4. Conflict of Interest

There is no publicly available evidence that the company has a policy on conflicts of interest.

There is no publicly available evidence that the company has procedures in place to manage conflicts of interest or their oversight.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company formally addresses conflicts of interest as a corruption risk, and has a clear policy that defines conflicts of interest, including actual, potential and perceived conflicts. There is evidence that this policy explicitly covers all of the categories of possible conflicts listed in the guidance. There is also evidence that the company states that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities.

There is evidence that the company has procedures to manage conflicts of interest, including actual, potential and perceived conflicts. There is evidence that the Audit Committee is responsible for investigating potential violations of its conflict of interest policy, which is understood to extend to oversight of the policy implementation overall. The company states that disciplinary measures will apply if the conflicts of interest policy is breached.

However, the company receives a score of ‘1’ because there is also no evidence that all employee and board member conflicts of interest declarations are recorded in a dedicated central register that is accessible to those responsible for oversight of the process. Furthermore, there is no evidence that the company provides examples of criteria for recusals.

There is evidence that the company has a policy which outlines controls to assess and regulate employment and offers of employment or consultancy engagement to current and recently departed public officials. There is evidence that the company requires legal approval for the initiation of any employment discussions with current or former public officials. There is also evidence that restrictions can be placed on the activities of former public officials upon joining the company, including whether they can have contact or a relationship with their former organisation on the company’s behalf.

The company receives a score of ‘1’ because the publicly available evidence suggests that its policy applies specifically to the employment of current or former public officials in the United States. There is no publicly available evidence in relation to the company’s policy regarding the recruitment of public officials in other jurisdictions. In addition, there is no evidence that the company’s U.S. policy includes cooling-off periods.

It is noted that the company makes reference to a policy entitled Recruiting of Government Employees / "Revolving Door" Recruiting, but this does not appear to be publicly accessible.

There is no evidence that the company publishes details of the contracted services of serving politicians.

There is evidence that the company has a policy on conflicts of interest, which applies to all employees and board members. This refers to actual and potential conflicts, and covers employee relationships, financial interests and other employment.

However, the company does not refer to government relationships.

The company provides some information on its conflicts of interest procedures. Employees and directors are required to disclose potential conflicts to management, human resources or in-house counsel, and the company outlines certain approval processes. The company indicates that disciplinary measures apply for breaches of the company’s conflicts policy.

However, the company does not state that all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process. The policy also does not mention criteria for recusals from conflicts.

There is evidence that the company has a policy that addresses the risks associated with the employment of current or former public officials.

However, while the company refers to following its standard hiring processes when considering employing current of former public officials, its policy does not include any specific controls to assess and regulate the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company has a clear conflict of interest policy which refers to actual, potential and perceived forms of conflict. The company’s policy covers employee relationships, government relationships, financial interests and other employment and applies to all employees and board members, as well as the company’s subsidiaries and anyone acting on the company’s behalf.

There is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company indicates that employees must provide information on conflicts to the legal and ethics and compliance departments. Although not specific to conflicts of interest alone, the company indicates that any violation of the Code of Conduct may result in disciplinary action, up to and including termination of employment.

However, it is not clear based on publicly available information whether employees and board members are required to make conflict of interest declarations and whether these are held in a central register or database. The company also does not provide examples of possible criteria for recusals.

There is evidence that the company highlights the risk around employing current or former government employees or military personnel. The company’s policy stipulates that such individuals must be vetted by legal and human resources before the initiation of any employment discussions. Once hired or retained, the company indicates that those individuals may have their activities restricted which relate to their former employment.

However, based on publicly available information, it is unclear whether sign-off is required from a senior compliance officer or individual of equivalent seniority. The company also does not state whether it applies a cooling-off period of at least 12 months before individuals can have any form of contact or relationship with their former organisation on the company’s behalf.

There is no evidence that the company publishes details of the contracted services of serving politicians.

Based on publicly available evidence, the company has a policy on conflicts of interest which applies to all employees and board members. This policy covers actual, potential and perceived conflicts of interest and covers employee relationships, other employment, government relations and financial interests as possible categories of conflict.

Based on publicly available evidence, the company has procedures in place to identify, declare and manage conflicts of interest. This includes declaring the actual or perceived conflict to a line manager or to the Ethics and Compliance team, the latter of which provides oversight of these declarations. However, there is no evidence that all declarations are recorded in a central register. Additionally, there is no information regarding the possible criteria for recusals or potential punitive measures for breaches of the policy.

There is no evidence that the company has a policy regulating the employment of current or former public officials. Although the company acknowledges the need to comply with all applicable laws and regulations when hiring such individuals, there is no evidence of a policy with specific controls to regulate such interactions.

There is no publicly available evidence that the company reports details of contracted services of serving politicians.

There is no publicly available evidence that the company has a conflict of interest policy.

There is no publicly available evidence that the company has procedures to manage conflict of interest or their oversight.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is no evidence to suggest that the company has a policy on conflicts of interest.

There is no evidence that the company has procedures to manage conflicts of interest.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

The company has a policy for conflicts of interest that applies to all employees, and third parties.

However, there is no evidence that the policy covers all of the categories listed in the question, and it does not clearly define the types of relationships or conflicts covered under its policy.

While there is some evidence to suggest that the company has a policy to identify conflict of interest (whistleblowing channel) with clearly assigned responsibility over handling the reported cases, there is no evidence that there are further procedures to declare and manage conflicts of interest. The company does not state that all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process, and the policy does not mention examples of criteria for recusals and does not state that disciplinary measures will apply if breached. Therefore, there is no evidence that the company has sufficiently clear procedures in order to receive a score of ‘1’.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company has a conflicts of interest policy, which applies to all employees and board members, and covers actual, potential and perceived conflicts of interest. This policy covers conflicts relating to personal relationships, financial interests and outside employment.

However, the company receives a score of ‘1’ because its policy does not address conflicts of interest associated with government relationships.

There is some evidence to indicate that the company’s Corporate Governance Committee has a role in the oversight and management of conflicts of interest. However, the company receives a score of ‘1’ because it does not provide sufficient information on its specific procedures and mechanisms for identifying, declaring and managing conflicts of interest.

Based on publicly available information, there is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company publishes details of the contracted services of serving politicians.

There is publicly available evidence that the company has a policy on conflicts of interest, which makes specific reference to actual, perceived and potential conflicts of interest. There is evidence that the company’s policy covers employee relationships, financial interests and other employment.

However, the company receives a score of ‘1’ because there is no publicly available evidence that this policy covers conflicts associated with government relationships. In addition, there is evidence to indicate that the policies apply primarily to directors and managers; it is not clear that the same conflict of interest policies apply to all employees.

There is some evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts.

However, the company receives a score of ‘1’ because there is no evidence that all employee and board member declarations are held in a dedicated central register that is accessible to those responsible for oversight of the process. Based on publicly available evidence, it is not clear that a specific body or individual provides oversight and has accountability for handling cases. There is also no indication that the company provides examples of criteria for recusals, nor that disciplinary measures will apply for breaches of the policy.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is no evidence that the company has a policy on conflicts of interest.

There is no evidence that the company has procedures in place to manage conflicts of interest or their oversight.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company has a policy for conflicts of interest, which refers to actual, potential and perceived conflicts of interest. The company has procedures on conflicts of interest for employees and board members, and there is some indication that its approach covers possible conflicts arising from employee relationships and business relationships.

However, the company receives a score of ‘1’ because there is no evidence that its policy addresses and covers possible conflicts arising from government relationships, financial interests or outside employment.

Based on publicly available information, there is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company states that disciplinary measures will apply if its Anti-Bribery and Corruption Policy or Code of Conduct, which include its conflict of interest policy, are breached. The company indicates that director declarations are stored in a central register made available to the board, which has responsibility for managing director conflicts of interest.

However, the company receives a score of ‘1’ because there is no evidence that all employee conflicts declarations are held in a dedicated central register. It is also not clear whether a specific body or individual holds responsibility for oversight and accountability for handling conflicts of interests of all employees.

There is no publicly available evidence that the company has a policy or procedure regulating the appointment of directors, employees or consultants from the public sector.

There is no evidence that the company publicly reports details of any contracted services of serving politicians.

Based on publicly available information, there is evidence that the company has a policy defining conflicts of interest, including actual, potential and perceived conflicts. There is evidence that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities. The company’s policy makes specific reference to conflicts arising from employee relationships, financial interests, other employment and government relationships.

There is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. There is evidence that the Business Chief Counsel is responsible for handling conflicts and that the company records conflicts in a dedicated register that is accessible to those responsible for oversight of the process. The company’s Code of Conduct, which covers conflicts of interest, indicates that disciplinary action could apply if breached and provides examples of conflicts and recommended actions.

There is some evidence that the company addresses the risks associated with the employment of public officials. The company indicates that responsibility for compliance in this area sits with the Human Resources Director for each business.

However, the company receives a score of ‘1’ because there is no evidence that it publishes details of other controls in place to mitigate these risks. For example, there is no evidence that the company requires senior compliance officer (or equivalent) approval for the initiation of any employment discussions with former or current public officials, a review of actual, potential or perceived conflict of interest and restrictions on their activities if such conflicts of interest are identified.

In addition, although the company states that it follows government rules on appointments including cooling-off periods, there is no evidence that the company has a policy to implement a cooling-off period of at least 12 months before any public official is permitted to have any form of contact or relationship with their former organisation on the company’s behalf.

There is no evidence that the company publishes details of the contracted services of serving politicians.

There is evidence that the company has policies covering actual and perceived conflicts of interest, which apply to all employees and directors, including those employed by subsidiaries and the company’s other holdings. The policies cover conflicts of interest concerning the employment of current and former government officials, secondary employment, employee relationships and financial interests. There is also evidence that the company has an internal policy covering conflicts of interest, but this is not publicly accessible.

There is evidence that the company’s Nominating/Corporate Governance Committee is responsible for oversight of conflicts of interest within the organisation. However, the company provides insufficient information regarding its procedures for managing conflicts of interest to receive a score of ‘1’.

There is evidence that the company has a policy that addresses the risks associated with the employment of public officials.

However, the policy does not include any specific controls to assess and regulate the employment of current or former public officials, such as requiring senior approval for the initiation of employment discussions, undertaking a conflict of interest review and imposing restrictions on activities if risks are identified, or stipulating a cooling-off period of 12 months.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the institute recognises the potential risks posed by conflicts of interest by listing it as a reporting category on the EthicsPoint portal and providing a broad definition. However, the institute receives a score of ‘0’ because there is no evidence that the company has a formal policy on conflicts of interest that covers those actual, potential and perceived, as well as those stemming from certain relationships (e.g. government, financial, etc.).

There is no evidence that the institute has procedures in place to manage conflicts of interest or their oversight.

There is no evidence that the institute has a policy regulating the employment of current or former public officials.

There is no evidence that the institute reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company has a clear policy and procedure that defines conflicts of interest, including actual, potential and perceived conflicts. There is evidence that the policy explicitly covers employee relationships, government relationships, financial interests and other employment. The company states that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities.

Based on publicly available information, there is evidence that the company has clear procedures to identify, declare and manage conflicts of interest, actual, potential and perceived. This includes a statement that all employee and board member declarations of actual and potential conflicts of interest are recorded in a dedicated register that is accessible to those responsible for oversight of the process.

There is evidence that potential and actual conflict of interest declarations are reviewed and overseen by Ethics and Compliance Officers, and/or the Chief Ethics and Compliance Officer, who has ultimate accountability for implementation of the policy and handling of individual cases. The description of this procedure also includes examples of criteria for recusals and a description of the potential punitive measures for breaches of the policy.

There is evidence that the company has a policy which includes controls to assess and regulate employment and offers of employment or consultancy engagement to current and recently departed public officials. There is evidence that the policy requires senior compliance officer approval for the initiation of any employment discussions with former or current public officials, a review of conflict of interests, and restrictions on their activities if such conflicts of interest are identified.

However, there is no evidence that the company has a policy to implement a cooling-off period of at least 12 months before such public officials are permitted to have any form of contact or relationship with their former organisation on the company’s behalf.

The company publishes a clear statement that it does not contract serving politicians, so therefore receives a score of ‘2’.

There is no publicly available evidence to suggest that the company has a policy on conflict of interest.

There is no evidence that the company has procedures in place to manage conflict of interest or their oversight.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company has formal policies to address conflicts of interest, which apply to all employees and board members. The company’s policy covers actual and perceived conflicts of interest and specifically addresses potential conflicts arising from employee relationships, financial interests and other employment.

However, the company receives a score of ‘1’ because there is no clear evidence that its conflict of interest policy addresses potential risks associated with government relationships.

There is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual and perceived conflicts. The company states that disciplinary measures will apply if the policy is breached.

However, the company receives a score of ‘1’ because there is no evidence that all employee and board member declarations are held in a dedicated central register that is accessible to those responsible for oversight of the process. In addition, there is no clear evidence that there is a specific body or individual with oversight and accountability for handling all cases. There is also no evidence that the policy includes examples of criteria for recusals.

Based on publicly available information, there is some evidence that the company has a policy regarding the employment of current public officials. However, the company receives a score of ‘0’ because there is no evidence that this policy addresses conflicts of interest or that it includes specific controls to assess and regulate the employment of such individuals. There is also no evidence that this applies to former or recently departed public officials.

There is no evidence that the company publishes details of the contracted services of serving politicians.

There is publicly available evidence that the company has policies covering conflicts of interest, which include actual and potential conflicts and apply to all employees and board members. There is evidence that the policies cover possible conflicts relating to employee relationships, financial interests and other employment. However, the company receives a score of ‘1’ because there is no evidence that its policies address government relationships.

There is some evidence that the company has procedures to manage conflicts of interest, including disciplinary actions for breaches of the policy. However, these procedures are sufficiently unclear that they do not satisfy the requirements of score ‘1’.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company has a policy that addresses conflicts of interest and that defines actual, potential and perceived conflicts. There is evidence that this policy covers possible risks arising from employee relationships, government relationships, financial interests and other employment. There is evidence that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities.

Based on publicly available information, there is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. There is evidence that all employee and board member declarations of actual and potential conflicts of interest are recorded in a dedicated register that is accessible to those responsible for oversight of the process.

There is evidence that a dedicated team within the Ethics and Business Conduct organisation is responsible for implementation of the policy and the handling of individual cases. The company states that breaches of this policy may result in disciplinary action. Although the company only mentions recusals in the context of directors and corporate officers, there is sufficient accompanying evidence for the company to receive a score of ‘2’.

Based on publicly available information, there is evidence that the company has a policy that addresses the risks associated with the employment of current and former public officials. The company states that it will review potential conflicts arising from such appointments and require certain controls to be adopted, such as cooling off periods and lifetime bans from certain projects.

However, the company receives a score of ‘1’ because there is no clear evidence that it requires senior-level approval for the initiation of any employment discussions with former or current public officials.

The company publishes a clear statement that it does not contract or employ serving politicians.

There is evidence that the company formally addresses conflicts of interest as a corruption risk and that it covers actual, potential and perceived conflicts. The company’s policy clearly applies to all employees and board members, including those of subsidiaries and other controlled entities. In addition, there is evidence that the company’s policy addresses possible conflicts arising from personal financial interests, personal relationships and outside employment, and that it addresses government relationships.

There is some evidence that the company has procedures to identify, declare and manage conflicts of interest. The company indicates that employees must disclose any actual, potential or perceived conflicts to managers and to withdraw from activities where possible. The company’s policy also mentions examples of criteria for recusals.

However, the company receives a score of ‘1’ because there is no publicly available evidence that disciplinary actions will apply if this policy is breached, nor is there evidence that all employee and board member declarations are held in a dedicated central register that is accessible to those responsible for oversight of the process.

Based on publicly available information, there is evidence that the company has a policy that addresses the risks associated with the employment of public officials. There is evidence that the company has a system to implement additional approval and screening requirements when hiring former public officials. The company also states that it complies with all applicable laws and restrictions on post-U.S. government employment restrictions.

However, there is no publicly available evidence that the company’s policy includes further measures to reduce possible corruption or conflict of interest risks, such as a requirement for senior compliance officer (or equivalent) approval before the initiation of employment discussions, clear cooling off periods or restrictions on certain activities post-employment. It is noted that the company references a separate policy document that may contain further details on this subject, but it does not appear to be publicly available.

There is no evidence that the company publishes details of the contracted services of serving politicians.

There is evidence that the company formally addresses conflict of interest as a corruption risk, and that it has a clear policy in place that defines conflicts of interest, including actual, potential and perceived conflicts. There is evidence that the company’s policy addresses possible conflicts arising from employee relationships, government relationships, financial interests, outside employment. In addition, there is evidence that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities.

There is some evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company states that directors must notify the General Counsel if they become aware of any conflicts as outlined in its policy.

However, the company receives a score of ‘1’ because it does not provide further publicly available information on its procedures to declare and manage conflicts of interest. There is no publicly available evidence that all employee and board member declarations are held in a central register or database that is accessible by those with oversight of the process. In addition, there is no evidence that the company provides examples of criteria for recusals, nor does it clearly indicate that disciplinary measures will apply if its policy is breached. It is noted that the company’s publicly available information refers to separate policies on specific types of conflicts, but there is no evidence that these documents are publicly accessible.

There is evidence that the company has a policy with controls to assess and regulate the employment – as well as offers of employment or offers of consultancy engagement – of current and recently departed public officials. The company’s policy indicates that the General Counsel must give approval before the initiation of any employment discussions with former or current public officials. In addition, the company indicates that the Chief Executive Officer must give approval before any offers of employment to former military officers above a certain rank or former senior civilian officials.

However, the company receives a score of ‘1’ because it does not provide further publicly available information on whether it has procedures to conduct a conflicts of interest review prior to engagement, nor that the company may impose restrictions on their activities if such conflicts are identified. It is also not clear whether the company has a policy to implement a cooling-off period of at least 12 months before such public officials are permitted to have any form of contact with their former organisation on the company’s behalf. It is noted that the company states that it has a separate policy covering the employment of individuals from the public sector, but this document does not appear to be publicly available.

There is no evidence that the company publishes details of the contracted services of serving politicians.

There is evidence the company formally addresses conflict of interest as a corruption risk, and has a policy that defines conflicts of interest, including actual, potential and perceived conflicts. There is evidence that the policy explicitly covers all of the categories of possible conflicts listed in the guidance, and that it applies to all employees and board members, including those of subsidiaries and other controlled entities.

There is some evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts.

The company receives a score of ‘1’ because there is no evidence that all employee and board member declarations are held in a dedicated register or repository accessible to those responsible for handling cases. In publicly available evidence, the company also does not name a designated body or individual with specific responsibility for handling cases, nor does the company mention examples of criteria for recusals or state that disciplinary measures will apply if its conflicts of interest policy is breached.

There is some evidence that the company has a policy that addresses the risks associated with the employment of public officials.

However, the company receives a score of ‘1’ because there is no evidence that the company’s policy includes specific controls to assess and regulate the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is no evidence to suggest that the company has a policy on conflict of interest.

There is no evidence of procedures to manage conflict of interest or of their oversight.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company formally addresses conflicts of interest as a corruption risk, and has a clear policy that defines conflicts of interest, including actual, potential and perceived conflicts. The company states that this policy applies to employees and board members, including those of subsidiaries and other controlled entities. The policy covers employee relationships, financial interest and other employment.

However, the company receives a score of ‘1’ because the policy does not cover government relationships.

There is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts.

However, the company receives a score of ‘1’ because it does not state that all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process. There is also no reference to a specific body or individual with oversight and accountability for handling cases and the policy does not mention examples of criteria for recusals.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is no evidence to suggest that the company has a policy on conflicts of interest.

There is no evidence that the company has procedures to manage conflicts of interest or their oversight.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is no evidence that the company has a policy or procedure regulating conflicts of interest.

There is no evidence the company has procedures to manage conflicts of interest or their oversight.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

Based on publicly available information, there is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company formally addresses conflicts of interest as a corruption risk, and there is evidence that it has policies and procedures in place that define conflicts of interest, including those actual, potential and perceived. There is evidence that the company’s policy specifically addresses possible conflicts arising from personal relationships, outside employment and financial investments. The company states that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it addresses possible conflicts of interest relating to government relationships.

There is evidence that the company has procedures in place to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts.

However, the company receives a score of ‘1’ because there is no evidence that all employee and board member declarations are held in a dedicated central register that is accessible to those responsible for oversight of the process. In addition, there is no evidence that a specific body or individual has oversight and accountability for handling cases, nor that the company provides examples of criteria for recusals or state that disciplinary measures will apply if breached.

There is evidence that the company has a policy that addresses the risks associated with the employment of public officials.

However, the company receives a score of ‘1’ because there is no evidence that its policy includes specific controls to assess and regulate the employment of current or former public officials, beyond a commitment to take legal advice in order to ensure that it is compliant with laws. There is some indication that the company has a policy on Hiring Current and Former USG Employees, but this does not appear to be publicly available.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company has a clear policy that defines conflicts of interest, including actual, potential and perceived conflicts. The policy explicitly covers employee relationships, government relationships, financial interests and other employment. The policy applies to all employees of the company.

However, it is not clear whether this policy applies to board members.

There is evidence that the company requires employees to disclose potential conflicts of interest to their manager, Human Resources, Corporate Compliance or the Law Department. There is also some evidence that employees may make disclosures on the company website. Any violation of the Code of Business Conduct can result in various forms of disciplinary action for employees.

However, the company receives a score of ‘1’ because there is no reference to a specific body or individual with oversight and accountability for handling cases and it is not stated whether declarations are held in a dedicated register or central depository which is accessible to those responsible for oversight of the process. The company also does not mention examples of criteria for recusals.

There is no evidence that the company has a policy regulating the employment of current or former public officials, or that the company addresses the corruption risks associated with the employment of public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company formally addresses conflict of interest as a corruption risk, and that it has a policy that defines conflicts of interest, including actual, potential and perceived conflicts. The policy explicitly covers all the categories of possible conflicts listed in the question guidance. The company states that this policy applies to all employees and board members, including those of subsidiaries.

There is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company’s Code of Conduct describes potential punitive measures for breaches of the Code as a whole, which includes its policy on conflicts of interest.

However, the company receives a score of ‘1’ because there is no evidence that all employee and board member declarations are held in a dedicated central register that is accessible to those responsible for oversight of the process and the policy does not provide examples of criteria for recusals.

There is evidence that the company has a policy that addresses and acknowledges the risks associated with the employment of public officials. However, the company receives a score of ‘1’ because this policy does not include specific controls to assess and regulate the potential risks associated with the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is no clear evidence that the company has a policy to define and address conflicts of interest. There is some evidence that the company acknowledges some risks related to employee relationships and outside employment; however, this information is not sufficiently detailed to satisfy the requirements of score ‘1’.

There is no publicly available evidence that the company has procedures to manage conflicts of interest or their oversight.

There is no publicly available evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company has a policy for conflicts of interest.

However, the company receives a score of ‘1’ because there is no evidence that this policy differentiates between actual, potential and perceived conflicts, nor does it cover specific types of conflicts of interest, such as employee relationships, government relationships, financial interests or other employment. Furthermore, there is no evidence that the policy applies to board members.

It is noted that the company has a policy entitled ‘Personal & Business Integrity’ which may contain more information on conflicts of interest, but this does not appear to be publicly accessible.

Based on publicly available information, there is some evidence that the company has some procedures in place to manage conflicts of interest. The company indicates that it requires management approval in certain cases.

However, the company receives a score of ‘0’ because it does not provide further publicly available information on its controls and procedures in place to identify, declare or manage conflicts of interest.

There is no publicly available evidence to indicate that the company has a policy regulating the employment of current or former public officials.

There is no publicly available evidence to indicate that the company reports details of the contracted services of serving politicians.

There is some evidence that the company has a policy on conflicts of interest. The company’s Ethical Charter indicates that all employees should avoid direct or indirect conflicts where possible, and there is some evidence that this statement addresses possible conflicts arising from personal relationships and financial interests.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that this policy addresses conflicts possible conflicts arising from outside employment or government relationships. There is also no clear evidence to indicate that this applies to board members.

There is no publicly available evidence that the company has procedures to identify, declare and manage conflict of interest or to manage the oversight of any identified conflicts.

There is no publicly available evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company publishes details of the contracted services of any serving politicians.

There is evidence the company formally addresses conflict of interest as a corruption risk. The company’s Code of Ethics and Standards Business Conduct defines conflicts of interest, including actual, potential and perceived conflicts. The company’s policy covers conflicts in employee relationships, government relationships, financial interests and in secondary employment positions. There is evidence that the policy applies to all employees and board members, including those of subsidiaries and other controlled entities.

There is evidence the company has procedures to identify, declare and manage conflicts of interest, actual, potential and perceived. The company explicitly states that violations of its Code of Ethics and Standards of Business Conduct policy, which contains the company's conflict of interest policy, will lead to disciplinary action and possible termination. There is evidence that the company’s ethics and compliance department collects conflict of interest declarations from every employee and oversees the process of regulating and mitigating conflict of interest cases.

However, there is no publicly available evidence that all employee conflict of interest disclosures are recorded in a central register.

There is evidence that the company recognises the corruption risks associated with employing government officials. The company has a policy which includes controls to assess and regulate employment and offers of employment or consultancy engagement to current and recently departed public officials, including politicians. The policy requires the consultation and approval of the human resources and legal departments before initiating any employment discussions with present or past government officials.

However, the company does not state that it has a policy to implement a cooling-off period of at least 12 months before former public officials are permitted to have any form of contact or relationship with their former organisation on the company’s behalf. There is also no evidence that the company reviews the former state employee's position and past responsibilities to mitigate any potential conflict of interests arising as part of their work with the company.

There is no publicly available evidence that the company reports details of the contracted services of serving politicians nor that the company has a policy not to contract serving politicians.

There is evidence that the company has a conflict of interest policy for board members and it states that a similar policy applies to all employees of the group. There is evidence that the company addresses risks arising from personal relationships and some indication that it addresses financial interests, though this category is not fully defined.

The company receives a score of ‘1’ because, based publicly available information, there is no evidence that this policy covers actual, potential and perceived conflicts, nor whether explicitly applies to all employees, including those of subsidiaries and other controlled entities. In addition, there is no evidence that the company’s policy addresses other categories of conflict outlined in the scoring criteria, such as government relationships or other employment.

There is evidence that the company has procedures to identify and manage conflicts of interest. The company states that director interests are held in a dedicated register which is presented to the company’s shareholder on an annual basis, and there is an indication that a similar process applies to all employees.

However, the company receives a score of ‘1’ because it is unclear with there is a specific body or individual with oversight and accountability for handling cases. There is also no evidence that the company describes criteria for recusals, nor does it explicitly state that disciplinary measures will apply if the policy is breached.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence the company has a policy on conflicts of interest that applies to all employees company-wide. However, the company receives a score of ‘1’ because there is no publicly available evidence that its policy accounts for potential or perceived conflicts, nor is there evidence that it defines and addresses specific types of relationships that may present a possible conflict of interest risk.

There is no publicly available evidence that the company has procedures in place to identify, declare or manage conflicts of interest, nor is there evidence that a specific body or individual is responsible for oversight of this process.

There is no publicly available evidence that the company has a policy to regulate the employment of current or former public officials.

The company publishes a clear statement that it has not contracted the services of any serving politicians in the past 12 months.

There is evidence that the company has a conflict of interest policy which explicitly applies to all employees and board members. This covers actual, potential and perceived conflicts. It refers to all of the categories of conflicts listed in the question, namely employee and government relationships, financial interests and other employment.

There is no evidence that the company has procedures in place to manage conflicts of interest or their oversight.

There is evidence that the company has a policy that addresses the risks associated with the employment of public officials. The company requires employees to consult the legal or human resources departments before starting discussions about the potential employment of current or former public officials.

However, there is limited information on the specific controls in place to assess and regulate the employment of current or former public officials. It is not explicitly stated that sign-off is required from the company’s General Counsel. Additionally, although the company states that the activities of the official may be restricted after joining the company, it does not refer to a specific cooling-off period.

There is no evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company addresses conflicts of interest as a corruption risk, and has a policy that defines conflicts of interest, including actual, potential and perceived conflicts. There is evidence that the company’s policy addresses possible conflicts arising from employee relationships, financial interests and outside employment. In addition, the company’s policy makes reference to the possible conflict of interest risks arising from relationships with government officials.

Based on publicly available information, there is evidence that the company has procedures in place to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company indicates that its Compliance and Legal Departments are responsible for managing conflict of interest cases.

However, the company receives a score of ‘1’ because there is no publicly available evidence that all employee and board member declarations are held in a dedicated central register that is accessible to those responsible for oversight of the process. There is also no evidence that the policy provides examples of possible criteria for recusals, nor does it indicate that disciplinary measures will apply if the policy is breached.

Based on publicly available information, there is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company publicly reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company has policies that address and define conflicts of interest, including actual, potential and perceived conflicts. There is evidence that the policies explicitly cover all of the categories of possible conflicts listed in the guidance – employee relationships, government relationships, financial interests and other employment – and apply to all employees and board members, including those of subsidiaries and other controlled entities.

Based on publicly available information, there is evidence that the company has procedures to identify, declare and manage actual, potential and perceived conflicts of interest. There is evidence that managers and board members are required to complete declarations of conflicts of interest, which are reviewed by a designated body. The company states that disciplinary measures apply for breaches of its policies.

However, the company receives a score of ‘1’ because there is no evidence that all employees are required to make conflicts of interest declarations, nor that declarations are held in a dedicated central register. In addition, there is no evidence that the company’s conflict of interest policy provides examples of criteria for recusals.

Based on publicly available information, there is some evidence that the company has controls to assess and regulate the employment of current or former public officials to its board of directors. However, the company receives a score of ‘0’ because the company’s policy only appears to apply to appointments to the board. There is no evidence that the company has a broader policy regulating the employment of current or former public officials.

There is no evidence that the company publicly reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company has a policy defining actual and potential conflicts of interest. This policy defines several categories of possible conflicts including employee relationships and financial interests. There is evidence that the policy applies to all employees and board members.

However, the company receives a score of ‘1’ because there is no evidence that its policy addresses possible conflicts associated with government relationships and other employment. The policy also does not explicitly refer to perceived conflicts of interest.

Based on publicly available information, there is no clear evidence that the company has a procedure dedicated to identifying, declaring and managing conflicts of interests. Although the company states that possible conflicts of interest must be declared to the Group’s Compliance Department, the procedures beyond this are sufficiently unclear, based on publicly available information, that they cannot satisfy the requirements of score ‘1’.

Based on publicly available information, there is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company publishes details of the contracted services of serving politicians.

The company formally addresses conflicts of interest as a corruption risk, and has a policy that defines conflicts of interest, including actual, potential and perceived conflicts. The policy explicitly covers all of the categories of possible conflicts listed in the guidance. There is evidence that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities.

Based on publicly available information, there is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. All employee and board member declarations are held in a dedicated register that is accessible to those responsible for oversight of the process. The description of this procedure also includes examples of criteria for recusals and potential punitive measures for breaches of the policy. There is evidence that potential or actual conflict of interest declarations are reviewed and overseen by the Oversight Board.

There is evidence that the company has a policy which includes controls to assess and regulate consultancy engagements to current and recently departed public officials, including politicians. There is evidence indicating that the company undertakes a review of conflicts of interest and appointments require the approval of the company’s CEO. The company has a policy to implement a cooling-off period of 36 months before such public officials are permitted to have any form of contact or relationship with their former organisation on the company’s behalf. However, there is no clear publicly available evidence that the company has similar rules concerning the employment of current or former public officials.

The company does not publish details of the contracted services of serving politicians.

There is evidence that the company formally addresses conflict of interest as a corruption risk, and that it has a policy to clearly define conflicts of interest, including those actual, potential and perceived. There is evidence that this policy covers possible conflicts arising from employee relationships, financial interests, government relationships and other employment. The company indicates that the policy applies to all employees and board members, including those of subsidiaries and other controlled entities.

There is some evidence that the company has procedures to identify, declare and manage conflicts of interest, including those actual, potential and perceived. The company indicates that Human Resources, Corporate Compliance and the Law Department are jointly responsible for managing conflict of interest cases within the organisation, with the Chief Compliance Officer ultimately responsible for the system’s operation. There is evidence that employees are required to disclose potential conflicts when joining the company and as part of an annual compliance certification. The company states that disciplinary measures apply for breaches of this code.

However, the company receives a score of ‘1’ because there is no evidence that employee and board member declarations are held in a dedicated central register that is accessible to those responsible for oversight of the process. There is also no indication that the company provides examples of criteria for recusals.

There is evidence that the company has a policy that addresses the risks associated with the employment of public officials and specifies controls to assess and regulate such risks. The company’s policy states that employees must seek advice from both the Human Resources Department and the Law Department before initiating employment conversations with a government employee. There is also evidence that government employees must disclose any actual or potential conflicts upon joining the company and indicates that it may be appropriate to impose restrictions on the type of work individuals can perform, as a result of such disclosures.

Although the company does not explicitly state that it may implement a cooling-off period, there is evidence that the company commits to comply with national restrictions that may be imposed for a period of time after a senior government or contracting official leaves their position, and this is deemed sufficient to receive a score of ‘2’.

The company publishes a clear statement that it does not hire any current or serving government officials as consultants, directors or employees.

Based on publicly available information, there is evidence that the company has a policy which addresses conflicts of interest, including actual, potential and perceived conflicts. The policy covers conflicts of interest associated with employee relationships, financial interests and other employment. There is evidence the policy applies to all employees and executives across the group.

However, while the company has a policy on government relationships, there is no specific mention of the risks associated with conflicts of interest in these relationships.

Based on publicly available information, there is some evidence the company has procedures to manage conflicts of interest. Employees must report potential conflicts to their manager while the board of directors exercises oversight of potential conflicts of interest involving directors.

However, there is no evidence that all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process. The company’s policies also do not mention examples of criteria for recusals nor do they state that disciplinary measures will apply if breached.

Based on publicly available information, there is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company publicly reports details of the contracted services of serving politicians.

There is evidence that the company formally addresses conflicts of interest as a corruption risk, and that it has a policy that defines conflicts of interest, including actual, potential and perceived conflicts. The company’s policy clearly addresses possible conflicts arising from personal employee relationships, government relationships, financial interests and outside employment. There is evidence that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities.

There is evidence that the company has procedures in place to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company indicates that employee declarations are reviewed by a “designated risk leader” along with relevant managers, Human Resources (HR) and the legal counsel, while the Governance and Public Affairs Committee reviews any potential conflicts involving directors. There is evidence that employee and director declarations are held in a dedicated online register. The company provides some examples of criteria for recusals and there is evidence that disciplinary measures apply if the policy is breached.

There is evidence that the company has a policy which includes controls to assess and regulate employment and offers of employment or consultancy engagement to public officials. This policy prohibits employees from entering into employment discussions with government officials or individuals from the public sector while they can influence decisions relating to the company. In addition, there is evidence that the company has a policy to implement a cooling-off period of one to two years depending on the circumstance, in line with the mandatory requirements in a particular jurisdiction.

However, the company receives a score of ‘1’ because there is no clear evidence that it conducts a review of actual, potential or perceived conflicts of interest when any former government employees join the company, nor is it clear that the company may place restrictions on their activities if such conflicts are identified. It is noted that the company has a ‘Hiring From the Government Implementing Procedure’ which may contain more information, but this is not publicly available.

The company publishes a clear statement that it does not currently engage any serving politicians contracted as consultants. There is evidence that this statement accounts for the most recently reported financial year.

There is no publicly available evidence that the company has a conflict of interest policy.

There is no publicly available evidence that the company has procedures in place to manage conflict of interest or their oversight.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company has a policy that formally addresses conflicts of interest as a potential corruption risk and defines such conflicts, including those actual, potential and perceived. The company indicates that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities. The policy makes reference to financial interest, employee relationships and other employment situations.

However, the company receives a score of ‘1’ because there is no evidence that its policy covers possible conflicts arising from government relationships. Although the company has a procedure in place for hiring government officials in certain countries, this relates to legal restrictions rather than conflict interest risks.

There is evidence that the company has some procedures in place to identify, declare and manage conflicts of interest, including actual and perceived conflicts. The company indicates that employees and directors must disclose conflicts of interest to ethics officers within their relevant business unit. The company also provides some criteria for recusals and states that disciliplinary measures will apply if employees fail to disclose conflicts of interest.

However, the company receives a score of ‘1’ because there is no evidence that employee and board member declarations are held in a dedicated central register that is accessible to those responsible for oversight of the process. In addition, there is no evidence that a specific body or individual is responsible for oversight and has accountability for the handling of conflict of interest cases.

There is some evidence that the company has a policy that addresses the risks associated with the employment of public officials. The company’s policy notes that in some countries this practice may be prohibited, and indicates that employees must seek legal advice before recruiting, interviewing or hiring former government officials.

However, the company receives a score of ‘1’ because there is no evidence that the policy provides any further controls to assess and regulate the eployment of current or former public officials, such as stipulating a cooling-off period.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is no publicly available evidence that the company has a conflict of interest policy. The company publishes a statement about avoiding conflicts of interest, but this is insufficiently detailed. While the company’s Supplier Code of Conduct includes a conflict of interest statement, there is no evidence that this extends to GKN Aerospace employees.

There is no evidence that the company has procedures in place to manage conflicts of interest, which are overseen by a responsible body or individual.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is no publicly available evidence that the company has a conflict of interest policy.

There is no evidence that the company has procedures in place to manage conflicts of interest.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company has a policy that defines conflicts of interest, including actual and potential conflicts. The policy applies to all employees and board members, including those of subsidiaries and other controlled entities. The policy explicitly covers employee and government relationships, financial interests and other employment.

However, the company receives a score of ’1’ because there is no clear publicly available evidence that its policy covers perceived conflicts of interest.

Based on publicly available information, there is evidence that the company has procedures to declare and manage conflicts of interest, including actual and potential conflicts. The company indicates that the Compliance Team and the Audit Team are responsible for managing conflict of interest cases. The company states that disciplinary measures will apply if the policy is breached.

However, there is no evidence that all employee and board member declarations are held in a dedicated central register or database that is accessible to those responsible for oversight of the process. There is also no evidence that the company provides examples of criteria for recusals.

There is evidence that the company has a policy which includes controls to assess and regulate employment and offers of employment or consultancy engagement to current and recently departed public officials, including politicians. The company requires senior compliance office approval for the initiation of any employment discussions with former or current public officials. There is evidence that the company has a policy to implement a cooling-off period of at least 36 months before such public officials are permitted to have any form of contact or relationship with their former organisation on the company’s behalf.

The company publishes a clear statement that it does not hire or engage the services of serving politicians.

Based on publicly available information, there is evidence that the company has policies that define conflicts of interest, including actual, potential and perceived conflicts. The company’s policy clearly apply to all employees and board members and address possible conflicts arising from government relationships, outside employment, financial interests and employee relationships.

Based on publicly available information, there is some evidence the company has procedures to manage conflicts of interest, including actual, potential and perceived conflicts. The company states that employees are required to disclose potential conflicts to their manager, while directors must report potential conflicts to the Chairman of the board.

However, there is no evidence that all employee and board member declarations are held in a dedicated central register that is accessible to those responsible for oversight of the process. There is no evidence that a specific body or individual has overarching oversight and accountability for handling cases, nor that its policy provides examples of criteria for recusals or indicate that disciplinary measures will apply if breached.

Based on publicly available information, there is evidence the company has a policy that addresses the risks associated with the employment of public officials. The company’s policy stipulates that the compliance officer must give prior approval for the initiation of any employment discussions with former or current public officials.

However, the company receives a score of ‘1’ because there is no clear evidence that its recruitment process for current or former public officials includes a review of actual, potential or perceived conflicts of interest, or that restrictions may be placed on their activities if such conflicts of interest are identified. There is also no evidence that the company has a policy to implement a cooling-off period of at least 12 months before public officials are permitted to have any form of contact or relationship with their former organisation on the company’s behalf. It is noted that the company has a separate policy which may contain more information on its approach, but this document does not appear to be publicly accessible.

There is no evidence that the company publishes details of any contracted services of serving politicians.

There is no clear evidence to suggest that the company has a policy on conflict of interest. The company makes reference to conflicts of interest in its publicly available information on its hotline whistleblowing service; however, there is no evidence of a policy defining conflicts of interest across the company.

There is no evidence that the company maintains procedures to manage conflict of interest or of their oversight.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company has policies covering conflicts of interest, actual, potential and perceived, which apply to all employees, board members, and employees of the wider corporate group, as well as contractors and third parties. These policies cover potential conflicts of interest including personal relationships, financial interests and outside employment, as well as those linked to government relationships

The company states that all employees must report if a close relative has a role at a company in a business relationship with the company, and that board members must also declare interests which could constitute a conflict of interest.

However, the company cannot receive a score of ‘1’ as there is insufficient evidence that the company has in place procedures to identify, declare and manage all types of conflicts of interest across the organisation. There is also no evidence of a senior body or individual with responsibility for managing and overseeing the resolution of conflicts of interest within the organisation.

There is evidence that the company, an SOE, has a policy, based on government guidelines, which regulates the process by which its directors may join public sector companies. However, the company receives a score of ‘0’ because there is no evidence that it has a policy regulating the processes by which it might hire current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company formally addresses conflicts of interest as a corruption risk and that it has clear policies to define actual, potential and perceived conflicts. There is evidence that the company’s policy specifically addresses possible conflicts arising from outside employment, financial interests, dealings with family members and recruitment of former government officials. The company states that all employees and directors must adhere to its policies covering these risks.

Based on publicly available information, there is evidence that the company has procedures in place to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company states that employees can report any conflicts to the HR, Law, or Global Integrity and Compliance departments. The company also gives various examples of potential scenarios which highlight conflicts of interest.

However, the company receives a score of ‘1’ because there is no publicly available evidence that all employee and director conflict of interest declarations are held in a dedicated central register or database accessible to those with responsibility for oversight. There is also no clear evidence that breaches of the conflict of interest policy may result in disciplinary action; the company only states that conflicts of interest must be avoided. In addition, it is not clear that a specific body has ultimate oversight of all conflict of interest cases.

There is evidence that the company acknowledges the possible bribery and conflict of interest risks associated with the recruitment of government officials. The company indicates that employees must receive approval from the HR and Global Integrity and Compliance departments before appointing a current or former government official.

However, the company receives a score of ‘1’ because it does not provide further publicly available details on its procedures to mitigate the risks from such appointments, for example by implementing cooling-off periods, requiring a conflict of interest review and potentially imposing restrictions on the individual’s activities if any conflicts are identified.

There is no publicly available evidence that the company publishes details of the contracted services of serving politicians.

The company has a policy on conflicts of interest which refers to actual, potential and perceived conflicts. This policy is set out in the Code of Ethics and Business Conduct which applies to all employees and directors as well as non-employees who act on the company’s behalf in any capacity. The policy explicitly covers employee relationships, government relationships, financial interests and other employment.

The company indicates that it has a governance committee that has oversight of conflicts of interest. It also suggests that any violations of the Code of Ethics and Business Conduct, containing its conflicts of interest policy, are subject to disciplinary measures, including potential termination of employment. There is evidence indicating that the company’s Ethics and Business Conduct Office maintains all employee and board member conflicts of interest declarations in a central database. The company additionally provides examples of criteria for recusals.

There is evidence that the company has a policy that addresses the risks associated with the employment of US public officials. The company states that it will only hire former officials after one to two years of a cooling-off period. The company states that it requires permission from the legal department to initiate recruitment discussions with a background in the public sector. The company states that all potential public sector hires are screened to avoid scenarios which might appear to represent a conflict of interest. The above procedures relate to former US public officials, where the company does the vast majority of its business. The company states that in recruiting former officials of other jurisdictions it will apply measures consistent with anti-corruption policies and local legal and regulatory restrictions.

The company states that it has a policy to not contract serving US politicians. It also indicates that will only contract foreign serving politicians if there are no actual or perceived conflicts of interest. The company states that it does not currently contract any foreign or domestic serving politicians.

However, it is not clear that the company updates this information on an annual basis.

There is some evidence that the company has a policy for conflicts of interest, which covers employee relationships.

However, the company receives a score of ‘1’ because there is no publicly available evidence its policy covers potential or perceived conflicts of interest. There is also no evidence that the company’s policy makes reference to government relationships, financial interests and other employment. Based on publicly available information, it is not clear that the policy applies to all employees and board members.

Based on publicly available information, there is no clear evidence that the company has procedures to manage conflicts of interest or ensure their oversight. Where conflicts involve employee relationships, the company states that employees should consult with their supervisor or human resources team; but it is not clear that this applies to all conflicts of interest as part of a broader set of procedures.

There is no publicly available evidence that the company has a policy regulating the employment of current or former public officials.

There is no publicly available evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is no evidence that the company has a policy on conflicts of interest. The company includes a statement in its Code of Conduct that all employees should avoid conflicts of interest, but does not provide any further publicly available information on its policy to address and regulate any possible risks.

There is no publicly available evidence the company has procedures in place to identify, declare and manage conflicts of interest.

There is no publicly available evidence that the company has a policy regulating the employment of current or former public officials.

There is no publicly available evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence the company has a policy on conflicts of interest that refers to actual conflicts. The company’s policy also addresses possible conflicts arising from employee relationships and outside employment. There is evidence the policy applies to all employees and board members.

However, the company receives a score of ‘1’ because there is no publicly available evidence that its policy addresses possible conflicts associated with government relationships or financial interests. It is also not clear that the company’s policy for all employees applies to perceived or potential conflicts of interest.

Based on publicly available information, there is no evidence that the company has procedures to manage conflict of interest or their oversight. The company indicates that employees should avoid conflict of interest situations, but it does not provide further publicly available information on the procedures that it has in place to accompany its policy.

There is no publicly available evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company publishes details of the contracted services of any serving politicians.

There is no publicly available evidence to indicate that the company has a conflicts of interest policy.

There is no publicly available evidence to indicate that the company has procedures to manage conflicts of interest.

There is no publicly available evidence to indicate that the company has a policy regulating the employment of current or former public officials.

There is no publicly available evidence to indicate that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company has a policy that defines conflicts of interest. The company’s policy addresses actual and potential conflicts and makes clear reference to possible conflicts arising employee relationships and financial interests.

However, the company receives a score of ‘1’ because there is no publicly available evidence that its policy covers potential and perceived conflicts of interest, nor is there evidence that it addresses possible conflicts arising from government relationships or other employment.

There is evidence the company has procedures in place to identify, declare and manage conflicts of interest. The company indicates that its employees must report any actual or perceived conflicts of interest through the company’s Direct Channel, while the board reviews any conflicts associated with directors. Since the Compliance Unit is responsible for reviewing reports from the Direct Channel, there is some evidence that this body is responsible for the handling of cases. There is evidence that disciplinary measures will apply if the company’s policy is breached.

However, there is no clear evidence that all employee and board member declarations are held in a dedicated central register that is accessible to those responsible for oversight of the process. In addition, or employees, there is also no evidence that a specific body or individual with oversight and accountability for handling cases.

There is evidence that the company has a policy to regulate the hiring of any politically exposed persons, which stipulates additional controls to reduce the associated risks. However, in publicly available evidence the company does not provide further details on its policy or the controls that it has in place.

There is no evidence that the company publishes details of the contracted services of any serving politicians.

There is evidence that the company has a policy for actual and potential conflicts of interest, which refers to financial interests, employee relationships, and applies to all employees and board members.

However, in publicly available evidence, the company does not refer to perceived conflicts. It also does not refer to conflicts associated with government relationships or other employment.

Based on publicly available evidence, directors are required to make conflicts of interest declarations. The company also states that it has policies through which it manages and avoids conflicts of interest throughout the organisation. However, the company does not provide further clarifying information and its wider procedures for managing conflicts are therefore sufficiently unclear that they cannot satisfy the requirements of a score of '1'.

Based on publicly available information, there is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company publicly reports details of the contracted services of serving politicians.

There is no publicly available evidence that the company has a conflict of interest policy.

There is no publicly available evidence that the company has procedures in place to manage conflicts of interest or their oversight.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company formally addresses conflict of interest as a corruption risk, and has a clear policy to define actual, potential and perceived conflicts. The company indicates that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities. In addition, there is evidence that the company’s policy clearly addresses possible conflicts arising from employee relationships, financial interests and outside employment and government relationships.

There is evidence that the company has procedures in place to identify, declare and manage conflicts of interest. The company indicates that the Director of Business Conduct is ultimately responsible for reviewing and handling conflicts of interest when reported by employees, and states that senior executives must report specific conflicts as part of an annual compliance certification process. In addition, there is evidence that the Chief Executive Officer and Audit Committee review certain conflicts related to senior executives. The company also indicates that its policy includes examples of possible criteria for recusals and indicates that disciplinary actions may apply if this policy is breached.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that all employee and board member conflict of interest declarations are held in a central register that is accessible to those with oversight of the process.

There is evidence that the company has a procedure in place with controls to assess and regulate employment and offers of employment to current and recently departed public officials, including politicians. There is evidence that this policy requires approval from a HR representative or the Anti-Corruption Compliance team for the initiation of any employment discussions with former or current public officials, and a review of actual, potential or perceived conflict of interest.

However, the company receives a score of ‘1’ because there is no evidence that it provides further publicly available information on this procedure. There is no evidence that the company implements restrictions on the activities of the hired people if conflicts of interest are identified, nor is it clear that the company may require a cooling-off period of at least 12 months before such public officials are permitted to have any form of contact or relationship with their former organisation on the company’s behalf.

There is evidence that the company publishes a clear statement that it does not contract serving politicians.

There is no evidence to suggest that the company has a policy on conflict of interest.

There is no evidence that the company has procedures to manage conflicts of interest.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company has a policy for conflicts of interest that covers perceived conflicts of interest as well as specific categories of conflict such as employee relationships, financial interests and other employment. The policy applies to all employees and board members.

However, the company receives a score of ‘1’ because there is no evidence that its policy covers potential or actual conflicts, or conflicts that may arise from government relationships.

Based on publicly available information, there is evidence that the company has procedures to identify, declare and manage conflict of interest, including actual, potential and perceived, with oversight from the Law and Human Resources Department.

However, the company receives a score of ‘1’ because it does not state that all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process. The policy also does not indicate that disciplinary measure will apply of breached.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company has a policy on conflicts of interest that covers actual, potential and perceived conflicts. This policy applies to both employees and board members. It defines and describes financial interests and other employment as categories of potential conflict of interest risk.

However, the company receives a score of ‘1’ because its conflict of interest policy does not clearly define all types of relationship listed in the question guidance, such as employee and government relationships. It is also not clear whether this policy applies to those not directly employed by the company, such as those of subsidiaries and other controlled entities.

There is some publicly available evidence that the company has procedures in place to manage conflicts of interest; for example, its conflict of interest policy states that any actual or potential conflicts must be disclosed to a manager and receive approval.

However, there is no evidence that actual and potential conflict of interest declarations are held in a central register, nor that such declarations are reviewed and overseen by a designated body or individual with ultimate accountability for the management of the process. Moreover, the company does not provide any further detail on its criteria for recusals or the potential disciplinary measures for breaches of the policy.

There is no publicly available evidence to indicate that the company has a policy regulating the employment of current or former public officials.

There is no publicly available evidence to indicate that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company has a policy which covers actual conflicts of interest. The policy covers employee relationships and other employment. There is evidence the policy applies to all employees and board members.

However, in publicly available evidence, the company does not refer to potential or perceived conflicts, nor does it clearly cover conflicts associated with financial interests and government relationships.

Based on publicly available information, there is some evidence that the company has procedures in place to deal with conflicts of interest in certain instances.

However, the evidence is incomplete regarding a broader policy or set of procedures in place to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts, across all areas of its operations.

Based on publicly available information, there is some evidence that the company conducts some screening of civil servants before employment. However, there is no evidence that the company has a specific policy regulating the employment of current or former public officials.

There is evidence that the company publishes a statement that it does not enter into contractual relationships with current or serving politicians in the conduct of business.

There is some evidence that the company has a policy for conflicts of interest that applies company-wide.

However, the policy does not explicitly cover all of the categories of possible conflicts listed in the question. The company also does not clearly define the types of relationships or conflicts covered under its policy.

While the company states that employees must inform their manager of conflicts of interest, there is no further publicly available evidence concerning the company’s procedures for managing conflicts of interest and their oversight.

There is some evidence that the company has a policy that addresses the risks associated with the employment of public officials. The company states that human resources and compliance departments must review the hiring process for former government employees or their family members.

However, the company scores ‘1’ as publicly available evidence does not provide further details of specific controls to assess and regulate the employment of current or former public officials. There is no evidence that the company has a policy to implement a cooling-off period of at least 12 months before such public officials are permitted to have any form of contact or relationship with their former organisation on the company’s behalf.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence the company formally addresses conflicts of interest as a corruption risk, and that it has a clear policy to define conflicts of interest, including actual, potential and perceived conflicts. The company’s policy covers possible conflicts arising from government relationships, employee relationships, financial interests, and outside employment. There is evidence that this policy applies to all employees, directors and any third parties with which the company does business.

There is evidence the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company indicates that its Human Resources and Ethics and Compliance departments are responsible for reviewing conflicts of interest declarations and for the subsequent management of individual cases. In addition, the company states that disciplinary measures apply for violations of the company’s Code of Conduct, which outlines the company’s policy on conflicts of interest.

However, the company receives a score of ‘1’ because there is no clear evidence that it has a dedicated central register for all employee and board member declarations, which is accessible to the teams tasked with managing conflict of interest cases. The company also does not provide examples of possible criteria for recusals.

There is evidence that the company has a policy that addresses the risks associated with the employment of public officials. The company states that it requires a legal review prior to hiring former public officials, and indicates that employees must consult with management before initiating employment discussions with current or former government employees. There is some evidence to suggest that such pre-employment reviews include an assessment of actual or potential conflicts of interest.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it may impose restrictions on the activities of former public officials once appointed, based on the results of a conflict of interest review. There is also no clear evidence that the company requires a cooling-off period of at least 12 months before public officials are permitted to have any form of contact or relationship with their former organisation on the company’s behalf.

There is no evidence that the company publishes details of the contracted services of serving politicians.

There is evidence that the company formally addresses conflict of interest as a corruption risk, and that it has a clear policy that defines conflicts of interest, including actual, potential and perceived conflicts. The company’s policy clearly covers conflicts of interest concerning government relationships, outside employment opportunities and employee relationships. This policy applies to all company employees and board members.

There is evidence that the company has procedures in place to identify, declare and manage conflicts of interest, actual, potential and perceived. The company indicates that potential or actual conflict of interest declarations are reviewed and overseen by its ethics and compliance department, which is ultimately accountable for the handling and implementation of individual cases and mitigations. The company also provides examples of potential conflicts of interest which would lead to recusals. In addition, the company states that in the event that an identified conflict of interest concerning a director cannot be mitigated then the director would be required to resign.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that all employee and board member declarations of actual and potential conflicts of interest are recorded in a dedicated central register or database that is accessible to those responsible for oversight of the process. There is also no publicly available evidence that the company provides a description of potential punitive measures that may be applied for breaches of its conflicts of interest policy.

It is noted that the company indicates that it has separate policies on conflicts of interest and their review processes, which may contain further information, but these documents are not publicly available.

There is evidence that the company has a policy and accompanying procedures which include controls to assess and regulate employment and offers of employment or consultancy engagement to current and recently departed public officials. The company states that officials cannot discuss employment opportunities unless they have disqualified themselves from responsibilities in which they would be active in work concerning the company.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that its policy regulating the hiring of former government officials also applies to former and current politicians, including non-US government officials, nor that any discussion of employment opportunities with former or current public officials requires senior ethics and compliance officer sign off.

There is no evidence that the company publishes details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the has a policy that defines conflicts of interest, including actual and potential conflicts. The policy explicitly covers all of the categories of possible conflicts listed in the guidance. The company states that this policy applies to all employees and board members, including those at subsidiaries and other controlled entities.

Based on publicly available information, there is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual and potential conflicts. The Surveillance Body has oversight and accountability for handling cases. The policy mentions that disciplinary measures will apply if the Code of Ethics, in which conflicts of interest is regulated, is breached. The company indicates that all conflict of interest declarations must be submitted to the Surveillance Body.

Based on publicly available information, there is evidence that the company has a procedure which includes controls to assess and regulate employment and offers of employment or consultancy engagement to current and recently departed public officials, including politicians. There is evidence indicating the policy requires the involvement of the Senior Compliance Officer in employment discussions with former or current public officials, a review of conflict of interest and restrictions on their activities if such conflicts of interest are identified.

In accordance with Italian law, the company has a policy to implement a cooling-off period of at least three years before public officials are permitted to have any form of contact or relationship with their former organisation on the company’s behalf. However, there is no clear evidence that this requirement extends to all of the company’s countries of operation.

The company publishes a clear statement that it does not contract serving politicians in all countries of operation.

There is evidence that the company has a policy for actual conflicts of interest. The policy covers financial interests, other employment, and employee relationships. The policy applies to all employees.

However, the company receives a score of ‘1’ because it does not explicitly cover potential or perceived conflicts and it does not mention government relationships. It is also not clear whether the policy applies to board members.

There is evidence that the company has procedures to identify, declare and manage actual conflicts of interest, and that the Compliance department has oversight and accountability for handling cases.

However, the company receives a score of ‘1’ because it does not state that all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process. Additionally, the policy does not mention examples of criteria for recusals and does not state that disciplinary measures will apply if the policy is breached.

There is no evidence that the company has a clear policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company formally addresses conflicts of interest as a corruption risk, and has a clear policy that defines conflicts of interest, including actual, potential and perceived conflicts. The policy explicitly covers all of the categories of possible conflicts listed in the scoring guidance, namely employee relationships, government relationships, financial interests and other employment. The company’s policy applies to all employees and board members, including those of subsidiaries and other controlled entities.

There is evidence that the company has procedures in place to identify, declare and manage actual, potential and perceived conflicts of interest. The company requires that employees make a written disclosure of conflicts, and states that disciplinary measures will apply if the company’s policies are breached. Potential conflicts of interest are held in a dedicated online depository. All employees have access to this depository, including the company’s Legal Department, which has ultimate oversight and accountability for the handling of individual cases. The policy mentions some examples of criteria for recusal, though detail is limited since the policy is not publicly available.

There is evidence that the company has a policy which includes controls to assess and regulate employment and offers of employment or consultancy engagements to current and recently departed public officials, including politicians. The company requires a conflict of interest review before an employment or consulting offer is made to a current or former government employee. The company’s Legal Counsel is responsible for advising on post-employment restrictions, which may include permanent or one to two-year post-employment procedures. These restrictions may include a cooling-off period before public officials are permitted to have any form of contact or relationship with their former organisation on the company’s behalf.

There is evidence that the company does not contract the services of acting or serving politicians due to national laws.

However, it is not clear that the company prohibits such engagement as a matter of principle, even in countries where such activities are not prohibited by law.

There is evidence the company has a policy that defines conflicts of interest, including actual and potential conflicts. The company’s policy clearly covers possible conflicts arising from employee and government relationships, financial interests and other employment. There is evidence this policy applies to all employees and board members.

However, the company receives a score of ‘1’ because there is no publicly available evidence that this policy includes perceived conflicts, nor is it clear that it applies to the company’s subsidiaries and other controlled entities. It is noted that the company has an additional policy on conflicts of interest - ManTech policy CG 306 – Personal Conflict – but this does not appear to be publicly available.

There is evidence the company has procedures in place to identify, declare and manage conflicts of interest, including actual and potential conflicts.

However, the company receives a score of ‘1’ because there is no evidence that all employee and board member declarations are held in a dedicated central register or database that is accessible to those responsible for oversight of the process. There is also no clear evidence that disciplinary measures will apply if the company’s policy on conflicts of interest is breached. It is noted that the company has an additional policy on conflicts of interest – ManTech policy CG 306 – Personal Conflict – but this does not appear to be publicly available.

There is evidence that the company has a policy that addresses the risks associated with the employment of public officials. The company’s policy states that employees are required to obtain permission from the company’s Human Resources Department before engaging in employment discussions with current or former government employees.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it has a policy to implement a cooling-off period of at least 12 months before such public officials are permitted to have any form of contact or relationship with their former organisation on the company’s behalf. In addition, although the company states that it will comply with legally-required employment restrictions, it is not clear that the company may impose its own restrictions to prevent conflicts of interest with former government officials.

There is no publicly available evidence that the company reports details of the contracted services of serving politicians.

The institute formally addresses conflicts of interest as a corruption risk, and has a clear policy and/or procedure that defines conflicts of interest, including actual, potential and perceived conflicts. The policy explicitly covers multiple categories of possible conflicts listed in the guidance. The institute states that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities.

The institute has clear procedures to identify, declare and manage conflicts of interest – including those actual, potential and perceived – relating to financial interests. This includes a statement that all employee and board member declarations of actual and potential conflicts of interest are recorded in a dedicated register that is accessible to and reviewed by those responsible for oversight of the process. The description of this procedure also includes examples of criteria for recusals and a description of the potential punitive measures for breaches of the policy.

However, the institute receives a score of ‘1’ because it is not clear that such detailed procedures are followed for other forms of conflicts of interest. Although there seem to be informal mechanisms in place for managing other conflicts of interest, there is insufficient evidence for these to be considered formal management channels.

There is no evidence that the institute has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company has a policy on conflicts of interest which applies to all employees and covers actual, potential and perceived conflicts. However, there is no publicly available evidence that the company’s policy addresses the risks arising from specific categories of conflicts, such as employee and government relationships, financial interests and other employment.

There is no clear evidence that the company has procedures in place to identify, declare and manage conflicts of interest. The company indicates that employees must disclose potential conflicts to their manager, but it does not provide further details on its management or oversight systems.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company publishes details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company has a formal policy which defines conflicts of interest, including actual, potential and perceived conflicts. The company’s policy clearly addresses possible conflicts arising from employee relationships, financial interests and other employment. The policy applies to all employees and board members.

However, there is no clear evidence that the company’s policy addresses possible conflicts arising from government relationships. It is noted that the company references a document with specific standards of business conduct for those working on United States government contracts; but this does not appear to be available in the public domain and it is not clear that this would apply Group-wide.

Based on publicly available information, there is some evidence the company has procedures to identify, declare and manage conflicts of interest. The company states that it conducts an annual conflict of interest survey to identify any actual or potential conflicts, and there is evidence that it maintains a conflict of interest register for board members. The company indicates that disciplinary measures will apply if the company’s policy is breached.

However, the company receives a score of ‘1’ because there is no evidence that it has a conflict of interest register in place for employee declarations; the company’s publicly available information indicates that its register is specifically for conflicts relating to the board. In addition, it is not clear from publicly available information which individual or body holds oversight and accountability for handling all conflict of interest cases.

There is no publicly available evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company publishes details of the contracted services of serving politicians.

There is evidence that the organisation has a policy that formally requires employees to avoid any actual or perceived conflicts of interest. The organisation states that this includes both personal and business relationships, and there is evidence that this applies to all employees and third parties.

However, the organisation receives a score of ‘1’ because it does not provide any further information on potential categories of conflicts – e.g. government relationships, financial interests, etc. – and it does not explicitly state that this policy applies to all board members.

There is no publicly available evidence that the organisation has procedures to manage conflicts of interest or their oversight. The organisation requires all employees to avoid actual or perceived conflicts but does not provide further information on specific procedures to identify, declare or manage conflicts of interest.

There is no evidence that the organisation has a policy regulating the employment of current or former public officials.

There is no evidence that the organisation reports details of the contracted services of serving politicians.

There is no evidence to suggest that the company has a policy to regulate conflicts of interest.

There is no evidence that the company has procedures to manage conflict of interest or their oversight.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence the company has a formal policy on conflicts of interest, which refers to actual, potential and perceived conflicts of interests. There is evidence that the policy applies to all employees and board members across the company, including those employed by subsidiaries and controlled entities. In addition, there is evidence that the company’s policy addresses possible conflicts of interest related to employee relationships, financial interests and other employment.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that its policy addresses possible conflicts arising from government relationships.

Based on publicly available information, there is evidence the company has procedures in place to identify, declare and manage conflicts of interest. There is evidence that the company’s Legal Department is responsible for the appropriate management and handling of conflicts of interest cases, and that disciplinary measures apply for breaches of the policy.

However, the company receives a score of ‘1’ because there is no publicly available evidence that all employee and director declarations are held in a dedicated central register that is accessible to the Legal Department. There is also evidence that the company provides examples of criteria for recusals.

There is no publicly available evidence that the company has a policy regulating the employment of current and former public officials.

There is no evidence that the company publishes details of the contracted services of serving politicians.

There is evidence that the company has a policy covering actual and perceived conflicts of interest, which applies to all employees and board members. The company makes explicit reference to possible conflicts concerning other employment, and, for its senior executives, personal relationships.

However, the company receives a score of ‘1’ because there is no evidence that the policy includes conflicts concerning financial interests, employee relationships, or government relationships for all employees.

There is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company states that for directors, the Audit Committee is responsible for handling declarations of conflicts of interest, and provides criteria for recusals for directors.

However, it is not clear whether these same controls apply to all employees, and the company does not state that all declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company has a policy for conflicts of interest that explicitly applies to all employees and board members. Based on the company’s publicly available information, there is evidence that this policy addresses conflicts that might arise from employee relationships, financial interests and other/outside employment.

However, the company receives a score of ‘1’ because there is no evidence that its policy specifically addresses or covers government relationships.

There is evidence that the company has some procedures in place to identify, declare and manage conflicts of interest, which include reporting any potential conflicts to management and review of business assignments if a conflict arises.

However, the company receives a score of ‘0’ because its conflict of interest procedure does not include further details of specific controls to identify, declare and manage conflicts. For example, there is no evidence that a specific body or individual has oversight and accountability for handling cases, nor that employee declarations are held in a central register accessible by those responsible for oversight of the process. There is also no evidence that the company outlines criteria for recusals, though this information could possibly be provided in the training module on conflicts of interest. The company provides details of how any ethical concerns are handled, but it is not clear that this includes a specific procedure to handle conflicts of interest.

Based on publicly available information, there is no evidence to indicate that the company has a policy regulating the employment of current or former public officials.

Based on publicly available information, there is no evidence to indicate that the company reports details of the contracted services of serving politicians.

The company has a policy for conflicts of interest which applies to all employees and board members. The policy refers to actual, potential and perceived conflicts and as well as conflicts associated with employee relationships, financial interests, government relationships, and other employment.

There is evidence that the company has procedures for identifying, declaring and managing conflicts of interest. The company’s public documents refer to an individual conflict of interest declaration which can be completed. Potential or actual conflict of interest declarations are reviewed and overseen by the Remuneration, Appointments, Ethics and Corporate Social Responsibility Committee, which is ultimately accountable for handling individual cases. The company mentions criteria for recusals and states that disciplinary measures also apply if employees breach the company’s policy on conflicts of interest.

However, there is no evidence that all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

Based on publicly available information, there is no evidence that the company has a clear policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company has a policy that covers conflicts of interest, which refers to actual, potential and perceived conflicts arising from employee relationships, financial interests and other employment. There is evidence that this policy applies to all employees and board members.

However, the company receives a score of ‘1’ because its policy does not clearly cover conflicts which arise from government relationships.

There is evidence that the company has procedures to identify, declare and manage conflicts of interest, actual, potential and perceived. There is evidence that declarations of conflicts of interest are recorded in a dedicated register and that they are reviewed and overseen by a designated body with ultimate accountability for the handling of individual cases. The company states that disciplinary actions will apply if its policy is breached and also gives examples of criteria for recusals.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is no evidence to suggest that the company has a policy on conflicts of interest.

There is no evidence that the company has a conflict of interest policy, nor a procedure to manage conflicts of interest or of their oversight.

There is no evidence that the company has a conflict of interest policy, nor a policy regulating the employment of current or former public officials.

There is no evidence that the company has a conflict of interest policy, nor that the company reports details of the contracted services of serving politicians.

The company has a policy for conflicts of interest which applies to employees and directors of the company. This covers actual, potential and perceived conflicts. The policy covers employee relationships, financial interests and other employment.

However, the company does not refer to government relationships.

The company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. This includes disciplinary measures for breaching the company’s procedures.

However, the company does not state that all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process. There is also no reference to a specific body or individual with oversight and accountability for handling cases and the policy does not mention examples of criteria for recusal.

There is no publicly available evidence that the company has a policy regulating the employment of current or former public officials.

There is no publicly available evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company has a policy that addresses and defines conflicts of interest, including actual, potential and perceived conflicts. The company’s policy clearly covers possible conflicts arising from employee and government relationships, as well as financial interests and other employment. The company’s policy applies to all employees and board members.

There is some evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company states that any actual or potential conflicts must be immediately disclosed and indicates that the relevant manager, ethics office, law department and the General Counsel may be involved in the handling of cases.

However, the company receives a score of ‘1’ because it does not provide further details on its management of conflict of interest cases. There is no evidence that employee and board member declarations are held in a central register that is accessible by those responsible for oversight of the process, nor is it clear that disciplinary measures will apply if the policy is breached. In addition, the company lists several individuals or departments that may be able to advise on possible conflict of interest issues, but does not provide any clear evidence that a designated senior individual or central body is responsible for oversight and accountability of the process.

There is some evidence that the company has a policy that addresses the risks associated with the employment of public officials. The company’s policy includes pre-employment screening procedures, cooling off periods and activity restrictions once the individual has joined the company.

However, the company receives a score of ‘1’ because it does not provide further details on the controls that it may implement to reduce risks. Although the company indicates that employees should be careful when engaging in pre-employment discussions with current or former public officials, there is no evidence that it requires senior sign-off before the initiation of such discussions. In addition, there is no indication that the company stipulates the duration of its cooling off periods, nor is it clear that such procedures would apply in all jurisdictions including those where such periods are not directly required by law.

The company publishes a clear statement that it does not retain the services of serving politicians.

There is evidence that the company formally addresses conflicts of interest as a corruption risk, and that it has a policy and procedure that defines possible conflicts, including those actual, potential and perceived. There is evidence that the policy covers employee relationships, financial interests and other employment. However, the company receives a score of ‘1’ because there is no evidence that its policy references or addresses government relationships as a possible category of conflict.

There is some evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company indicates that the Compliance Office is responsible for this process.

However, the company receives a score of ‘1’ because there is no evidence that all employee and board member declarations are held in a central register that is accessible to those responsible for oversight of the process. There is also no evidence that the policy mentions examples of criteria for recusals or that it states that disciplinary measures will apply if breached.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is no publicly available evidence that the company has a policy on conflict of interest.

There is no evidence that the company has procedures to manage conflict of interest or their oversight.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company has a policy on conflicts of interest, which covers actual, potential and perceived conflicts. The policy refers to employee relationships, financial interests and external employment as categories of conflict. The policy applies to all employees and board members, including those of subsidiaries and other controlled entities.

However, there is no publicly available evidence that the company’s policy covers conflicts of interest related to government relationships.

There is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. There is evidence that the Global Ethics & Compliance department has oversight and accountability for handling cases. There is evidence that all employee and board member declarations are held in a dedicated central depository that is accessible to those responsible for oversight of the process. The description of this procedure also includes examples of criteria for recusals and a description of the potential punitive measures for breaches of the policy.

There is evidence that the company has a policy and/or procedure, which includes controls to assess and regulate employment and offers of employment to former public officials. As a minimum, the policy requires senior compliance officer (or equivalent) approval for the initiation of any employment discussions with former or current public officials, a review of actual, potential or perceived conflict of interest and restrictions on their activities if such conflicts of interest are identified. There is also evidence that the company has a policy to implement a cooling-off period of at least 12 months before such public officials are permitted to have any form of contact or relationship with their former organisation on the company’s behalf.

There is no evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company has a policy for conflicts of interest covering both actual and potential conflicts. There is evidence indicating that the policy covers employee relationships and financial interests, and there is evidence that the policy applies to all employees and board members including those at subsidiaries.

However, there is no evidence that the company’s policy addresses perceived conflicts. There is also no clear evidence that its policy covers possible conflicts arising from government relationships and other employment.

Based on publicly available information, there is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual and potential conflicts. The company indicates that its General Counsel oversees the handling of cases and that disciplinary measures apply if the policy is breached.

However, there is no evidence that the policy mentions examples of criteria for recusal. In addition, although the company states that it maintains a register of related parties, there is no clear evidence that all employee and board member conflict declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

There is no publicly available evidence that the company has a policy regulating the employment of current or former public officials.

There is evidence that the company publicly reports details of the contracted and retained services of serving politicians, including the name and position of the individual, the services for which they have been retained and fees paid to each individual. There is evidence that this list is updated on an annual basis.

There is evidence the company has a policy that defines conflicts of interest, including actual, potential and perceived conflicts. The policy explicitly covers all of the categories of possible conflicts listed in the guidance, namely employee and government relationships, financial interests and other employment. The company states that this policy applies to all employees and board members, and those conducting work on its behalf.

There is some evidence the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company states that employees should consult their manager, the Human Resources Department, the Ethics and Compliance Officer or Legal Department if they are uncertain about the company’s policies and procedures. Disciplinary measures apply to individuals which breach the company’s code of conduct.

However, there is no reference to a specific body or individual with oversight and accountability for handling cases, nor is there evidence that all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process. The policy also does not mention examples of criteria for recusals.

There is evidence that the company has a policy that addresses the risks associated with the employment of public officials. The company states that it conducts screening of current and former government employees.

However, there is no evidence that the company has a policy to implement a cooling-off period of at least 12 months before such public officials are permitted to have any form of contact or relationship with their former organisation on the company’s behalf. There is also no evidence the company requires senior compliance officer (or equivalent) approval for the initiation of any employment discussions nor that it conducts a review of actual, potential or perceived conflicts of interest.

There is no evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is no evidence that the company has a policy on conflict of interest.

There is no evidence that the company has procedures to manage conflicts of interest or their oversight.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company has a policy for conflicts of interest that covers actual conflicts of interest. There is evidence that the policy defines financial interests, other employment and government relationships and applies to employees and directors.

However, there is no evidence that the company’s policy mentions potential or perceived conflicts of interest, or that it covers employee relationships as a possible conflict.

There is evidence that the company requires its employees and board members to obtain approval before engaging in activities that may cause a conflict of interest.

However, the company scores a score of ‘0’ because no further information was found regarding the company’s procedures to identify, declare and manage conflicts of interest.

There is evidence that the company has a policy which includes controls to assess and regulate employment and offers of employment or consultancy engagement to recently departed public officials and politicians.

However, the company receives a score of ‘1’ because the evidence does not indicate that senior approval is required for the initiation of employment discussions with former or current public officials, or that the company undertakes a conflict of interest review and imposing restrictions on activities if risks are identified.

The company publishes a clear statement that it does not contract advisory or consulting services from politicians.

There is no publicly available evidence that the company has a policy on conflicts of interest.

There is no publicly available evidence that the company has procedures in place to identify, manage and declare conflicts of interest.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

The company has a conflict of interest policy which refers to actual and potential conflicts and applies to all employees and board members. The policy covers employee relationships, financial interests and other employment.

However, it does not cover government relationships.

The company has procedures for managing and declaring conflicts, including actual and potential conflicts, with disciplinary measures applying when the policy is breached. Publicly available information shows that the Risk and CSR Committee has ultimate oversight and accountability for the conflict of interest policy.

However, it is not clear from publicly available information whether all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process. The company’s policy also does not mention examples of criteria for recusals. Although the company also refers to a Managing Conflicts of Interest Group Procedure, this is not available on its website.

While there is evidence that the company acknowledges that the employment of former public officials may require additional scrutiny, there is no further publicly available information on its policy and/or procedures.

There is no evidence that the company reports details of the contracted services of serving politicians

There is evidence that the company formally addresses conflict of interest as a corruption risk, and has a policy for conflicts of interests that covers actual, potential and perceived conflict of interests. The policy refers to financial interests, employee relationships, government relationships and other employment. There is evidence that this policy applies to all employees, suppliers and business partners associated with the company, which is understood to also include all board members, third parties and employees of joint ventures.

There is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company states that it forms committees to handle conflicts of interests which include representatives from the human resources and legal departments as well as a member of the executive team. There is evidence which indicates that employees who breach the company’s policies are subject to disciplinary action.

However, the company receives a score of ‘1’ as there is no evidence that all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process. There is also no evidence that the company provides examples of criteria for recusals.

There is some evidence that the company has a policy that addresses the risks associated with the employment of public officials. The company states that it follows local laws and regulations concerning cooling-off periods related to hiring current or former government officials.

However, the company receives a score of ‘1’ as it does not publish sufficient detail regarding specific controls to assess and regulate the employment of current or former public officials, such as requiring senior approval for the initiation of employment discussions or stipulating that any cooling off period must be for at least 12 months before such public officials are permitted to have any form of contact or relationship with their former organisation on the company’s behalf.

There is no evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company has a policy that defines conflicts of interest, including actual, potential and perceived conflicts. The company’s policy explicitly covers conflicts of interest concerning employee relationships, financial interests and external employment, as well as government relationships. In addition, there is evidence that its conflict of interest policy applies to all employees and board members, as well as to all employees of subsidiaries and other controlled entities.

Based on publicly available information, there is evidence the company has procedures to identify, declare and manage conflicts of interest. The company states that all employee and board member declarations of actual and potential conflicts of interest are recorded in a dedicated tool that is accessible to those responsible for oversight of the process.

There is evidence that potential or actual conflict of interest declarations are reviewed and overseen by a designated body, namely the company’s Ethics and Business Conduct Office, which holds ultimate accountability for its implementation and the handling of individual cases. The company’s description of conflicts of interest procedures also includes termination as a potential punitive measure for breach of the policy.

Based on publicly available information, there is evidence that the company has a policy which outlines controls to assess and regulate employment, offers of employment and consultancy engagement with current and recently departed public officials. The company requires approval from the office of the General Counsel or Ethics Office prior to the initiation of any employment discussions with former or current public officials, as well as requiring a review of actual, potential or perceived conflicts of interest. There is also evidence that the company’s policy includes placing restrictions on their activities if such conflicts of interest are identified, which is understood to include restrictions on job functions as well as implementing a potential cooling off period.

Based on publicly available information, there is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company has a policy that defines conflicts of interest, including actual and potential conflicts. The policy covers employee relationships, financial interests, government relationships, and other employment.

There is some evidence that the company has procedures to identify, declare and manage conflicts of interest. There is evidence that the Compliance Organisation is responsible for handling cases and that disciplinary measures will apply for breaches of the company’s policy.

However, there is no evidence that all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process. There is also no evidence that the company mentions examples of criteria for recusal.

There is evidence that the company has a policy that addresses the risks associated with the employment of public officials.

However, the controls that the policy has to assess and regulate the employment of current or former public officials are too vague.

The company states that it does not contract serving politicians, however, it does provide evidence which suggests that an active politician serves on its supervisory board.

There is evidence that the company has a policy for conflict of interest.

However, the company receives a score of ‘1’ because the policy does not cover all of the categories of possible conflicts and does not clearly define the types of relationships or conflicts covered under its policy. It is also unclear whether the policy applies to all employees and board members.

There is no evidence that the company has procedures to manage conflict of interest or of their oversight.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

The company formally addresses conflicts of interest as a corruption risk and has a clear policy and procedure which defines conflicts, including those actual, potential and perceived. The policy is outlined in the company’s Code of Conduct, which applies to all employees and board members, including those of subsidiaries and other controlled entities. The company’s policy documents make reference to conflicts of interest concerning employee and government relationships, financial interests and outside employment.

There is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. Employees are required to submit conflict of interest reports to the Ethics and Compliance team, which reviews the reports and oversees the process. The company has additional procedures in place for members of its board of directors, and states that disciplinary measures will apply if these policies are breached. The company additionally publishes a statement that all employee and board member declarations of actual and potential conflicts of interest are recorded in a dedicated register or central depository that is accessible to members of the company’s Ethics and Compliance Team.

There is some evidence that the company has a policy that addresses the risks associated with the employment of directors, employees or consultants from the public sector. The company states that recent government officials are not permitted to be involved in activities which may give the company an undue advantage. The company states that all new hires, including those from the public sector are required to submit a conflict of interest disclosure.

However, the company receives a score of ‘1’ because its policy does not describe specific controls to assess and regulate the employment of current or former public officials, such as requiring a 12-month cooling off period before employment discussions can begin or controls preventing new public sector recruits from representing the company to their former organisation.

The company publishes a statement that it does not contract serving politicians due to the risk of potential conflicts of interest.

There is evidence that the company formally addresses conflict of interest as a corruption risk, and has a clear policy that defines conflicts of interest, including actual and potential conflicts. There is evidence that the policy specifically covers conflicts involving personal and family relationships, outside employment and financial interests and explicitly applies to all employees and board members. There is evidence that the company makes some reference to the employment of former government officials; however, there is no evidence that this fully covers possible conflicts of interest that could arise from an employee also acting as an officer of any government or government department.

There is evidence that the company has clear procedures to identify, declare and manage conflicts of interest, actual, potential and perceived. This includes a publicly available statement that all employee and board member declarations of actual and potential conflicts of interest are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process. There is evidence that potential or actual conflict of interest declarations are reviewed and overseen by a designated body or individual with ultimate accountability for its implementation and handling of individual cases. The publicly available description of this procedure also includes examples of criteria for recusals and potential punitive measures for breaches of the policy.

The company states publicly that when hiring individuals previously employed in the public sector it is sometimes required by regulations to obtain written permission from state bodies to facilitate their appointment. The company, however, receives a score of ‘0’, because there is no evidence that it has a clear policy regulating the hiring of former public sector employees with a view to mitigating corruption risks.

There is no evidence that the company reports details of the contracted services of serving politicians

There is evidence that the company formally addresses conflicts of interest as a corruption risk and has a clear policy and procedure that defines conflicts of interest, including actual, potential and perceived conflicts. The policy explicitly covers conflicts concerning financial interests, employee relationships, government relationships and outside employment opportunities. There is evidence that this policy applies to all employees, as well as to employees of subsidiaries and other controlled entities.

However, it is not clear whether this policy applies to board members.

There is evidence that the company has clear procedures to identify, declare and manage conflicts of interest, actual, potential and perceived and there are examples of criteria for recusals. There is evidence that all employees and the Board are required to complete an annual declaration on conflicts of interest, and that these are submitted to the Internal Control and Audit department, although it is unclear whether they are held in a dedicated register or central depository. Nevertheless, there is evidence that this department compiles a report and recommendations for the final decision of the Board of Directors, which has ultimate accountability.

The company states that it takes steps to avoid conflicts of interest when conducting activity with public officials or hiring relatives of public officials. However, there is no clear evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company formally addresses conflicts of interest as a corruption risk, and that it has a clear policy that defines conflicts of interest, including those actual, potential and perceived. It is clear that the company’s policy covers possible conflicts arising from employee relationships, government relationships, financial interests and other employment. The company indicates that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities.

There is evidence that the company has procedures in place to identify, declare and manage conflicts of interest, including those actual, potential and perceived. This includes a statement that all employee and board member declarations of actual and potential conflicts of interest are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.

In addition, there is evidence that a designated body is responsible for monitoring all conflicts of interest, while relevant managers are accountable for the handling of individual cases. The company’s description of this procedure includes examples of criteria for recusals and it states that disciplinary consequences may apply if the policy is breached.

There is evidence that the company has a policy regulating the employment of current or former public officials. The company requires compliance officer approval before the initiation of any employment discussions with former or current public officials who pose an actual, potential or perceived conflict of interest. In addition, the company states that if employment is approved, that a further review will take place to determine whether a conflict of interest exists, and if so, what restrictions are appropriate to place on their activities.

Although the company does not provide any information on cooling off periods, there is evidence to indicate that such a procedure would conflict with the Swiss political system and therefore the company is exempt from this requirement.

There is no evidence that the company publishes details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company has a policy which addresses actual and potential conflicts of interest. There is evidence that this policy covers personal relationships and financial interests and applies to all employees of the company.

However, the company receives a score of ‘1’ because there is no evidence that the policy covers conflicts of interest associated with government relationships or other employment. It also does not refer to perceived conflicts of interest and there is no clear evidence that the company’s policy applies to board members.

Based on publicly available information, there is evidence that the company has procedures to identify, declare and manage conflicts of interest. The company indicates that potential or actual conflict of interest declarations are reviewed and overseen by its Commission for the Regulation of Conflicts of Interest, a designated body which has ultimate accountability for handling individual cases. There is evidence that this body records all employee and board member declarations of actual and potential conflicts of interest. The description of this procedure also includes examples of criteria for recusals and a description of the disciplinary measures which apply for breaches of the policy.

Based on publicly available information, there is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company formally addresses conflicts of interest as a corruption risk and has a clear policy that defines conflicts of interest, including actual and potential conflicts. The policy covers employee relationships, government relationships, financial interests and other employment. There is evidence that the policy applies to all employees and board members, including those of subsidiaries and other controlled entities.

There is some evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual and perceived conflicts.

However, there is no publicly available evidence that all employee and board member declarations are held in a dedicated register or central depository and there is no reference to a specific body or individual with oversight and accountability for handling cases. There is no publicly available evidence that the company provides examples of criteria for recusals nor that disciplinary measures will apply if the company’s procedures are breached.

There is some evidence that the company has a policy that addresses the risks associated with the employment of public officials.

However, the company does not describe any specific controls to assess and regulate the employment of current or former public officials, such as requiring senior approval for the initiation of employment discussions, undertaking a conflict of interest review and imposing restrictions on activities if risks are identified, or stipulating a cooling-off period of 12 months.

There is no publicly available evidence to indicate that the company reports details of the contracted services of serving politicians.

There is evidence that the company formally addresses conflict of interest as a corruption risk, and that it has a clear policy defining possible conflicts, including those actual, potential and perceived. This policy explicitly covers all of the categories of possible conflicts listed in the question guidance, specifically employee relationships, government relationships, financial interest and other employees. This policy applies to all employees. The management of conflicts of interest for board members is covered separately in the rules covering the board of directors.

There is some evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts both for employees and members of the Board.

However, the company receives a score of ‘1’ because there is no evidence that a specific body or individual has oversight and accountability for handling conflict of interest cases involving employees. There is also no evidence that the employee and board member declarations are held in a dedicated register that is accessible to those responsible for oversight of the process. The company also does not provide examples of criteria for recusals.

There is evidence that the company has a policy that addresses the risks associated with the employment of public officials. This policy stipulates that any former public agents recruited by the company will be subject to a cooling-off period.

However, the company receives a score of ‘1’ because its policy is insufficiently detailed. The company states that a cooling-off period of three years will apply in France, as dictated by French conflict of interest laws, but the company’s approach to cooling-off periods in other jurisdictions is not clear. There is also no evidence of additional controls regulating the employment of current or former public officials, for example whether senior compliance officer (or equivalent) approval is required for the initiation of employment discussions or whether it imposes restrictions on their activities once employed.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company formally addresses conflict of interest risks. There is evidence that the company’s Code of Conduct states that conflicts should be avoided if possible and makes specific reference to conflicts arising from other employment, and that this applies to all employees and board members. In its publicly available additional guidance for executive directors and board members, the company refers to both actual and perceived conflicts.

However, the company receives a score of ‘1’ because there is no evidence that it addresses the potential corruption risks arising from other categories mentioned in the question guidance, such as employee relationships, government relationships and financial interests. There is also no evidence that actual, potential and perceived conflicts are considered for employees as well as board members, nor is there evidence that this policy applies to subsidiaries and other controlled entities.

There is some evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual and perceived conflicts. There is evidence that the company’s Risk Oversight Committee is responsible for managing conflicts of interest involving the company’s executive management and board, who may be subject to disciplinary measures for breaking the policy.

However, the company receives a score of ‘1’ because it is not clear whether this also applies to conflict of interest cases involving employees, or whether this is undertaken by a separate body. Additionally, there is no evidence that the company mentions examples of criteria for recusals from conflicts of interest, nor is there evidence that declarations are held in a dedicated register accessible by those with oversight of the process.

There is no publicly available evidence that the company has a policy or procedure to regulate the employment of current or former directors, employees or consultants from the public sector.

There is no evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company formally addresses conflicts of interest as a corruption risk and has a clear policy and procedure that defines conflicts of interest, including actual, potential and perceived conflicts. There is evidence that this policy covers all of the categories of possible conflicts listed in the guidance. The company indicates that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities.

Based on publicly available information, there is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. There is evidence that the company has a dedicated register for recording conflicts of interest. The company states that disciplinary measures will apply if its conflict of interest policies are breached and gives a number of examples of criteria for recusals. The company outlines the oversight and reporting structure governing conflicts of interest cases, with responsibility for regulating cases held between middle management and the relevant divisional Ethics and Compliance Office.

Based on publicly available information, there is evidence that the company has a policy that addresses the risks associated with the employment of public officials, and screens each new recruit from the public sector for potential conflicts of interest, implementing controls if risks are subsequently identified.

However, the company receives a score of ‘1’ because there is no evidence that it requires senior compliance officer (or equivalent) approval for the initiation of any employment discussions with former or current public officials. There is also no evidence that the company has a policy to implement a cooling-off period of at least 12 months before such public officials are permitted to have any form of contact or relationship with their former organisation on the company’s behalf.

There is no evidence that the company publishes details of the contracted services of serving politicians.

There is some evidence that the company addresses potential and perceived conflicts of interest in its Code of Business Conduct. It is clear that this policy applies to all employees.

However, the company receives a score of ‘1’ because there is no evidence that the company has a formal policy to define and address conflicts of interest, beyond a high-level statement. The company’s statement also does not specifically make reference to actual, potential or perceived conflicts arising from employee relationships, financial interests, government relationships and other employment.

There is no evidence that the company has procedures to manage conflict of interest or their oversight.

There is evidence that the company addresses the risks associated with the employment of public officials, by providing details of the board appointment process.

However, the company receives a score of ‘1’ because there is no evidence that its policy includes any specific controls to assess and regulate the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is no publicly available evidence that the company has a policy on conflicts of interest.

There is no publicly available evidence that the company has procedures in place to manage conflicts of interest or their oversight.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company formally addresses conflict of interest as a corruption risk and has a clear policy that defines conflicts of interest, including actual, potential and perceived conflicts. The policy explicitly makes reference to conflicts concerning personal relationships, financial interests and outside employment.

However, there is no evidence that the company mentions potential conflicts concerning government relationships. Also, while the company states that its policy applies to all employees, it does not explicitly mention board members or employees of subsidiaries and joint venture partners.

There is evidence that the company has clear procedures to identify, declare and manage conflicts of interest, actual, potential and perceived. There is evidence that employee declarations of actual and potential conflicts of interest are recorded and reviewed by a designated body, the company’s Department of Internal Control, which has ultimate accountability for the implementation of this policy and the handling of individual cases. The company also describes, examples of criteria for recusals and potential punitive measures for breaches of the policy.

There is no evidence that the company has a policy governing the appointment of directors, employees or consultants from the public sector.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company has a conflict of interest policy, and it is clear that this policy addresses conflicts related to financial interests, employee relationships and outside employment opportunities. There is also evidence that this policy applies to all employees.

However, the company receives a score of ‘1’ because there is evidence to suggest that the policy published on its website is a template copied elsewhere, so the extent to which the company has incorporated these policies into its own operations is unclear. In addition, the policy does not explicitly apply to all board members, nor does it specifically address and cover conflicts of interest concerning government relationships.

There is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company states that its supervisory board, as well as designated independent directors, are responsible for managing and resolving conflicts of interest. The company also states that employees must gain approval from the supervisory board before accepting outside employment, in order to avoid conflicts of interest.

However, there is no clear evidence that all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process. Beyond outside employment opportunities, the policy does not mention examples of criteria for recusals. The policy also does not state that disciplinary measures will apply if breached.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company has a policy on conflicts of interest, which applies to all employees and board members. The company’s policy makes specific reference to possible conflicts arising from financial interests and personal relationships.

However, the company receives a score of ‘1’ because there is no clear evidence that its policy defines and addresses possible conflicts arising from government relationships or outside employment opportunities. It is also not clear that the company’s policy addresses actual, potential and perceived conflicts of interest.

There is no publicly available evidence that the company has procedures in place to identify, declare and manage conflicts of interest. The company indicates that employees who become aware of a conflict must report this information to the HR manager, however the company does not provide any further details on this process or any oversight mechanisms.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company publishes details of any contracted services of serving politicians.

There is no publicly available evidence that the company has a conflict of interest policy.

There is no evidence that the company has procedures in place for managing conflicts of interest or their oversight.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company has a policy for conflicts of interest that covers actual and perceived conflicts of interest. The company’s policy specifically addresses possible conflicts arising from employee and government relationships, financial interests and other employment. In addition, there is evidence that this policy applies to all employees and board members.

Based on publicly available information, there is evidence that the company has some procedures in place to identify, declare and manage conflicts of interest, including actual and potential conflicts. The company states that employees should seek advice in instances where potential conflicts of interest arise. The company provides one example of a criterion for recusal.

However, the company receives a score of ‘1’ because there is no evidence that all employee and board member declarations are held in a dedicated central register that is accessible by those responsible for oversight of the process. There is also no indication that a central body or senior individual is responsible for oversight and accountability of handling cases, nor that the policy states that disciplinary measures will apply if the policy is breached.

There is no publicly available evidence that the company has a policy regulating the employment of current or former public officials.

The company publishes a clear statement that it does not engage or contract the services of serving politicians.

Based on publicly available information, there is evidence that the company has policies for conflicts of interest which apply to all employees and board members, and refer to actual, potential and perceived conflicts. The publicly available policies make specific reference to conflicts related to employee relationships, outside employment and financial interests.

However, the company receives a score of ‘1’ because there is no evidence that its policies make specific reference to conflicts of interest concerning government relationships.

Based on publicly available information, there is evidence that the company has procedures to identify and declare conflicts of interest, including actual, potential and perceived conflicts. For employees, the company states that the employee’s Ethics & Compliance Officer or Company Legal Counsel must approve conflicts. There is evidence that Directors must report potential conflicts to the board Chairman, the CEO and the chair of the Nominating and Corporate Governance Committee. Additionally, the company makes publicly available examples of criteria for recusals of directors. The company states that breaches of its Business Conduct Guidelines, which contain policies covering conflicts of interest, will lead to disciplinary action.

The company receives a score of ‘1’ because there is no evidence that employees and directors are required to make conflict declarations that are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

Based on publicly available information, there is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company publishes details of the contracted services of politicians.

There is no publicly available evidence that the organisation has a conflict of interest policy.

There is no evidence that the organisation has procedures to manage conflicts of interest or their oversight.

There is no evidence that the organisation has a policy regulating the employment of current or former public officials.

There is no evidence that the organisation reports details of the contracted services of serving politicians.

There is evidence that the company formally addresses conflicts of interest as a corruption risk, and has a policy that defines conflicts of interest, including those actual, potential and perceived. This policy covers employee relationships, financial interests, government interests and other employment and applies to all employees and board members.

There is evidence that the company has procedures to identify, declare and manage conflicts of interest. Employees must declare conflicts of interest in writing to their superiors and the responsible Compliance Officer or Regional Compliance Officer. The company provides examples of criteria for recusals and also states that disciplinary measures will apply if the conflicts of interest policy is breached. The company states that it has a central repository for conflict of interest declarations when it is assessing candidates for leadership positions, which is accessible to the compliance officers responsible for overseeing the process.

However, there is no evidence that the company has a unified repository which holds all employee and board member declarations and which is accessible to those responsible for overseeing conflict of interest management across the organisation.

There is evidence that the company has a policy that addresses the risks associated with the employment of public officials. The company indicates that it implements a cooling-off period when recruiting such officials as legally required.

However, the policy does not indicate whether the cooling-off period is at least 12-months long or whether it requires senior compliance officer approval for the initiation of any employment discussions with former or current public officials.

The company publishes a clear statement that it has a policy to not contract serving politicians at any level.

There is no clear publicly available evidence that the company has a policy on conflicts of interest. Although the company addresses conflict of interest as a corruption risk, there is no evidence that it defines actual, potential and perceived conflicts. There is also no evidence that the company’s policy applies to all employees and directors, nor that it covers employee relationships, financial interests, government relationships and other employment.

There is no publicly available evidence that the company has procedures in place to identity, declare and manage conflicts of interest.

Based on publicly available information, there is evidence that the company has a policy that addresses the risks associated with the employment if public officials. The company commits to follow all applicable laws and regulations, and indicates that it may place restrictions on a former public official’s activities when they join the company.

However, the company receives a score of ‘1’ because it does not provide any further information on the specific controls that it has in place to mitigate possible corruption risks. There is no evidence that the company requires senior approval before initiating employment discussions with current or former officials, nor that it conducts a full conflict of interest review or implements cooling-off periods.

There is no evidence that the company publishes details of the contracted services of serving politicians.

Based on publicly available information, there is evidence that the company has a policy on conflicts of interest. The policy explicitly covers actual, potential and perceived conflicts and states that it applies to all employees and board members. It also defines employee relationships, financial interests and other employment.

However, the company scores ‘1’ as there is no evidence it has a policy on conflicts of interest in government relationships.

Based on publicly available information, there is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. There is reference to an individual with oversight and accountability for handling cases, the General Counsel, and the policy mentions sanctions in case of violations of the Code of Business Conduct.

However, the company scores ‘1’ as there is no evidence that all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

There is no publicly available evidence to indicate that the company has a policy regulating the employment of current or former public officials.

There is no publicly available evidence to indicate that the company reports details of the contracted services of serving politicians.

There is some evidence that the company has a policy on conflicts of interest, which covers conflicts of interest related to employee relationships, other employment and financial interests. There is evidence that the company policy includes potential or actual conflicts of interest.

However, the company receives a score of ‘1’ because it does not refer to conflicts of interests related to government relationships. There is also no evidence that the policy explicitly applies to all employees and board members, including those of subsidiaries and other controlled entities.

There is no evidence that the company has procedures to manage conflict of interest or their oversight.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is some evidence the company has a conflicts of interest policy, which refers to actual and potential conflicts, and makes specific reference to personal financial interests.

However, the company receives a score of ‘1’ because in publicly available evidence it does not make specific reference to employee relationships, government relationships or outside employment. The policy also does not refer to perceived conflicts. In publicly available evidence the company does not explicitly state that its policy applies to all board members.

There is some evidence the company has procedures to identify, declare and manage conflicts of interest, including actual and potential conflicts. The policy outlines some examples of criteria for recusals and states that disciplinary measures will apply if breached. There is evidence that different individuals are designated responsible for resolving conflicts of interest dependent on the position of the relevant employee or manager. The company does not refer to a specific body or individual with oversight and accountability for handling all cases.

The company receives a score of ‘1’ as there is no evidence that all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no publicly available evidence that the company publishes details of the contracted services of serving politicians.

Based on publicly available information, there is some evidence that the company has a policy for conflicts of interest. The policy makes reference to actual and potential conflicts of interest. There is evidence that the company has procedures on conflicts of interest for employees and board members.

However, the company receives a score of ‘1’ because there is no clear publicly available evidence that its policy covers perceived conflicts, nor does it define the types of relationships or conflicts covered under its policy. In addition, there is no evidence that the policies apply to subsidiaries and other controlled entities.

Based on publicly available information, there is some evidence that the company has procedures to identify, declare and manage conflicts of interest. The company indicates that directors are required to report actual or potential conflicts to the board, while employees are advised to discuss the matter with their line manager.

However, the company receives a score of ’0’ because it does not provide further information on its procedures for handling conflicts of interest, such as identifying a specific body or individual with oversight and accountability for handling cases. There is also no evidence that the company records all employee and board member declarations in a dedicated central register that is accessible to those responsible for oversight of the process, nor that it provides a description of criteria for recusals or disciplinary measures.

There is no publicly available evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company publicly reports details of the contracted services of serving politicians.

The company provides a clear definition of actual and potential conflicts of interest and there is evidence that it has a policy which covers conflicts of interest arising from employee relationships and financial interests. However, there is no evidence that the policy addresses conflicts arising from other employment or government relationships. In addition, there is no clear evidence that the applies to all employees and board members.

It is noted that the company makes reference to an internal policy entitled “Regulations on Conflicts of Interest”, but this does not appear to be publicly available.

There is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual and potential conflicts. There is also evidence that some employees are required to declare any conflicts of interest. The company states that the Commission on Corporate Ethics and Conflict of Interest Regulation is responsible for managing conflicts of interest.

The company receives a score of ‘1’ because there is no evidence that employee and board member declarations are held in a dedicated central register that is accessible to those responsible for oversight of the process. There is also no evidence that the company’s policy provides examples of criteria for recusals, nor does it indicate that disciplinary measures will apply if breached.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company has a policy covering conflicts of interest, which is referenced on its website and in its Anti-Corruption Policy. The company’s publicly available information indicates that employees must declare any actual, potential or perceived conflicts, and there is evidence that its policy covers possible conflicts arising from financial interests, other employment or corporate relationships, and personal relationships.

However, the company receives a score of ‘1’ because there is no evidence that its policy addresses possible conflicts arising from government relationships. It is noted that the company’s full policy document does not appear to be available in the public domain.

Based on publicly available information, there is some evidence that the company has procedures in place to identify, declare and manage conflicts of interest. The company states that the Deputy General Manager of Security is ultimately responsible for organising all anti-corruption activities, including the management of conflicts of interest, and that departmental managers are also assigned partial responsibilities in this area.

However, the company receives a score of ‘1’ because there is no evidence that all employee and board member declarations are held in a dedicated central register that is accessible to those responsible for oversight of the process. The company also indicates that it has a Commission for regulating conflicts of interest, but does not provide further details on this in its publicly available information. There is also no evidence that the company provides examples of criteria for recusals, nor does the company indicate that disciplinary measures will apply if the policy is breached. It is noted that the company has full procedures on the identification and management of conflicts of interest, however this document does not appear to be available in the public domain.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is no clear evidence that the company has a policy on conflicts of interest that defines certain types of conflict and that applies to actual, potential and perceived conflicts. In its most recently published Annual Report (2015), the company states that it has a policy covering conflicts of interest; however it does not provide further information and the policy document does not appear to be publicly available.

There is some evidence that conflict of interest cases are managed by a specific Commission within the company. However, the company receives a score of ‘0’ because it does not provide further information on any procedures to identify, declare and manage actual, potential and perceived conflicts of interest.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence that the company formally addresses conflicts of interest as a corruption risk and that it has a clear policy in place that defines conflicts of interest, including actual, potential and perceived conflicts. There is evidence that the company’s policy addresses possible conflicts arising from employee relationships, government relationships, financial interests and other employment. This policy applies to all company employees.

However, the company receives a score of ‘1’ because there is no clear publicly available evidence that this policy applies to all board members or employees of subsidiaries and other controlled entities.

There is evidence that the company has clear procedures in place to identify, declare and manage conflicts of interest. The company indicates that potential and actual conflict of interest declarations are reviewed and overseen by a designated body – the Commission for Corporate Ethics and Conflicts of Interest Resolution – which has ultimate accountability for the handling of individual cases. In addition, there is evidence to suggest that all employee conflicts of interest declarations are held by the Human Resources Department and inspected by the above named commission.

However, it is not clear from publicly available information that the company provides descriptions of possible criteria for recusals nor that breaches of its policy in this area will result in disciplinary measures.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company publishes details of the contracted services of serving politicians.

There is evidence that the company has a policy covering actual and potential conflicts of interest, which applies to all employees and board members. This policy covers conflicts relating to other employment and financial interests.

However, the policy does not make reference to government relationships or personal relationships.

The company states that it has created systems for shareholders and board members to identify and manage conflicts of interest. However, there is no evidence that declarations are held in a dedicated register and there is no reference to a specific body or individual with oversight and accountability for handling cases. It is also not sufficiently clear whether there are procedures in place for employees to identify, declare and manage conflicts of interest.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is evidence the company addresses conflicts of interest as a corruption risk, and has a policy and procedure that define conflicts of interest, including actual, potential and perceived conflicts. The company’s policy clearly covers possible conflicts arising from concerning employee relationships, government relationships, financial interests and outside employment. There is evidence that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities.

There is evidence the company has procedures to identify, declare and manage conflicts of interest, including those actual, potential and perceived. There is evidence that employee and board member declarations of actual and potential conflicts of interest are recorded in a central depository that is accessible to those responsible for oversight of the process.

In addition, the company states that potential or actual conflict of interest declarations are reviewed and overseen by the Chief Human Resources Officer and the Chief Legal Officer, and there is evidence that they are accountable for the implementation of the policy and handling of individual cases. The company also provides examples of criteria for recusals and there is evidence that disciplinary measures apply to employees who violate the policy.

There is evidence the company has a policy which includes controls to assess and regulate employment and offers of employment or consultancy engagement to current and recently departed public officials. According to the policy, employment discussions with current and former state officials require approval from the company’s human resources and legal departments. There is also evidence the company assesses potential conflicts of interest around appointments of current or former public officials.

However, the company receives a score of ‘1’ because there is no clear publicly available evidence that the company may proactively require a cooling-off period of at least 12 months before public officials are permitted to have any form of contact or relationship with their former organisation on the company’s behalf.

There is no evidence that the company publishes details of the contracted services of serving politicians on its website.

There is evidence that the company has a policy on conflicts of interest for its employees, which specifically refers to actual and perceived conflicts. There is evidence that the categories of conflict it covers include employee relationships and financial interests. The company also has a separate policy that applies to its board members and refers to actual, potential and perceived conflicts.

However, the company receives a score of ‘1’ because its employee conflict of interest policy does not cover government relationships or other employment, and its board member policy does not discuss any of the possible categories of conflict outlined in the scoring criteria.

There is evidence that the company has procedures to identify, declare and manage conflicts of interest. The company states that employees must inform the company’s legal counsel of any apparent conflicts, while directors must inform the chairperson of the board. In situations where board members are found to have conflicts, there is evidence that they may be required to resign from the board or be exempt from voting on related matters.

However, the company receives a score of ‘1’ because there is no evidence that all employee and board member declarations are held in a dedicated central register that is accessible to those responsible for oversight of the process. The policy also does not mention examples of criteria for recusal and does not specifically state that disciplinary measures apply if the company’s policy on conflicts is breached.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.

There is no publicly available evidence that the company has a policy on conflict of interest.

There is no evidence that the company has procedures to manage or oversee conflicts of interest.

There is no evidence that the company has a policy regulating the employment of current or former public officials.

There is no evidence that the company reports details of the contracted services of serving politicians.