting policy – and therefore also its non-retaliation policy – does not explicitly mention anti-bribery and corruption incidents, allegations or concerns. There is also no evidence to suggest that the institute takes steps to assure itself of its employees’ confidence in this commitment, through surveys or other clearly stated means.

The institute has multiple channels to report instances of suspected corrupt activity. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and an independent third party, through the provision of an externally-operated hotline. These channels allow for confidential and, wherever possible, anonymous reporting which extends to both employees and non-employees. Lincoln Laboratory is active only in the U.S. and therefore the reporting channels are automatically available in the relevant jurisdiction and language.

There is evidence that the company provides training for its employees that outlines the basic principles of its anti-bribery and corruption policy, including the whistleblowing options. The company indicates that this training is provided to all employees.

However, the company receives a score of ‘1’ because it is not clear how frequently this training takes place or whether employees are required to undertake refresher courses at least every three years.

There is some evidence that the company provides tailored anti-bribery and corruption training for employees based on an assessment of their role and exposure to corruption risk. The company states that it ensures that persons in sensitive positions have guidance on how to conduct business responsibly. However, it is unclear whether they are provided with a training programme that is tailored to their role’s risk exposure and which are all the high risk groups identified in (a), (b) and (c) in the question.

There is no publicly available evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is some evidence that the company’s rewards for employees incorporate ethical principles. The company states that employee performance incentives cannot be in place if they are only achievable through unethical behaviour.

However, further information about how the company ensures this in practice is not publicly available. There is no evidence to suggest that incentives are designed to reward behaviour in line with the company’s ethical values, as identified through performance appraisals or conduct in the work place. It is also not clear whether financial incentive schemes are required to be proportionate to employees’ salaries in the case of high risk employees.

There is no publicly available evidence that the company commits to supporting and protecting employees who refuse to act unethically.

There is no evidence that the company has a publicly available policy of non-retaliation against employees who report bribery and corruption incidents. However, there is no clear evidence that this policy extends to those employed by the group as third parties, suppliers and joint venture partners. There is also no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company provides whistleblowing and advice channels for its employees to report concerns or allegations of bribery and corruption. The company states that it will treat all concerns confidentially. In addition, there is evidence that the company’s channels are sufficiently varied to allow employees to raise concerns across the management chain.

However, the company receives a score of ‘1’ because there is no evidence that it offers an external channel for employees to report outside of the organisation, for example one operated by an independent third party. It is also not clear whether reports may be made anonymously. The company indicates that it schannels are available to all employees but it is not explicitly clear that they are available in multiple languages or to the employees of third parties, suppliers and joint venture partners.

There is evidence that the company provides training for its employees that outlines the basic principles of its anti-bribery and corruption policy, including the whistleblowing options available. There is also evidence that it provides this training on an annual basis to all employees across all divisions and countries of operation. In addition, the company indicates that it provides training in multiple languages.

There is some evidence that the company provides tailored anti-corruption training to employees based on their role or exposure to corruption risk. The company states that all board members and directors must undertake anti-corruption training, and indicates that employees working with third parties receive training on preventing corruption.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it provides tailored anti-corruption training to middle management. The company indicates that tailored training is delivered at specific sites, but it is not clear which employees this applies to or whether the selection is based on an assessment of corruption risk. There is also no evidence that employees in high risk positions must refresh their training on an annual basis.

There is evidence that the company reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme. The company indicates that it has a system in place to conduct employee engagement surveys on an annual basis, which include questions on ethics, communications and training. In addition, there is evidence to indicate that the results are used to update specific parts of the company's anti-bribery and corruption initiatives.

Based on publicly available information, there is some evidence that the company’s incentive schemes for employees incorporate ethical principles. The company indicates that annual salary evaluations take into account personal performance and that all employees set annual objectives in line with the company’s values and culture.

However, the company receives a score of ‘1’ because it does not provide further publicly available information on how its incentives are designed or how they reward ethical behavior while discouraging corrupt practices. There is no evidence that the company ensures such rewards are proportionate to base salary, nor is there evidence that it addresses employees in high risk positions or departments.

The company publishes a clear statement that it will support and protect employees who choose to “do the right thing” and indicates that this approach informs all areas of the business. However, the company receives a score of ‘1’ because there is no evidence that it assures itself of its employees’ confidence in this statement through anonymised surveys or other clearly stated means.

There is evidence the company promotes a policy of non-retaliation against whistleblowers and employees who report bribery and corruption incidents. The company indicates that this applies to all employees, and since this commitment appears in global policies it is understood to apply to employees of suppliers and third parties.

However, the company receives a score of ‘1’ because there is no evidence that it assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

Based on publicly available information, there is evidence that the company provides whistleblowing and advice channels for its employees to report instances of suspected corrupt activity and seek advice on its anti-bribery and corruption programme. The company indicates that these channels are sufficiently varied to allow the employee to raise concerns across the management chain, as well as externally to an independent third party. These chanels allow for anonymous and confidential reporting, and they are available to all employees in all relevant countries and in multiple languages. The company indicates that this applies to all employees, and since this commitment appears in global policies it is understood to apply to employees of suppliers and third parties.

There is no evidence that the organisation provides anti-bribery and corruption training to all employees.

There is no evidence that the organisation provides tailored anti-bribery and corruption training to its employees depending on their exposure to potential risks.

There is no evidence that the organisation measures or reviews the effectiveness of its anti-bribery and corruption communications or training programme.

There is no evidence that the organisation’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the organisation commits to support or protect employees who refuse to act unethically.

The organisation does not have a publicly available policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is evidence that the organisation provides whistleblowing and advice channels for use by its employees. The organisation states that these channels allow for anonymous reporting and that concerns may be raised in confidence.

However, the organisation receives a score of ‘0’ because the information provided about these channels is insufficiently clear and there is no publicly available evidence of how employees may access these channels. It is also not clear whether the organisation provides both internally- and externally-operated channels, nor is it clear whether these channels are available to employees of third parties, suppliers and joint venture partners.

There is evidence that the company provides training that outlines the basic principles of the anti-bribery and corruption policy. The company provides this training to all employees across all divisions and countries of operation on an annual basis.

However, the company receives a score of ‘1’ because it is not clear that this training is provided in all appropriate languages or if the training includes the whistleblowing options available to employees.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk. The company’s CSR report indicates that senior managers and directors receive specialised training for their roles, but it is not clear that this includes anti-bribery and corruption principles.

There is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme.

However, the company receives a score of ‘1’ because the measures are limited to the number of personnel trained and completion rates. There is also no evidence that results are used to update specific parts of the company's anti-bribery and corruption – or compliance – communications and training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

There is no clear evidence that the company promotes a policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is evidence that the company has multiple channels to report instances of suspected corrupt activity. The company indicates that these channels are sufficiently varied to allow the employee to raise concerns across the management chain and to channels managed by independent external parties. There is evidence that the company’s channels are available to all employees in all jurisdictions, including those employed by the group as third parties, and that they allow for confidential and, wherever possible, anonymous reporting.

However, the company receives a score of ‘1’ because there is no evidence that employees are encouraged to use the channels to seek advice about the company’s anti-corruption policies, nor that the channels are available in multiple languages.

Based on publicly available information, there is evidence that the company provides training for its employees that outlines the basic principles of its anti-bribery and corruption policy. The company indicates that it provides this training to all employees worldwide.

However, the company receives score ‘1’ because there is no publicly available evidence to indicate that employees must undertake and refresh their training at least every three years, nor is it clear evidence that this training specifically covers the whistleblowing options available.

There is some evidence that the company provides tailored anti-bribery and corruption training to employees based on an assessment of their role. The company indicates that it provides specific training and guidance for employees in technical and skilled jobs.

However, there is no publicly available evidence that the company provides tailored anti-corruption training to employees in middle management positions and to board members. In addition, there is no evidence that employees in high risk positions must refresh their training on an annual basis and it is not clear that the training is tailored on the basis of exposure to corruption risk.

There is evidence that the company measures and reviews the effectiveness of its compliance communications and training programme through metrics such as completion rates and employee awareness surveys. There is evidence that the company undertakes these reviews on an annual basis.

However, the company receives a score of ‘1’ because there is no clear publicly available evidence that the results of such reviews are used to update specific parts of the company's anti-bribery and corruption communications and training programme, nor that a review of the programme takes place at least every three years.

There is no publicly available evidence that the company’s incentive schemes for employees incorporate anti-bribery and corruption principles.

There is some evidence that the company encourages all employees to act with integrity and to avoid unethical conduct in the pursuit of growth, or face potential termination. There is no publicly available evidence that the company commits to support and protect employees who refuse to act unethically, even where such actions may result in a disadvantage or loss of business. There is also no clear evidence that the company assures itself of its employees’ commitment in this statement through clearly stated means such as anonymised surveys.

Based on publicly available information, there is evidence the company promotes a policy of non-retaliation against whistleblowers and employees who report bribery and corruption issues. There is evidence to indicate that the company’s policy on non-retaliation extends to external parties, who may use its whistleblowing line.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

Based on publicly available information, there is evidence that the company provides several whistleblowing and advice channels that allow employees and third parties, including business partners, to raise concerns and seek advice on its compliance programme. There is evidence that these channels allow for confidential reporting and that they are available to all employees in all jurisdictions where the company operates, and in all relevant languages.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it provides an external reporting mechanism for employees, such as a channel operated by an independent third party. In addition, it is not clear whether the company’s channels allow for anonymous reporting where possible.

There is evidence that the company provides training to all employees on its Statement Of Business Ethics, which outlines the basic principles of its ethics and anti-corruption programme, including whistleblowing options available to employees. The company states that training is provided for all new hires and is repeated bi-annually.

However, the company receives a score of ‘1‘ because there is no evidence that training is systematically provided to all employees across all divisions, all countries of operation and in all relevant languages.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is evidence that the company states that employees must not engage in unethical practices, even if it results in lost business. However, there is no evidence that the company explicitly commits to protecting or supporting employees in such situations.

There is evidence that the company promotes a clear non-retaliation policy and states that employees who breach this policy will face disciplinary action. However, the company cannot receive a score of ‘1’ because it does not explicitly state that this policy applies company-wide to include those employed by the group as third parties, suppliers and joint venture partners. There is also no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company has both whistleblowing and advice channels.

However, the company receives a score of ‘1’ because the company does not state that these channels are available to all employees in any country of operation, or in multiple languages, or to any employees of third parties, suppliers or joint venture partners. The evidence also indicates that the company only operates internal channels.

There is evidence that the company provides training that outlines the basic principles of its anti-bribery and corruption policy as described in the Ethical Code of Conduct and Anti-Corruption Manual, which includes the whistleblowing options available to employees. The company states that it provides e-learning modules in all relevant languages for most employees, supplemented by in-person training for the remaining staff members. There is evidence that employees are required to refresh their training on an annual basis.

Based on publicly available information, there is some evidence that employees in certain positions receive different or tailored anti-bribery and corruption training. There is evidence in the company’s publicly available documents that employees in high risk positions, middle management and board members (including external board members) are required to undertake tailored ethics and anti-corruption training. The company indicates that dilemma training for employees in high risk positions is delivered on an annual basis, as well as during the onboarding process.

Based on publicly available information, there is evidence that the company reviews its anti-bribery and corruption communications and training programme. The company indicates that it monitors its training and communications programme using training completion rates, as well as undertaking periodic employee surveys to ensure employee understanding. There is evidence that company monitors this on a monthly basis and reviews the overall results of any evaluations on an annual basis.

Although the company does not explicitly state that this information is used to update the programme at least every three years, there is sufficient evidence to indicate that the results of such reviews are used to update the programme so the company receives a score of ‘2’.

There is no evidence to indicate that the company’s employee incentive schemes incorporate ethical or anti-bribery and corruption principles. The company provides some information on its top-level remuneration for senior management, but there is no evidence that this includes ethical targets nor that it applies to other employees.

The company publishes a statement that any employee who refuses to act unethically, in keeping with the company’s ethical and anti-corruption values and policy, will be protected and supported even where such actions result in a disadvantage to the company. However, the company receives a score of ‘1’ because there is no evidence that it assures itself of employees’ confidence in this specific commitment through anonymised surveys or other clearly stated means.

There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption-related concerns or incidents. This policy is stated in the company’s Ethical Code of Conduct, and therefore applies to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners. However, the company receives a score of ‘1’ because there is no evidence that it assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company provides multiple channels to report instances of suspected corrupt activity and seek advice on the company’s anti-bribery and corruption programme. These channels are sufficiently varied to allow the employee to raise concerns across the management chain and to relevant external bodies through the SpeakUp channel. The company states that these channels allow for confidential and, where possible, anonymous reporting. There is evidence that the company’s whistleblowing channel is available and accessible to all employees in Europe, as well as an email channel that is available to those employed by the group as third parties, suppliers and joint venture partners based in other jurisdictions.

Although the company states that it operates an external reporting channel (SpeakUp), it is noted that the company does not provide further details on how employees or external entities may access it.

There is evidence that the company provides a training module that outlines the basic principles of its anti-bribery and corruption policy, including the whistleblowing options available to employees. There is some evidence that the company provides this training to all employees across all divisions and countries of operation, and in all appropriate languages. The company states that dependent on an assessment of their exposure to corruption risk, some employees are required to undertake refresher courses or modules on the anti-bribery and corruption programme at least every three years.

However, there is no evidence that all employees are required to undertake refresher trainings at least every three years.

There is evidence that employees in certain positions receive different or tailored anti-bribery and corruption training. The company states in its public materials that training is aimed at employees that are most exposed to corruption risks. It makes specific reference to tailored training for employees in high risk positions, board members and middle management.

Although there is evidence that the company’s training plan is updated annually, the company indicates that training for employees in high risk positions is refreshed every three years, rather than on an annual basis.

There is evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme. There is evidence that the company has a system to do this, through dedicated questions in staff surveys. The company commits to assuring itself of this annually.

However, it is unclear that results are used to update specific parts of the company's anti-bribery and corruption communications and training programme.

Based on publicly available information, there is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

Based on publicly available information, there is no evidence that the company commits to support or protect employees who refuse to act unethically, even when it results in a loss of business.

The company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents in the company’s Compliance Code of Conduct. This applies to all employees of the group as well as other stakeholders that engage with the group.

However, there is no evidence that the company assures itself of its employees’ confidence in its commitment to non-retaliation through surveys, usage data, or other clearly stated means.

The company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. These channels are sufficiently varied to allow the employee to raise concerns across the management chain and to relevant external bodies. These channels allow for confidential and, wherever possible, anonymous reporting. The company’s whistleblowing line is open to all employees and third parties, suppliers and joint venture partners. There is evidence that channels are available in all relevant languages.

There is evidence that the company provides training to its employees that outlines the principles of its anti-bribery and corruption policy, and that it covers the procedure for reporting unusual or suspicious transactions.

The company scores ‘1’ because although there is evidence that corruption training takes place once a year, it is not specified whether all employees are required to attend this training, and therefore it is unclear how frequently employees are required to undertake or refresh their training on anti-bribery and corruption. It is also not clear from the available evidence that training is provided to all employees across all divisions, in all countries/regions of operation or in all appropriate languages.

There is evidence that the company provides different or tailored anti-bribery and corruption training to senior and middle managers.

However, the company receives a score of ‘1’ because there is no evidence that it provides tailored training to all the different categories of employees listed in the question, including board members or other employees in high-risk roles. Moreover, there is no clear evidence that employees in high-risk positions are required to undertake and refresh their training on at least an annual basis.

There is some evidence that the company reviews the effectiveness of its anti-bribery and corruption training programme. There is evidence that the anti-bribery and corruption training programme is evaluated annually to ensure it is kept up-to-date with legal changes, and that the company conducts employee surveys to measure the effectiveness of its training to some extent.

However, the company receives a score of ‘1’ because there is no evidence that it uses the results of these surveys to update specific parts of its anti-bribery and corruption training and communications programme. It is also not clear how frequently these surveys take place, and therefore whether the company assures itself of the effectiveness of its communications and training programme on at least an annual basis.

There is some evidence that the company’s incentive schemes incorporate ethical and anti-bribery and corruption principles.

However, the company receives a score of ‘1’ because the publicly available evidence on this topic comes in the form of a short statement. It is not clear whether incentives are designed to reward behaviour in line with the company’s ethical values as identified through performance appraisals or conduct in the workplace and there is no evidence that the company acknowledges that financial rewards must be proportionate to the base salary in the case of high risk employees, such as sales roles.

There is no evidence that the company publicly commits to support or protect employees who refuse to act unethically.

There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report compliance-related allegations. There is evidence that this applies to all employees across the organisation, including those employed by the group as third parties.

However, the company receives a score of ‘1’ because whilst the company publishes some data indicating that it tests employees’ belief in the company’s general commitment to anti-corruption and compliance, there is no evidence that it specifically assures itself of its employees’ confidence in the company’s non-retaliation commitment, either through surveys, usage data, or other clearly stated means.

There is evidence that the company has multiple whistleblowing and advice channels for employees to report instances of suspected corrupt activity or seek advice on the company’s anti-bribery and corruption programme. The company states that it assures the confidentiality and anonymity of reports received through its whistleblowing channel, and there is evidence that the channels are available to all employees and third parties.

However, the company receives a score of ‘1’ because the evidence suggests that the company only offers internally operated channels and does not provide an option for reporting allegations to a hotline managed by an independent third party.

Based on public information, there is evidence that the company provides training that outlines the principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees. The company provides this training to all employees across all divisions and countries of operation, and in all appropriate languages. There is evidence that compliance trainings are undertaken annually by the employees.

Based on public information, the company states that employees in certain positions receive different or tailored anti-bribery and corruption training.

However, these positions are unclear and the company does not make specific reference to all three categories of employee referred to in the question.

Based on public information, there is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme on an annual basis.

However, the measures are too simplistic and it is unclear that results are used to update specific parts of the company's anti-bribery and corruption communications and training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

Based on public evidence, the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents that explicitly applies to all employees across the organisation, including those employed by the group as third parties. The company assures itself of its employees’ confidence in this commitment by monitoring the usage data of the whistleblowing channels.

Based on public evidence, the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and to relevant external bodies. These channels allow for confidential reporting. They are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties.

There is evidence that the company provides a training module that outlines the basic principles of its anti-bribery and corruption policy, including the whistleblowing options available to employees. The evidence indicates that this training is provided to all employees.

However, it is unclear how frequently training is refreshed and whether the training is provided in all appropriate languages.

The company states that employees in certain positions receive tailored anti-bribery and corruption training, including employees in high risk positions and managers.

However, it is not clear how frequently this training takes place and the company does not make specific reference to board members as a category of employee requiring tailored training.

There is no publicly available evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no publicly available evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no publicly available evidence that the company commits to support or protect employees who refuse to act unethically.

There is evidence that the company has a publicly available policy of non-retaliation against whistleblowers, which applies to employees and directors, as well as employees of third parties or members of the general public.

However, there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

The company has some whistleblowing and advice channels, which allow confidential reporting. These channels are available to employees across the group as well as those employed by third parties or members of the public.

However, the company does not appear to offer anonymous channels or any externally operated channels. The channels are also not explicitly available to all employees in any country of operation, and in all relevant languages.

Based on publicly available information, there is evidence that the company provides training for its employees that outlines the principles of its anti-bribery and corruption policy, including the whistleblowing options available. There is evidence that the company provides this training to all employees and in multiple languages. There is evidence that all employees must undertake annual ethics and compliance training.

Based on publicly available information, there is evidence that the company provides tailored anti-corruption training to its employees based on an assessment of their role and exposure to corruption risk. The company indicates that it provides such training to management, board members and employees in high risk positions, such as those in business development, programme management and finance.

However, there is no clear publicly available evidence that the employees in high risk positions must refresh their role-specific training on an annual basis.

Based on publicly available information, there is evidence that the company has a system for measuring and reviewing the effectiveness of its anti-bribery and corruption communications and personnel training programme. The company’s internal audit department audits the training programme, which also includes quizzes designed to test the effectiveness of materials. The company commits to assuring itself of this on an annual basis. It is clear that the results of these reviews are used to update specific parts of the company's anti-bribery and corruption communications and training programme.

There is some evidence that the company’s incentive schemes for employees incorporate ethical and anti-bribery and corruption principles. The company states that compensation schemes are designed to reward behaviour in line with the company’s ethical values.

However, the company receives a score of ‘1’ because it is not clear that these incentives apply to all employees or whether financial rewards must be proportionate to the employee’s base salary in the case of high risk employees, such as sales roles. It is also unclear how the company incentivises ethical conduct in the workplace, such as through performance appraisals.

Based on publicly available information, there is evidence that the company will support any employee who refuses to act unethically, even if this might impact on the company’s business. There is evidence that the company assures itself of its employees’ confidence in this statement through annual anonymised surveys.

Based on publicly available information, there is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is evidence that the company assures itself of its employees’ confidence in this commitment through anonymised surveys. In addition, the company indicates that its whistleblowing line is open to third parties including suppliers and that its commitment on non-retaliation extends to these parties.

There is evidence that the company provides multiple channels for its employees to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. There is evidence that these channels are sufficiently varied to allow the employee to raise concerns across the management chain and to a reporting hotline operated by an independent third party. These channels allow for confidential and, wherever possible, anonymous reporting. The company indicates that its channels are available and accessible to all employees, in all jurisdictions where the company operates, including those employed by the group as third parties such as suppliers, and in all relevant languages.

There is evidence that the company provides a training module that outlines the basic principles of its anti-bribery and corruption policy. However, the company receives a score of ‘1’ because there is no evidence that training is provided to all employees systematically, across all divisions, in all countries/regions of operation or in all appropriate languages, nor is there evidence of how frequently employees are required to undertake or refresh their training.

There is some evidence that employees in certain positions receive different or tailored anti-bribery and corruption training. The company refers specifically to senior management and employees in high risk positions.

However, the company receives a score of ‘1’ because there is no evidence that board members receive this enhanced training. There is also no evidence that training for employees in high risk positions is refreshed on at least an annual basis.

There is no publicly available evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption communications or training programme.

There is no publicly available evidence that the company’s employee incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no publicly available evidence that the company commits to support or protect employees who refuse to act unethically.

There is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, which explicitly applies to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners.

However, the company receives a score of ‘1’ because there is no evidence that it assures itself of employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company has multiple channels to report instances of suspected corrupt activity, and to seek advice on the company's anti-bribery and corruption programme. There is evidence that these channels are sufficiently varied to allow employees to raise concerns across the management chain and to an external channel operated by an independent third party, and that these channels allow for confidential and, wherever possible, anonymous reporting. There is also evidence that they are available and accessible to all employees, in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners. Although there is no evidence that the company’s hotline is available in all relevant languages, a score of ‘2’ has been awarded on the basis that there is no evidence that the company operates overseas and therefore no other languages would be necessary.

Based on publicly available information, there is evidence that the company provides a training module on compliance to all employees that outlines the whistleblowing options available to them. There is evidence that this compliance training included a specific anti-bribery and corruption module in 2014, however it is not clear whether the company provides an anti-corruption module regularly or since 2014. In addition, there is no evidence that the training is provided to all employees across all divisions, all countries and regions of operation or in all appropriate languages.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk. Although there is evidence that managers receive tailored training on compliance matters, it is unclear whether this training includes a specific section on anti-bribery and corruption.

Based on publicly available information, there is some evidence that the company measures the effectiveness of its compliance training through fixed point observations and a compliance awareness survey. However, it is not clear whether this training includes anti-bribery and corruption so the company receives a score of ‘0’.

Based on publicly available information, there is evidence that the company aims to make the decision-making process around compensation for its Board Members and Executive Directors transparent and objective. However, there is no evidence that the company’s incentive schemes incorporate ethical principles specifically nor is it clear that this applies for all employees.

There is no publicly available evidence that the company commits to support or protect employees who refuse to act unethically.

Based on publicly available information, there is evidence that the company has a policy of non-retaliation against whistleblowers and employees who report bribery and corruption incidents, which explicitly applies across the organisation.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data or other clearly stated means.

Based on publicly available information, there is some evidence that the company has provides channels for employees to report instances of suspected corrupt activity.

However, the company receives a score of ‘0’ because there is no publicly available evidence to indicate how they can be accessed. It is not explicitly clear that these channels allow for anonymous or confidential reporting, nor is there evidence that the company provides externally-operated channels (i.e. by an independent third party). The company also does not provide evidence to indicate whether employees can use these channels to seek advice on the company’s anti-bribery and corruption programme. Furthermore, the channels are not explicitly available to all employees in any country of operation, or in multiple languages, or to any employees of third parties, suppliers or joint venture partners.

The company states that employees in certain positions receive tailored anti-bribery and corruption training.

However, these positions are unclear and do not make specific reference to all three categories of employee referred to in the question. Additionally, the company does not state that training for employees in high risk positions is refreshed on at least an annual basis.

There is some evidence that the company reviews its anti-bribery and corruption communications and training programme annually.

However, the measures described for doing so appear overly simplistic and are limited to completion rates. There is also no evidence that the results of such reviews are used to update specific parts of the training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is insufficient evidence that the company commits to support or protect employees who refuse to act unethically.

There is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents that explicitly applies to all employees across the organisation, including those employed by the group as third parties and suppliers.

However, there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents that explicitly applies to all employees across the organisation, including those employed by the group as third parties and suppliers.

However, there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

The company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. Channels are sufficiently varied to allow employees to raise concerns across the management chain and to a relevant external organisation. These channels allow for confidential and, wherever possible, anonymous reporting. There is also evidence that these reporting channels are available and accessible to employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners, and in all relevant languages.

Based on publicly available information, there is evidence that the company provides training for its employees on the principles of its Ethical Code of Conduct, which contains its anti-bribery policy and covers the whistleblowing options available. There is evidence that the company provides this training to all employees across all divisions, all countries of operation and in all appropriate languages. The company states that employees are required to undertake this training annually.

Based on publicly available information, there is evidence that the company tailors its ethical training programme to the different levels of risk faced by employees in different roles, with specific reference to the categories of employee referred to in the question. There is evidence indicating that employees working in high risk positions, such as those in sales and procurement, are required to refresh their training on at least an annual basis.

Based on publicly available information, there is evidence that the company reviews its ethical communications and training programme, and that the results of such reviews are used to update specific parts of the programme, as demonstrated by its personnel surveys.

However, the company states that personnel surveys are undertaken every two or three years. There is therefore no clear evidence that the company assures itself of the quality of its training programme on at least an annual basis.

Based on publicly available information, there is evidence that the company’s incentive schemes incorporate ethical and anti-bribery and corruption principles. There is evidence that the company’s incentives are designed to reward behaviour in line with the company’s ethical values as identified through performance appraisals, and that the company offers non-monetary rewards such as remote working and job rotation.

However, there is no evidence in publicly available information that the company tailors its approach for employees in high risk positions, such as those in sales roles. There is also no clear evidence that financial rewards must be proportionate to employees’ salaries in the case of high-risk employees.

There is no publicly available evidence that the company clearly commits to support or protect employees who refuse to act unethically in the workplace.

Based on publicly available information, there is evidence that the company has a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. The company’s whistleblowing line is open to external stakeholders and there is evidence indicating that the company extends its policy on non-retaliation to these parties. There is also evidence that the company assures itself of its employees’ confidence in this commitment through employee surveys.

Based on publicly available information, there is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's ethical and compliance programme. There is evidence that the company’s channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an external body outside the organisation. These channels allow for anonymous reporting and are available to all employees in all jurisdictions where the company operates, including those employed by external stakeholders.

While the company states that it provides training to its employees, there is no clear evidence that the training covers anti-bribery and corruption.

There is no clear evidence that the company provides anti-bribery and corruption training for its employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no clear evidence that the company commits to support or protect employees who refuse to act unethically, even when it might result in a loss of business.

There is evidence the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, which applies company-wide. There is some evidence that the company extends this commitment to third parties including suppliers.

However, there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's ethics programme. Channels are sufficiently varied to allow employees to raise concerns across the management chain and to a relevant external body. These channels allow for confidential and anonymous reporting. There is evidence indicating the channels are available to all employees in any country of operation and in all relevant languages. There is also evidence indicating that the company’s whistleblowing line is open to third parties including suppliers.

There is no evidence that the company provides anti-bribery and corruption training to its employees.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

There is no publicly available evidence that the company has a policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is no evidence that the company provides whistleblowing or advice channels for its employees to report suspected incidents of bribery or corruption or seek advice on the company’s anti-corruption activities.

Based on publicly available information, there is evidence that the company provides a training module that outlines the basic principles of the anti-bribery and corruption policy. The evidence suggests that training is provided at least on an annual basis.

However, there is no evidence to suggest that the training is systematically provided to all employees, in all countries or regions of operation and in all appropriate languages. It is also not clear whether training includes outlining the whistleblowing options available to employees.

There is evidence that the company provides tailored anti-bribery and corruption training to employees in different roles, including employees working in high-risk positions. There is evidence which suggests that employees in high risk positions are required to undertake training in this area on at least an annual basis.

However, there is no publicy available evidence that the company provides training to all three categories of employees referred to in the question. There is some evidence that refers to employees in decision making roles, but it is not clear whether they are expected to undertake training or deliver it to other employees. There is no evidence in relation to anti-bribery and corruption training for board members.

Based on publicly available information, there is some evidence that the company measures the effectiveness of its anti-bribery and corruption communications and personnel training programme, although the frequency with which the company assures itself of this is not stated. Furthermore, it is unclear whether the results of evaluations are used to update specific parts of the company's anti-bribery and corruption communications and training programme. There is also no evidence that the company conducts a full review of its anti-bribery and corruption training programme at least every three years.

Although the company states that its Compliance Officer may present rewards or promotions to employees who have demonstrated ethical conduct, the company’s approach to incentives for employees across the company is unclear and so receives a score of ‘0’.

Although the company states that it cannot justify violations of its Code of Ethics in order to make a profit or reach targets, there is no publicly available evidence to indicate that the company commits to support or protect employees who refuse to act unethically, even where such actions result in a loss to the company.

Based on publicly available information, there is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents.

However, there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys or usage data. Furthermore, the policy does not explicitly apply to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners.

Based on publicly available information, there is evidence that the company has both whistleblowing and advice channels. There is evidence that channels are sufficiently varied to allow employees to raise concerns across the management chain, and that they allow for confidential and, wherever possible, anonymous reporting. The evidence states that any person can report a violation through its various channels and so it is understood that they are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners.

However, the company receives a score of ‘1’ because it is not clear that it offers an external channel operated by an independent party.

There is no publicly available evidence that the company provides anti-bribery and corruption training to its employees.

There is no evidence that the company provides tailored anti-bribery and corruption training to its employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

There is no publicly available evidence that the company has a policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is no evidence that the company provides whistleblowing or advice channels for its employees to raise concerns or seek advice about the its anti-bribery and corruption programme.

There is evidence that the company provides training – embedded in a business ethics course – that outlines the principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees. The company provides this training to all employees across the group on an annual basis and in all appropriate languages.

The company states that it provides tailored training on its anti-bribery and corruption programme to employees in high risk positions on a bi-annual basis. Board members receive annual business ethics training.

However, it is unclear whether this is tailored and the company does not refer to tailored training for middle management.

There is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme.

However, the measures are too simplistic, the frequency of the assurance is unclear, and there is no evidence that results are used to update specific parts of the company's anti-bribery and corruption communications and training programme.

There is some evidence that the company incorporates ethical considerations into its approach to incentives, however, the company’s approach to incentives is unclear to the extent that it cannot satisfy the requirements to receive a score of ‘1’.

The company clearly states that any employee who refuses to act unethically, in keeping with the company’s anti-corruption commitments, will be protected and supported, even where such actions result in a loss of business or another disadvantage to the company.

However, there is no evidence that the company assures itself of its employees’ confidence in this statement through anonymised surveys or other means.

The company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. This applies to all employees across the group. The company also expects that its suppliers’ employees are free to report concerns without fear of retaliation.

However, it is not explicitly stated that the same is true for all third parties employed by the group, including joint venture partners. There is also no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

The company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and to relevant external bodies, and they allow for confidential and anonymous reporting. The channels are described in the company’s Code of Conduct, which applies to all employees across the group, including third parties. The external channel is available in multiple countries and in English, French and Dutch.

There is evidence that the company provides training that outlines the basic principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees. There is evidence that the company provides this training to all employees and in all appropriate languages. However, the company receives a score of ‘1’ because it is unclear how frequently employees are required to refresh their training on anti-bribery and corruption.

There is evidence that the company provides tailored anti-bribery and corruption training to employees in different roles based on their exposure to corruption risk, with specific reference to the three categories of employee referred to in (a), (b) and (c) of the question. However, there is no evidence that employees in high risk positions specifically are required to undertake and refresh their training on at least an annual basis.

There is evidence that the company measures and reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme. There is evidence that the company has a system to do this, for example through risk assessments, feedback from employees and results of internal audits and the company commits to assuring itself of this on at least on an annual basis. There is evidence that the results of such reviews are then used to update specific parts of the company's anti-bribery and corruption communications and training programme, with a review of the programme taking place on an annual basis.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

There is evidence the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is evidence to indicate that this policy extends to any individual who wishes to report an incident, including all employees of suppliers, third parties and joint venture partners.

However, the company receives a score of ‘1’ as there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. Channels are sufficiently varied to allow the employee to raise concerns across the management chain, by telephone, email or mail. There is evidence that these channels allow for confidential and anonymous reporting. There is some evidence these channels are open to all employees and third parties, although the company does not refer to employees of suppliers and joint venture partners specifically.

However, the company receives a score of ‘1’ as the evidence suggests that it only offers internally operated channels, with no evidence of an external channel operated by an independent third party. It is also unclear whether the channels are available in all relevant languages.

Based on publicly available information, there is evidence that the company provides training to all employees through its ethics and compliance education and training programme. This outlines the principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees. The company indicates that employees are required to undertake annual refresher modules on the anti-bribery and corruption programme. There is also evidence that the training is provided to all employees, across all divisions and countries of operation, and in all appropriate languages.

Based on publicly available information, there is evidence that the that the company provides tailored anti-bribery and corruption training to employees in different roles based on their exposure to corruption risk, with reference to the three categories of employee referred to in (a), (b) and (c) in the question. There is evidence that employees in high risk positions are required to undertake and refresh their training on at least an annual basis.

Based on publicly available information, there is evidence that the company measures and reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme on at least an annual basis. The company does this through dedicated questions in annual staff surveys. There is evidence that the results of such reviews are used to update specific parts of the company's anti-bribery and corruption communications and training programme.

Based on publicly available information, there is some evidence that the company incorporates accountability principles and adherence to the company’s values in its employee performance reviews. The company indicates that only those who meet these expectations are eligible for performance-based compensation.

However, the company receives a score of ‘1’ because it does not provide further information on how such assessments impact the company’s bonus or reward schemes. There is also no clear evidence to indicate that, where financial rewards are part of incentive schemes, there are procedures in place to ensure that they are proportionate to the base salary in the case of high risk employees.

Based on publicly available information, there is evidence the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. This policy explicitly applies to all employees across the organisation, including those engaged by the group as third parties and business partners. There is evidence that the company commits to assure itself of its employees’ confidence in this commitment through employee surveys and monitoring the number of reports to the company’s ethics department.

Based on publicly available information, there is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. Channels are sufficiently varied to allow employees to raise concerns across the management chain, as well as through an external channel operated by an independent third party. These channels allow for confidential and, wherever possible, anonymous reporting.

In addition, there is evidence to indicate that these channels are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, and in all relevant languages.

There is evidence that the company provides a training module that outlines the basic principles of its anti-bribery and corruption policy, including the whistleblowing options available to employees. There is evidence that the company provides this training to all employees across its divisions and countries of operation, and that employees are required to take annual refresher courses. There is evidence that the training is provided in all appropriate languages.

There is some evidence that employees in certain positions receive tailored anti-bribery and corruption training on an annual basis. The company refers to risk-specific training for management and employees involved in sales or purchasing.

However, the company does not refer specifically to tailored training for board members.

There is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme.

However, the measures appear to be limited to tracking the number of personnel trained. There is no evidence the results are used to update specific parts of the company's anti-bribery and corruption communications and training programme.

There is no clear evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically, even when it might result in a loss of business.

There is evidence the company has a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents that explicitly applies to all employees across the organisation. There is also evidence that the company’s whistleblowing line is open to external business partners.

However, there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an independent Ombudsman. These channels allow for confidential and, wherever possible, anonymous reporting. They are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners, and in multiple relevant languages.

There is no evidence that the company provides anti-bribery and corruption training to all employees.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

There is no evidence that the company has a publicly available policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is no evidence that the company has either whistleblowing or advice channels.

There is evidence that the company provides ethics and compliance training to all of its employees worldwide. The company states that, in 2018, this training focused on its Code of Conduct, which includes the company’s anti-bribery and corruption policy as well as the whistleblowing options available to employees. There is evidence that employees receive mandatory training on an annual basis, and that this applies to all employees in all jurisdictions in which the company operates.

There is evidence that the company requires employees in high risk positions to undertake dedicated training on anti-bribery and corruption, with refresher training every two years.

However, there is no evidence that board members and middle managers receive anti-bribery and corruption training tailored to their roles.

There is evidence that the company measures the efficacy of its anti-bribery and corruption communications and training programme and that the company also uses the results of such reviews to modify and update specific parts of its training and communications programme. The company publishes data on the number of personnel trained and completion rates, as well as the number of reports received through the company’s whistleblowing line. There is evidence that this information is gathered on an annual basis and is reviewed by the internal audit department.

There is evidence that the company’s incentive schemes for employees are designed to promote ethical behaviour and discourage corrupt practices. The company indicates that managers who fail to complete training on the company’s Code of Conduct are subject to capped performance reviews. The remuneration policy for directors outlined in the company’s Annual Report indicates that a breach of the Code of Conduct will result in a penalty and there is also evidence indicating that executive and manager remuneration is subject to ethical conduct appraisal. Additionally, the company states that it does not offer bonuses based on purely financial targets for sales roles.

The company publishes a clear commitment to support employees who refuse to act unethically even when doing so results in lost business. There is also further evidence that the company assures itself of employees’ confidence in this commitment through monitoring of reporting data and employee interviews.

The company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, which explicitly applies to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners. There is additional evidence that the company assures itself of employees’ confidence in this commitment through monitoring of incident reporting data.

There is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and to a relevant external body. These channels allow for confidential and, wherever possible, anonymous reporting. They are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners, and in all relevant languages.

Publicly available evidence suggests that the company provides training on its anti-bribery and corruption programme, including the whistleblowing options available to employees.

However, the company receives a score of ‘1’ because there is no clear evidence that the company provides training systematically to all employees across all divisions, all countries and regions of operation and in all appropriate languages. It is also unclear, based on publicly available information, how frequently the company conducts anti-corruption training.

The company states in publicly available information that some employees in certain positions receive different or tailored anti-bribery and corruption training, including senior managers and those in higher risk positions.

However, there is no evidence as to how systematically this tailored training is conducted or whether it is refreshed on at least an annual basis. There is also no evidence that board members receive tailored training

There is evidence that the company publicly commits to continuously work to improve its educational and outreach programme in the area of anti-corruption. However, there is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

While there is some evidence that employees’ conduct is taken into account when under consideration for promotion, there is insufficient evidence to suggest that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is evidence that this explicitly applies to all employees across the organisation, including those employed by the group as third parties, without making specific reference to suppliers and joint venture partners.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in its non-retaliation commitment through surveys, analysis of usage data, or other clearly stated means.

There is evidence that the company has whistleblowing and advice channels, which allow for confidential and anonymous reporting. It is stated in publicly available information that these channels are available to all employees and third parties, although there is no clear evidence as to whether this includes employees of suppliers and joint venture partners, or whether all employees in every country of operation can access these channels in all relevant languages. Based on publicly available information, there is evidence that the company only offers internally operated reporting and advice channels.

There is evidence that the company provides training that outlines the principles of the anti-bribery and corruption programme and that employees are required to undertake refresher courses or modules on the anti-bribery and corruption programme every two to three years.

The company, however, receives a score of ‘1’ because it makes no explicit statement that it provides anti-bribery and corruption training to all employees across all operations and in all appropriate languages. It is also not clear whether training covers the whistleblowing options available to employees.

While the company states that it conducts annual ethical certification of middle and senior managers, the evidence is insufficiently clear to determine whether the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

While the company states that it takes into consideration employees’ adherence to ethical principles when considering them for promotion to more senior positions, there is insufficient evidence to determine whether the company’s incentive schemes specifically incorporate ethical or anti-bribery and corruption principles.

The company clearly states that any employee who refuses to act unethically, in keeping with the company’s anti-corruption commitments, will not be subject to sanctions, even where such actions result in a loss of business or another disadvantage to the company.

However, there is no evidence that the company assures itself of its employees’ confidence in this statement through anonymised surveys or other clearly stated means.

There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is evidence that this policy applies to all employees across the organisation, including those engaged by the group as third parties and partners.

However, the company receives a score of ‘1’ because there is no clear evidence that it assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that employees are able to access multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme, including channels provided by the parent company. There is evidence that channels are sufficiently varied to allow the employee to raise concerns across the management chain and they allow for confidential and, wherever possible, anonymous reporting. There is also evidence that it is clear that channels are available to all employees in any country of operation and to any employees of third parties, suppliers or joint venture partners.

However, the company receives a score of ‘1’ because, based on publicly available information, employees only appear to have access to internally operated channels.

There is evidence that the company provides training for its employees that outlines the principles of the anti-bribery and corruption policy, including the whistleblowing options available. The company indicates that it provides this training to all employees across all divisions and countries of operation, and in all appropriate languages. There is evidence that employees are required to undertake refresher courses or modules on the anti-bribery and corruption programme at least every three years.

There is some evidence that the company provides tailored anti-bribery and corruption training to its employees based on the different levels of risk facing those in different roles. The company makes specific reference to specialised training for employees in high risk positions, middle management and board members.

However, the company receives a score of ‘1’ because there is no evidence that employees in high risk positions are required to undertake tailored refresher training on at least an annual basis.

There is some evidence that the company measures and reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme on a regular basis. The company indicates that it undertakes dedicated employee surveys and measures the number of compliance-related inquiries in a year, as well as measuring completion rates of its anti-bribery and corruption e-learning course. There is evidence that the results of these reviews and surveys are used to update specific parts of the training programme, with the entire programme subject to a comprehensive review at least every three years.

There is evidence that the company’s incentive schemes for employees are designed in such a way that they promote ethical behaviour and do not undermine its commitment to anti-bribery and corruption. Where financial rewards are part of its incentive scheme, the company indicates that any performance-based incentives are proportionate to the employee’s salary. In addition, the company indicates that its employee incentives are based on performance reviews and regular feedback sessions. Although the company does not explicitly mention employees in high risk roles, there is clear evidence that the company ensures that incentives are proportionate for employees in sales roles.

Based on publicly available information, there is no clear evidence that the company commits to support and protect employees who refuse to act unethically. The company states that employees must adhere to its code of conduct and indicates that neglecting this to secure business is against its values, but there is no clear evidence that it commits to support and protect its employees to do the right thing.

There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. The company’s policy applies to all employees across the organisation, as well as external employees and third parties who use its whistleblower system. There is evidence that the company assures itself of its employees‘ confidence in this commitment through usage data.

There is evidence that the company provides multiple channels for its employees to report instances of suspected corrupt activity and seek advice on its anti-bribery and corruption programme. There is evidence that these channels are sufficiently varied to allow employees to raise concerns across the management chain and to external bodies through an independently operated hotline. The company indicates that these channels allow for confidential and, wherever possible, anonymous reporting.

In addition, there is evidence that the company’s reporting channels are available and accessible to all employees in all jurisdictions where it operates, including to external parties such as employees of suppliers and joint venture partners, and in all relevant languages.

Based on publicly available information, there is no evidence that the company provides anti-bribery and corruption training to its employees. The company states that it carries out preventative measures to minimise the risk of corruption across the company without making any specific reference to training programmes.

Based on publicly available information, there is no evidence that the company provides anti-bribery and corruption training to its employees.

Based on publicly available information, there is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme. There is evidence that the company makes a general commitment to review the effectiveness of anti-corruption measures but it makes no specific reference to a communications and training programme.

Based on publicly available information, there is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

Based on publicly available information, there is no evidence that the company commits to support or protect employees who refuse to act unethically, even when it might result in a loss of business.

The company’s parent company (Rostec) publishes a policy on its whistleblowing hotline which states that no employee in the corporation or third party who makes a corruption allegation using the service can be subject to sanction. This policy is published on the company’s own website.

However, the company scores ‘0’ as there is no clear evidence that the policy on non-retaliation applies to both whistleblowers and employees who report bribery and corruption incidents by other means.

Based on publicly available information, there is evidence that the company maintains several whistleblowing channels alongside policies which guarantee employees anonymity and confidentiality when making reports. There is some evidence that these channels are open to third parties, although the company does not explicitly refer to employees of suppliers or joint venture partners.

The company receives a score of ‘1’ because, based on publicly available information, the company only appears to offer internally operated whistleblowing channels and no advice channels. There is also no clear evidence that the channels are available to all employees in any country of operation, or in multiple languages.

There is evidence that the company provides anti-bribery and corruption training that outlines the basic principles of the Code of Conduct, which includes the whistleblowing options available to employees. There is evidence that the training is provided to all employees across all divisions and all countries of operation. The Board of Directors and the Group Management of Saab receive anti-bribery training every three years.

However, it is unclear how frequently training is conducted for employees.

There is evidence that employees in certain positions receive tailored anti-corruption training, namely employees in high risk positions, middle management and board members.

However, there is no evidence that training for employees in high risk positions or middle managers is refreshed on at least an annual basis.

There is no publicly available evidence to indicate that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

The company’s approach to incentives is not sufficiently clear to receive a score of ‘1’ and the company also makes no mention of ethics or integrity in relation to its incentive schemes.

The company clearly states that any employee who refuses to act unethically, in keeping with the company’s anti-corruption commitments, will be protected and supported, even where such actions result in a loss of business.

However, there is no evidence that the company assures itself of its employees’ confidence in this statement through anonymised surveys or other clearly stated means.

The company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. The company states that this policy applies to all employees without exception. However, it is not clear whether the hotline is available to those employed by the group as third parties, suppliers and joint venture partners, and the company therefore receives a score of ‘0’. There is also no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.mmitment through surveys, usage data, or other clearly stated means.

Based on publicly available information, there is evidence that the company has multiple whistleblowing and advice channels. The channels – which the company states can be used for both whistleblowing and to seek advice – allow for confidential and, wherever possible, anonymous reporting. The company also offers an externally-operated channel and these options are available to all employees in any country of operation and in multiple languages. The company indicates that the whistleblowing channels are accessible across the entire group.

However, there is no publicly available evidence that the channels are available to employees of third parties, suppliers or joint venture partners. Additionally, it is not clear how employees can access the hotline.

There is evidence that the company provides a training module to all employees that outlines the basic principles of the anti-bribery and corruption policy. It is clear that training is provided to all group companies worldwide.

However, the company receives a score of ‘1’ because it is unclear how regularly this training is conducted or whether employees are required to refresh their training. There is also no publicly available information on the content of the training module, so it is unclear whether the training covers the whistleblowing options available to employees.

There is some evidence that that employees in certain positions receive different or tailored anti-bribery and corruption training.

However, the company receives a score of ‘1’ because it does not make specific reference to all three categories of employee as referred to in the question. It is also unclear how frequently training is conducted.

There is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme.

However, the company receives a score of ‘1’ because the review measures described in its publicly available evidence are limited to data collection and completion rates. Information memos are issued on an annual basis, but it is not fully clear whether the results of these measures are used to update specific parts of the company’s anti-bribery and corruption programme. It is also unclear whether the company’s anti-corruption certification by an external company, the Agency in charge of Providing Technological Information (“ADIT”), includes a review of training.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles. Publicly available descriptions of the structure of company’s Corporate Officer and Chief Executive Officer compensation packages do not refer to anti-bribery and corruption. The company briefly mentions that employee compensation accounts for individual commitment to issues such as workplace health and safety and compliance with international labour conventions, but there is no evidence to suggest that this includes anti-bribery and corruption principles.

There is no evidence that the company commits to support and protect employees who refuse to act unethically. The company makes a clear commitment to business integrity, even if it means a loss of business. However, this is not accompanied or reinforced by a statement that the company will support and protect those who refuse to act unethically. There is also no evidence that the company assures itself of its employee’s confidence in this statement through anonymised surveys or other clearly stated means.

There is evidence that the company has a policy of non-retaliation and non-discrimination against employees who make reports. The policy applies to all employees across the organisation, including those employed by the Group as third parties, suppliers and joint venture partners.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company has whistleblowing and advice channels that allow for anonymous and confidential reporting. Employees may raise concerns or ask questions about bribery and corruption-related issues through direct means – by consulting a supervisor or a compliance or human resources professional – or indirectly through a dedicated email address. This whistleblowing line is operated by an external party and accessible to all employees in all jurisdictions where the company operates, including those employed by the Group as third parties, suppliers and joint venture partners. There is also evidence that the company’s whistleblowing and advice line is available in all relevant languages.

There is no clear publicly available evidence that the company provides training on its anti-bribery and corruption policy or programme to all employees. The company indicates that directors and senior executives receive ethics training, however it is not clear that the company provides training to all employees at all levels.

There is no publicly available evidence that the company provides tailored anti-bribery and corruption training to different employees based on an assessment of their role and exposure to corruption risk. The company indicates that directors must undertake ethics training but it is not clear that this training is specifically tailored to their role, nor is there evidence that the company provides training to the other categories of employees listed in the question.

There is no publicly available evidence that the company measures or reviews the effectiveness of its anti-corruption communications or training programme.

There is no publicly available evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles. Although the company publishes some information about its approach to executive compensation, there is no evidence that this involves promoting ethical behaviour and discouraging corrupt practices.

There is some evidence that the company encourages employees to act with integrity and report alleged misconduct; however there is no clear evidence that the company commits to support and protect those who refuse to act unethically, nor that it assures itself of its employees’ belief in this commitment.

There is evidence that the company has a policy of non-retaliation against whistleblowers and employees who report bribery and corruption concerns. However, there is no evidence that this policy extends to third parties and joint venture partners, nor is there evidence that the company takes steps to assure itself of its employees’ belief in this statement.

There is evidence that the company provides multiple whistleblowing and advice channels for employees to report concerns and seek advice about its anti-corruption programme. The company indicates that these channels allow for anonymous and confidential reporting if necessary, and there is evidence that they are sufficiently varied to allow employees to raise concerns across the management chain and to an external reporting system run by an independent third party provider.

Although the company does not explicitly state that these channels are available to employees of third parties, suppliers and joint ventures, there is evidence that the hotline and online reporting system may be accessed by any such individual. The online system also contains a function to change the language, making it accessible to employees in all relevant languages and jurisdictions.

Based on publicly available information, there is evidence that the company provides training that outlines the principles of its anti-bribery and corruption programme, including the whistleblowing options available to employees. The company provides this training to all employees across all divisions and countries of operation and in all appropriate languages. The company indicates that employees are required to undertake refresher courses on at least an annual basis.

Based on publicly available information, there is evidence that the company provides tailored anti-bribery and corruption training for employees in high-risk positions, middle management and board members. The company states that the training is tailored to these groups based on an assessment of their role and exposure to corruption risk. There is evidence indicating that this training is refreshed on an annual basis.

Based on publicly available information, there is some evidence that the company reviews its anti-corruption communications and training programme regularly to ensure that its standards reflect best practice.

However, the company receives a score of ‘1’ because there is no evidence that the company conducts assurance on at least an annual basis, nor that the results of these reviews are used to update specific parts of the company's training programme. In addition, there is no clear evidence that the company has a system or specific measures in place for reviewing the efficacy of its training programme.

Based on publicly available information, there is evidence that the company’s incentive schemes incorporate ethical principles. The company indicates that it conducts performance appraisals, which consider values-based behaviour. The company also indicates that employees are only eligible for financial bonuses if they complete annual anti-corruption training and have not been found in breach of the Code of Conduct.

However, the company receives a score of ‘1’ because there is clear evidence that incentives or rewards must be proportionate to the employee’s salary in the case of high-risk employees.

There is clear evidence that the company commits to support and protect any employee who refuses to act unethically, in keeping with the company’s anti-corruption commitments, even where such actions result in a loss of business or another disadvantage to the company.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this statement through anonymised surveys or other clearly stated means.

Based on publicly available information, the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, which applies to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners. There is some indication that the company assures itself of confidence in this system through randomized interviews with employees who have reported ethics incidents to ensure that they did not feel like they experienced any acts of retaliation.

Based on publicly available information, there is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's ethics programme. There is evidence that the company’s channels are sufficiently varied to allow the employee to raise concerns across the management chain and through external channels operated by an independent third party.

There is evidence that the company’s channels allow for confidential and, wherever possible, anonymous reporting. They are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners, and in all relevant languages.

There is evidence that the company provides a training module that outlines the basic principles of the anti-bribery and corruption policy. There is also evidence that this training is provided to all employees and that they are required to refresh their knowledge on an annual basis. Based on the company’s Code of Business Conduct and Ethics, there is evidence that this training covers the whistleblowing options available to employees. Although it is not explicitly stated that training is provided in all countries and regions of operation, there is sufficient evidence to receive a score of ‘2’.

Based on publicly available information, there is evidence that employees in certain positions receive different or tailored anti-bribery and corruption training every two years.

However, the company receives a score of ‘1’ because it does not provide information on the types of positions that receive this tailored training, so it is not clear that it covers employees in high risk positions, middle management, nor board members.

There is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme.

However, the company receives a score of ‘1’ because the measures are limited to the number of personnel trained. There is no evidence that the company assures itself of this on at least an annual basis and it is unclear that results are used to update specific parts of the company's anti-bribery and corruption communications and training programme.

There is evidence that the company’s incentive schemes incorporate ethical and anti-bribery and corruption principles.

However, the company receives a score of ‘1’ as there is no evidence to suggest that incentives are designed to reward behaviour in line with the company’s ethical values as identified through performance appraisals or conduct in the workplace. It is also unclear whether the policy does not apply to high-risk employees, such as sales roles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

Based on publicly available evidence, the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents that explicitly applies to all employees across the organisation, including those employed by the group as third parties, including suppliers.

However, the company receives a score of ‘1’ as there is no evidence that it assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

Based on publicly available evidence, the company has multiple channels to report instances of suspected corrupt activity. These channels are sufficiently varied to allow the employee to raise concerns across the management chain and through a hotline operated by a external independent party. These channels allow for confidential and anonymous reporting. They are available and accessible to all employees in all relevant jurisdictions where the company operates, including those employed by the group as third parties, suppliers and in all relevant languages.

However, the company receives a score of ‘1’ because it is not clear that these channels are available to employees of joint ventures. There is also no clear evidence that the reporting channels may be used by employees to seek advice or ask questions about the company’s anti-bribery and corruption programme.

There is no evidence that the company provides anti-bribery and corruption training to its employees.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s employee incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

There is no publicly available evidence that the company has a policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is no evidence that the company provides either whistleblowing or advice channels for its employees to ask questions and raise concerns about suspected bribery or corruption.

There is insufficient evidence to suggest that the company provides anti-bribery and corruption training to all employees.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

The company states that it takes into account whether employees have complied with the Anti-Corruption Policy when considering employees for promotion. However, information is lacking on the breadth of the scheme and how financial incentives in high risk departments are handled.

There is no evidence that the company commits to support employees even where such actions result in a loss to the company.

There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, without making an explicit statement that this commitment also applies to individuals employed by the group as third parties, suppliers and joint venture partners.

There is no evidence that the company assures itself of its employees’ confidence in its non-retaliation commitment through surveys, usage data, or other clearly stated means.

There is clear evidence that the company has multiple channels to report instances of suspected corrupt activity, which allow for confidential reporting. However, there is evidence that the company only offers internally operated channels, and it is not evident that the company offers advice channels alongside whistleblowing channels, or anonymous reporting channels. The company also does not state that its channels are explicitly available to all employees in any country of operation, or in multiple languages, or to any employees of third parties, suppliers or joint venture partners.

There is no evidence that the company provides anti-bribery and corruption training for its employees.

There is no evidence that the company provides tailored anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company has a commitment to support or protect employees who refuse to act unethically.

There is no publicly available evidence that the company has a policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is no evidence that the company has either whistleblowing or advice channels for employees to report allegations or incidents of suspected bribery or corruption.

There is no publicly available evidence that the company provides anti-bribery and anti-corruption training to its employees.

There is no evidence that the company provides anti-bribery and corruption training to its employees, nor that it tailors this training to certain employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption training programme.

There is no evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles.

There is no publicly available evidence that the company commits to support and protect employees who refuse to act unethically.

There is no publicly available evidence that the company has a policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is evidence that the company provides confidential whistleblowing and reporting channels for its employees. The company indicates that reports may be made anonymously, but there is evidence that the company discourages anonymous reporting to avoid abuses of the channel.

However, the company receives a score of ‘1’ because there is no evidence that it provides employees with an external reporting channel, such as an independently operated hotline. There is also no evidence that reports made through the company’s channels are confidential. In addition, there is no clear evidence that these channels are available to all employees in any country of operation, or in multiple languages, or to any employees of third parties, suppliers or joint venture partners.

There is evidence that the company provides training on anti-bribery and corruption, which appears to include the whistleblowing options available to employees. However, it is unclear how frequently training is conducted and whether it is systematically provided to all employees across all divisions, all countries/regions of operation or in all appropriate languages.

There is no evidence that the company tailors its anti-bribery and corruption training for employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s employee incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is some evidence that the company commits to support and protect employees who refuse to act unethically. The company states that integrity and ethical principles are key corporate values and encourages employees to speak up if they have any concerns. However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this statement through anonymised surveys or other clearly stated means.

There is no publicly available evidence that the company has a policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is evidence that the company provides a whistleblowing line for employees to raise concerns or report suspected incidents of bribery or corruption. There is evidence that this channel allows for anonymous reporting.

However, the company receives a score of ‘1’ because there is no evidence that it provides an externally operated channel (i.e. one operated by a third party), nor is there clear evidence that reports are treated confidentially or that the channel can be used to seek advice on the company’s anti-bribery and corruption policy. There is also no clear evidence that the channel is available to all employees in any country of operation, in multiple languages, or to any employees of third parties, suppliers or joint venture partners.

Based on publicly available information, there is evidence that the company provides training that outlines the principles of the anti-bribery and corruption policy including the whistleblowing options available to employees. The company provides this training to all employees, across all divisions and countries of operation and in all appropriate languages. The company states that employees are required to undertake refresher trainings on the anti-corruption programme at least every two years.

There is evidence that the company tailors its anti-bribery and corruption training programme to the different levels of risk facing employees in different roles, with specific reference to those in high risk positions, middle management and board members. There is evidence that employees working in high risk positions are required to refresh their training in this area on at least an annual basis.

Based on publicly available information, there is evidence that the company reviews its anti-bribery and corruption communications and personnel training programme. The company assures itself of this on a continuous basis through the monitoring of training and there is evidence that results are used to update parts of the company's anti-bribery and corruption communications and training programme. The company indicates that its training programme is updated on this basis every two years.

Based on publicly available information, there is no clear evidence that the company’s incentive schemes for employees incorporate ethical and anti-corruption principles. The company states that it reviews its incentive structures to ensure that they do not undermine the its anti-corruption efforts and commitment, however it does not provide further details on the way in which such schemes are designed.

There is evidence that the company commits company to protect and support any employee who refuses to act unethically, in keeping with the company’s ethical and anti-bribery and corruption values and policy, even where such actions result in a loss of business or other disadvantage to the company. There is evidence that the company assures itself of its employees' confidence in this commitment through anonymised surveys.

Based on publicly available information, there is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. This policy applies to all employees across the organisation, including those engaged by the group as third parties, suppliers and joint venture partners. There is evidence that the company assures itself of its employees’ confidence in this commitment through surveys.

Based on publicly available information, there is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-corruption compliance programme. The company indicates that its channels are sufficiently varied to allow employees to raise concerns across the management chain and to external. These channels allow for confidential and, wherever possible, anonymous reporting.

In addition, there is evidence that the company’s channels are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners, and in all relevant languages.

Based on publicly available information, there is evidence that the company provides a training module for employees that outlines the basic principles of its ethics and compliance programme. There is evidence that training is provided for all employees across the company’s operations and geographies, and in all relevant languages.

However, the company receives a score of ‘1’ because it is not clear how often employees are required to refresh their training on this subject. There is also no clear evidence that the company’s training includes an overview of the whistleblowing options available to employees.

There is some evidence that the company provides tailored anti-bribery and corruption training for employees in different positions based on an assessment of their role and exposure to corruption risk. There is evidence that training is provided to employees in management positions, and the company indicates that employees in high risk positions must undertake periodic training.

However, the company receives a score of ‘1’ because there is no clear evidence that it provides tailored anti-bribery and corruption training to its board members. It is also not clear from publicly available information that employees in high risk positions specifically are required to refresh their training on an annual basis.

There is some evidence that the company measures the effectiveness of its anti-bribery and corruption communications and training programme, by indicating that it monitors the completion rates of its online training modules.

However, the company receives a score of ‘1’ because there is no evidence that it measures or reviews the effectiveness of its initiatives beyond completion rates, for example through dedicated questions in staff surveys or audits, on a regular basis.

Based on publicly available information, there is no evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles.

Based on publicly available information, there is evidence that the company commits to support employees who refuse to act unethically, even when it might result in a loss of business. However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this statement specifically through anonymised surveys or other clearly stated means.

Based on publicly available information, there is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is also evidence indicating that this commitment extends to the company’s business partners.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this commitment specifically through surveys, usage data, or other clearly stated means.

There is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme, including an external whistleblowing service operated by a third party. There is evidence that the company’s channels allow for confidential and, wherever possible, anonymous reporting and are available and accessible to all employees in all jurisdictions where the company operates. There is also evidence that the company’s channels are available in all relevant languages and to the company’s business partners.

There is no evidence that the organisation provides anti-bribery and corruption training to all employees.

There is no evidence that the organisation provides tailored anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the organisation measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the organisation’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the organisation commits to support or protect employees who refuse to act unethically.

There is no publicly available evidence that the organisation has a policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is no evidence that the organisation provides whistleblowing or advice channels for its employees.

There is some evidence that the company provides a training module that outlines the basic principles of its anti-bribery and corruption policy, including the whistleblowing options available to employees. The company states that training is delivered to all employees across all divisions and countries of operation, and in all appropriate languages. Although the company does not provide a specific timeframe, there is evidence that employees undertake training regularly (at least every three years).

There is evidence that the company tailors its anti-bribery and corruption training programme to the different levels of risk facing employees in different roles, with specific reference to the three categories of employee referred to in the question.

However, the company states that employees in high-risk positions must refresh their training in this area regularly but does not specify if this occurs on at least an annual basis.

There is evidence that the company reviews its anti-bribery and corruption communications and personnel training programme through KPI measures of participant and fulfilment rates. In addition, the company reviews the effectiveness of training through staff evaluations, surveys and workshops. The company commits to assuring itself of this on a continuous basis. There is evidence that the results of such reviews are used to update specific parts of the company's anti-bribery and corruption communications and training programme.

There is some evidence that the company incorporates ethical and anti-corruption principles in its incentive schemes for its employees and executives by way of ethical conduct evaluations as part of performance appraisals. The company states that incentives are denied on the basis of compliance infractions.

However, there is no evidence that the company ensures that financial rewards are proportionate to the salaries of high-risk employees. Although the company indicates that more detail on these measures can be found in an appendix, this document is not publicly available.

There is evidence that the company expects employees to act ethically, even if this could result in loss of business, and that it assures itself of employees’ confidence in this commitment through surveys.

There is evidence that the company promotes a policy of non-retaliation against whistleblowers who report concerns via its reporting system, which is open to all company employees and those employed by the group as third parties. There is evidence that the company assures itself of its employees’ confidence in this commitment through surveys.

There is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and to relevant external bodies. These channels allow for confidential and, wherever possible, anonymous reporting. They are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as external parties, and in all relevant languages.

Based on publicly available information, there is some evidence that the company provides compliance training and awareness activities for employees. The company indicates that this training outlines the basic principles of its Standards of Conduct and clearly states that it covers the whistleblowing and reporting options available to employees. There is some evidence to indicate that the company provides this training to all employees in all group companies, and in all relevant languages.

However, the company receives a score of ‘1’ because there is no clear evidence that employees are required to undertake and refresh their training on anti-corruption on an annual basis.

There is some evidence that the company provides tailored anti-bribery and corruption training for employees based on their role and exposure to corruption risk. The company states that senior management and executive officers receive training, and there is some evidence that employees in certain functions receive training on accounting compliance.

However, the company receives a score of ‘1’ because there is no clear evidence that the different training provided is tailored based on anti-bribery and corruption risk. There is also no evidence that employees in high risk positions must refresh their training in this area on an annual basis.

There is some evidence that the company reviews its anti-bribery and corruption communications and training programme. The company indicates that it does this through seminars and conversations with employees aimed at preventing compliance violations.

However, there is no clear evidence that the company conducts such reviews on at least an annual basis, nor is there evidence that the results of such reviews are used to update specific parts of the company's anti-bribery and corruption communications and training programme.

There is no publicly available evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles. The company provides some information on its compensation system for directors and executive officers, but there is no evidence that these incentives incorporate ethical principles and they do not apply to all employees.

There is no evidence that the company publicly commits to support or protect employees who refuse to act unethically.

There is no publicly available evidence that the company promotes a policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is evidence that the company provides whistleblowing and advice channels for its employees to report concerns and seek advice on its anti-corruption programme. The company indicates that these channels allow for confidential and anonymous reporting. There is evidence that these channels are sufficiently varied to allow employees to raise concerns across the management chain, directly to the Audit Committee and to an external attorney’s office.

However, the company receives a score of ‘1’ because there is no clear evidence that its channels are accessible and available to all employees in all countries of operation, or in multiple languages, or to employees of third parties or joint ventures. The company indicates that it provides a channel for suppliers, however it is not clear how this channel may be accessed.

Based on publicly available information, there is some evidence that indicates that the company provides training on laws relating to improper payments to government officials. However, there is no evidence that the company publishes any further information on its training programme and there is no clear evidence that the company provides anti-bribery and corruption training to all employees.

There is no evidence that the company tailors any anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no publicly available evidence to indicate that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

Based on publicly available information, there is evidence that the company reviews the incentive elements of its compensation arrangements to determine whether they encourage excessive risk-taking. However, there is no evidence that the company´s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is publicly available evidence to indicate that the company expects employees to act ethically. However, there is no specific evidence that the company commits to support or protect employees who refuse to act unethically, even when this might result in a loss of business.

Based on publicly available information, there is evidence that the company has a policy of non-retaliation against whistleblowers and employees who report bribery and corruption incidents.

However, the company scores ‘0’as there is no clear evidence that this policy applies to those employed by the group as third parties, suppliers and joint venture partners.

Based on publicly available information, there is evidence that the company has multiple channels to report instances of suspected corrupt activity and to seek advice on the company's anti-bribery and corruption programme. There is evidence that channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an external channel operated by an independent third party, and that these channels allow for confidential and, wherever possible, anonymous reporting. There is evidence that they are available and accessible to all employees in all jurisdictions where the company operates and in all relevant languages.

However, the company scores ‘1’ as there is no evidence as to whether these channels are available to the employees of third parties, including suppliers or joint venture partners.

There is no evidence that the company provides anti-bribery and corruption training to all employees.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect emplyees who refuse to act unethically.

There is some evidence to suggest that the company has a policy of non-retaliation against those who report allegations or incidents of bribery or corruption. However, the company receives a score of ‘0’ because the policy is unclear and there is no evidence that it applies to all employees company-wide and to those employed by the group as third parties, suppliers and joint venture partners.

There is evidence that the company has a whistleblowing channel.

However, the company receives a score of ‘1’ because there is no evidence that its channels are anonymous or confidential, or that the company has any externally operated channels. There is no evidence that the company has an advice channel. There is also no evidence that the company’s whistleblowing channels are available to all employees in any country of operation, in multiple languages, and to employees of third parties, suppliers or joint venture partners.

There is evidence that the company provides a training module outlining the basic principles of the anti-bribery and corruption policy, although there is no specific reference to training on the whistleblowing options available to employees. The company requires all new employees to take a mandatory briefing on the company’s anti-corruption programme and on relevant anti-corruption laws and regulations.

However, the company receives a score of ‘1’ because it does not explicitly state that training is provided systematically to employees across all its operations and geographic locations, and in all appropriate languages. Based on publicly available evidence, it is unclear how frequently training is conducted.

There is no evidence that the company provides tailored anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is some evidence that the company submits its anti-corruption training programme to regular reviews as part of audits and reviews of its wider programme. The company states that it adapts its training programme based on the reports of management and the corruption risks identified. There is also some evidence that the company monitors employee attendance at anti-corruption training events.

The company, however, receives a score of ‘1’ because it is not clear from publicly available information that the company has clear systems in place to measure the effectiveness of its anti-corruption training and communications programme, nor is it clear that such measures would be employed to enhance and improve the programme. There is also no evidence that it conducts this assurance on a regular basis.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence the company makes a specific public commitment to protect employees who refuse to act unethically, even when it might result in a loss of business.

There is some evidence the company commits to protecting and supporting both employees who report corruption incidents and whistleblowers across the organisation. There is some evidence the company’s whistleblowing line is open to third parties and it is inferred that the company’s policy of non-retaliation extends to these parties.

The company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company operates both whistleblowing and advice channels and that these channels allow for anonymous and confidential reporting. The company additionally states that these channels are available to business partners.

However, the company receives a score of ‘1’ because evidence indicates that the company offers only internally operated channels. There is also no evidence that these channels are available in all appropriate languages and in all countries of operation.

Based on publicly available information, there is evidence that the company provides a training module that outlines the basic principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees. The company states that all employees are required to complete anti-bribery training on an annual basis. In its 2019 Annual Report, the company indicates that 95% of its employees have completed the training, indicating that training is systematically provided to all employees, in all divisions and in all countries/regions of operation.

Based on publicly available information, there is evidence that employees in certain positions receive tailored anti-bribery and corruption training based on their roles or exposure to corruption risk. The company mentions that it provides dedicated training for employees in high-risk positions.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it provides tailored training for middle management and board members. The company also does not specify whether employees in high risk positions must refresh their training on at least an annual basis.

Based on publicly available information, there is some evidence that the company reviews its communications and personnel training programme. However, the company receives a score of ‘1’ because the measures appear to be limited to tracking training completion rates. There is no clear evidence that the results are used to update specific parts of the company's anti-bribery and corruption communications and training programme.

Based on publicly available evidence, there is no clear evidence that the company’s approach to employee incentive schemes is designed to incorporate ethical behaviour and discourage corrupt practices.

Based on publicly available information, there is some evidence that the company will support employees who refuse to act unethically. However, the company does not specify that it will do so even where such actions result in a loss of business to the company and there is no evidence that the company assures itself of its employees’ confidence in this statement through clearly stated means, such as surveys.

Based on publicly available information, there is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is some evidence indicating that this policy applies to all employees across the organisation, including those employed by the group as third parties.

However, there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

Based on publicly available information, there is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and to external parties through an independently-operated hotline. These channels allow for confidential and, wherever possible, anonymous reporting. There is some evidence indicating that the whistleblowing channels are available to all employees, including those employed by the group as third parties, and in all relevant languages.

There is evidence that the company provides a training module that outlines the basic principles of the anti-bribery and corruption policy, including the reporting channels available to employees. The company indicates that this training is provided to all employees, including those of subsidiaries and affiliated companies.

However, the company receives a score of ‘1’ because there is no evidence to indicate how frequently employees are required to undertake this training on anti-corruption. There is also no evidence that training is provided to all employees across all divisions, all countries and regions of operation or in all appropriate languages.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk. There is some indication that the company may provide individual training to employees involved in foreign activities, but it is not clear what this training might involve or how frequently it is conducted.

There is no evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles.

The company clearly states that any employee who refuses to act unethically, in keeping with the company’s anti-corruption commitments, will be protected and supported, even where such actions result in a loss of business or another disadvantage to the company.

However, there is no evidence that the company assures itself of its employees’ confidence in this statement through anonymised surveys or other clearly stated means.

There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. The company indicates that this policy applies to all employees across the organisation. It is noted that the non-retaliation policy applies to counterparties of the company, but it does not make specific reference to those employed as third parties, suppliers or joint venture partners.

The company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company provides whistleblowing channels for its employees, which are available to all employees in the organisation and to those employed by third parties.

However, the company receives a score of ‘1’ because the company only offers internally operated reporting channels and there is no evidence that employees may use these channels to seek advice in addition to reporting incidents. The company also indicates that anonymous reports are not allowed and will not be investigated. In addition, it is not whether the channels are available to all employees in any country of operation, or in multiple languages, or to employees of suppliers or joint venture partners.

There is some evidence that the company provides employees with anti-corruption training, which includes an explanation of the company’s policies and the law regarding anti-corruption.

However, the company receives a score of ‘0’ because it is not clear that the training covers the whistleblowing options available to employees, nor is there evidence to suggest that training is provided to all employees across all divisions or all countries regions of operation. Furthermore, there is no evidence to indicate how frequently training is conducted.

There is no publicly available evidence that the company provides tailored anti-bribery and corruption training to its employees based on an assessment of their role or exposure to corruption risk. The company states that the category of trainees should be taken into account when organising training, but it is unclear whether that includes the three categories of employee listed in the question, nor is it clear how frequently such training is provided.

Based on publicly available information, there is no evidence that the company measures or reviews the effectiveness of its communications or training on anti-bribery and corruption. The company states that it analyses the results of anti-corruption initiatives, but it is not clear that this includes measuring effectiveness, nor that it applies specifically to its employees understanding of its training and communications.

There is no evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

There is evidence that the company has a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. The company’s policies indicate that this applies to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners.

However, the company receives a score of ‘1’ because there is no evidence that it assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is some evidence that the company provides whistleblowing channels for its employees, which allow for anonymous reporting of allegations or incidents.

However, the company receives a score of ‘1’ because there is no evidence that the company provides an option for employees to report to an external or independent third party, nor is it clear that the channels may be used to seek advice on the company’s anti-corruption policies. There is also no clear evidence that these channels are available to all employees in any country of operation, or to any employees of third parties, suppliers or joint venture partners. The company does not indicate whether these channels are available in multiple languages.

There is no publicly available evidence that the company provides anti-bribery and corruption training to all its employees which outlines the available whistleblowing options. The Anti-Corruption Charter of Russian Business contains some limited information on this subject, but it is not sufficiently clear that the company has integrated this into its own anti-bribery and corruption framework, so this evidence is not considered in the assessment.

There is no publicly available evidence that the company provides tailored anti-corruption training to employees based on an assessment of their role and exposure to corruption risk. The Anti-Corruption Charter of Russian Business contains some limited information on this subject, but it is not sufficiently clear that the company has integrated this into its own anti-bribery and corruption framework, so this evidence is not considered in the assessment.

There is no publicly available evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme. The Anti-Corruption Charter of Russian Business contains some limited information on this subject, but it is not sufficiently clear that the company has integrated this into its own anti-bribery and corruption framework, so this evidence is not considered in the assessment.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no publicly available evidence that the company has established its own policy to support or protect employees who refuse to act unethically. The Anti-Corruption Charter of Russian Business contains some limited information on this subject, but it is not sufficiently clear that the company has integrated this into its own anti-bribery and corruption framework, so this evidence is not considered in the assessment.

There is no publicly available evidence that the company has a non-retaliation policy against whistleblowers or employees who report bribery and corruption incidents. The regulations established by its parent company state that employees using its hotline will not be subject to any sanctions; however it is not clear whether the company makes the same commitment regarding employees who report incidents through its own channels.

There is evidence that the company provides some whistleblowing and incident reporting channels, in addition to the whistleblowing service operated by its parent company. Although there is evidence that the parent company’s whistleblowing hotline allows for anonymous reporting, the company indicates that reports received through its own channels that are anonymous may not be investigated.

In addition, there is no clear evidence that these channels are available to all employees including those employed by third parties, suppliers or joint venture partners. There is also no evidence that the company provides channels through which employees can seek advice on the company’s anti-bribery and corruption programme, nor is there evidence that it provides channels for employees to raise concerns externally.

Based on publicly available information, there is some evidence that the the company provides training for its employees which outlines the principles of its anti-bribery and corruption policies.

However, the company receives a score of ‘1’ because there is no clear evidence that all employees must undertake this training, nor is it clear that such training covers the whistleblowing options available. It is also not clear that all employees must undertake and refresh their training in this area every three years.

There is no evidence that the company provides tailored anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no publicly available evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption communications or training programme.

There is no publicly available evidence that the company’s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles.

The company publishes a statement to indicate that no employee will suffer financial or career progression consequences for refusing to act unethically, even where such actions result in a loss of business or another disadvantage to the company.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this statement through anonymised surveys or other clearly stated means. In addition, the company does not clearly indicate in its published statement that it will support and protect employees who raise concerns or report incidents.

There is some evidence that the company has a publicly available policy of non-retaliation against employees who report bribery and corruption incidents which applies company wide.

However, it is not clear from publicly available information that this policy extends to whistleblowers. In addition, there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

There is evidence that the company provides internal whistleblowing and advice channels for its employees to raise concerns and report allegations or incidents of bribery and corruption. There is evidence that these channels allow for confidential and anonymous reporting.

However, there is no publicly available evidence that the company provides an external reporting channel for its employees, for example an ethics line operated by an independent third party. In addition, there is no clear evidence that these channels are available to all employees in any country of operation, or to any employees of third parties, suppliers or joint venture partners.

The company states that training forms a part of risk management procedures. However, there is no evidence that the company provides anti-bribery and corruption training to all employees.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

The company has a policy of non-retaliation against employees who report bribery and corruption incidents. However, the policy does not explicitly refer to whistleblowers, and it is unclear whether it applies to those employed by third parties, suppliers and joint venture partners. There is also no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

Although the company makes reference to the existence of a hotline, it provides no further details and therefore cannot receive a score of ‘1’.

There is evidence that the company provides training for employees that outlines the principles of its anti-bribery and corruption policy, including the whistleblowing options available. There is evidence the company provides this training to all employees annually, across all divisions and countries of operation, and in all appropriate languages.

There is evidence that the company provides tailored anti-bribery and corruption training based on the different levels of risk facing employees in different roles. The company states that it provides dedicated training to board members, employees in high-risk roles and middle management. There is evidence that employees in these categories must refresh their training on at least an annual basis.

There is evidence that the company measures and reviews the effectiveness of its anti-corruption training programme on an annual basis. The company indicates that it does this through anonymous employee surveys, the results of which are used to update specific elements of the training programme.

There is no evidence that the company’s incentive or reward schemes for employees incorporate ethical or anti-bribery and corruption principles.

Based on publicly available information, there is some evidence that the company commits to support and protect employees who refuse to act unethically. The company indicates that it supports its employees to make ethical decisions and maintain honesty and integrity in all business dealings, even when pressured by internal or external third parties to act unethically.

However, the company receives a score of ‘1’ because there is no clear evidence that it assures itself of its employees' confidence in this commitment through anonymised surveys or other clearly stated means.

There is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, as outlined in the company’s Code of Conduct. There is evidence the Code of Conduct applies to business partners of the company, including suppliers and joint venture partners.

However, the company receives a score of ‘1’ because there is no clear publicly available evidence that it commits to assure itself of its employees’ confidence in this commitment through surveys or other clearly stated means. This could include monitoring the usage statistics of whistleblowing channels across different parts of the organisation or conducting independent anonymised employee surveys.

There is evidence that the company provides multiple channels for its employees report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. There is evidence that the company’s channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an external helpline operated by an independent third party. These channels allow for confidential and, wherever possible, anonymous reporting.

In addition, the company indicates that its channels are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners. The company publishes copies of its Code of Conduct in various languages and there is evidence indicating that reports to its external helpline can be made in multiple languages.

There is some evidence that the company provides its employees with regular training, however it is not explicitly clear that this training covers anti-bribery and corruption. There is no evidence to indicate how frequently employees are required to undertake training, nor whether training is provided to all employees across all divisions and countries of operation, and in all appropriate languages.

There is no evidence that the company provides tailored anti-bribery and corruption training for employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures and reviews the effectiveness of its anti-bribery and corruption or compliance programme.

There is no evidence that the company’s incentive schemes for employees incorporate anti-bribery and corruption principles. There is some evidence to indicate that the promotion of an ethical culture forms part of the incentive structure for the company’s leadership, however there is no evidence that this applies across the organisation to all employees.

There is some evidence that the company commits to support and protect employees who refuse to act unethically, when where such decisions may result in a loss of business or profit. The company’s Guide to Business Conduct encourages employees to ask questions about workplace behaviour if necessary and states that employees should not deviate from company values in order to make a profit.

However, the company receives a score of ‘1’ because there is no evidence that it assures itself of its employees’ confidence in this statement through anonymised surveys or other clearly stated means.

There is evidence that the company has a publicly stated policy of non-retaliation against whistleblowers and employees who report concerns around unethical business practices.

However, the company receives a score of ‘1’ because there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means. There is also no clear evidence that this policy applies to those engaged by the group as third parties, suppliers and joint venture partners.

There is evidence that the company provides multiple channels for employees to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. There is evidence that these channels are sufficiently varied to allow the employee to raise concerns across the management chain and to external bodies through an independent third party hotline. These channels allow for anonymous reporting and there is evidence that they are available to employees in countries of operation where the company has a significant presence.

However, the company receives a score of ‘1’ because it does not indicate that reports are treated confidentially and there is no evidence that channels are available in all countries of operation or all appropriate languages. Moreover, although suppliers are able to use the whistleblowing line, there is no indication that third parties and joint venture partners are also invited to use the channels.

There is no evidence that the company provides anti-bribery and corruption training to all employees.

There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

There is no evidence that the company measures and reviews the efficacy of its anti-bribery and corruption training programme.

There is no evidence that the company has an incentive scheme for its employees that incorporates ethical or anti-bribery and corruption principles.

There is no evidence that the company commits to support or protect employees who refuse to act unethically.

There is no evidence that the company has a publicly available policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.

There is no evidence that the company provides whistleblowing or advice channels for its employees.