Agents, Intermediaries an... Commitment: Moderate commitment
Score:
65/100
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7. Agents, Intermediaries and Joint Ventures

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Score

65/100

65/100

Points

13/20

7.1.1 Does the company have a clear policy on the use of agents?

Points

POINTS: 2/2

This is a policy question

This question is looking for evidence that the company has a clearly defined approach to the use of agents, whether by implementing stringent controls on their use or by choosing not to use agents in the course of business.

Agents can make a valuable contribution to any defence transaction, and may perform a range of legitimate functions. Yet they are also widely recognised as one of the most significant and pervasive bribery and corruption risks in the defence sector. Agents pose a unique corruption threat as they may be authorised to act on behalf of the company’s interests, often with a high level of discretion and minimal oversight. Companies that choose to use agents despite these risks must ensure that they operate with a clear and consistent approach, putting in place controls to combat this threat. Such an approach should also include an assessment of whether the employment of an agent is necessary in each case, or whether those functions could be performed through in-country employees or other entities.

A company may also choose not to use agents in the conduct of business in face of the corruption risks these pose, as a way of eliminating associated corruption risks.

Score: 2/2

The company scored 2/2 for this question

There is evidence that the company has a clear policy and/or procedure to control the use of agents, which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. This policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures.

Or, the company publishes a clear statement that it does not use agents and the assessor has no evidence contradicting this statement.

Score: 1/2

There is evidence that the company has a policy covering the use of agents, however this policy is lacking in some way. For example:

  • The policy does not address the corruption risks associated with the use of agents and/or does not provide details of specific controls to mitigate these risks;
  • The policy does not explicitly commit to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function; or
  • It is not clear or there is no evidence that this policy also applies to subsidiaries and joint ventures.

Score: 0/2

There is no evidence that the company has a policy covering the use of agents, or, the information provided is sufficiently unclear that it cannot satisfy the requirements of score ‘1’. For example, the company provides a simple statement on the use of agents without clearly addressing the potential corruption risks.

Comments

Based on publicly available information, there is evidence that the company has a policy covering the use of consultants and sales representatives – which is understood to include agents. It is clear that this policy applies group-wide to any entities that may employ agents. There is evidence that the company commits to establishing that the use of an agent is, in each case, based on a clear need identified in a business and market plan. The company also provides details of specific controls in place to mitigate the potential risks associated with the use of agents, for example by requiring that all sales representatives undergo dedicated ethics training, by ensuring that such entities comply with its Ethical Code of Conduct and through regular reporting. There is also evidence that the company’s Group-level Legal & Compliance department is responsible for oversight and due diligence of agents, which is consistent with the level of risk.

Although the company does not directly address the corruption risks associated with agents, it does provide a statement on the compliance risks associated with consultants, agents and sales representatives as part of a broader statement on third parties, which is deemed sufficient for a score of ‘2’ given the accompanying information.

7.1.2 Does the company conduct risk-based anti-bribery and corruption due diligence when engaging or re-engaging its agents and intermediaries?

Points

POINTS: 2/2

This is a policy question

This question is looking for evidence that the company conducts due diligence on all its agents and intermediaries, which is based on and determined by an assessment of bribery and corruption risks. This refers specifically to any agents, advisers, consultants or intermediaries authorised to act for or on behalf of the company to further its business interests.

Due to the high corruption risks associated with the use of agents and intermediaries, companies must find a suitable methodology for screening their agents to ensure they obtain the right information needed to uncover red flags and assess the level of integrity of an agent against consistent criteria. It is essential that such checks are conducted on a continuous or frequent enough basis to ensure that the company is aware of any changes or developments in the risk profile of any particular agent, rather than simply at the start of the contractual relationship. For example, conflicts of interest can arise and develop over time. A frequency of every two years has been found to be the best practice standard across the sector and reflects the high corruption risk posed by agents.

If the company publishes a clear statement that it does not use agents, and the assessor cannot find any evidence to the contrary, this question should be marked N/A.

Score: 2/2

The company scored 2/2 for this question

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging and/or re-engaging any agents and intermediaries, at least every two years and/or when there is a significant change in the business relationship. All agents and highest risk intermediaries are subject to enhanced due diligence. The company commits to not engaging or terminating its engagement with agents or intermediaries where risks identified in the due diligence cannot be mitigated.

Score: 1/2

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging and/or re-engaging with its third parties and agents; however, these procedures are lacking in some way. For example:

  • The company states that it conducts due diligence on third parties, without clearly specifying agents or high risk intermediaries;
  • It is not clear that agents and highest risk intermediaries are subject to enhanced due diligence;
  • The company only conducts due diligence before engaging agents and is not repeated at least every two years and/or when there is a significant change in the business relationship; or
  • There is no evidence or it is not clear that the company commits to not engaging or terminating its engagement with agents or intermediaries where risks identified in the due diligence cannot be mitigated.

Score: 0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries, or the information provided is sufficiently unclear that it cannot satisfy the requirements of score ‘1’.

Comments

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with its third parties and agents. The company indicates that agents are subject to enhanced due diligence based on the size, type and country risk. There is evidence that the company conducts due diligence during the onboarding phase and every two years throughout the business agreement, supplemented with continuous monitoring. The company’s description of its due diligence process indicates that agents will only be contracted if the due diligence is approved and indicates that it is willing to review or terminate its engagement if the agreement is breached.

7.1.3 Does the company aim to establish the ultimate beneficial ownership of its agents and intermediaries?

Points

POINTS: 1/2

This is a policy question

This question is looking for evidence that the company aims to know and verify the beneficial ownership of the agents and intermediaries it does business with as part of its due diligence process.  A ‘beneficial owner’ is the natural person(s) who ultimately owns or controls the legal person or legal arrangement.

Knowing the beneficial ownership of high risk business partners such as agents is an important part of the screening information needed to uncover red flags and assess the level risk involved in doing business together. As a first step a company would request the agent to submit their beneficial ownership information, which then can be verified by the company.

There is a difference between verification and independent verification. Verification means that companies use documentation, usually government-issued, such as information available in company registries, to confirm the identity information. Independent verification, on the other hand, relates to the process of conducting additional verification using independent sources, such as watch lists, commercial databases, information found on the internet, personal visits, and social networks, among others. While independent verification may not be necessary for all agents, depending on their risk profile, the company should have systems in place to verify the identity agents identified as high risk independently.

Companies with a strong commitment to anti-corruption should not engage with parties whose beneficial ownership identities they are unable to establish.

If the company publishes a clear statement that it does not use agents, and the assessor cannot find any evidence to the contrary, this question should be marked N/A.

Score: 2/2

There is evidence that the company has formal procedures in place to establish the beneficial ownership of agents prior to engaging them, and at least every two years and/or when there is a significant change in the business relationship. The company operates, as a minimum, a risk-based beneficial ownership verification policy, whereby all agents must disclose this information to the company; and there is evidence that information provided by agents is verified and that information provided by high risk agents is independently verified. The company commits to not engaging or terminating its engagement with agents or intermediaries where ultimate beneficial ownership cannot be established.

Score: 1/2

The company scored 1/2 for this question

There is evidence that the company has formal procedures in place to establish the beneficial ownership of agents prior to engaging them, which includes requiring agents to disclose this information and verifying it as part of the due diligence process; however, this is lacking in some way. For example:

  • There is no evidence that the company commits to independently verify the beneficial ownership information provided by high risk agents;
  • There is no information that the company verifies this information both before onboarding and at least every two years and/or when there is a significant change in the business relationship; or
  • The company does commit to reviewing its engagement with agents or intermediaries if beneficial ownership cannot be established, but it does not mention potential termination.

Score: 0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents, or there is no evidence that the company commits to not engaging or terminate its engagement with agents in cases where beneficial ownership cannot be established.

Comments

There is evidence that the company has formal procedures in place to establish the beneficial ownership of its agents as part of the due diligence process. The company indicates that such checks take place during the onboarding phase, as well as every two years throughout the business agreement.

The company receives a score of ‘1’ because it does not clearly publish a statement to indicate that it would not engage or terminate its engagement with agents or intermediaries in cases where the beneficial ownership cannot be established.

7.1.4 Does the company’s anti-bribery and corruption policy apply to all agents and intermediaries acting for or on behalf of the company, and does it require anti-bribery and corruption clauses in its contracts with these entities?

Points

POINTS: 2/2

This is a policy question

This question is looking for evidence that, in all cases, the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for and/or on behalf of the company. This commitment is reinforced by a contractual agreement with the agent, whereby the contracted entity is required to implement and uphold an anti-bribery and corruption policy comparable to or aligned with its own. The contractual clause should cover both foreign and domestic bribery and corruption. The contract should include the implementation of controls to prevent and detect breaches, including audit rights and termination rights.

A contract with the third party is more than an agreement – it is a critical anti-corruption control. It communicates explicitly the company’s expectations regarding anti-corruption and ethical behaviour, establishes rights and specifies anti-corruption requirements and processes for monitoring, reappointment, remediation, termination and exit. Audit and termination rights provide companies with formal mechanisms through which they can assure themselves that the agents they associate with are implementing these controls in practice and are committed to addressing and preventing bribery and corruption in their operations.

If the company publishes a clear statement that it does not use agents, and the assessor cannot find any evidence to the contrary, this question should be marked N/A.

Score: 2/2

The company scored 2/2 for this question

There is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. The company states that all agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include clear audit rights and termination rights to detect, control and prevent breaches.

Score: 1/2

There is evidence the company’s anti-bribery and corruption policy applies to agents and intermediaries, and that it includes anti-bribery and corruption clauses in its contracts with such entities, with audit and termination rights. However, it is not clear that this applies to all agents and intermediaries without exception, or the company states that such clauses apply in general to ‘all third parties’ without specifying agents and intermediaries.

Score: 0/2

There is evidence that the company’s anti-bribery and corruption policy applies to agents and intermediaries and that it includes anti-bribery and corruption clauses in its contracts with such entities; however, there is no evidence that these clauses include audit and termination rights. Alternatively, there is no evidence that the company’s anti-bribery and corruption policy applies to agents and intermediaries, or it is not clear that the company includes anti-bribery and corruption clauses in its contracts with these entities.

Comments

There is evidence that the company’s anti-bribery and corruption policy applies to all agents and sales representatives acting for or on behalf of the company. The company’s publicly available information indicates that agreements with all sales representatives include monitoring clauses to mitigate corruption and compliance risks, as well as audit and termination rights to detect, control and prevent breaches.

7.1.5 Does the company ensure that its incentive schemes for agents are designed in such a way that they promote ethical behaviour and discourage corrupt practices?

Points

POINTS: 1/2

This is a policy question

This question is looking for evidence that the company recognises the role that incentive structures can play in motivating ethical and limiting corrupt behaviour of agents and considers mechanisms to ensure incentive structures promote behaviour in line with its anti-bribery and corruption policy.

Entirely performance-based remunerations can incentivise agents to ‘push the deal through’ at any cost. Similarly, disproportionately large upfront payments can be an indicator of bribes funnelled through agents to customers or other parties. Recent defence corruption scandals involving agents have also led many companies to ban the payment of agent remuneration into foreign or offshore accounts as a best practice measure. In this question, ‘incentive structures’ are used to refer to the structure of remuneration and financial compensation provided to agents for the provision of services for or on behalf of the company.

The assessor is looking for evidence that the company directly addresses the corruption risks associated with incentive payments to agents, and implements clear controls to mitigate these risks, such as a cap on sales-based commissions to agents, reasonably sized payments, staged payments and only paying agents into local bank accounts.

If the company publishes a clear statement that it does not use agents, and the assessor cannot find any evidence to the contrary, this question should be marked N/A.

Score: 2/2

There is evidence that the company explicitly highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company states that it places a threshold on sales-based commissions to agents so that payments do not exceed a proportion of the net fee to the agent, and there is evidence that remuneration to agents is paid only in staged payments over the course of their contract, based on clear milestones. There is also evidence that the company commits to only paying agents into local bank accounts.

Score: 1/2

The company scored 1/2 for this question

There is evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. However, there is no evidence that the company imposes a threshold on the payment of sales commissions to agents, and/or there is no requirement that remuneration is paid in stage payments or into local bank accounts.

Score: 0/2

There is no evidence that the company addresses incentive structures as a risk factor in agent behaviour, or there is no evidence that the company’s incentive structures for agents include measures to mitigate potential bribery and corruption risks.

Comments

There is evidence that the company addresses incentive structures for agents as a factor in bribery and corruption risk, by stipulating measures to control such processes as part of its compliance programme. The company states that remuneration for sales representatives must be proportionate to the service rendered and supported by relevant documentation, as well as noting that any payments should adhere to generally accepted accounting principles.

However, the company receives a score of ‘1’ because there is no evidence that it places a threshold on sales-based commissions to agents so that payments to not exceed a proportion of the net fee, nor does it commit to paying agents into local bank accounts or through staged payments over the course of their contract.

7.1.6 Does the company publish details of all agents currently contracted to act with and on behalf of the company?

Points

POINTS: 1/2

This is a transparency question

This question is looking for evidence that the company is open and transparent about agents it engages. Agents are widely recognised as the most significant and pervasive bribery risk in defence, and recurring – as well as recent – corruption cases within the sector continue to highlight the difficulty to manage them. Despite the maturing of compliance systems, enhanced due diligence, and mitigation measures, company processes will only go some way to protect it from these risks. The disclosure of agents used by companies would reduce the opportunity for corruption and improve collective oversight and accountability within the sector. The pervasiveness of corruption risks posed by third-party intermediaries certainly warrants such an enhanced level of circumspection.

In these circumstances, companies can and should adopt a policy of openness about the agents with which they engage, by routinely publishing a list of agents authorised to act for or on behalf of the company. Any company committed to reducing the risks of corruption which arise when intermediaries are engaged has a legitimate interest in maintaining such a list, as an aspect of its legitimate interest in minimising (or seeking to eliminate) the risks of corruption and in pursuing a more transparent way of doing business. Adopting a clear policy and drawing this to the attention of agents will ensure that any agent or prospective agent is aware that this information will be published while engaging with the company.

This information should be presented in a format that is clear, regularly updated, and sufficiently detailed so as to identify the agent.

If the company publishes a clear statement that it does not use agents, and the assessor cannot find any evidence to the contrary, this question should be marked N/A.

Score: 2/2

The company publishes a list of agents authorised to act for, or on its behalf. This list is published and updated at least once every year to reflect all agents engaged at that time and any agents engaged in the past 12 months. The details should include, at minimum, the name of the agent. The list is accompanied by a statement or other indication that, to the best of the company’s knowledge, this list includes all agents currently working for or on behalf of the company.

Score: 1/2

The company scored 1/2 for this question

The company publishes a list of agents authorised to act for, or on its behalf; however, this information is lacking in some way. For example:

  • The company publishes an aggregate figure of the number of agents currently employed, or it publishes a basic list that falls short of the minimum level of detail required in score ‘2’;
  • There is evidence to suggest that the list is incomplete; for example, the list does not appear to reflect all agents currently contracted to work for or on behalf of the company; or it is not accompanied by a statement or other indication that it includes all agents; or
  • There is evidence that the list is out of date; for example, the list was not published within the past 12 months.

Score: 0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

Comments

There is evidence that the company publishes an aggregate figure of the number of agents employed to act for or on its behalf, for the most recently reported financial year. The company also publishes high-level information to indicate the regions in which these agents have been active.

The company receives a score of ‘1’ because the information published falls short of the level of detail required to receive a score of ‘2’ such as the names of the sales representatives.

7.1.7 Does the company publish high-level results from incident investigations and sanctions applied against agents?

Points

POINTS: 0/2

This is a transparency question

This question is looking for evidence that the company collects and publishes data on anti-bribery and corruption inquiries and investigations involving its agents contracted to act for or on behalf of the company. Best practice would advise that companies publish data relating to any ethics and compliance-related issues; however, companies are encouraged to disaggregate the data to show anti-bribery and corruption-related incidents where possible.

Transparency around the results of these investigations, in the form of disciplinary actions, provides a high level indication that the company’s anti-bribery and corruption controls function in practice and reflect the company’s effective monitoring and oversight of its agents. Publication of this information also provides an industry benchmark to help companies assess their programmes. This information should be limited to high-level data, in other words the reports should be anonymised and summarised in a way that prevents individuals from being identified.

If the company publishes a clear statement that it does not use agents, and the assessor cannot find any evidence to the contrary, this question should be marked N/A.

Score: 2/2

The company publishes high-level data from all ethical or bribery and corruption-related incidents and investigations involving its agents. This should include, at a minimum: the number of investigations launched; and the number and types of sanctions applied as a result of investigation findings. This data is published at regular intervals or on at least an annual basis covering cases in the past 12 months.

Score: 1/2

The company publishes some high level information on its ethical, bribery or corruption-related incidents and investigations involving agents, however this data is lacking in some way. For example:

  • There is no evidence to suggest that this ethics and compliance-related data would include details of bribery or corruption related incidents, investigations or disciplinary actions;
  • The information that the company publishes does not cover all of the specific measures described in score ‘2’; or
  • The data does is not updated on at least an annual basis and/or does not cover the past 12 months.

Score: 0/2

The company scored 0/2 for this question

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

Comments

Based on publicly available information, there is no evidence to indicate that the company publishes data on ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving agents.

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

7.2.1 Does the company conduct risk-based anti-bribery and corruption due diligence when entering into and operating as part of joint ventures?

Points

POINTS: 2/2

This is a policy question

This question is looking for evidence that the company conducts due diligence on its joint venture partners, which is based on and determined by an assessment of bribery and corruption risks.

Joint ventures are becoming an increasing feature in the defence sector, as companies seek to expand into overseas markets without the constraints of acquisitions or establishing local operations. There are many benefits of this approach: faster market entry, lower costs, local expertise and, in many cases, access to an existing local customer base. However, joint ventures can present a range of bribery and corruption risks. Companies may be contractually required by the purchasing customer to enter into a joint venture with an unfamiliar entity, where the due diligence may reveal that the partner company is state-owned or related to the purchasing customer through other means, thereby increasing the corruption risk. Companies may also enter into and operate in joint ventures in unfamiliar or new markets, meaning that due diligence is an important factor in establishing the context and operating environment for the new entity.

An effective and regular due diligence process can mitigate these risks. Due diligence on joint venture partners should be conducted at several stages in the partnership, including when a preferred counterpart is identified, when the definitive agreement is signed and on an ongoing basis once the joint venture has been established. While focused on identifying high risk partners, the due diligence methodology should be capable of managing large numbers of entities within the available resources.

Due diligence checks should specifically include establishing the ultimate beneficial ownership of the joint venture partner, and be refreshed on a regular basis throughout the lifespan of the joint venture.

If the company explicitly states that it does not enter into or operate in joint ventures, this question should be scored N/A.

Score: 2/2

The company scored 2/2 for this question

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on all of its joint venture partnerships. At a minimum, the company states that this includes establishing the ultimate beneficial ownership of the partner company, with enhanced due diligence for joint ventures operating in high risk countries or with high risk partners, such as state-owned enterprises. There is evidence that the company conducts anti-bribery and corruption due diligence both prior to entering into a joint venture and on both the entity and its activities once established, at least every two years and/or when there is a significant change in the business relationship.

Score: 1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering and while operating in a joint venture; however, this is lacking in some way. For example:

  • There is no evidence that the company conducts due diligence on every joint venture partnership;
  • It is not clear that the company’s due diligence explicitly includes checks on the ultimate beneficial ownership of the partner company;
  • There is no evidence to suggest that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence; or
  • The company only conducts due diligence before engaging joint ventures, and does not repeat these checks at least every two years or when there is a significant change in the business relationship.

Score: 0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its joint ventures. Or, there is no evidence that this due diligence includes – and is based on – an assessment of potential bribery and corruption risk.

Comments

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all of its joint venture partnerships. The company indicates that joint venture partners are subject to enhanced due diligence based on country, size, type, role, nature of the transaction and historical relationship. These criteria imply that the company undertakes enhanced due diligence for joint ventures operating in high risk countries or with high risk partners.

There is also evidence to indicate that the company’s due diligence includes establishing the beneficial ownership of joint venture partners and that such checks are conducted prior to entering into the contract and then every two years throughout the relationship. Although the company provides this information in relation to sales representatives, it publishes a statement that the same due diligence process applies for joint ventures and therefore it merits a score of ‘2’.

7.2.2 Does the company commit to incorporating anti-bribery and corruption policies and procedures in all of its joint venture partnerships, and does it require anti-bribery and corruption clauses in its contracts with joint venture partners?

Points

POINTS: 2/2

This is a policy question

This question is looking for evidence that the company has measures to establish anti-bribery and corruption policies and procedures in its joint venture relationships from the outset, as part of the process when entering into a joint venture. This commitment is reinforced by a contractual agreement with the joint venture partner, whereby the new entity is required to implement and uphold certain standards of anti-bribery and corruption controls.

A contractual clause is more than just an agreement – it is a critical anti-corruption control. It communicates explicitly the company’s expectations regarding anti-corruption and ethical behaviour, establishes rights and specifies anti-corruption requirements and processes for monitoring, remediation, termination and exit. Audit and termination rights provide companies with formal mechanisms through which they can assure themselves that the counterparties they partner with are also working to implement these controls in practice and are committed to addressing and preventing bribery and corruption in the new entity.

If the company explicitly states that it does not enter into or operate in joint ventures, this question should be scored N/A.

Score: 2/2

The company scored 2/2 for this question

There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies and procedures in all of its joint ventures; for example, by requiring the adoption of its own anti-bribery and corruption programme or by developing a programme jointly with the relevant partner company. The company states that it includes anti-bribery and corruption clauses in its joint venture contracts – and that it will only enter into joint ventures if such contractual clauses are included – at minimum prohibiting foreign and domestic bribery and facilitation payments, as well as specifying clear audit and termination rights to detect, control and prevent breaches.

Score: 1/2

There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies in all of its joint ventures, but it is unclear how the company ensures this in practice. For example, the company does not state that it requires all joint ventures to adopt its own programme or that it works with partner companies to develop a programme. Or, the company states that it accounts for anti-bribery and corruption considerations when entering into a joint venture, but does not specify that it takes steps to detect, control and prevent breaches through the inclusion of audit and termination rights in the contract.

Score: 0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, and/or there is no evidence that it requires anti-bribery and corruption clauses in its contracts with joint venture partners.

Comments

There is evidence that the company commits to establishing and implementing anti-bribery and corruption procedures in all of its joint ventures. The company clearly states that it includes anti-bribery and corruption clauses in its joint venture contracts, and there is evidence that it requires all business partners to abide by the standards outlined in its Ethical Code of Conduct throughout the business relationship. The Ethical Code of Conduct therefore applies to all third parties and business partners, and stipulates policies and procedures prohibiting bribery and facilitation payments. The company also makes reference to audit and termination rights in its contracts, though it is noted that although this evidence applies to joint ventures, it is presented primarily in the context of sales representatives.

7.2.3 Does the company commit to take an active role in preventing bribery and corruption in all of its joint ventures?

Points

POINTS: 0/2

This is a policy question

This question is looking for evidence that the company has practical measures in place to counter bribery and corruption risks in its joint ventures, in addition to policies and procedures where appropriate.

Even where the company may be a minority partner in a joint venture, there are ways to ensure that certain standards of anti-bribery and corruption measures are upheld. For example, a company can stipulate that the Chief Compliance Officer in the joint venture be transferred from or appointed by their own company or report directly to the main company’s audit committee. Similarly, companies with more mature ethics and compliance programmes may take the lead in providing tailored anti-bribery and corruption training to employees of the joint venture or may institute a secondment scheme to ensure that high standards are upheld throughout the joint venture’s operations. Other such controls could include provisions for real-time access to electronic books and records or a separate internal audit function.

If the company explicitly states that it does not enter into or operate in joint ventures, this question should be scored N/A.

Score: 2/2

There is evidence that the company explicitly commits to take an active role in preventing bribery and corruption in all of its joint ventures. There is clear evidence to support the company’s commitment, either through practical examples or a statement of possible controls that it may implement, dependent on the context; such controls could include, for example, secondments of staff to the leadership of the joint venture or provision of anti-bribery and corruption training to joint venture staff.

Score: 1/2

There is evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. However, the company does not provide any further information or practical details to support this statement.

Score: 0/2

The company scored 0/2 for this question

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. Or, it is unclear whether this commitment applies to all of the company’s joint ventures.

Comments

There is some evidence that the company expects its business partners to adhere to ethical standards and that it conducts regular anti-bribery and corruption reviews of its third parties. However, there is no clear evidence to suggest that the company commits to take an active role in preventing bribery and corruption in its joint ventures, beyond requiring that such entities follow its Ethical Code of Conduct.

Compare scores by company

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AAR Corporation /2
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Abu Dhabi Shipbuilding 0/2

There is no publicly available evidence that the company has a policy covering the use of agents.

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company's incentive structures for agents are designed to minimise risks of bribery and corruption or that incentive structures are recognised as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on its behalf.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in its joint ventures.

Accenture PLC 1/2

There is evidence that the company has a policy on the use of agents, which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. There is evidence that this policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures.

However, there is no evidence that the company explicitly commits to verifying in each case that the use of an agent is necessary to perform a legitimate business function.

1/2

There is some evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging with its third parties and agents.

However, it is not clear that highest risk agents and intermediaries are subject to enhanced due diligence. Also, while the company states that due diligence is conducted periodically throughout the business relationship, the frequency of this process is unclear. There is also no clear evidence that due diligence is repeated at least every two years and/or when there is a significant change in the business relationship.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents, or that it commits to not engaging or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.

0/2

There is evidence that the company’s anti-corruption policies explicitly apply to all agents and third parties acting for or on behalf of the company. However, there is no evidence that the company includes anti-bribery and corruption clauses in contracts with agents and intermediaries to detect, control and prevent breaches.

0/2

There is no evidence that the company addresses incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

1/2

There is some evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering and while operating in all joint ventures.

However, there is no evidence that the company’s due diligence explicitly includes checks on the ultimate beneficial ownership of the partner company. There is also no evidence that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence. Additionally, while the company states that due diligence is conducted periodically throughout the business relationship, there is no clear evidence that it is repeated at least every two years or when there is a significant change in the business relationship.

0/2

There is evidence that entities controlled by the company are required to comply with the standards contained in its Code of Business Ethics.

However, the company scores ‘0’ because there is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in all of its joint ventures. Furthermore, there is no evidence that it requires anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no evidence that the company commits to taking an active role in preventing bribery and corruption in all of its joint ventures.

AECOM 2/2

There is evidence that the company has a policy which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. There is evidence that the company commits to establishing that the use of agents is necessary to perform a legitimate business function. This policy applies to all divisions within the organisations, including subsidiaries and joint ventures.

1/2

The company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging with its third parties and agents. There is also evidence that the company undertakes enhanced due diligence for high-risk agents. The company commits to not engaging or terminating its engagement with agents or intermediaries where the risks identified in the due diligence cannot be mitigated. The company states that it typically repeats due diligence every three years or when there is a significant change in the business relationship.

The company receives a score of ‘1’ because it does not refresh its due diligence at least every two years.

0/2

Although the company indicates that it seeks to identify whether there have been changes to the ownership of third parties when refreshing its due diligence, it does not explicitly commit to establishing the beneficial ownership of its agents at the outset of the business relationship. Moreover, the company does not commit to not engaging or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.

0/2

There is evidence the company’s anti-corruption policy applies to agents and intermediaries, and that it includes anti-bribery and corruption clauses in its contracts with such entities. The company indicates that it includes audit rights in its contracts with third parties in some cases but it does not explicitly state that it also includes termination rights in its contracts with these entities.

1/2

There is evidence that the company highlights incentive structures for agents as a factor in bribery and corruption risk. The company states that it places a threshold on sales-based commissions to agents so that payments do not exceed a proportion of the net fee to the agent.

However, the company does not explicitly state that remuneration to agents is paid only in staged payments over the course of their contract, based on clear milestones, into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering and while operating in a joint venture. The company states that partners in certain markets may be subject to more in-depth due diligence, and that it typically repeats due diligence every three years or when there is a significant change in the business relationship.

However, it is not clear that the company’s due diligence explicitly includes checks on the ultimate beneficial ownership of the partner company, or that it conducts due diligence every two years.

1/2

The company states that its Code of Conduct is applicable to joint ventures where it holds the majority interest. The company includes anti-corruption clauses in all third party contracts and audit rights in some high-risk joint ventures.

However, it is unclear whether the company establishes anti-bribery and corruption policies in joint ventures where it does not hold a controlling interest. Additionally, the company does not specify that it takes steps to detect, control and prevent breaches through the inclusion of audit and termination rights in all of its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. Although the company includes anti-corruption contractual clauses in its contracts with all third parties, it does not provide any further public information on active steps it might take to prevent bribery and corruption in all of its joint ventures.

Aerojet Rocketdyne 0/2

There is no publicly available evidence that the company has a policy on the use of agents or its approach to managing the corruption risks associated with them, such as by establishing and verifying that the use of agents is necessary to perform a legitimate business function.

1/2

The company states that it conducts due diligence when selecting or reappointing agents to minimise corruption risk. However, the company does not provide any further publicly available on the company’s due diligence procedure, such as the scope of due diligence, the frequency at which it is undertaken and refreshed, nor whether the company undertakes enhanced due diligence for higher risk agents.

0/2

There is no publicly available evidence that the company aims to establish the ultimate beneficial ownership of agents and intermediaries.

0/2

There is evidence that the company’s Code of Conduct applies to all agents and intermediaries acting for or on behalf of the company. However, there is no publicly available evidence about whether the company’s contracts with agents and intermediaries include anti-bribery and corruption clauses.

0/2

There is no publicly available evidence to suggest that the company recognises incentive structures as a risk factor in agent behaviour, or that its incentive structures have been designed to minimise risks of bribery and corruption.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

0/2

Based on publicly available information, there is no evidence that the company conducts anti-bribery and corruption due diligence on its joint ventures.

0/2

Based on publicly available information, there is no evidence that the company commits to incorporating anti-bribery and corruption policies and procedures in all of its joint venture relationships.

0/2

Based on publicly available information, there is no evidence that the company commits to taking an active role in preventing bribery and corruption in all of its joint venture relationships.

Airbus Group 2/2

Based on publicly available evidence, the company has a policy on the use of agents which acknowledges the associated corruption risks and provides details of specific controls to mitigate these risks. There is evidence that the company’s approach includes ensuring that third parties conduct work under a valid, approved contract, thereby ensuring that agents are only engaged to perform legitimate business functions. There is evidence that this policy applies across all group companies.

2/2

Based on publicly available evidence, the company has in place formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with third parties. There is evidence that agents and high risk intermediaries are subject to enhance due diligence, and it is clear that these checks are conducted regularly throughout the entire life of the relationship. There is evidence that the company commits to review or terminate its engagement with third party agents and intermediaries where risks identified in the due diligence cannot be mitigated.

2/2

There is publicly available evidence that the company has formal procedures in place to establish and verify the beneficial ownership of third party agents prior to engaging with them and on an ongoing basis throughout the relationship. The company commits to not engaging or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.

2/2

According to publicly available information, the company requires that all of its third parties comply with its anti-bribery and corruption policies as well as with international anti-corruption laws. The company monitors its third parties in this respect throughout the duration of the relationship and conducts regular audits of these parties. There is evidence that the company’s contracts with third party agents include formal provisions to terminate the relationship if necessary.

1/2

Based on publicly available information, incentive structures for agents are highlighted and addressed as a factor in bribery and corruption risk. However, there is no evidence that the company imposes a threshold on the payment of sales commissions to agents, and there is no requirement that remuneration is paid in stage payments or into local bank accounts.

0/2

There is no evidence that the company publishes details of the agents currently contracted on its behalf.

0/2

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

1/2

Based on publicly available information, there is evidence that the company has procedures in place to conduct due diligence when entering into and operating as part of joint ventures. The company states that it has processes to ensure that corruption risks associated with joint ventures are detected, assessed and mitigated. There is some evidence that high-risk intermediaries are subject to enhanced due diligence. The company’s due diligence explicitly includes checks on the ultimate beneficial ownership of the partner company. However, there is no evidence that due diligence checks are conducted at least every two years.

2/2

Based on publicly available information, there is evidence that the company commits to establishing and implementing anti-bribery and corruption policies and procedures in all of its joint ventures. The company implemented a directive that requires the company to terminate a joint venture following a breach of anti-corruption representations and warranties in its joint venture agreement, and that also specifies the company’s right to conduct periodic audits of these entities.

1/2

There is evidence that the company publicly commits to take an active role in preventing bribery and corruption in all of its joint ventures. However, the company does not provide any further statements or evidence to support this claim.

Almaz-Antey 0/2

There is no evidence that the company has a policy covering the use of agents.

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is no evidence that the company has an anti-corruption policy which applies to agents and intermediaries, or that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company considers incentive structures as a risk factor in agent behaviour, nor is there evidence that the company's incentive structures for agents are designed to minimise risks of anti-bribery and corruption.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or and on behalf of the company.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Arab Organization for Industrialization (AOI) 0/2

There is no evidence that the company has a clear policy covering the use of agents.

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents. There is no evidence that the company commits to not engaging or terminate its engagement with agents or intermediaries if beneficial ownership cannot be established.

0/2

There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company considers incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in its joint ventures.

Arsenal JSCo. 0/2

There is no evidence that the company has a policy covering the use of agents.

0/2

There is no evidence that the company states that it conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company mentions incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on behalf of the company.

0/2

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

0/2

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

0/2

There is no evidence to suggest that the company requires anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Aselsan A.Ş. 0/2

Based on publicly available information, there is no clear evidence that the company has a policy on agents which addresses the corruption risks associated with their use. The company states that it has a policy on the ‘Appointment and Management of Foreign Agents’, however this document does not appear to be publicly available so it is unclear whether the company recognises the corruption risks associated with agents or has specific controls in place to mitigate these risks. In addition, there is no evidence that the company commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function.

0/2

Based on publicly available information, there is insufficient evidence to indicate whether the company has procedures in place to conduct anti-bribery and corruption due diligence on its agents and intermediaries. The company states that it has a policy on the ‘Appointment and Management of Foreign Agents’, however this document does not appear to be publicly available so it is unclear whether due diligence forms a part of the selection and appointment process. Furthermore, the company states that it will not engage with firms found to have been involved in corrupt activity, but it is not clear that this stems from a due diligence process.

0/2

Based on publicly available information, there is no evidence that the company aims to establish the ultimate beneficial ownership of its agents and intermediaries.

0/2

Based on publicly available information, there is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries. There is some evidence that the company’s anti-bribery and corruption policy applies to companies providing consultancy services to the company, but it is not clear that the policy applies to agents and intermediaries acting on the company’s behalf.

0/2

Based on publicly available information, there is no evidence that the company addresses incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

1/2

Based on publicly available information, there is some evidence that the company has procedures to conduct due diligence on business partners – which is understood to include joint venture partners – during the selection and appointment phase. The company states that it will not engage with any partners that have been involved in corrupt activity, though it is not clear whether this stems from the results of due diligence.

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

1/2

There is evidence that the company’s anti-bribery and corruption policy applies to joint ventures in which the company holds more than 49% of shares or voting rights. The company also indicates that it takes steps to ensure compliance with the policy in joint ventures where it holds less than 49% of shares or voting rights by conducting certain checks on the entity.

However, the company receives a score of ‘1’ because it is not clear that the company includes anti-bribery and corruption clauses in its contracts with joint venture partners to detect, control and prevent breaches. The nature of the checks that the company conducts to ensure compliance in minority-owned joint ventures is also unclear.

0/2

Based on publicly available information, there is no clear evidence that the company commits to taking an active role in preventing bribery and corruption in all its joint ventures. There is evidence that the company’s policy applies to majority-owned joint ventures and that it takes steps to ensure compliance in minority-owned joint ventures, but the publicly available details of the steps taken to ensure this is not sufficiently detailed to receive a score of ‘1’.

Austal 0/2

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

0/2

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

0/2

There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is no publicly available evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no publicly available evidence that the company recognises incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on its behalf.

0/2

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

0/2

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

0/2

There is no publicly available evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Aviation Industry Corporation of China (AVIC) 0/2

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

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company commits to establishing the beneficial ownership of its agents, nor that it commits to not engaging or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.

0/2

There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company considers incentive structures as a risk factor in agent behaviour, nor that incentive structures for agents are designed to minimise risks of anti-bribery and corruption.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on behalf of the company.

0/2

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

0/2

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

0/2

There is no clear evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, nor that it requires anti-bribery and corruption clauses in its contracts with joint venture partners. The company publicly commits to operate in accordance with the law and in good faith in all of its business partnerships, without making specific reference to corruption, but this does not specifically relate to joint ventures nor does it imply that specific anti-corruption policies will be put in place.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Babcock International Group 2/2

There is evidence that the company has a policy and procedures to control the use of agents, which address the corruption risks associated with their use and provide details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. There is evidence indicating that this policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures.

2/2

Based on publicly available information, there is evidence the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and/or re-engaging any agents and intermediaries. There is also evidence that all agents and highest risk intermediaries are subject to several layers of enhanced due diligence. The company indicates that it refreshes this due diligence every two years and that all agent relationships are reviewed as part of an annual risk assessment process.

In addition, there is some evidence to indicate that the company may escalate the findings of due diligence to a Sector Manager or one of the Group’s lawyers if red flags arise. The company states that the appointment of agents may only proceed in compliance with the due diligence process, indicating that it may terminate its engagement with agents in cases where red flags identified cannot be mitigated.

2/2

Based on publicly available information, there is evidence the company has formal procedures to establish the beneficial ownership of agents prior to engaging them as part of its due diligence process. There is evidence that the company commits to independently verify the beneficial ownership information provided by high risk agents with due diligence repeated at least every two years.

In addition, there is some evidence to indicate that the company may escalate to a Sector Manager or one of the Group’s lawyers if red flags arise. The company states that the appointment of agents may only proceed in compliance with the due diligence process, indicating that it may terminate its engagement with agents in cases where beneficial ownership cannot be established.

0/2

Based on publicly available information, there is evidence the company’s anti bribery and corruption policy applies to all agents acting for or on behalf of the company. The company includes anti-bribery and corruption clauses in its contracts with such entities. However, the company receives a score of ‘0’ because there is no clear evidence that these contractual clauses include audit and termination rights.

2/2

There is clear publicly available evidence the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company indicates that compensation for agents must be based on the work provided and commensurate with legitimate market rates in the given jurisdiction, to avoid disproportionate or significant success fees or commissions. In addition, the company commits to question any requests for payments into foreign bank accounts. Although the company does not explicitly state that agents are paid based on clear milestones, there is sufficient evidence that all payments are monitored and that must be appropriately invoiced that the company can receive a score of ‘2’.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf. The company indicates that it maintains a database of all agents, including name, term of appointment, territory, project and the services rendered; however, this database does not appear to be publicly available.

0/2

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

2/2

Based on publicly available information, there is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all of its joint venture partnerships. There is evidence that this process includes establishing the beneficial ownership of the partner company, as well as enhanced due diligence for joint ventures operating in high risk countries or when other red flags are identified. In addition, there is evidence to indicate that the company repeats these checks at least every two years or when there is a significant change in the business relationship.

1/2

Based on publicly available information, there is evidence the company commits to establishing and implementing anti-bribery and corruption policies in all of its joint ventures. The company states that joint venture partners are expected to adopt its own Anti-Bribery and Corruption Policy or implement equivalent standards.

However, the company receives a score of ‘1’ because there is no clear evidence that it takes steps to detect, control and prevent breaches through the inclusion of audit and termination rights in its contracts with such entities.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

BAE Systems PLC 2/2

There is evidence that the company has a policy to regulate the use of agents, or ‘advisers’, which addresses the corruption risks associated with their use and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an adviser is, in each case, necessary to perform a legitimate business function. There is evidence that this policy applies to all divisions within the organisation that might employ advisers, including subsidiaries.

2/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with third parties and agents. The company indicates that this due diligence is conducted before engaging agents and is repeated at least every two years or when there is a significant change in the business relationship. There is evidence that all agents are subject to enhanced due diligence.

2/2

There is evidence that the company aims to establish the beneficial ownership of third parties, including agents, at the outset of the business relationship and every two years. There is evidence that the company commits to independently verify the beneficial ownership information of agents, and the company indicates that it will not engage or terminate its engagement with agents if beneficial ownership cannot be established.

2/2

There is evidence to indicate that the company’s anti-bribery and corruption policy applies to agents acting for or on behalf of the company. The company indicates that all agents are subject to anti-bribery and corruption clauses in their contracts, which include audit and termination rights.

1/2

There is some evidence that the company highlights incentive structures for agents as a factor in bribery and corruption risk. The company indicates that there must be a compelling justification for the renumeration proposed and states payment terms are reviewed by its Business Development Adviser Compliance Panel.

However, the company receives a score of ‘1’ because it does not provide further details on how incentive structures for agents are designed to minimise risks of anti-bribery and corruption. For example, there is no evidence that the company imposes a threshold on the payment of sales commissions to agents, nor that it commits to paying remuneration into local bank accounts or in stage payments based on clear milestones.

0/2

There is no evidence that the company publishes any details of the agents or ‘advisers’ currently contracted to act for or and on its behalf.

0/2

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

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering a joint venture partnership, which includes checks on the beneficial ownership of the partner company. There is evidence that the company conducts enhanced due diligence where required, but it is not clear whether this would include joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises.

The company receives a score of ‘1’ because there is no clear evidence to indicate that it repeats due diligence on its joint ventures at least every two years.

2/2

Based on publicly available information, there is evidence that the company establishes and implements anti-bribery and corruption policies in its controlled joint ventures, by ensuring that they follow its Operational Framework (OF) and anti-corruption programme. In addition, it takes active steps to encourage the joint ventures which are not fully controlled by BAE Systems to adopt substantially equivalent standards in relation to anti-bribery and corruption. The company indicates that its joint venture contracts include anti-corruption provisions and can include audit and termination rights.

2/2

There is evidence that the company commits to take an active role in preventing bribery and corruption its joint ventures. The company indicates that it may do this in practice by providing training to employees in controlled joint ventures and by appointing employees to board positions – or comparable bodies in non-controlled joint ventures – to encourage equivalent standards of governance.

Ball Aerospace & Technologies Corporation 0/2

There is no evidence that the company has a policy covering the use of agents.

0/2

There is some evidence that the company undertakes due diligence on its third parties. However, the information provided is insufficiently detailed to receive a score of ‘1’.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is some evidence that the company’s anti-bribery and corruption policy applies to agents and intermediaries acting on the company’s behalf. However, the company does not include clear audit and termination rights in its contracts with these entities.

0/2

There is no evidence that the company acknowledges incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

0/2

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

0/2

There is evidence that the company’s anti-bribery and corruption policies or procedures apply to its joint venture partners. However, there is no evidence that it requires anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Battelle Memorial Institute NA

There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.

NA

There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.

NA

There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.

NA

There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.

NA

There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.

NA

There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.

NA

There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.

0/2

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

0/2

There is no evidence that the institute commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures; it does not require anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no evidence that the institute commits to take an active role in preventing bribery and corruption in its joint ventures.

Bechtel Corporation 2/2

There is evidence that the company has a clear policy to control the use of agents which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. There is evidence that this policy applies company-wide to all divisions within the organisation which might employ agents, including any subsidiaries and joint ventures.

2/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging any agents and intermediaries, at least every two years. The company states that agents and highest risk intermediaries are subject to enhanced due diligence. The evidence suggests that the company will not engage or terminate its engagement with agents where the risks identified in the due diligence cannot be mitigated.

2/2

There is evidence that the company has formal procedures to establish the beneficial ownership of agents, as part of its due diligence process, prior to engaging them, and at least every two years. There is evidence that the company operates, as a minimum, a risk based beneficial ownership verification policy, whereby all agent provided information is verified and high risk agent’s information is independently verified. In addition, the company indicates that it conducts media searches and may use a third party research company if this information is not readily available.

There is also evidence company will not engage or terminate its engagement with agents where red flags identified in the due diligence cannot be mitigated. Although the company does not explicitly state that this includes rd flags on beneficial ownership, there is sufficient evidence that beneficial ownership checks are embedded throughout the process to satisfy this part of the scoring criteria for ‘2’.

1/2

There is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. There is clear evidence that agents must confirm their commitment to the Code of Conduct prior to undertaking work for the company, and that all agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts.

However, the company receives a score of ‘1’ because the company does not specifically clarify that these anti-corruption clauses include audit and termination rights.

1/2

Based on publicly available information, there is evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company indicates that it places a reasonable threshold on sales-based commissions and there is evidence that the company is alert to requests for unusually large payments or to pay individuals into non-local bank accounts.

However, the company receives a score of ‘1’ because there is no evidence that the company requires that remuneration is paid in stage payments over the course of their contract.

0/2

There is no publicly available evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

There is some publicly available evidence that the company publishes high-level data from ethical incidents and investigations, which includes reports from and about suppliers and contractors. However, it is not sufficiently clear that this evidence includes data about incidents and investigations involving agents or intermediaries, and therefore the company receives a score of ‘0’.

2/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on all of its joint venture partnerships. This includes establishing the ultimate beneficial ownership of the partner company, with enhanced due diligence for joint ventures operating in high risk countries. There is evidence that the company conducts anti-bribery and corruption due diligence prior to entering into a joint venture and once activities have been established, at least every two years.

1/2

There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies in all of its joint ventures, by requiring adherence to its Code of Conduct. There is evidence that the company states that it includes anti-bribery and corruption clauses in its joint venture contracts.

However, the company receives a score of ‘1’ because it does not specify that it takes steps to detect, control and prevent breaches of this policy through mechanisms such as audit and termination rights.

2/2

Based on publicly available information, there is evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. There is clear evidence to support the company's commitment, such as a requirement that the company has oversight of the joint venture’s financial activities, including access to books and records.

BelTechExport Company JSC 0/2

There is no publicly available evidence that the company has a policy on the use of agents.

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company does aims to establish the beneficial ownership of its agents, nor that it commits to not engaging or terminate its engagement with agents or intermediaries if beneficial ownership cannot be established.

0/2

There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company considers incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or and on its behalf.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in its joint ventures.

Bharat Dynamics 0/2

There is no publicly available evidence that the company has a policy covering the use of agents.

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company commits to establish the beneficial ownership of its agents.

0/2

There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company addresses incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on behalf of the company.

0/2

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

0/2

Based on publicly available information, there is no indication that the company conducts anti-bribery and corruption due diligence on its joint venture partnerships.

The company states that it does not currently have any joint ventures or associate companies; however there is no evidence that it may not enter into joint ventures in the future since the company does not state this as a matter of policy. The company therefore receives a score of ‘0’.

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, nor there is evidence that it requires anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Bharat Electronics 0/2

Based on publicly available information, there is some evidence that the company acknowledges the corruption risks associated with the use of agents, by stating that such entities should not seek or accept bribes.

However, the company receives a score of ‘0’ because it does not publish further details of controls to mitigate the specific risks associated with agents. Furthermore, the company does not explicitly commit to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function.

0/2

There is no clear evidence that the company has formal procedures in place to conduct anti-bribery and corruption due diligence prior to engaging and when working with agents and intermediaries. There is some indication that the company has formal procedures to conduct due diligence prior to engaging with consultants and vendors, but it is not clear that this includes agents, nor whether it covers anti-bribery and corruption considerations.

0/2

There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is some evidence that the company’s prohibition of bribery applies to agents. However, the company receives a score of ‘0’ because there is no indication that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no publicly available evidence that the company mentions incentive structures as a risk factor in agent behaviour.

0/2

There is no publicly available evidence that the company publishes any details of the agents currently contracted to act for or on behalf of the company.

0/2

There is no publicly available evidence that the company publishes any data on ethical or bribery and corruption related investigations, incidents or associated disciplinary actions involving agents.

0/2

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

0/2

There is some evidence that the company acknowledges where it could incur liability for corruption when entering into joint venture partnerships. However, there is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures. In addition, there is no evidence that it requires anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Boeing 1/2

Based on publicly available information, there is some evidence that the company has a policy on the use of agents, which it refers to as international consultants. The company provides details of some controls to mitigate these risks, including due diligence and multiple senior sign-offs of the agent’s scope of work. There is evidence to suggest the policy also applies to subsidiaries and joint ventures.

However, the company receives a score of ‘1’ because there is no publicly available evidence that the company commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function.

1/2

Based on publicly available information, there is some evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging with its agents.

However, the company receives a score of ‘1’ because there is no evidence that agents and the highest risk intermediaries are subject to enhanced due diligence. Although the company states that it renews due diligence at appropriate intervals, it is not clear that the company repeats due diligence at least every two years or when there is a significant change in the business relationship. There is also no clear evidence that the company commits to not engaging or terminating its engagement with agents or intermediaries where risks identified in the due diligence cannot be mitigated.

1/2

There is some evidence that the company’s due diligence procedures includes checks on the ownership of its agents and international consultants. The company provides information to indicate that such checks are conducted at the outset of the relationship and that this process is overseen by the Law Department.

However, the company receives a score of ‘1’ because there is no clear evidence that the company commits to independently verify the beneficial ownership information provided by high risk agents, nor is there evidence that it commits to not engaging or terminating its engagement with agents or intermediaries in cases where beneficial ownership cannot be established.

0/2

Based on publicly available information, there is some evidence that the company’s anti-bribery and corruption policy applies to agents, and that it includes anti-bribery and corruption clauses in its contracts with such entities. However, while the company indicates that it maintains contractual rights in case of a breach, there is no clear evidence that these include audit and termination rights.

0/2

Based on publicly available information, there is no evidence that the company considers incentive structures as a risk factor in agent behaviour, nor is there evidence that the company's incentive structures are designed to minimise risks of anti-bribery and corruption.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

1/2

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

1/2

Based on publicly available information, there is some evidence that the company has formal procedures to conduct risk based anti-bribery and corruption due diligence prior to entering into all of its joint venture partnerships.

However, the company receives a score of ‘1’ because there is no clear evidence that the company’s due diligence includes checks on the ultimate beneficial ownership of the partner company. In addition, there is no evidence to suggest that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence. It is also not clear that due diligence is repeated at least every two years or when there is a significant change in the business relationship.

2/2

Based on publicly available information, there is evidence that the company ensures that all of its joint ventures adopt equivalent anti-bribery and corruption policies to its own. The company also states that it includes ethics and compliance provisions in its contracts with joint venture partners, which include audit rights. There is some indication that the company’s contracts with such entities include termination rights in the event of a breach.

2/2

There is evidence that the company publicly commits to take an active role in preventing bribery and corruption in its joint ventures. The company indicates that it does this by requiring that its joint venture entities establish a formal anti-corruption policy, as well as by seconding board members and conducting ongoing risk assessments.

Booz Allen Hamilton Inc. 1/2

There is evidence that the company has a policy and procedures to control the use of agents which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks, including due diligence reviews, as well as reporting and invoicing requirements. This policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures.

However, there is no publicly available evidence that the company specifically commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function.

2/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and/or re-engaging any agents and intermediaries. There is evidence that all agents and highest risk intermediaries are subject to enhanced due diligence. There is additional evidence that the company commits to not engaging or terminating its engagement with agents or intermediaries where the risks identified in the due diligence cannot be mitigated. In addition, the company indicates that it has procedures in place to conduct due diligence reviews on a continuous basis throughout the business relationship.

1/2

There is evidence that the company’s due diligence process specifically includes procedures to establish the ultimate beneficial ownership of agents and intermediaries. The company indicates that it does this through a pre-agreement questionnaire, and there is evidence that the company will not engage or terminate its engagement with agents and intermediaries in situations where beneficial ownership cannot be established.

However, it is not clear from publicly available information that the company has procedures in place to independently verify beneficial ownership information provided by any agents or intermediaries identified as high risk. In addition, there is no publicly available evidence that the company conducts and reviews this information specifically at least every two years or when there is a significant change in the business relationship.

0/2

There is evidence that the company’s anti-bribery and corruption policy applies to agents, intermediaries and other entities working on its behalf. However, there is no publicly available evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries, nor that its contracts include clear audit and termination rights to detect, prevent and control breaches.

1/2

There is evidence that the company recognises incentive structures as a risk factor in agent behaviour, by stipulating a specific approval procedure for payments to such entities.

However, there is no further publicly available evidence that incentives for agents are designed to promote ethical behaviour and discourage corrupt practices, for example by imposing a threshold on the payment of sales commissions to agents, or by requiring that remuneration is paid in stages and into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering and while operating in a joint venture, and that this process includes checks on the ultimate beneficial ownership of the partner company.

However, it is not clear from publicly available information whether joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence. In addition, there is no evidence that the due diligence process is repeated at least every two years.

0/2

There is some evidence that the company commits to establishing anti-bribery and corruption policies and procedures in its joint ventures. However, there is no publicly available evidence that the company requires anti-bribery and corruption clauses in its contracts with joint venture partners nor that such clauses include clear audit and termination rights to detect, control and prevent breaches.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures, for example by providing training to employees of joint ventures or implementing a policy to second senior individuals to the partner company’s management board.

CACI International Inc. 0/2

There is no publicly available evidence that the company has a policy on the use of agents.

0/2

There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries. The company indicates that it will not enter into agreements with individuals or entities under trade restrictions or that are found to have violated relevant laws, however it is not clear from publicly available evidence that such information is identified through due diligence or an equivalent evaluation.

0/2

There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents, nor is there evidence that the company commits to not engage or terminate its engagement with agents or intermediaries if beneficial ownership cannot be established.

0/2

There is some evidence that the company requires that its third party consultants adhere to its anti-corruption and ethics policies, though it is not clear from publicly available information that such entities may include agents and intermediaries. In addition, although the company indicates that contracts with such parties include termination clauses, there is no evidence that the company includes audit rights in its employment contracts with third parties.

0/2

There is no publicly available evidence that the company addresses incentive structures as a risk factor in agent behaviour, nor that such incentives include measures to mitigate potential bribery and corruption risks.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

CAE Inc. 2/2

There is evidence that the company has a policy to control the use of agents which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. The company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. There is evidence that this policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures.

2/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging agents and intermediaries. The company states that it reviews due diligence on an annual basis. There is evidence that all agents and highest risk intermediaries are subject to enhanced due diligence. There is also evidence that the company commits to not engaging or terminating its engagement with agents or intermediaries where risks identified in the due diligence cannot be mitigated.

1/2

There is evidence that the company has formal procedures in place to establish the beneficial ownership of agents prior to engaging them, which includes requiring agents to disclose this information as part of the due diligence process. The company also states that it reviews due diligence on an annual basis.

However, the company receives a score of ‘1’ because there is no evidence that the company commits to independently verify the beneficial ownership information provided by high risk agents. The company also does not specifically commit to reviewing or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.

0/2

There is evidence that the company’s anti-bribery and corruption policy applies to agents and intermediaries. The evidence also suggests that the company includes anti-bribery and corruption clauses in its contracts with these entities.

However the company receives a score of ‘0’ because it is not explicitly clear that that contracts include audit and termination rights. It is noted that the evidence includes a hyperlink to a model agreement, however this information is not publicly accessible.

2/2

There is evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. There is evidence that the company places a threshold on sales-based commissions to agents so that payments do not exceed a proportion of the net fee to the agent. There is also evidence that the company has a chain of approval and monitors agent payments, and commits to only paying agents into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on behalf of the company.

0/2

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

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

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering into all joint venture agreements.

However, there is no evidence that the company’s due diligence explicitly includes checks on the ultimate beneficial ownership of the partner company. There is also no evidence to suggest that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence. Additionally, the company’s public statements only make reference to due diligence prior to entering into joint venture agreements and there is no evidence that due diligence is repeated every two years and/or when there is a significant change in the business relationship.

1/2

There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies and procedures in all of its joint ventures by requiring the adoption of its own, or equivalent, anti-bribery and corruption policy. The company also states that it must include anti-corruption provisions in its joint venture agreements.

However, the company receives a score of ‘1’ because it does not specify that it takes steps to detect, control and prevent breaches through the inclusion of audit and termination rights in contracts with joint venture partners.

0/2

There is insufficient publicly available evidence to show that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

CEA Technologies 0/2

The company does not have a publicly available policy covering the use of agents.

0/2

The company does not state that it conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

The company does not aim to establish the beneficial ownership of its agents.

0/2

The company does not include anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no mention of incentive structures as a risk factor in agent behaviour.

0/2

The company does not publish any details of the agents currently contracted to act for or and on behalf of the company.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

The company does not commit to take an active role in preventing bribery and corruption in all of its joint ventures.

Chemring Group PLC 2/2

There is evidence that the company has a policy to control the use of agents which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. This policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures.

2/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with its third parties and agents. The company states that it conducts due diligence on third parties and agents, with more thorough due diligence being undertaken for higher risk agents and third parties. The company states that due diligence is repeated at least annually. The company states that it will not engage with agents or intermediaries where risks identified in the due diligence cannot be mitigated and suggests that it would apply this same approach with existing relationships when refreshing its due diligence on an annual basis.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents.

2/2

There is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. All agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include clear audit rights and termination rights to detect, control and prevent breaches.

1/2

There is evidence that incentive structures for agents are highlighted and addressed as a factor in bribery and corruption risk.

However, the company receives a score of ‘1’ because there is no evidence that it imposes a threshold on the payment of sales commissions to agents, and there is no requirement that remuneration is paid in stage payments or into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on behalf of the company.

0/2

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

0/2

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

0/2

Although there is some evidence that the company commits to establishing and implementing anti-bribery and corruption policies in its subsidiaries and with any third parties with whom it engages, there is no evidence that the company states that it requires anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

China North Industries Group Corporation (NORINCO) 0/2

There is no evidence that the company has a clear policy covering the use of agents.

0/2

There is no evidence that the company states that it conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company aims to establish the ultimate beneficial ownership of the agents.

0/2

There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company mentions incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, and it does not require anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

China State Shipbuilding Corporation 0/2

There is no publicly available evidence that the company has a policy on the use of agents.

0/2

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

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents, nor that it commits to not engaging or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.

0/2

There is no publicly available evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries to detect, control and prevent breaches of its policy.

0/2

There is no evidence that the company considers incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, nor that it requires anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no evidence that the company publicly commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Cobham Ltd. 2/2

There is evidence that the company has a clear policy and procedure to control the use of agents, which addresses the corruption risks associated with their use and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. There is evidence that this policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures.

2/2

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its third parties and agents. There is some evidence that some agents require senior review and sign off based on an assessment of their risk and any red flags identified, which is understood to include an enhanced due diligence process. In addition, there is evidence that this due diligence is conducted at the start of the agreement and on an ongoing basis throughout the contractual relationship.

1/2

There is clear evidence that the company has procedures in place to verify and conduct checks on the ultimate beneficial ownership of its agents and third parties. The company indicates that such checks are conducted at the start of the agreement and on an ongoing basis throughout the contractual relationship.

However, the company receives a score of ‘1’ because there is no clear evidence that it is willing to terminate an existing agreement or not engage an agent in instances where ultimate beneficial ownership cannot be established.

2/2

There is evidence that the company’s Code of Business Conduct applies to all agents and intermediaries acting for or on behalf of the company. The company indicates that all agents are subject to anti-bribery and corruption clauses in their contracts, which include audit rights and termination rights to detect, control and prevent breaches.

1/2

There is evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. There is evidence that the company places a threshold on sales-based commissions to agents so that payments do not exceed a proportion of the net fee to the agent.

However, the company receives a score of ‘1’ because there is no further evidence that the company commits to paying agents in staged payments over the course of their contract, based on clear milestones, or into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on its behalf.

0/2

There is no evidence that the company publishes any data on ethical or bribery and corruption related investigations, incidents or disciplinary actions involving agents.

2/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on all of its joint venture partnerships, and that this process includes checks on ultimate beneficial ownership. The company also indicates that joint venture partners identified as higher risk are subject to enhanced due diligence and sign-off procedures. In addition, the company indicates that such checks are conducted at the start of the agreement and on an ongoing basis throughout the contractual relationship.

2/2

There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies and procedures in all of its joint ventures, by requiring the adoption of its own anti-bribery and corruption programme and by assisting in its implementation with the partner company. The company indicates that it will only enter into joint ventures if anti-bribery and corruption clauses are included in the contract, at minimum prohibiting foreign and domestic bribery and facilitation payments, as well as specifying clear audit and termination rights to detect, control and prevent breaches.

2/2

There is evidence that the company takes an active role in preventing bribery and corruption in all of its joint ventures. There is clear evidence to support the company's commitment, through practical examples of controls that it implements.

Cubic Corporation 1/2

There is evidence that the company has a policy on the use of agents. It commits to establishing that the use of agents is necessary to perform a legitimate business function.

However, the company provides little detail on the corruption risks associated with agents and there is no evidence of specific controls to mitigate these risks. It is also not clear whether the Code of Business Conduct applies to agents engaged by joint ventures and subsidiaries.

1/2

There is evidence that the company conducts anti-bribery and corruption due diligence on third parties (including consultants, technical advisors and business representatives).

However, the company receives a score of ‘1’ because it is not clear whether agents and highest risk intermediaries are subject to enhanced due diligence. It is also not clear if due diligence is repeated at least every two years and/or whenever there is a significant change in the business relationship.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents. The company does not commit to not engaging or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.

0/2

The company’s Code of Conduct for Third Parties applies in general to all third parties, including agents and the company’s representatives. This code prohibits bribery, facilitation payments, covers conflicts of interests and gifts and hospitality, and states that the company’s whistleblowing channel is also open to third parties. However, the company receives a score of ‘0’ because there is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company's incentive structures for agents are designed to minimise risks of bribery and corruption or that incentive structures are recognised as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on behalf of the company.

0/2

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

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its prospective joint venture partners based on an assessment of corruption risk.

0/2

There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Curtiss-Wright Corporation 1/2

The company has a policy covering the use of agents and addresses some of the corruption risks associated with the use of agents (referred to as ‘representatives’). There is evidence that this policy applies to all businesses within the organisation which might employ agents, including subsidiaries and joint ventures. However, the company receives a score of ‘1’ because there is no evidence that the company commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function.

0/2

There is no evidence that the company states that it conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is evidence that the company’s Code of Conduct – which includes its anti-bribery and corruption policy – applies to agents and intermediaries. However, there is no evidence that agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts which include audit and termination rights to detect, control and prevent breaches.

0/2

There is no evidence that the company addresses incentive structures as a risk factor in agent behaviour, nor that incentive structures for agents are designed to minimise risks of anti-bribery and corruption.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on behalf of the company.

0/2

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

0/2

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

0/2

There is evidence that the company’s Code of Conduct – which includes its anti-bribery and corruption policy – applies to all businesses and representatives, which is understood to include joint venture partnerships. However, there is no publicly available evidence to indicate that the company requires anti-bribery and corruption clauses in its contracts with joint venture partners, including audit and termination rights.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in its joint ventures.

Daewoo Shipbuilding & Marine Engineering 1/2

Based on publicly available information, there is some evidence that the company has a policy covering the use of agents, which stipulates certain measures and controls to mitigate the corruption risks associated with their use.

However, the company receives a score of ‘1’ because there is no evidence that the company commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. The company furthermore does not specify that this policy also applies to subsidiaries and joint ventures.

1/2

Based on publicly available information, there is some evidence that the company has procedures to conduct due diligence prior to engaging with its business partners, the definition of which includes agents. There is some evidence indicating the company would not engage with an agent when the risks identified in due diligence can not be mitigated.

However, there is no evidence that agents and the highest risk intermediaries are subject to enhanced due diligence, nor that the company repeats due diligence at least every two years and/or when there is a significant change in the business relationship.

0/2

There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents.

0/2

Based on publicly available information, there is some evidence that that all third party and agents are subject to the company’s ethics policies. The company indicates that these standards are ensured through anti-corruption clauses in contractual agreements, which include termination rights. However, there is no evidence that the company explicitly includes audit rights in its contracts with these entities and therefore the company receives a score of ‘0’.

0/2

There is no publicly available evidence that the company addresses incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on its behalf.

0/2

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

0/2

Based on publicly available information, there is no clear evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering and while operating in joint ventures. The company does not refer to joint ventures in its definition of business partners of the company.

0/2

Based on publicly available information, there is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures. The company does not refer to joint ventures in its definition of business partners of the company.

0/2

There is no publicly available evidence to indicate that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Damen Schelde Naval Shipbuilding 2/2

Based on publicly available information, there is evidence that the company has a policy covering the use of agents. The company’s policy addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. This policy also applies to subsidiaries and joint ventures. In addition, there is evidence that the company commits to establishing that the use of agents is, in each case, necessary to perform a legitimate business function.

1/2

Based on publicly available information, there is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging with third parties and agents. It is also clear that agents and highest risk intermediaries are subject to enhanced due diligence. The company commits to not engaging or terminating its engagement with agents or intermediaries where the risks identified in the due diligence cannot be mitigated.

However, there is no evidence that due diligence is repeated at least every two years or when there is a significant change in the business relationship. The company indicates that it has a ‘Financial Compliance Policy’ which may contain more information concerning its policy on agents, but this does not appear to be publicly accessible.

1/2

Based on publicly available information, there is evidence that the company asks of agents to disclose their beneficial ownership to the company as part of its enhanced due diligence processes.

However, there is no evidence that the company commits to establishing beneficial ownership of all agents or to verify this every two years or when there is a change in the relationship.

2/2

There is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. All agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include clear audit and termination rights to detect, control and prevent breaches.

1/2

There is some evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company indicates that it monitors such entities on an ongoing basis, and that the Compliance Department is responsible for reviewing all invoices before payment.

However, the company receives a score of ‘1’ because there is no evidence that it imposes a threshold on the payment of sales commissions to agents, nor is there evidence that the company requires that remuneration is made in stage payments or into local bank accounts.

0/2

There is no publicly available evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

1/2

Based on publicly available information, there is some evidence that the company publishes some high-level data on ethical or bribery and corruption related investigations involving agents. The company states that no confirmed incidents relating to corruption for all business partners took place in the past year.

However, the company receives a score of ‘1’ because there is no evidence that this information includes data on the number of investigations launched.

1/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering a joint venture partnership. There is evidence that this due diligence is conducted for every joint venture partnership and it is clear that the company’s due diligence includes checks on the ultimate beneficial ownership of the partner company.

However, there is no evidence to suggest that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence. In addition, there is no evidence that the due diligence is repeated at least every two years or when there is a significant change in the business relationship.

1/2

Based on publicly available information, there is evidence that the company states that it accounts for anti-bribery and corruption considerations when entering into a joint venture. The company states that its anti-bribery and corruption policy applies to joint venture partners, and it ensures this through the inclusion of termination rights in its contracts with them. The company states that it will only enter into joint ventures if anti-bribery and corruption clauses are included in the contract.

However, there is no evidence that the company includes audit rights in its contracts with joint venture partners.

0/2

There is no publicly available evidence to indicate that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Dassault Aviation 0/2

There is no publicly available evidence that the company has a clear policy on the use of agents. The company indicates that it has implemented procedures for assessing and mapping risks relating to intermediaries, but there is no further publicly available information regarding its approach to managing the corruption risks associated with agents or intermediaries.

0/2

There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its agents and intermediaries. The company indicates that it has implemented procedures for assessing and mapping risks relating to intermediaries, but there is no further publicly available information regarding its approach to formal due diligence and evaluations of agents or intermediaries prior to engagement and throughout the business relationship.

0/2

There is no publicly available evidence that the company aims to establish the ultimate beneficial ownership of its agents and intermediaries, nor is there evidence that it commits to not engage or terminate its engagement with such entities if beneficial ownership cannot be established.

0/2

There is some evidence that the company requires that its service providers abide by its own Code of Ethics and that this forms part of the company’s general purchasing conditions. There is evidence to indicate that this includes a ban on commercial bribery and any improper gifts or hospitality. The company also indicates that all parties must comply with relevant anti-bribery legislation.

However, the company receives a score of ‘1’ because there is no clear publicly available evidence that it takes active steps to ensure that intermediaries comply with its ethical standards by including anti-corruption clauses in contracts with such entities, with clear audit and termination rights.

0/2

There is no publicly available evidence that the company's incentive structures for agents are designed to minimise risks of anti-bribery and corruption.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or and on its behalf.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures or that it requires anti-bribery and corruption clauses in its contracts with joint venture partners. There is some evidence that the company requires that its suppliers and service providers comply with its Code of Ethics, but it is not clear whether this requirement includes or extends to joint ventures.

0/2

There is no publicly available evidence that the company commits to taking an active role in preventing bribery and corruption in all of its joint ventures.

Day & Zimmermann 2/2

There is evidence that the company has a policy to control the use of agents which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. This policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures. It is noted that the company's policy covering agents relates specifically to those employed in positions either dealing with foreign customers or based outside of the United States, as outlined in the International Business Relationships policy document. Evidence suggests that the company does not employ agents in dealing with US clients.

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging agents and intermediaries.

However, while the company refers to conducting periodic due diligence, there is no publicly available evidence that due diligence is repeated at least every two years or when there is a significant change in the business relationship. There is also insufficient evidence that all agents and the highest risk intermediaries are subject to enhanced due diligence.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents nor that the company is committed to not engaging or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.

2/2

There is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. The company also makes it clear that all agents and intermediaries will be subject to disciplinary action and possible termination of contract in the event that they breach the Code of Ethics and Standards of Business Conduct, which includes provisions for clear audit rights to detect, control and prevent corruption.

1/2

There is some evidence that the company considers incentive structures as a risk factor in agent behaviour. The company indicates that it monitors agent performance throughout the contract, and states that all invoices submitted are carefully examined. The company also stipulates that all payments must be properly documented

However, the company receives a score of ‘1’ because it does not provide further publicly available details on its measures to ensure that incentives for agents do not pose a bribery and corruption risk, for example by imposing a threshold on the payment of sales commissions or requiring stage payments.

0/2

There is no evidence that the company publishes details of the agents currently contracted to act for or on behalf of the company.

0/2

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

1/2

There is some evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering and while operating in joint ventures.

However, there is no publicly available evidence that the company’s due diligence includes checks on the ultimate beneficial ownership of the partner company, nor that enhanced due diligence is required in vetting possible joint venture partners in high risk markets and jurisdictions. While the company refers to conducting periodic due diligence, there is also no evidence that due diligence is repeated at least every two years. It is also noted that the policy only seems to relate to joint ventures outside of the United States.

1/2

There is some evidence that the company requires all joint venture partners to adhere to its own anti-corruption standards and procedures and that the company includes audit rights in its contractual agreements.

However, the company receives a score of ‘1’ because there is no clear, publicly available evidence that all joint venture partners are required to sign anti-corruption clauses with termination rights in contracts with the company.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Denel SOC 0/2

There is no evidence that the company has a clear policy covering the use of agents. In its Annual Report (2018), it commits to continuously reviewing and strengthening processes for appointing agents. The company receives a score of ‘0’ because it does not provide further information on these processes not does it specifically address the corruption risks associated with the use of agents.

0/2

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

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents, nor does it commit to not engaging or terminate its engagement with agents or intermediaries if beneficial ownership cannot be established.

0/2

There is some evidence that the company includes provisions related to ethics in its contracts with advisors, but it does not mention anti-bribery and corruption. In addition, there is no publicly available evidence that the company includes audit and termination rights in these contracts. It is also not clear that the company’s has an anti-bribery and corruption policy which applies to agents. As such, the company receives a score of ‘0’.

0/2

There is no evidence that the company's incentive structures for agents are designed to minimise risks of bribery and corruption or that incentive structures are recognised as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or and on behalf of the company.

0/2

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

0/2

The company states that it conducts anti-bribery and corruption due diligence on its potential partners but there is no evidence that the company directly refers to joint ventures.

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Diehl Stiftung & Co. KG 1/2

There is evidence that the company has a policy on the use of agents which addresses the corruption risks associated with their use and provides details of specific controls to mitigate these risks. The company indicates that it has procedures in place to ensure that any sales representatives meet high standards of integrity and to ensure compliance with all relevant regulations. In addition, there is evidence that the Corporate Compliance Officer (CCO) has oversight of all agreements with sales representatives. There is some evidence that this policy applies to all divisions and subsidiaries that might employ agents.

However, the company receives a score of ‘1’ because there is no evidence that it commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function.

2/2

There is evidence the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging any agents and intermediaries. The company indicates that due diligence is repeated at least every two years and when there is a significant change in the business relationship. There is evidence that all agents and highest risk intermediaries are subject to enhanced due diligence. In addition, the company commits to not engage or terminate its engagement with agents or intermediaries where any risks identified in the due diligence cannot be mitigated.

2/2

There is evidence the company has formal procedures in place to establish the beneficial ownership of agents prior to engaging them, and at least every two years and when there is a significant change in the business relationship. The company operates a risk based beneficial ownership verification policy, whereby all agent provided information is verified and high risk agent’s information is independently verified. There is evidence that the company commits to not engage or terminate its engagement with agents or intermediaries where ultimate beneficial ownership cannot be established.

2/2

There is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries. The company also provides evidence to indicate that these parties are subject to anti-bribery and corruption clauses in their contracts, which include clear audit rights and termination rights to detect, control and prevent breaches.

2/2

There is evidence that the company highlights and addresses incentive schemes for agents as a factor in bribery and corruption risk. There is evidence the company places a threshold on sales-based commissions to agents, and that all such remuneration requires approval from the Corporate Compliance Officer (CCO). The company also indicates that it remunerates agents in stage payments, based on clear milestones outlined in a written agreement. In addition, the company commits to only paying the agreed fees into local bank accounts or to a bank account in Germany.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

DynCorp International 1/2

There is some evidence that the company has specific procedures in place to control the use of agents. The company requires the approval of the legal department prior to engagement and will only work with agents who operate to its standards.

However, the company receives a score of ‘1’ because it does not explicitly address the corruption risks associated with the use of agents. It also does not commit to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function.

1/2

The company states has formal procedures to conduct anti-bribery and corruption due diligence prior to engaging third parties and agents.

However, the company receives a score of ‘1’ because it is not clear that agents and highest risk intermediaries are subject to enhanced due diligence. The company says that due diligence is conducted prior to entering into agreements and at later stages if red flags are identified, but it is unclear whether due diligence is repeated at least every two years or when there is a significant change in the business relationship.

0/2

Based on publicly available information, there is no evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is evidence that the company’s anti-bribery and corruption policy applies to agents and intermediaries. Agents must certify that they will comply with the company’s Code of Ethics and Business Conduct, and there is evidence that the Supplier Code of Ethics and Business Conduct also applies to agents and intermediaries. However, although the company states that it includes termination rights in its contracts with agents and intermediaries, there is no evidence that it also includes audit rights.

0/2

There is no evidence that the company's incentive structures for agents are designed to minimise risks of bribery and corruption or that incentive structures are recognised as a risk factor in agent behaviour.

0/2

The company does not publish any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

0/2

The company states that it conducts due diligence on all parties with whom it does business. However, it does not explicitly refer to joint ventures nor is there evidence that its due diligence process is based on an assessment of risk.

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in its joint ventures.

Elbit Systems 2/2

Based on publicly available information, there is evidence the company has a policy on the use of agents, which also applies to agents employed by subsidiaries and joint ventures. There is evidence to indicate that the company assures itself that there is a legitimate need and business rationale prior to contracting an agent. The company states that it conducts due diligence as one method for mitigating the corruption risks associated with using agents

1/2

Based on publicly available information, there is evidence the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with its third parties and agents. There is evidence indicating that the company conducts enhanced due diligence on the higher risk intermediaries. The company indicates that in instances where red flags identified during the due diligence process cannot be mitigated, third parties may be disqualified from engaging with the company.

However, there is no publicly available evidence that due diligence is repeated at least every two years or when there is a significant change in the business relationship.

0/2

Based on publicly available information, there is some evidence that the company aims to establish the identity and background of its agents as part of the due diligence process.

However, it is not clear publicly available information that this includes formally establishing the ultimate beneficial ownership of agents, nor is there evidence that the company commits to not engage or terminate its engagement with agents or intermediaries in situations where beneficial ownership cannot be established.

2/2

Based on publicly available information, there is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. The company indicates that all agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts. There is evidence indicating that the company includes audit and termination rights in its contracts with these entities.

1/2

There is publicly available evidence that the company highlights incentive structures for third parties as a factor in bribery and corruption risk. The company outlines a number of these risks, including cash payments and unusual payment methods, as well as excessive fees.

However, it is not clear from publicly available information that the company’s incentive structures for agents include further controls to reduce bribery and corruption risk, such as a threshold on the payment of sales commissions to agents or a requirement remuneration be made in stage payments or into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

1/2

Based on publicly available information, there is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all of its joint venture partnerships. The company indicates that it conducts enhanced due diligence on joint ventures operating in high risk countries.

However, the company receives a score of ‘1’ because there is no publicly available evidence that such due diligence is repeated at least every two years. There is also no clear evidence that the company’s due diligence procedure includes checks on the ultimate beneficial ownership of the partner company.

1/2

There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies and procedures in all of its joint ventures, by requiring the adoption of its own anti-bribery and corruption programme for all controlling joint ventures and by requiring a similar policy for other joint venture partnerships. These policies prohibit bribery and facilitation payments. There is evidence to indicate that the company requires anti-bribery and corruption clauses in its contracts with joint venture partners.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that its contracts with joint venture partners include clear audit and termination rights to detect, control and prevent breaches.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures, for example by providing training to employees of joint ventures or implementing a policy to second senior individuals to the partner company’s management board.

Embraer S.A 2/2

There is evidence that the company has a policy to control the use of agents, which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. There is evidence that this policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures.

1/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with agents and intermediaries.

However, the company receives a score of ‘1’ because it is not clear whether agents and highest risk intermediaries are subject to enhanced due diligence. There is also no evidence that due diligence is repeated every two years or when there is a significant change in the business relationship.

0/2

Based on publicly available information, there is evidence that the company has formal procedures in place to establish the beneficial ownership of agents prior to engaging them.

However, the company receives a score of ‘0’ because there is no evidence that it commits to not engaging or terminating its engagement with agents or intermediaries in cases where beneficial ownership cannot be established. In addition, although the company states that it may engage external vendors to independently verify beneficial ownership information, it is not clear whether it does so for all high risk agents. There is also no clear evidence that the company reviews ownership information at least every two years or when there is a significant change in the business relationship.

2/2

Based on publicly available information, there is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. There is evidence that the company includes anti-bribery and corruption clauses in their contracts, which include audit and termination rights.

0/2

There is evidence that the company recognises incentive structures for agents as a factor in bribery and corruption risk. The company lists several red flags for third party intermediaries which relate to incentive schemes. However, the company receives a score of ‘0’ because, based on publicly available information, there is no evidence that it has in place specific controls to mitigate these risks.

0/2

There is no evidence that the company publishes details of the agents contracted to act with and on behalf of the company.

0/2

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

1/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on joint venture partners, which are included in the definition of a third-party intermediary. There is evidence that this process includes checks on the ownership of the partner.

However, the company receives a score of ‘1’ because there is no evidence that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence. There is also no evidence to suggest that due diligence is repeated at least every two years or when there is a significant change in the business relationship.

2/2

Based on publicly available information, there is evidence that the company requires joint venture partners to adopt its own anti-corruption policy. There is also evidence that the company requires anti-bribery and corruption clauses in its contracts with joint venture partners, and that these include audit and termination rights.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Excalibur Army 0/2

Based on publicly available information, there is no clear evidence that the company has a policy on the use of agents. There is some evidence that the company’s Code of Ethics applies to intermediaries, but it is not clear that this relates to agents or brokers contracted to act or on behalf of the company.

0/2

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

0/2

Based on publicly available information, there is no evidence that the company commits to establish the beneficial ownership of its agents.

1/2

Based on publicly available information, there is evidence that the company’s anti-bribery and corruption policy applies to all external subjects working with the company, including consultants and intermediaries. There is some evidence that the company includes anti-bribery and corruption clauses in its contracts with these entities.

However, the company receives a score of ‘1’ because there is no evidence that it includes audit and termination rights in its contracts with agents and intermediaries.

0/2

Based on publicly available information, there is no evidence that the company considers incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on its behalf.

0/2

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

0/2

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

0/2

Based on publicly available information, there is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures. Although the company has such policies relating to external parties, it is not clear whether this includes joint venture partners.

0/2

Based on publicly available information, there is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Fincantieri S.p.A 2/2

Based on publicly available information, there is evidence that the company has a policy and procedure to control the use of agents. This addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. The company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. This policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures.

1/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging with its third parties and agents. There is some evidence that agents and highest risk intermediaries might be subject to enhanced due diligence. The company states that it verifies the integrity of agents at least annually, but it is not clear whether it repeats its due diligence process at least every two years or when there is a significant change in the business relationship. In publicly available evidence, the company does not explicitly commit to not engaging or terminating its engagement with agents or intermediaries where the risks identified in the due diligence cannot be mitigated.

0/2

There is evidence that the company asks agents to disclose their beneficial ownership to the company, and it verifies this information, as part of its due diligence processes. However, there is no clear evidence of a commitment to independently verify the beneficial ownership information of high risk agents. The company also does not publicly commit to reviewing or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.

1/2

Based on publicly available information, there is evidence that the company includes anti-bribery and corruption clauses as well as termination rights in its contracts with agents and intermediaries. However, the company does not explicitly include audit rights in its contracts with these entities.

1/2

Based on publicly available information, there is evidence that incentive structures for agents are highlighted and addressed as a factor in bribery and corruption risk, with some examples of controls to mitigate these risks. The company commits to only paying agents into local bank accounts. However, there is no evidence that the company imposes a threshold on the payment of sales commissions to agents.

0/2

The company does not publish any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

The company does not publish any data on ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving agents.

1/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering into all of its joint ventures. However, there is no evidence that the company’s due diligence explicitly includes checks on the ultimate beneficial ownership of the partner company, or that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence. In addition, there is no evidence that due diligence is repeated at least every two years.

1/2

Based on publicly available information, there is evidence that the company accounts for anti-bribery and corruption considerations when entering into a joint venture and requires compliance with its anti-bribery and corruption programme, which prohibits foreign and domestic bribery and facilitation payments. Contracts with joint venture partners include ethical provisions and termination rights. However, there is no publicly available evidence that the company includes audit rights in its contracts with joint venture partners.

0/2

There is no publicly available evidence to indicate that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Fluor Corporation 1/2

There is evidence that the company has a policy on the use of agents, which specifically addresses the corruption risks associated with their use and provides details of specific controls to mitigate these risks. This policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures.

However, the company receives a score of ‘1’ because there is no evidence that it commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function.

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with agents. However, the company receives a score of ‘1’ because there is no publicly available evidence that agents and highest risk intermediaries are subject to enhanced due diligence. It is also not clear that the company repeats this due diligence at least every two years and/or when there is a significant change in the business relationship.

0/2

There is no publicly available evidence that the company aims to establish the beneficial ownership of agents as part of its due diligence process.

2/2

There is evidence that the company publishes a Business Conduct and Ethics Expectations for Suppliers and Contractors policy that applies to agents and intermediaries. There is also evidence that the company includes clauses in its contracts with such entities that stipulate its right to terminate the relationship if any violations of its policies or values are identified. Although the company does not explicitly state that it includes audit rights in its contracts, there is evidence that the company reserves the right to verify that a third party’s operations meet its business conduct and ethics expectations, and this is deemed sufficient to receive a score of ‘2’.

2/2

There is evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company states that it does not operate on a commission based sales structure and notes that other red flags in relation to agent incentives include cash payments and requests for payment in another currency or into a foreign bank account. Although the company does not explicitly state that remuneration must be paid in stage payments, the company provides sufficient information on its other controls to receive a score of ‘2’.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

2/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering into all joint ventures. There is some evidence that due diligence on joint venture partners includes checks on ultimate beneficial ownership. The company indicates that joint ventures operating in high risk markets or with high risk partners, such as government affiliated entities, are subject to enhanced due diligence. In addition, there is evidence that the company monitors its joint venture partners on a continuous basis.

2/2

There is evidence that the company publishes a Business Conduct and Ethics Expectations for Suppliers and Contractors policy that applies to joint ventures. There is also evidence that the company includes clauses in its contracts with such entities that stipulate its right to terminate the relationship if any violations of its policies or values are identified. Although the company does not explicitly state that it includes audit rights in its contracts, there is evidence that the company reserves the right to verify that a third party’s operations meet its business conduct and ethics expectations, and this is deemed sufficient to receive a score of ‘2’.

1/2

There is some evidence that the company has a procedure in place to develop tailored corruption risk mitigation plans for all of its high risk projects or ‘teaming arrangements’, which is understood to include joint ventures. The company indicates that this plan forms the basis for implementing additional processes or procedures with the partner in relation to ethics and compliance, and states that such plans are reviewed throughout the lifecycle of the partnership.

However, the company receives a score of ‘1’ because it does not provide any further information or practical examples of how it may identify and implement such plans in practice or in specific relation to joint ventures.

Fujitsu Ltd. 1/2

Based on publicly available information, there is some evidence the company has a policy covering the use of agents, which addresses the corruption risks associated with the use of agents. The policy includes details of controls to mitigate these risks, including financial controls, contractual agreements and due diligence. There is evidence the policy applies across the group.

However, the company does not explicitly commit to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function.

0/2

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

0/2

Based on publicly available information, there is no evidence that the company aims to establish the ultimate beneficial ownership of its agents.

0/2

Based on publicly available information, there is evidence the company’s anti-bribery and corruption policy applies to agents and intermediaries, and that it includes anti-bribery and corruption clauses in its contracts with such entities. However, there is no evidence that the company includes audit and termination rights in its contracts with these entities.

1/2

Based on publicly available information, there is some evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk.

However, there is no evidence that the company imposes a threshold on the payment of sales commissions to agents, and there is no requirement that remuneration is paid in stage payments or into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

0/2

The company simply states publicly that it conducts due diligence on third parties without providing any specific details regarding its due diligence process. There is no clear evidence that due diligence includes and is based on an assessment of potential bribery and corruption risk.

1/2

Based on publicly available information, there is evidence that the company requires all business partners to comply with its Global Business Standards and it requires anti-bribery and corruption clauses in its contracts with all partners.

However, it is unclear how the company ensures that joint venture partners abide by these standards in practice. The company does not specify that it takes steps to detect, control and prevent breaches through the inclusion of audit and termination rights in the contract.

0/2

Based on publicly available information, there is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

GE Aviation 2/2

There is evidence that the company has a policy and procedure on the use of agents, which addresses the corruption risks associated with their use. The company states that it seeks to establish and verify that the use of agents is, in each case, necessary to perform a legitimate business function. There is evidence that this policy applies to all divisions within the organisation that might employ agents, including subsidiaries and majority-controlled joint ventures.

2/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging its third parties and agents and when there is a significant change in the business relationship. The company also states that agents and higher risk intermediaries are subject to enhanced due diligence requirements. There is evidence that the company commits to not engaging or terminating its engagement with agents or intermediaries where the risks identified in the due diligence process cannot be mitigated.

2/2

There is evidence that the company has formal procedures in place to establish the beneficial ownership of agents prior to engaging them and when there is a significant change in the business relationship. There is evidence the company operates a risk-based beneficial ownership verification policy. There is evidence indicating that the company will not engage or will terminate its engagement with agents or intermediaries where ultimate beneficial ownership cannot be established.

2/2

There is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on its behalf. There is evidence that agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include audit rights and termination rights to detect, control and prevent breaches.

1/2

There is some evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company indicates that payments to agents are based on market rates and that payments are made according to clear milestones.

However, the company receives a score of ‘1’ because there is no publicly available evidence that incentives or commission payments must be proportionate to the net fee or that payments must be made into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf. The company states that it does not publish such information.

0/2

There is no clear evidence that the company publishes high-level data from all ethical or bribery and corruption-related incidents and investigations involving its agents. The company publishes data on corruption-related investigations and disciplinary actions involving its entire workforce, but there is no evidence that it disaggregates this information to specifically show any investigations and actions against agents.

1/2

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to entering into, and while operating as part of, joint ventures. The company indicates that due diligence on joint ventures includes establishing ultimate beneficial ownership of the partner company and that high-risk potential partners are subject to enhanced due diligence.

However, the company receives a score of ‘1’ because there is no clear evidence that the company repeats due diligence at least every two years or when there is a significant change in the business relationship.

1/2

There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies in all of its joint ventures. The company requires its majority controlled joint ventures to adopt and follow its anti-corruption policies and states that it will encourage non-controlled ventures to do the same.

However, the company receives a score of ‘1’ because there is no evidence that includes audit and termination rights in its contracts with joint venture partners to detect, control and prevent breaches.

0/2

There is no clear publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. The company indicates that majority controlled joint ventures must adopt and follow its anti-corruption policies and states that it encourages non-controlled entities to do the same, but does not provide any further information or practical details of how it assures itself of this in practice.

General Atomics 0/2

There is no publicly available evidence that the company has a policy on the use of agents.

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is no publicly available evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company recognises incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on its behalf.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, nor that it requires anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

General Dynamics Corporation 0/2

There is no publicly available evidence that the company has a policy covering the use of agents.

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents and intermediaries.

0/2

There is no evidence to suggest that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company recognises incentive structures as a risk factor in agent behaviour, nor is there evidence that the company's incentive structures for agents are designed to minimise risks of anti-bribery and corruption.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on behalf of the company.

0/2

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

0/2

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

0/2

There is no clear evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, or that it requires anti-bribery and corruption clauses in its contracts with such entities. The company indicates that it expects joint venture partners to develop ethics programmes consistent with its values, but does not provide further details on how it assures this in practice.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

GKN Aerospace 0/2

There is no evidence that the company has a clear policy covering the use of agents.

0/2

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

0/2

Based on publicly available information, there is no evidence that the company aims to establish the beneficial ownership of its agents.

0/2

Although the company has a Supplier Code of Conduct, which requires suppliers to adopt anti-bribery and corruption policies, there is no evidence that this code applies to agents and intermediaries. Additionally, while the company’s standard purchasing contracts include anti-bribery and corruption clauses, it is also not clear that these contracts apply to agents and intermediaries.

0/2

There is no evidence that the company's incentive structures for agents are designed to minimise risks of anti-bribery and corruption or that incentive structures are recognised as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in its joint ventures.

Glock 0/2

There is no publicly available evidence that the company has a clear policy covering the use of agents.

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that company aims to establish the beneficial ownership of its agents.

0/2

There is no publicly available evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company considers incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, nor that it requires anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in its joint ventures.

Hanwha Aerospace 2/2

Based on publicly available information, there is evidence that the company has a clear policy and procedure to control the use of agents which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. There is evidence that this policy also applies to subsidiaries and joint ventures.

2/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging with its third parties and agents. There is evidence that due diligence is repeated when there is a significant change in the business relationship. There is some evidence to indicate that agents and the highest risk intermediaries are subject to enhanced due diligence.

0/2

There is evidence that the company asks agents to disclose their ownership to the company.

However, there is no clear evidence the company commits to independently verify the beneficial ownership information of high risk agents. While the company states that it can terminate contracts in circumstances where the ownership of the agent raises a compliance issue, there is no clear evidence that the company commits to not enganging or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.

2/2

Based on publicly available information, there is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. The company indicates that agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include audit and termination rights to detect, control and prevent breaches.

1/2

Based on publicly available information, there is evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company states that it will use only local bank accounts for payments to agents. The company imposes a threshold on sales commissions to agents.

However, there is no evidence that the company commits to pay the agent in stage payments over the course of their contract, based on clear milestones. The company also indicates the commission is based on a proportion of the net value of the total sale rather than the net fee to the agent.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on its behalf. The company publishes a statement that it does not disclose such information.

0/2

There is no evidence that the publishes any data on ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving agents. The company publishes a statement that it does not disclose such information.

NA

The company publishes a clear statement that it does not operate as part of joint ventures, and therefore it is exempt from scoring on this question.

NA

The company publishes a clear statement that it does not operate as part of joint ventures, and therefore it is exempt from scoring on this question.

NA

The company publishes a clear statement that it does not operate as part of joint ventures, and therefore it is exempt from scoring on this question.

Hewlett-Packard Enterprise Company 2/2

There is evidence that the company has a policy to control the use of agents which address the corruption risks associated with their use and provide details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. In addition, there is evidence that this policy applies to all of the company’s employees worldwide, including those employed by third parties and subsidiaries.

1/2

Based on publicly available information, there is evidence that the company has formal procedures in place to conduct anti-bribery and corruption due diligence prior to engaging agents and intermediaries.

However, the company receives a score of ‘1’ because there is no evidence that it commits to not engage or terminate its engagement with agents or intermediaries where risks identified in the due diligence cannot be mitigated. In addition, it is not clear that all agents and the highest risk intermediaries are subject to enhanced due diligence, nor that it conducts and refreshes this due diligence at least every two years or when there is a significant change in the business relationship.

0/2

There is some evidence that the company assesses the ownership of third parties in instances where it suspects government officials may have a direct or indirect interest in the company. However, there is no clear evidence that the company aims to establish the beneficial ownership of all its agents as part of its due diligence process, nor os there clear evidence that it commits to not engage or terminate its relationship with an agent if beneficial ownership cannot be established.

2/2

Based on publicly available information, there is evidence that the company’s Partner Code of Conduct applies to all agents and intermediaries acting for or on its behalf. The company indicates that all agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include audit and termination rights to detect, control and prevent breaches.

1/2

Based on publicly available information, there is evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company indicates that any sales-based commissions must be proportionate to the level and type of services provided and that such fees must be in line with a commission matrix. In addition, the company states that all payments are subject to approval procedures and that fees are only released upon proof of work completed. The company also commits to paying agents and intermediaries into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

1/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering joint ventures.

However, the company receives a score of ‘1’ because there is no clear evidence that the company’s due diligence includes checks on the ultimate beneficial ownership of the partner company. There is also no evidence to suggest that joint ventures operating in high risk markets or with high risk partners are subject to enhanced due diligence. It is also unclear whether or how frequently the company repeats due diligence on joint venture partners.

2/2

Based on publicly available information, there is evidence that the company commits to establishing and implementing anti-bribery and corruption policies and procedures in its joint ventures, by requiring the partner to conduct audits as part of its Partner Code of Conduct. There is also evidence that the company includes anti-corruption clauses in its contracts with such entities, with clear audit and termination rights to detect, control and prevent breaches.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures, for example by stipulating provisions for secondments of its senior management, providing specific anti-corruption training or establishing a separate internal audit function.

High Precision Systems 0/2

There is no evidence that the company has a policy covering the use of agents.

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is no clear evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company addresses incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or and on behalf of the company.

0/2

There is no evidence that the company publishes any data on ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving to agents.

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to actively preventing bribery and corruption in all of its joint ventures.

Hindustan Aeronautics Ltd. 1/2

There is evidence that the company has a policy covering the use third party consultants, without referring specifically to the term ‘agents’. This policy addresses the corruption risks associated with the use of external consultants and stipulates specific controls to mitigate these risks. The company also explicitly commits to establishing and verifying that their use, in each case, necessary to perform a legitimate business function.

However, the company does not clearly specify whether the policy also applies to subsidiaries and joint ventures.

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries but does not specify that it includes audit and termination rights in these contracts.

0/2

There is no evidence that the company's incentive structures for agents are designed to minimise risks of anti-bribery and corruption.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its joint ventures

1/2

The company states that it accounts for anti-bribery and corruption considerations when entering into a joint venture, and obliges all joint venture partners to adhere to its anti-bribery and corruption policies. There is further evidence that it includes anti-corruption clauses in its contracts with joint venture partners.

However, there is no evidence that the company takes steps to detect, control and prevent breaches through the inclusion of audit and termination rights in its contracts with joint venture partners.

0/2

The company states that it will communicate the importance of anti-corruption activities to all partners and third parties but there is no evidence that it commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Honeywell International 2/2

There is evidence that the company has a clear policy on the use of agents which addresses the corruption risks associated with their use and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. The company states that its policy applies to all divisions within the organisation, as well as subsidiaries and joint ventures.

1/2

There is evidence that the company conducts anti-corruption-focused due diligence when engaging and re-engaging with its agents and sales intermediaries.

However, the company does not provide further publicly available evidence to indicate whether it conducts and refreshes the due diligence on its intermediaries at least every two years or when there is a significant change in the business relationship. In addition, there is no evidence that the company has provisions to conduct enhanced due diligence on the high risk agents, nor that it may be willing to not engage or terminate its relationship with intermediaries where risks identified in the due diligence cannot be mitigated.

0/2

There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents and intermediaries as part of its due diligence process.

0/2

There is some evidence that all of the company’s third parties must comply with its Anti-Corruption Policy, as well as with relevant anti-corruption laws and regulations. In addition, the company’s Code of Business Conduct states that its rules – which outline the company’s anti-bribery and corruption policy – apply to all third parties working on behalf of the company. However, there is no publicly available evidence that the company takes steps to ensure that its third parties adhere to these standards by requiring anti-corruption clauses in contracts with its agents, with clear audit and termination rights.

1/2

There is some evidence that the company acknowledges incentive structures for agents as a risk factor in bribery and corruption risk. The company indicates that any third party receiving a commission or similar success fee must go through a clear due diligence process, with approval from the Global Integrity and Compliance Department.

However, the company receives a score of ‘1’ because it does not provide further publicly available information on the specific controls that it has in place to reduce these risks, such as imposing a threshold on the payment of sales commissions to agents, or requiring that remuneration is paid in stage payments or into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents contracted to act for or on its behalf.

0/2

There is no evidence that the company publishes any data on ethics and corruption-related reports, investigations and disciplinary actions involving its contracted agents.

1/2

Based on publicly available information, there is evidence that the company has formal procedures in place to conduct anti-corruption-focused due diligence on all joint venture partners.

However, the company receives a score of ‘1’ because there is no clear publicly available evidence that these due diligence checks include establishing the beneficial ownership of partner entities, nor is it clear whether the company has a risk-based approach to conduct enhanced due diligence on joint ventures operating in high risk markets or with high risk partners. It is also not clear how frequently due diligence into joint venture partners is conducted or refreshed.

0/2

There is no publicly available evidence that the company requires anti-corruption clauses in its contracts with joint venture partners, nor that the company has policies to incorporate anti-bribery and corruption policies in all of its joint ventures. The company indicates that joint ventures and acquired companies must follow its procedures on integrity and anti-corruption, but it does not provide further information on how it ensures compliance in practice.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures, for example by providing dedicated anti-corruption training to joint venture staff or seconding employees to leadership or other key positions in the joint venture.

Huntington Ingalls Industries, Inc. 2/2

There is evidence that the company has a policy and procedures to control the use of agents which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks, including contractual provisions, due diligence and oversight of activities. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. The company states that this policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures.

1/2

The company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with all third parties, including agents and intermediaries. The company states that all higher risk agents and intermediaries are subject to enhanced due diligence, and that all agents and intermediaries undergo due diligence every two years or whenever there is a significant change in the business relationship.

However, the company makes no clear commitment not to engage or to terminate a supplier relationship if a red flag identified in due diligence cannot be mitigated.

1/2

Based on publicly available evidence, the company has formal procedures to establish the beneficial ownership of agents prior to engaging them. The company operates, as a minimum, a risk-based beneficial ownership verification policy, whereby all agent provided information is verified; high-risk agents’ information is independently verified by the company’s Corporate Compliance Manager. The company commits to not engaging or terminating its engagement with agents or intermediaries where ultimate beneficial ownership cannot be established or raises concern.

However, there is no evidence that the company has procedures to verify the beneficial ownership of agents and intermediaries at least every two years and/or when there is a significant change in the business relationship.

1/2

There is evidence the company’s anti-bribery and corruption policy applies to all third parties, including agents and intermediaries, and that it includes anti-bribery and corruption clauses in its contracts with such entities. There is evidence indicating that all medium and high-risk representatives are subject to termination rights.

However, the company indicates that not all representatives are subject to audit rights.

2/2

The company recognises agent payments and incentive structures as a corruption risk and outlines various processes to mitigate these risks. These include staged payments, pre-agreed payments based on clear milestones and a cap on commissions. The company indicates that it will not pay agent fees into an account in a jurisdiction that raises concerns.

0/2

The company does not publish any details of the agents currently contracted to act for and/or on its behalf.

1/2

The company publishes a statement that it has not received any corruption-related reports involving its agents or representatives.

However, it is unclear whether the company updates this information on an annual basis.

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence before entering into joint ventures. The company states that its due diligence process includes establishing the ultimate beneficial ownership of the partner company, with enhanced due diligence for high-risk joint venture partners.

However, there is no evidence that the company repeats due diligence on joint venture partners at least every two years or whenever there is a significant change in the business relationship.

1/2

Based on publicly available evidence, the company commits to working jointly with its joint venture partners to implement an anti-corruption programme to the same standard as the company’s own. The company states that all joint venture agreements include anti-corruption clauses and termination rights.

However, evidence indicates that not all joint venture agreements include audit rights. Additionally, the company does not clearly specify the anti-corruption standards that all joint venture partners must adhere to, such as a prohibition of bribery, payments to public officials and facilitation payments.

2/2

The company publishes a statement that it commits to take an active role in preventing bribery and corruption in all of its joint ventures. There is clear evidence to support the company's commitment, with the company indicating that it appoints a compliance officer within the joint venture and regularly conducts monitoring and auditing of the joint venture.

Hyundai Rotem Company 0/2

There is no publicly available evidence that the company has a policy on the use of agents.

0/2

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

0/2

There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is no publicly available evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no publicly available evidence that the company addresses incentive structures as a risk factor in agent behaviour.

0/2

There is no publicly available evidence that the company publishes any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

There is no publicly available evidence that the company publishes any data on ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving agents.

0/2

There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its joint venture partners or entities.

0/2

There is no publicly available evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, nor that it requires anti-corruption clauses in its contracts with joint venture partners.

0/2

There is no publicly available evidence to indicate that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

IHI Corporation 0/2

There is no publicly available evidence that the company has a policy on the use of agents. The company provides some information on its business partners, however it is not clear from publicly available information that this term includes agents or intermediaries, nor does this evidence recognise the specific risks associated with such entities.

0/2

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

0/2

There is no publicly available evidence that the company aims to establish the ultimate beneficial ownership of its agents and intermediaries.

0/2

There is no publicly available evidence that that company’s anti-bribery and corruption policy applies to agents and intermediaries, nor that it requires anti-corruption clauses with such entities. The company indicates that its policy applies to business partners, but it is not clear from publicly available information that this term may include agents and intermediaries.

0/2

There is no publicly available evidence that the company recognises incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

0/2

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

0/2

There is no publicly available evidence that that company commits to implement anti-bribery and corruption policies in its joint ventures, nor that it includes anti-corruption clauses in its contracts with such entities. The company indicates that its policy applies to business partners, but it is not clear from publicly available information that this term may include joint venture partners.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in its joint ventures.

IMI Systems Ltd. 2/2

There is evidence that the company has a policy and procedures to control the use of agents, which addresses the corruption risks associated with their use and provides details of specific controls to mitigate these risks. As part of this policy, there is some evidence that the company aims to establish and verify that the use of an agent is, in each case, necessary to perform a legitimate business function. This policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures.

1/2

Based on publicly available information, there is evidence the company has formal procedures in place to conduct anti-bribery and corruption due diligence prior to engaging agents. There is evidence indicating that some agents are subject to enhanced due diligence and that the company may be willing to terminating the agreement if red flags are identified.

However, it is not clear from publicly available information that all agents and highest risk intermediaries are subject to enhanced due diligence. In addition, although the company states that it monitors its agents, there is no clear evidence that due diligence is repeated at least every two years and/or when there is a significant change in the business relationship.

0/2

There is some evidence that the company aims to establish the identity of its agents through background checks. However, it is not clear from publicly available information that such checks include full details of ultimate beneficial ownership nor that agreements with agents and intermediaries may be terminated in cases where beneficial ownership cannot be established.

0/2

Based on publicly available information, there is evidence that the company includes anti-bribery and corruption clauses in its contracts with agents. The company’s Code of Business Conduct also applies to all third parties acting on the company’s behalf, which can be understood to include agents. However, although there is some indication that the company includes termination rights in its contracts with agents, there is no clear evidence that these clauses also include audit rights.

1/2

Based on publicly available information, there is some evidence that the company recognises payments structures for agents as a factor in bribery and corruption risk. The company indicates that it prohibits cash payments to such entities and that payments must be made to an account in the name of the agent.

However, there is no further publicly available evidence that the company imposes a threshold on the payment of sales commissions to agents, nor that there is a requirement that remuneration is paid in stage payments or into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on its behalf.

0/2

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

1/2

Based on publicly available information, there is some evidence that the company has procedures to conduct anti-bribery and corruption due diligence on its joint venture partnerships.

However, it is not clear from publicly available information that the company’s due diligence includes checks on the ultimate beneficial ownership of the partner company. There is also no evidence to suggest that joint ventures operating in high risk markets or with high risk partners are subject to enhanced due diligence, nor is it clear that due diligence is repeated every two years or whenever there is a change in the business relationship.

1/2

Based on publicly available information, there is evidence that the company requires anti-bribery and corruption clauses in its contracts with joint venture partners. The company provides information to indicate that such clauses also include termination rights.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that its contracts with joint venture partners include audit rights.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Indian Ordnance Factories 0/2

There is no publicly available evidence to indicate that the company has a clear policy covering the use of agents.

0/2

There is no publicly available evidence to indicate that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no publicly available evidence to indicate that the company aims to establish the beneficial ownership of its agents.

0/2

There is no publicly available evidence to indicate that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no publicly available evidence to indicate that the company mentions incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on behalf of the company.

0/2

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

0/2

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

0/2

There is no publicly available evidence to indicate that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no publicly available evidence to indicate that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Indra Sistemas S.A. 1/2

There is some evidence that the company has a procedure on the use of agents, which it refers to as commercial consultants and strategic advisors. The company indicates that it conducts an evaluation prior to engagement, including an assessment of any reputational or other risks.

However, there is no clear publicly available evidence that the company commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. It is noted that the company has an internal document on the hiring of commercial consultants and strategic advisors, but this does not appear to be publicly accessible.

1/2

Based on publicly available information, there is some evidence that the company evaluates and conducts reputational due diligence on its agents and consultants. The company indicates that this process includes a review of any political exposed individuals.

However, there is no clear publicly available evidence that agents and highest risk intermediaries are subject to enhanced due diligence, nor that due diligence is repeated at least every two years or when there is a significant change in the business relationship. There is also no evidence that the company commits to not engaging or terminating its engagement with agents or intermediaries where risks identified in the due diligence cannot be mitigated.

0/2

There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents.

0/2

Based on publicly available information, there is evidence that the company’s Code of Ethics and Legal Compliance applies to agents and the company includes anti-bribery and corruption clauses in its contracts with these entities. However, there is no publicly available evidence that the company’s contracts with agents include clear audit and termination rights to detect, control and prevent breaches.

0/2

There is no publicly available evidence that the company highlights and addresses incentive structures as a risk factor in agent behaviour. The company indicates that it has a procedure to manage contracts with such entities, however further information on this does not appear to be publicly available.

0/2

There is no evidence that the company publishes the details of the agents currently contracted to act for or on its behalf. The company publishes a list of its business partners, but there is no evidence to indicate whether this includes third parties acting as agents or intermediaries on the company’s behalf.

0/2

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

0/2

There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its joint ventures. It is noted that the company has an internal regulation on the control and monitoring of joint ventures, but there is no evidence that this document is publicly accessible.

1/2

Based on publicly available information, there is some evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures. The company indicates that its Code of Ethics and Legal Compliance applies to all subsidiaries and third parties regardless of jurisdiction. In organisations where it does not have majority control, the company states that it takes steps to ensure that these entities have policies and procedures in place that meet the equivalent standard of its own Code of Ethics.

However, the company receives a score of ‘1’ because there is no clear publicly available evidence that it includes anti-bribery and corruption clauses in its contracts with joint venture partners. It is noted that the company has an internal regulation on the control and monitoring of joint ventures which may contain more information on this subject, but there is no evidence that this document is publicly accessible.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. The company states that it has internal procedures on the monitoring of joint ventures, however further information on this does not appear to be publicly accessible.

Israel Aerospace Industries (IAI) 2/2

There is evidence that the company has policies and procedures to control the use of agents and intermediaries (referred to as marketing consultants or the procurement of expert services) which addresses the corruption risks associated with the use of agents and intermediaries. The company provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent or intermediary is, in each case, necessary to perform a legitimate business function. There is evidence indicating that the policy applies to all divisions within the organisation which might employ agents and intermediaries, including subsidiaries and joint ventures.

1/2

There is evidence that the company has formal procedures to conduct anti-bribery and corruption due diligence prior to engaging and re-engaging with agents and intermediaries. There is also evidence that due diligence is repeated at least every two years.

However, based on publicly available information, there is no clear evidence that agents and the highest risk intermediaries are subject to enhanced due diligence.

0/2

Based on publicly available information, there is no evidence that the company aims to establish the ultimate beneficial ownership of its agents or intermediaries as part of its due diligence procedures.

0/2

There is evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries, which include termination rights. However, there is no evidence that the company includes audit rights in its contracts with these entities.

1/2

In publicly available information the company highlights incentive structures for agents and intermediaries as a factor in bribery and corruption risk. The company publishes details of its financial control procedures for agent and intermediary payments and requires that remuneration is paid in stage payments.

However, based on publicly available information, there is no evidence that the company imposes a threshold on the payment of sales commissions to agents and intermediaries, nor that it requires payments into local bank accounts.

0/2

The company does not publish any details of the agents or intermediaries currently contracted to act for and/or on behalf of the company.

0/2

The company does not publish any data on ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving agents and intermediaries.

1/2

There is evidence that the company has procedures to conduct due diligence on all its joint venture partnerships.

However, based on publicly available information, there is no evidence that due diligence includes checks on the ultimate beneficial ownership of the partner company nor that due diligence is repeated at least every two years. There is also no evidence to suggest that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence

1/2

There is evidence that the company’s anti-corruption policies and procedures apply in joint ventures in which the company has a controlling interest. The company includes anti-corruption clauses in its contracts with all joint ventures.

However, there is no evidence that the company takes steps to detect, control and prevent breaches through the inclusion of audit and termination rights in these contracts.

0/2

Based on publicly available information, there is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Japan Marine United Corporation 0/2

There is no publicly available evidence that the company has a policy to regulate the use of agents.

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is no publicly available evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company recognises incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or and on its behalf.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Kawasaki Heavy Industries Ltd. 0/2

There is no publicly available evidence that the company has a policy on the use of agents.

0/2

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

0/2

There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents and intermediaries.

0/2

There is some evidence that the company’s anti-bribery and corruption policy applies to agents. However, the company receives a score of ‘0’ because there is no publicly available evidence that such provisions are included as contractual clauses with these entities, nor that contractual agreements include audit and termination rights.

0/2

There is no publicly available evidence that the company considers incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and on its behalf.

0/2

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

0/2

There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence when entering into joint ventures.

0/2

There is no evidence that the company publicly commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in its joint ventures.

KBR Inc. 2/2

There is evidence that the company has a clear policy and/or procedure to control the use of agents which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. This policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures.

2/2

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging any agents and intermediaries. The company indicates that agents and highest risk intermediaries are subject to enhanced due diligence. The company commits to not engaging or terminating its engagement with agents or intermediaries where the risks identified in the due diligence cannot be mitigated. In addition, there is evidence that the company reviews this due diligence periodically or at least every three to five years throughout the relationship.

2/2

There is evidence that the company has formal procedures to establish the beneficial ownership of agents prior to engaging them and whenever there is a significant change in the business relationship. The company indicates that high-risk agents and intermediaries are subject to enhanced due diligence and that it may engage an external legal counsel to review such information depending on the risk and circumstances. There is evidence that the company commits to not engaging or terminating its engagement with agents or intermediaries where ultimate beneficial ownership cannot be established.

2/2

There is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. The company indicates that all agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include clear audit rights and termination rights to detect, control and prevent breaches.

1/2

There is some evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company indicates that part of its anti-corruption due diligence includes ensuring that any proposed compensation is reasonable and that payments are reviewed periodically.

However, there is no publicly available evidence that the company imposes a threshold on the payment of sales commissions to agents, nor that it remuneration must be paid in stage payments or into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on all of its joint venture partnerships. The company conducts enhanced due diligence for joint ventures operating in high risk countries or with high risk partners. There is evidence that the company conducts anti-bribery and corruption due diligence both prior to entering into a joint venture and on both the entity and its activities once established.

However, the company receives a score of ‘1’ because there is no publicly available evidence to indicate that the company establishes the beneficial ownership of its joint venture partners as part of due diligence, nor is there evidence that such checks are repeated at least every two years throughout the relationship.

2/2

There is evidence that the company clearly commits to establishing and implementing anti-bribery and corruption policies and procedures in all of its joint ventures, by requiring the adoption of its own Code of Conduct, inclusive of its anti-bribery and corruption programme. There is evidence that the company requires anti-bribery and corruption clauses in its contracts with joint venture partners. There is also evidence that the company specifies clear audit and termination rights to detect, control and prevent breaches.

2/2

There is evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. There is clear evidence to support the company's commitment, through practical examples and a statement of possible controls that it may implement, dependent on the context.

King Abdullah II Design and Development Bureau 0/2

The company does not have a clear policy covering the use of agents.

0/2

The company does not state that it conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company considers incentive structures as a risk factor in agent behaviour.

0/2

The company does not publish any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in its joint ventures.

Komatsu Ltd. 1/2

Based on publicly available information, there is some evidence that the company has a policy covering the use of agents. The company indicates that the employment and payment of sales agents or representatives must comply with any relevant laws or regulations.

However, the company receives a score of ‘1’ because its policy does not address the corruption risks associated with the use of agents and does not provide details of specific controls to mitigate these risks. The policy also does not explicitly commit to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. It is unclear whether this policy applies to subsidiaries and joint ventures.

0/2

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

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents, nor does it explicitly commit to not engaging or terminate its engagement with agents or intermediaries if beneficial ownership cannot be established.

0/2

There is no publicly available evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

1/2

Based on publicly available information, there is some evidence that the company addresses incentive structures for agents as a factor in bribery and corruption risk. There is evidence that the company makes payments in accordance with local laws of the country in which the agent is located, and that unreasonable requests for commission payments are handled primarily by the Law Department. The company also acknowledges the risk that payments to agents may be transferred to government employees, and states that it will not engage where this risk is present.

However, the company receives a score of ’1’ because there is no evidence that the company imposes a threshold on the payment of sales commissions to agents nor that remuneration is paid in stage payments throughout the contractual relationship.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on behalf of the company.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Kongsberg Gruppen ASA 2/2

Based on publicly available information, there is evidence that the company has a policy covering the use of agents. This policy addresses the corruption risks associated with the use of agents and applies this to subsidiaries and joint ventures. The company states that the use of agents must be justified with a business rationale.

1/2

Based on publicly available information, there is evidence that the company has formal procedures for conducting risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging its third parties and agents. There is evidence that agents and highest-risk intermediaries are subject to enhanced due diligence. The company also commits to not engaging with intermediaries where risks identified in the due diligence cannot be mitigated.

However, there is no evidence that this due diligence is repeated at least every two years or when there is a significant change in the business relationship.

0/2

There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents and intermediaries, or that it commits to not engaging or terminate its engagement with agents or intermediaries if beneficial ownership cannot be established.

2/2

Based on publicly available information, there is evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries. The company includes audit and termination rights in its contracts with these parties to detect, control and prevent breaches.

1/2

There is some evidence that incentive structures for agents are highlighted and addressed as a risk factor in bribery and corruption risk. The company states that fees and bonuses must be justifiable and reasonable, and that payments to agents must be pro rata in accordance with the project.

However, there is no evidence that the company imposes a specific threshold on the payment of sales commissions to agents so that they do not exceed a proportion of the net fee to the agent, or that the company requires that remuneration be paid in stages into local bank accounts.

0/2

There is no publicly available evidence that the company publishes any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

There is no publicly available evidence that the company publishes any data on ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving agents.

1/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering a joint venture. There is evidence that this due diligence is conducted for every joint venture partnership.

However, it is not clear that the company’s due diligence explicitly includes checks on the ultimate beneficial ownership of the partner company or that due diligence is repeated at least every two years.

2/2

Based on publicly available information, there is evidence that the company commits to establishing and implementing anti-bribery and corruption policies in all of its joints ventures. The company indicates that it monitors its joint ventures’ compliance with these agreements and that it includes termination rights in its contracts to prevent breaches.

1/2

Based on publicly available information, there is evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

However, the company does not provide any further statements or evidence to support this claim.

Korea Aerospace Industries Ltd. 1/2

There is some evidence that the company has a policy covering the use of agents.

However, in publicly available evidence, the company does not address in any detail the corruption risks associated with the use of agents. There is no evidence that the company commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. There is also no evidence that the company’s policy applies to subsidiaries and joint ventures.

1/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct anti-bribery and corruption due diligence prior to engaging with its third parties and agents.

However, there is no clear evidence that due diligence is repeated at least every two years or when there is a significant change in the business relationship. There is also no clear evidence that agents and the highest risk intermediaries are subject to enhanced due diligence.

0/2

There is evidence that the company asks agents to disclose their beneficial ownership to the company as part of its due diligence processes. However, there is no clear evidence that the company verifies this information, nor that the company commits to not engaging or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.

2/2

Based on publicly available information, there is evidence indicating that the company’s anti-bribery and corruption policy applies to business partners, which can be understood to include agents and intermediaries. All agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include audit and termination rights.

0/2

There is no publicly available evidence that the company addresses incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

1/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct anti-bribery and corruption due diligence prior to entering all of its joint ventures. There is evidence indicating that this includes checks on the ownership of the company.

However, there is no evidence that joint ventures operating in high risk markets or with high risk partners are subject to enhanced due diligence, nor that due diligence is repeated at least every two years.

2/2

Based on publicly available information, there is evidence that the company commits to establishing and implementing anti-bribery and corruption policies and procedures in all of its joint ventures. The company’s Code of Conduct applies to joint ventures. The company includes anti-bribery and corruption contractual terms in its contracts with joint ventures, which include audit and termination rights.

0/2

There is no clear publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Krauss-Maffei Wegmann (KMW) 0/2

While the company states that the use of sales partners, which can be understood to include agents, is governed by internal procedures, the company does not publish any further information on these procedures.

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is evidence that the company’s Ethics Charter applies to sales partners, which can be understood to include agents and intermediaries. However, there is no publicly available evidence that the company includes audit and termination rights in its contracts with these entities.

0/2

There is no evidence that the company's incentive structures for agents are designed to minimise risks of bribery and corruption.

0/2

The company does not publish any details of the agents currently contracted to act for or on behalf of the company.

0/2

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

0/2

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

0/2

There is no publicly available evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, or that it requires anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

L3 Harris Technologies Inc. 2/2

There is evidence that the company has a policy on the use of agents, as part of its policy on third parties. As part of its approach, the company states that it commits to establish and verify whether the use of an agent is necessary to perform a legitimate business function. In addition, there is evidence that the company has specific controls in place to regulate their use, including enhanced risk-based due diligence. There is evidence that this policy applies group-wide to all employees and divisions that may employ agents.

1/2

There is evidence the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging with agents and intermediaries. There is evidence that higher risk agents or intermediaries are subject to enhanced due diligence, and there is some indication that the company commits to not engage or terminate its engagement with third parties that engage in improper conduct.

Although the company indicates that it conducts period renewal reviews of its third parties, there is no clear evidence that due diligence on agents is repeated at least every two years or when there is a significant change in the business relationship.

1/2

There is evidence that the company has formal procedures in place to establish the beneficial ownership of agents and intermediaries prior to engaging them. The company indicates that it has procedures to independently verify the beneficial ownership of agents based on an assessment of risk. In addition, there is some indication that the company may review its engagement with third parties if information highlighted in this process is unclear or depending on the possible risks.

The company receives a score of ‘1’ because there is no clear evidence it commits to not engage or terminate its engagement with agents or intermediaries if beneficial ownership cannot be established.

2/2

There is evidence that the company’s anti-bribery and corruption policy applies to all third parties acting on for or on its behalf, including agents and intermediaries. The company publishes a Supplier Code of Conduct, which requires all third parties, including agents, to adhere to equivalent ethical standards. There is evidence agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include audit and termination rights.

1/2

There is some evidence the company addresses and considers incentive structures for agents as a factor in corruption risk. The company states that it has a procedure to review any proposed compensation structures before engaging with third parties.

However, the company receives a score of ‘1’ because it does not provide further publicly available information on the way that it incentivises agents. For example, there is no evidence that the company imposes a threshold on the payment of sales commissions to agents, nor that it requires that remuneration be paid in stage payments or into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

1/2

The company states that it conducts risk-based due diligence on all third parties that pose a heightened corruption risk to the company. There is evidence to suggest that high-risk third parties are subject to enhanced due diligence and that the company seeks to establish the ultimate beneficial ownership of third parties. Although it does not specifically mention joint ventures in its list of entities considered to be third parties, the company references “business partners” and this is understood to cover joint venture partners.

Although the company indicates that it conducts period renewal reviews of its third parties, there is no clear evidence that due diligence on joint ventures is repeated at least every two years or when there is a significant change in the business relationship.

1/2

There is evidence the company establishes and implements anti-bribery and corruption policies with all of its third parties, including joint venture “business partners”. The company indicates that all third parties with which it does business must follow its Supplier Code of Conduct and indicates that partners should implement equivalent standards.

However, the company receives a score of ‘1’ because there is no publicly available information that it commits to establishing and implementing anti-corruption procedures in joint ventures in which it has an ownership stake. It is also not clear that the company’s contracts with joint venture partners include anti-corruption clauses with audit and termination rights; the company’s publicly available information indicates that such clauses apply specifically to intermediaries.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures, beyond ensuring that such partners follow its Supplier Code of Conduct. This could include, for example, stipulating provisions for secondments of its senior management, providing specific anti-corruption training or establishing a separate internal audit function.

Leidos Inc. 1/2

There is evidence to indicate that the company states has implemented policies and measures to regulate agent conduct and to mitigate against and control the corruption risks associated with agents.

However, the company receives a score of ‘1’ because there is no publicly available evidence that its policy contains details of specific measures used to control and regulate agent conduct. In addition, it is not clear from publicly available information that its policies include measures to verify that the in each instance the use of an agent is used to perform a legitimate business function. It is also not clear that the company’s policies covering agent behaviour apply to its subsidiaries and joint ventures.

1/2

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence both prior to engaging third parties and agents and on an ongoing basis throughout the business relationship. The company indicates that, based on a prevalence of high-risk factors, certain high-risk agents and intermediaries are subject to enhanced due diligence.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that it will not engage or terminate its engagement with an agent if a red flag identified during due diligence cannot be mitigated.

0/2

There is no publicly available evidence that the company aims to establish the ultimate beneficial ownership of agents and intermediaries.

1/2

There is some evidence that the company’s third parties are prohibited from engaging in bribery and corruption, as outlined in its Code of Conduct. There is also clear evidence that the company includes audit rights in contracts with agents and third parties to detect, prevent and control breaches.

However, the company receives a score of ‘1’ because there is no clear publicly available evidence that the company’s contracts with such entities include clear termination rights.

0/2

There is no publicly available evidence that the company addresses incentive structures as a risk factor in agent behaviour, nor that it has procedures in place to mitigate such risks.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or and on behalf of the company.

0/2

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

0/2

There is no evidence that the company clearly states that it conducts anti-bribery and corruption due diligence on its joint ventures.

0/2

There is evidence that the company has policies requiring joint venture partners to adhere to high ethical standards but receives a score of ‘0’ because there is no evidence that the company makes a clear commitment to establishing and implementing anti-bribery and corruption policies in all of its joint ventures. It also makes no clear statement that it includes audit or termination rights in joint venture contracts.

0/2

There is no evidence that the company makes a clear commitment to take an active role in preventing bribery and corruption in all of its joint ventures.

Leonardo S.p.A 2/2

Based on publicly available information, there is evidence that the company has a policy covering the use of agents. The policy addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. The company commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. There is evidence indicating that the policy applies to subsidiaries and joint ventures.

2/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging any agents and intermediaries at least every two years or when there is a modification to the contract. The company also indicates that it will refresh its due diligence prior to making any payments to agents and intermediaries. All agents and highest risk intermediaries are subject to enhanced due diligence. The company commits to not engaging or terminating its engagement with agents or intermediaries where the risks identified in the due diligence cannot be mitigated.

1/2

Based on publicly available information, there is evidence that the company asks its agents to disclose their beneficial ownership to the company, which it verifies as part of its due diligence processes. The company states that it will not engage with agents or intermediaries if beneficial ownership cannot be established. The company also indicates that if any of the information provided by the agents or intermediaries is found to be inaccurate, it may suspend or terminate the contract.

However, the company scores ‘1’ as there is no clear evidence of a commitment to independently verify the beneficial ownership information of high risk agents.

2/2

There is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. All agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include audit rights and termination rights.

2/2

Based on publicly available information, there is evidence that incentive structures for agents are addressed as a factor in bribery and corruption risk. The company places a clear threshold on sales-based commissions to agents and states that remuneration to agents is paid only in staged payments over the course of their contract, based on milestones. The company also commits to only paying agents into bank accounts where the company has its registered office.

1/2

The company publishes a figure of the number of agents it currently contracts disaggreated by contract type. The list covers the most recent financial year.

However, the list falls short of the minimum level of detail required in score ‘2’ as the company does not publish the names of agents.

2/2

Based on publicly available information, there is evidence that the company publishes high-level data from all bribery and corruption-related incidents and investigations involving its agents. This includes the number of incidents and the types of sanctions applied as a result of investigation findings. This data is published on an annual basis.

2/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering joint ventures. There is evidence indicating that the company’s due diligence process includes checks on the owners of the partner company and joint ventures operating in high risk markets are subject to enhanced due diligence. There is evidence that the company conducts anti-bribery and corruption due diligence both prior to entering into a joint venture and when there is a significant change in the business relationship.

2/2

Based on publicly available information, there is evidence that the company commits to establishing and implementing anti-bribery and corruption policies in all of its joint ventures. It does so by requiring joint ventures to adopt its own programme. The company includes audit and termination rights in its contracts with joint venture partners.

2/2

In publicly available evidence the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. There is evidence to support the company's commitment. The company indicates that it will work through its board representatives to ensure the adoption of a compliance programme. It also periodically performs assessments and holds staff meetings and workshops on anti-bribery and corruption.

LIG Nex1 Co. 0/2

There is no publicly available evidence that the company has a policy on the use of agents.

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging with its third parties and agents. The company indicates that due diligence is conducted before engaging with new agents and repeated when renewing contracts.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that agents and highest risk intermediaries are subject to enhanced due diligence, and there is no evidence that due diligence is repeated at least every two years or when there is a significant change in the business relationship.

0/2

There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is some evidence that the company’s Code of Ethics extends to sales agents and third parties, and that it includes anti-bribery and corruption clauses in its contracts with agents. The company provides information to indicate that these contractual clauses termination rights. However, there is no clear publicly available evidence that the company includes audit rights in its contracts with such entities to detect, control and prevent breaches.

0/2

There is no publicly available evidence that the company highlights and addresses incentive schemes as a possible risk factor in agent behavior. The company provides some information to indicate that it prohibits contractual commissions but it does not indicate specifically that this applies to agents and intermediaries, nor does it provide further information on how compensation for agents is structured to reduce bribery and corruption risk.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering into and while operating in joint venture partnerships.

However, the company receives a score of ‘1’ because it is not clear that the company’s due diligence explicitly includes checks on the ultimate beneficial ownership of the partner company. There is also no evidence to suggest that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence. The company does not state that due diligence is repeated at least every two years.

1/2

There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies in all of its joint ventures and that it includes termination rights in contracts with joint venture partners.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that the company takes steps to detect, control and prevent breaches through the inclusion of audit rights in the contracts.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Lockheed Martin Corporation 2/2

There is evidence that the company has a clear policy on the use of agents, which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. As part of this policy, the company outlines oversight mechanisms and commits to only retaining agents and consultants where there is a sufficient business case justification and where all appropriate laws and regulations are followed. This policy forms part of the company’s overall ethics and anti-corruption policies, which apply to all divisions within the corporation that might employ agents, including subsidiaries and controlled joint ventures.

1/2

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging any agents and intermediaries. There is evidence that Legal Counsel is involved in determining the appropriate level of anti-corruption due diligence based on exposure to risk, suggesting that higher risk agents and intermediaries are subject to enhanced due diligence.

However, there is no evidence that the company refreshes its due diligence at least every two years or when there is a significant change in the business relationship.

1/2

The company has formal procedures to establish the beneficial ownership of agents. The company requests this information from agents through its International Anti-Corruption Questionnaire. Where agents and intermediaries fail or refuse to provide the appropriate information the company states that it will immediately terminate the relationship.

However, the company receives a score of ‘1’ because while it states that it verifies ultimate beneficial ownership, it is not clear whether information provided by high risk agents is independently verified. Furthermore, it is not clear whether the company repeats its due diligence process, including checks on ultimate beneficial ownership, at least every two years or when there is a significant change in the business relationship.

2/2

There is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. All agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include clear audit and termination rights to detect, control and prevent breaches.

2/2

There is evidence that incentive structures for agents are explicitly highlighted and addressed as a bribery and corruption risk factor. The company places a clear threshold on sales-based commissions to agents so that payments do not exceed a proportion of the net fee to the agent, and states that remuneration to agents is structured in staged payments over the course of their contract, based on clear milestones, into local bank accounts.

0/2

The company does not publish any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering into and while operating in any joint venture agreement. The company states that its due diligence process includes checks on the beneficial ownership of third parties, including joint venture partners. The company also indicates that third parties operating in high-risk jurisdictions may require enhanced due diligence.

However, the company receives a score of ‘1’ because it is not clear that due diligence on joint venture partners is repeated at least every two years; instead, the company states that due diligence is reassessed and updated periodically.

2/2

There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies in its joint ventures. Where it has a non-controlling ownership interest, the company states that it will employ its best efforts to ensure such controls are adopted. The company states that its agreements with joint venture partners must include anti-corruption provisions, procedures and controls in order to ensure ongoing adherence to its anti-bribery and corruption programme, which includes a ban on facilitation payments and foreign and domestic bribery. It conducts periodic reviews to ensure that such policies and procedures are effective. The company indicates that a violation of its anti-corruption policy, which applies to joint venture partners, may result in termination of contract.

0/2

There is no evidence that the company commits to taking an active role in preventing bribery and corruption in all of its joint ventures. Although it indicates that it has procedures in place to do so, it does not specify what these are.

Examples of such procedures could include: stipulating that the Chief Compliance Officer in the joint venture be transferred from, or appointed by, their own company or report directly to the main company’s audit committee; instituting a secondment scheme; taking the lead in providing tailored anti-bribery and corruption training; ensuring provisions for real-time access to electronic books and records; or establishing a separate internal audit function.

ManTech International Corporation 0/2

There is no publicly available evidence that the company has a policy on the use of agents.

0/2

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

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is no publicly available evidence that the company’s anti-corruption policy applies to agents, nor that it includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company considers incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

0/2

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

0/2

There is no publicly available evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, nor that it requires anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no publicly available evidence that the company commits to taking an active role in preventing bribery and corruption in all of its joint ventures.

Massachussetts Institute of Technology (MIT) NA

There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.

NA

There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.

NA

There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.

NA

There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.

NA

There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.

NA

There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.

NA

There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.

0/2

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

0/2

There is no evidence that the institute commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, nor is there evidence that it requires anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no evidence that the institute commits to take an active role in preventing bribery and corruption in all of its joint ventures.

MBDA 1/2

There is evidence that the company has a policy covering the use of agents, which includes due diligence and a requirement for the agent to certify their compliance with the company’s ethics principles. The company’s policy extends to all controlled subsidiaries and joint venture partners. In addition, this policy addresses corruption risks that may be associated with the use of agents, such as ethics compliance, remuneration and payments.

However, there is no clear evidence that the company commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. The company stipulates that agents must be assigned clear duties, however it is not clear that this includes ensuring the legitimacy of their use.

1/2

There is evidence that the company has procedures to conduct due diligence on its agents prior to engaging them, and the company indicates that such checks include business ethics. However, it does not indicate whether this due diligence is anti-bribery and corruption focused or based on an assessment of risk. There is also no evidence that this due diligence is repeated at least every two years or when there is a significant change in the business relationship.

0/2

There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents, nor is there evidence that it commits to not engage or terminate its engagement with agents or intermediaries if beneficial ownership cannot be established.

1/2

There is some evidence that, as part of its contractual arrangements, the company requires that agents certify their compliance with its business ethics principles. However, the company receives a score of ‘1’ because there is no evidence that its contracts with these entities include anti-bribery and corruption clauses to detect, control and prevent breaches.

1/2

There is evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company indicates that remuneration for business advisers must be proportionate to the complexity of the project and relative to the market rate in the given jurisdiction.

However, there is no evidence that the company imposes a threshold on the payment of sales commissions to agents, nor that it requires that remuneration is made in stage payments or into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

1/2

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all of its joint venture partnerships. The company clearly indicates that this includes establishing the ultimate beneficial ownership of the partner company. There is some evidence that due diligence is tailored according to the level of risk facing the company.

However, there is no evidence that due diligence is repeated at least every two years or when there is a significant change in the business relationship.

1/2

There is some evidence that the principles outlined in the company’s Business Ethics Policy apply to joint venture partnerships. In addition, the company states that in some cases joint ventures may implement different ethics policies but indicates that the standards must be equivalent to its own Business Ethics Policy.

However, there is no publicly available evidence that the company requires the inclusion of anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in its joint ventures, for example, by stipulating provisions for secondments of its senior management, providing specific anti-corruption training or establishing a separate internal audit function.

Meggitt PLC 2/2

There is evidence that the company has a policy on the use of agents, which address the corruption risks associated with their use and provide details of specific controls to mitigate these risks. The company states that it has decided not to appoint any new sales representatives nor to renew existing agreements other than in exceptional circumstances. There is evidence the policy applies to all divisions within the organisation which might employ agents or intermediaries.

2/2

Based on publicly available information, there is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging with its third parties and agents. There is evidence that agents and the highest risk intermediaries are subject to enhanced due diligence, and the company indicates such checks are repeated at least every two years or when there is a significant change in the business relationship.

0/2

There is some evidence that the company seeks to establish the ownership of agents and intermediaries. However, there is no clear evidence that the company commits to independently verify beneficial ownership information of high risk agents, nor that it commits to not engage or terminate its engagement with intermediaries if beneficial ownership cannot be established.

1/2

Based on publicly available information, there is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on its behalf. The company indicates that all sales representatives receive and must follow its Code of Conduct and Anti-Corruption Policy. In addition, there is evidence that the company has provisions to conduct audits on intermediaries.

However, the company receives a score of ‘1’ because there is no evidence that its contracts with agents and intermediaries include clear anti-bribery and corruption clauses, which include termination rights.

1/2

Based on publicly available information, there is some evidence that incentive structures for agents are highlighted as a factor in bribery and corruption risk. The company indicates that its remuneration usually accords to a percentage of sales, and there is some evidence that it requires further review if a sales representative requests a commission payment.

However, the company receives a score of ‘1’ because it does not provide further publicly available information o its specific controls to mitigate bribery and corruption risks in agent incentives. There is no clear evidence that the company imposes a threshold on the payment of sales commissions to agents, nor that remuneration is paid in stage payments or into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or and on behalf of the company. It is noted that the company states that it is taking steps to reduce its number of intermediaries and indicates that it will not enter into new agreements.

0/2

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

1/2

Based on publicly available information, there is some evidence that the company has procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering into joint ventures.

However, there is no further publicly available evidence to suggest that its due diligence includes establishing the beneficial ownership of the partner company, nor that joint ventures operating in high risk markets or with high risk partners are subject to enhanced due diligence. It is also not clear how frequently this due diligence is conducted or repeated.

0/2

There is no evidence that the company publicly commits to establishing anti-bribery and corruption policies or procedures in its joint ventures, nor that it requires anti- corruption clauses in its contracts with such partners.

0/2

There is no evidence that the company publicly commits to take an active role in preventing bribery and corruption in all of its joint ventures.

MITRE Corporation NA

There is no readily available evidence that the organisation engages agents in the conduct of business due to its nature as a non-profit organisation.

NA

There is no readily available evidence that the organisation engages agents in the conduct of business due to its nature as a non-profit organisation.

NA

There is no readily available evidence that the organisation engages agents in the conduct of business due to its nature as a non-profit organisation.

NA

There is no readily available evidence that the organisation engages agents in the conduct of business due to its nature as a non-profit organisation.

NA

There is no readily available evidence that the organisation engages agents in the conduct of business due to its nature as a non-profit organisation.

NA

There is no readily available evidence that the organisation engages agents in the conduct of business due to its nature as a non-profit organisation.

NA

There is no readily available evidence that the organisation engages agents in the conduct of business due to its nature as a non-profit organisation.

0/2

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

0/2

There is no evidence that the organisation commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the organisation commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Mitsubishi Electric Corporation 0/2

There is no evidence that the company has a policy to regulate the use of agents.

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

1/2

Based on publicly available information, there is some evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk.

However, the company receives a score of ‘1’ because there is no evidence that it has controls in place to mitigate these risks, such as imposing a threshold on the payment of sales commissions to agents or a requirement that remuneration is paid in stage payments or into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or and on behalf of the company.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, nor that it requires anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Mitsubishi Heavy Industries 1/2

Based on publicly available information, there is some evidence that the company has a policy covering the use of agents. There is evidence that the company’s Group Global Code of Conduct applies to agents and lists some controls to address the corruption risks associated with the use of agents. There is also evidence that this policy applies to subsidiaries and the company’s business partners.

However, the company receives score of ‘1’ because there is no clear evidence that the policy commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function.

0/2

There is some evidence that the company conducts due diligence on its third parties. However, there is no evidence that the company provides further publicly available details on this process so it is not clear whether such checks include anti-bribery and corruption provisions, nor that they are conducted on a regular basis and specifically on all agents.

0/2

There is no publicly available evidence that the company aims to establish the ultimate beneficial ownership of its agents.

0/2

Based on publicly available information, there is evidence that the company’s anti-bribery and corruption policy applies to agents and intermediaries acting for or on its behalf. The company indicates that it includes contractual provisions in its agreements with third parties to regulate their conduct.

However, there is no publicly available evidence that the company’s contracts with agents and intermediaries specifically include clear audit and termination rights to detect, control and prevent breaches. In addition, although the company indicates that its contracts with third parties include rules on conduct, it is not clear whether this includes following the standards outlined in its anti-bribery and corruption policy.

1/2

Based on publicly available information, there is some evidence that the company recognises incentive structures for agents as a risk factor in bribery and corruption. The company indicates that fees and expenses paid to third parties must represent appropriate and justifiable renumeration for the services rendered.

However, the company receives a score of ‘1’ because there is no evidence that it imposes a threshold on the payment of sales commissions to agents. There is also no evidence that the company requires that remuneration is paid in stage payments or into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and on its behalf.

0/2

There is no evidence that the company publishes high-level results from ethical reports, investigations and associated disciplinary actions involving its agents.

0/2

There is some evidence that the company conducts due diligence on third parties. However, there is no evidence that the company provides further publicly available details on this process so it is not clear whether such checks include anti-bribery and corruption provisions, nor that they are conducted on a regular basis and specifically on all joint venture partners.

1/2

There is evidence that the company’s Group Global Code of Conduct applies to business partners acting on its behalf, which can be understood to include joint venture partners. The company indicates that its agreements or contracts with third parties must include contractual provisions requiring them to act properly.

However, the company receives a score of ‘1’ because there is no publicly available evidence that the company’s contracts with joint venture partners specifically include clear audit and termination rights to detect, control and prevent breaches. In addition, although the company indicates that its contracts with third parties include rules on conduct, it is not clear whether this includes following the standards outlined in its anti-bribery and corruption policy.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in its joint ventures.

Moog Inc. 0/2

There is no evidence that the company has a clear policy covering the use of agents.

0/2

There is no evidence that the company states that it conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company mentions incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on behalf of the company.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures and or that it requires anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Nammo AS 2/2

Based on publicly available information, there is evidence that the company has a policy covering the use of consultants and sales representatives – which is understood to include agents. It is clear that this policy applies group-wide to any entities that may employ agents. There is evidence that the company commits to establishing that the use of an agent is, in each case, based on a clear need identified in a business and market plan. The company also provides details of specific controls in place to mitigate the potential risks associated with the use of agents, for example by requiring that all sales representatives undergo dedicated ethics training, by ensuring that such entities comply with its Ethical Code of Conduct and through regular reporting. There is also evidence that the company’s Group-level Legal & Compliance department is responsible for oversight and due diligence of agents, which is consistent with the level of risk.

Although the company does not directly address the corruption risks associated with agents, it does provide a statement on the compliance risks associated with consultants, agents and sales representatives as part of a broader statement on third parties, which is deemed sufficient for a score of ‘2’ given the accompanying information.

2/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with its third parties and agents. The company indicates that agents are subject to enhanced due diligence based on the size, type and country risk. There is evidence that the company conducts due diligence during the onboarding phase and every two years throughout the business agreement, supplemented with continuous monitoring. The company’s description of its due diligence process indicates that agents will only be contracted if the due diligence is approved and indicates that it is willing to review or terminate its engagement if the agreement is breached.

1/2

There is evidence that the company has formal procedures in place to establish the beneficial ownership of its agents as part of the due diligence process. The company indicates that such checks take place during the onboarding phase, as well as every two years throughout the business agreement.

The company receives a score of ‘1’ because it does not clearly publish a statement to indicate that it would not engage or terminate its engagement with agents or intermediaries in cases where the beneficial ownership cannot be established.

2/2

There is evidence that the company’s anti-bribery and corruption policy applies to all agents and sales representatives acting for or on behalf of the company. The company’s publicly available information indicates that agreements with all sales representatives include monitoring clauses to mitigate corruption and compliance risks, as well as audit and termination rights to detect, control and prevent breaches.

1/2

There is evidence that the company addresses incentive structures for agents as a factor in bribery and corruption risk, by stipulating measures to control such processes as part of its compliance programme. The company states that remuneration for sales representatives must be proportionate to the service rendered and supported by relevant documentation, as well as noting that any payments should adhere to generally accepted accounting principles.

However, the company receives a score of ‘1’ because there is no evidence that it places a threshold on sales-based commissions to agents so that payments to not exceed a proportion of the net fee, nor does it commit to paying agents into local bank accounts or through staged payments over the course of their contract.

1/2

There is evidence that the company publishes an aggregate figure of the number of agents employed to act for or on its behalf, for the most recently reported financial year. The company also publishes high-level information to indicate the regions in which these agents have been active.

The company receives a score of ‘1’ because the information published falls short of the level of detail required to receive a score of ‘2’ such as the names of the sales representatives.

0/2

Based on publicly available information, there is no evidence to indicate that the company publishes data on ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving agents.

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

2/2

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all of its joint venture partnerships. The company indicates that joint venture partners are subject to enhanced due diligence based on country, size, type, role, nature of the transaction and historical relationship. These criteria imply that the company undertakes enhanced due diligence for joint ventures operating in high risk countries or with high risk partners.

There is also evidence to indicate that the company’s due diligence includes establishing the beneficial ownership of joint venture partners and that such checks are conducted prior to entering into the contract and then every two years throughout the relationship. Although the company provides this information in relation to sales representatives, it publishes a statement that the same due diligence process applies for joint ventures and therefore it merits a score of ‘2’.

2/2

There is evidence that the company commits to establishing and implementing anti-bribery and corruption procedures in all of its joint ventures. The company clearly states that it includes anti-bribery and corruption clauses in its joint venture contracts, and there is evidence that it requires all business partners to abide by the standards outlined in its Ethical Code of Conduct throughout the business relationship. The Ethical Code of Conduct therefore applies to all third parties and business partners, and stipulates policies and procedures prohibiting bribery and facilitation payments. The company also makes reference to audit and termination rights in its contracts, though it is noted that although this evidence applies to joint ventures, it is presented primarily in the context of sales representatives.

0/2

There is some evidence that the company expects its business partners to adhere to ethical standards and that it conducts regular anti-bribery and corruption reviews of its third parties. However, there is no clear evidence to suggest that the company commits to take an active role in preventing bribery and corruption in its joint ventures, beyond requiring that such entities follow its Ethical Code of Conduct.

Naval Group 1/2

There is evidence that the company has a policy on the use of agents. The company indicates that it has a dedicated team that works with agents, and states in its Compliance Code of Conduct that agents are subject to monitoring.

However, the company does not have a comprehensive policy covering agents and it is unclear how the company assesses the corruption risks around agents and the specific controls it has put in place to mitigate these risks. The company also does not explicitly commit to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function.

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging or re-engaging any agents and intermediaries. All agents and highest risk intermediaries are subject to enhanced due diligence. The company commits to not engaging or terminating its engagement with agents or intermediaries where the risks identified in the due diligence cannot be mitigated.

However, due diligence is repeated at least every three years, rather than every two years, as required for a score of ‘2’.

1/2

There is evidence that the company has formal procedures to establish the beneficial ownership of agents prior to engaging them. The company commits to not engaging or terminating its engagement with agents or intermediaries where ultimate beneficial ownership cannot be established.

However, the company receives a score of ‘2’ because these check are conducted every three years and not at least every two years and there is no evidence of a commitment to independently verify beneficial ownership information of high risk agents.

1/2

There is evidence the company’s anti-bribery and corruption policy applies to agents and intermediaries, and that it includes anti-bribery and corruption clauses in its contracts with such entities, with clear audit and termination rights.

However, the company states that such clauses apply in general to subcontractors without referencing agents specifically.

1/2

There is evidence that incentive structures for agents are highlighted and addressed as a factor in bribery and corruption risk.

However, there is no evidence that the company imposes a threshold on the payment of sales commissions to agents, and/or there is no requirement that remuneration is paid in stage payments or into local bank accounts.

0/2

The company does not publish any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering and while operating with all third parties, including joint ventures. There is evidence that the company’s due diligence explicitly includes checks on the ultimate beneficial ownership of the partner company.

However, there is no evidence to suggest that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence. In addition, it is unclear how frequently due diligence is repeated.

2/2

The company explicitly commits to establishing and implementing anti-bribery and corruption policies and procedures in all of its joint ventures by requiring the adoption of its own anti-bribery and corruption programme in its joint ventures. In its public materials, the company states that it includes anti-corruption clauses in its contracts with stakeholders. These clauses include clear audit and termination rights to detect, control and prevent breaches.

2/2

The company explicitly commits to take an active role in preventing bribery and corruption in all of its joint ventures. There is clear evidence to support the company's commitment, through a statement of possible controls that it may implement.

Navantia S.A 1/2

There is evidence that the company has a policy covering the use of agents which addresses the corruption risks associated with the use of agents and provides details of controls to mitigate these risks. There is evidence that this policy applies to all divisions within the organisation which might employ agents, including subsidiaries.

However, while the company’s policy indicates that it conducts an assessment of the economic rationale of working with high-risk entities, it is not clear from publicly available evidence that the company takes steps to establish and verify that the use of agents is necessary to perform a legitimate business function.

2/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging any agents and intermediaries, and when there is a significant change in the business relationship. There is evidence that highest risk intermediaries are subject to enhanced due diligence. There is evidence that suggests that the company will not engage or terminate its engagement with agents or intermediaries where the risks identified in the due diligence process cannot be mitigated.

0/2

There is evidence that the company aims to establish the beneficial ownership of its agents. However, there is no publicly available evidence that the company commits to not engaging or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.

2/2

Based on publicly available information, there is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. The company states that all agents and third parties are subject to anti-bribery and corruption clauses in their contracts, which include clear audit and termination rights to detect, control and prevent breaches.

1/2

There is some evidence that the company addresses incentive structures for agents as a factor in bribery and corruption risk. The company states that specific measures are in place to manage this risk, such as requiring that payments to agents be made into EU-registered banks and restricting the type and quantity of transactions. The company also states that due diligence is carried out to check for signs of possible corruption prior to awarding agents “success fees”.

However, the company receives a score of ‘1’ because there is no evidence that agents receive remuneration in staged payments over the course of their contract, based on clear milestones. There is also no mention of proportionality as a factor in determining agent remuneration.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for, or on its behalf.

1/2

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

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

2/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on its joint venture partners. The company states that it conducts enhanced due diligence on joint ventures operating in high-risk countries or with high risk partners. There is evidence that the company conducts due diligence both prior to entering into a joint venture and on both the entity and its activities once established, or when there is a significant change in the business relationship. There is also evidence that the company’s due diligence procedures include establishing the ultimate beneficial ownership of the partner company.

2/2

There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies and procedures in its joint ventures. There is evidence that the company requires its business partners, which is understood to include joint venture partners, to comply with its anti-corruption manual, which prohibits foreign and domestic bribery and facilitation payments. The company indicates that it includes this requirement as a contractual clause, which also specifies audit and termination rights to detect, control and prevent breaches.

1/2

There is some evidence that the company commits to take an active role in preventing bribery and corruption when engaging with third parties, which is understood to include when it engages with joint venture partners. However, the information in relation to this is insufficiently detailed to satisfy the requirements of score ‘2’.

NEC Corporation 0/2

There is no evidence that the company has a clear policy covering the use of agents.

1/2

Based on public evidence, the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with its third parties.

However, the company states only that it conducts due diligence on third parties, without specifying agents or high risk intermediaries, and it is not clear that agents and highest risk intermediaries are subject to enhanced due diligence. Additionally, due diligence is only conducted before engaging agents and is not repeated at least every two years or when there is a significant change in the business relationship.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company mentions incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

0/2

Based on public information, there is no clear evidence that the company undertakes due diligence when entering into a joint venture partnership. While there is evidence that the company conducts due diligence on third parties that it employs, it does not make reference to doing so for its joint venture partners.

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Nexter Group 1/2

The company has a clear policy and procedure to control the use of agents which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks.

However, the company does not explicitly commit to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. It is also not specified whether this policy applies to subsidiaries and joint ventures.

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with agents and intermediaries.

However, the company does not explicitly state that agents and highest risk intermediaries are subject to enhanced due diligence. It is also unclear whether the company repeats due diligence when it re-engages agents and intermediaries, or how frequently its due diligence is reviewed.

0/2

There is some evidence that the company aim to identify the beneficial ownership of its agents and intermediaries. However, there is no publicly available evidence that the company commits to not engaging or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.

0/2

There is evidence that the company includes anti-bribery and corruption clauses in its contracts with third parties, however, there is no publicly available evidence to suggest that it includes audit and termination rights in its contracts with these entities.

1/2

There is evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company indicates that agents must paid in local bank accounts, and acknowledges that sales commissions are a higher risk form of remuneration.

However, there is no evidence that the company imposes a threshold on the payment of sales commissions to agents, and there is no requirement that remuneration is paid in stage payments.

0/2

The company does not publish any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

1/2

There is evidence that the company has formal procedures to conduct due diligence on its joint venture partners. The company indicates that its procedures include identifying the ultimate beneficial ownership of its partners.

However, there is no evidence to suggest that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence. It is also unclear whether or how frequently due diligence on joint venture partners is repeated.

1/2

There is some evidence that the company accounts for anti-bribery and corruption considerations when entering into a joint venture, through the inclusion of anti-corruption clauses and obligations in its contracts with them.

However, it is unclear how it ensures this in practice and it does not specify that it takes steps to detect, control and prevent breaches through the inclusion of audit and termination rights in its contracts with its partners.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. While it includes anti-corruption contractual clauses in its contracts with its third parties, it does not provide any further public information on practical steps it might take to prevent bribery and corruption in its joint venture partnerships.

Northrop Grumman Corporation 1/2

There is some publicly available evidence that the company has a policy on the use of agents, which includes enhanced due diligence procedures and restrictions on remuneration for such entities. There is evidence to indicate that this policy applies to all sales representatives and agents acting on behalf of the company.

However, the company receives a score of ‘1’ because there is no clear evidence that its policy addresses the specific corruption risks associated with the use of agents, nor is there evidence that its commit to establishing that the use of each agent is necessary to perform a legitimate business function.

2/2

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging with its third parties and agents. There is evidence that agents and the highest risk intermediaries are subject to enhanced due diligence. The company states that it refreshes due diligence periodically and when there is a change in the risk profile of the third party.

In addition, there is evidence that the company commits to not engage or review and potentially terminate its engagement with agents or intermediaries where the risks identified in the due diligence cannot be mitigated.

2/2

Based on publicly available information, there is evidence that the company seeks to establish the ultimate beneficial ownership of agents and intermediaries as part of its due diligence processes. There is evidence that the company has enhanced screening procedures to examine the beneficial ownership of high risk agents. The company indicates that it conducts such checks periodically throughout the lifecycle of the business relationship, and indicates that all agents are contractually obliged to report any material changes in beneficial ownership information, which may trigger additional controls or a review of the relationship.

In addition, there is evidence that the company commits to not engage or review and potentially terminate its engagement with agents or intermediaries where the risks identified in the due diligence cannot be mitigated.

2/2

There is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. The company indicates that all agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include clear audit and termination rights to detect, control and prevent breaches.

2/2

There is evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company states that commission fees are determined according to local market value and that both expenses and commissions are capped to ensure that the overall remuneration remains reasonable and proportionate. In addition, there is evidence that the company only pays remuneration to agents in staged payments over the course of their contract, based on clear milestones, and it commits to only paying agents into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

2/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on all of its joint venture partnerships. The company states that this includes establishing the ultimate beneficial ownership of the partner company, with enhanced due diligence for joint ventures operating in high risk markets. There is evidence that the company conducts anti-bribery and corruption due diligence prior to entering into a joint venture and when there is a change in the business relationship.

1/2

There is some evidence that the company considers anti-bribery and corruption issues when entering into a joint venture and that it requires all third parties to commit to anti-corruption undertakings. There is also evidence that the company includes anti-corruption clauses in its contracts with joint venture partners, with clear termination rights in the event of a compliance violation or after a review of any changes to its beneficial ownership.

However, the company receives a score of ‘1’ because there is no clear evidence that it requires all joint ventures to adopt its own anti-bribery and corruption programme or that it works with partner companies to develop a programme. There is also no evidence that the company includes audit rights in its contracts with joint venture partners to detect, control and prevent breaches.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in its joint ventures, for example, by stipulating provisions for secondments of its senior management, providing specific anti-corruption training or establishing a separate internal audit function.

OGMA – Indústria Aeronáutica de Portugal SA 1/2

There is some evidence that the company has a policy covering the use of agents. However, the company receives a score of ‘1’ because there is no evidence that its policy addresses the potential corruption risks associated with the use of agents, nor that it explicitly commits to establishing that the use of agents is, in each case, necessary to perform a legitimate business function.

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging its agents. There is evidence that the company commits to not engaging or terminating its engagement with agents or intermediaries where the risks identified in the due diligence cannot be mitigated.

However, the company receives a score of ‘1’ because there is no evidence that agents and highest risk intermediaries are subject to enhanced due diligence. There is also no evidence that the company repeats due diligence at least every two years or when there is a significant change in the business relationship.

1/2

There is some evidence that the company aims to establish the ultimate beneficial ownership of its agents and intermediaries, and that it commits to independently verifying this information as part of its due diligence process.

However, the company receives a score of ‘1’ because, although there is evidence that the company’s relationships may be terminated if red flags cannot be mitigated, there is no evidence that this would apply as a rule if ultimate beneficial ownership cannot be established.

0/2

Based on publicly available information, there is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. The company indicates that it includes anti-bribery and corruption clauses in its contracts with agents and that business relationships with those that violate its policy may be terminated.

However, the company receives a score of ‘0’ because there is no evidence that it includes audit rights in its contracts with these entities and it is therefore unclear how it assures itself of its suppliers’ compliance with its policy in practice.

1/2

There is some evidence that the company addresses incentive structures and remuneration for agents as a factor in bribery and corruption risk. The company’s anti-corruption policy lists several red flags relating to agent payment, such as risks stemming from payments to overseas accounts, cash payments, payments to a third party who has no relationship to the business operation, or excessive commission fees.

However, the company receives a score of ‘1’ because there is no evidence that the company imposes a threshold on the payment of sales commissions to agents, nor that there is a requirement that agent remuneration is paid in stage payments.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on all of its joint venture partners. The company states that this includes establishing the ultimate beneficial ownership of the partner company.

However, the company receives a score of ‘1’ because there is no evidence to suggest that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence. It is also unclear whether due diligence is repeated at least every two years.

1/2

There is evidence that the company considers potential anti-bribery and corruption risks when entering into a joint venture. However, the company receives a score of ‘1’ because there is no evidence that it takes steps to detect, control and prevent breaches through the inclusion of audit and termination rights in its contracts with joint venture partners.

0/2

There is no evidence that the company publicly commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Oki Electric Industry 0/2

There is no publicly available evidence that the company has a policy covering the use of agents.

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company commits to establish the beneficial ownership of its agents.

0/2

There is no publicly available evidence that shows that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company addresses incentive structures as a risk factor in agent behaviour or that it incorporates ethical principles into agent incentive structures.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, nor is there evidence that it requires anti-bribery and corruption clauses in its contracts with joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Oshkosh Corporation 0/2

There is insufficient publicly available evidence that the company has a policy which addresses the corruption risks associated with the use of agents, or that it includes details of controls to mitigate these risks.

1/2

There is some evidence that the company has formal procedures to conduct due diligence on its agents.

However, in publicly available evidence, it is not clear whether agents and the highest risk intermediaries are subject to enhanced due diligence. There is also no evidence that the company repeats due diligence at least every two years and/or when there is a significant change in the business relationship.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents and intermediaries.

0/2

There is some evidence that the company’s anti-bribery and corruption policy applies to agents and intermediaries. Although the company indicates that it may include termination rights in its contracts with these entities, it does not mention audit rights.

1/2

There is some evidence that incentive structures for agents are acknowledged as a factor in bribery and corruption risk.

However, there is no evidence that the company imposes a threshold on the payment of sales commissions to agents, and there is no requirement that remuneration is paid in stage payments or into local bank accounts.

0/2

The company does not publish any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Patria Oyj 2/2

Based on publicly available information, there is evidence that the company has a policy covering the use of agents. There is also evidence that the company recognises and accounts for the heightened bribery and corruption risks associated with the use of third party agents by dedicating special attention to this area in its internal audits. There is evidence that the company has specific controls to mitigate the corruption risks associated with using agents, and there is evidence that it establishes that the use of an agent is, in each case, necessary to perform a legitimate business function.

2/2

Based on publicly available information, there is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging any agents and intermediaries, at least every two years. There is evidence that all agents and highest risk intermediaries are subject to enhanced due diligence, and that the company commits to not engaging or terminating its engagement with agents or intermediaries where risks identified in the due diligence cannot be mitigated.

1/2

Based on publicly available information, there is evidence that the company seeks to establish the ultimate beneficial ownership of agents and intermediaries as part of its due diligence process. There is evidence indicating that this scope of due diligence is repeated at least every two years, and that the company commits to not engaging or terminating an agent relationship if ultimate beneficial ownership cannot be established.

However, there is no clear evidence that the company seeks to independently verify the ultimate beneficial ownership of its highest risk agents and intermediaries.

2/2

There is evidence that the company’s Ethical Code of Conduct applies to all agents and intermediaries acting for or on behalf of the company. There is evidence that all agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include audit and termination rights.

1/2

Based on publicly available information, there is some evidence the company highlights incentive structures for agents as a factor in bribery and corruption risk. There is evidence that the company monitors the activities of its agents before making payments.

However, there is no evidence that the company’s policy stipulates further controls on such payments, such as imposing a threshold on the payment of sales commissions to agents. There is also no evidence that the company requires payments to be made in stage payments or into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on its behalf.

2/2

The company publishes a statement that it received no reports of misconduct, launched no investigations and applied no disciplinary action against agents and intermediaries during the most recent reporting period.

2/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on all of its joint venture partnerships prior to entering into the venture and at least every two years thereafter. There is also evidence indicating that due diligence includes establishing the ultimate beneficial ownership of the partner company, with enhanced due diligence for joint ventures operating in high risk countries or with high risk partners.

2/2

Based on publicly available information, the company commits to establishing and implementing anti-bribery and corruption policies in all of its joint ventures by developing a programme based on the company’s existing policies. The company also states that it includes anti-corruption clauses in contracts with joint venture partners and there is evidence that these clauses include audit and termination rights.

1/2

Based on publicly available information, there is some evidence that the company commits to take an active role in preventing bribery and corruption in all its joint ventures. However, there is no evidence that the company provides practical details to support this statement or to indicate how it might do so in practice.

Perspecta 1/2

There is some evidence that the company has a policy related to the use of agents.

However, the company does not provide details of specific controls to mitigate the corruption risks associated with the use of agents. There is also no evidence that the company commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. In addition, it is unclear whether the company’s policy also applies to subsidiaries and joint ventures.

0/2

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

0/2

There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is evidence that the company’s code of conduct, The Standard, applies to agents and intermediaries. However, there is no publicly available evidence that the company incorporates anti-corruption clauses in contracts with its agents and intermediaries, which include clear audit and termination rights.

0/2

There is no evidence that the company's incentive structures for agents are designed to minimise risks of anti-bribery and corruption.

0/2

The company does not publish any details of the agents currently contracted to act for or on behalf of the company.

0/2

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

0/2

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

0/2

There is no publicly available evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures. There is also no evidence that the company requires anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Polish Defence Holding 0/2

There is no publicly available evidence that the company has a policy on the use of agents.

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents or intermediaries.

0/2

There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company considers incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on its behalf.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in its joint ventures.

Poongsan Corporation 1/2

There is evidence that the company has a policy covering the use of agents, which addresses the corruption risks associated with their use and outlines a number of restrictions and controls to mitigate these risks.

The company, however, receives a score of ‘1’ because it does not commit to establishing and verifying that the use of agents, is in each case necessary to perform a legitimate business function. The company also does not specify that its policy applies to subsidiaries and joint ventures.

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on its third parties and agents. There is also evidence that third parties are required to complete a due diligence questionnaire before engaging with the company, which is understood to apply to agents and intermediaries. There is some evidence that suggests that the company commits to not engaging with third parties where risks identified in the due diligence cannot be mitigated.

The company receives a score of ‘1’ because there is no evidence that agents and highest risk intermediaries are subject to enhanced due diligence. Furthermore, it is not clear from the available evidence that due diligence is repeated at least every two years and/or when there is a significant change in the business relationship.

1/2

Based on publicly available information, there is evidence that the company has formal procedures in place to establish the beneficial ownership of third parties prior to engaging them, which is understood to include agents and intermediaries. There is evidence that suggests that the company will not engage with third parties where beneficial ownership cannot be established.

However, the company receives a score of ‘1 because there is no evidence that the company commits to independently verify the beneficial ownership information provided by high risk agents, nor that the company checks this information at least every two years and/or when there is a significant change in the business relationship.

2/2

There is evidence that the company’s anti-bribery and corruption policy applies to agents and intermediaries acting for or on behalf of the company. The company states that agents and intermediaries who deal with public officials or employees of public corporations are subject to anti-bribery and corruption clauses in their contracts, which includes clear termination rights.

0/2

Although there is evidence that the company conducts checks in relation to whether payments to agents are reasonable, there is no evidence that the company's incentive structures for agents include measures to mitigate potential bribery and corruption risks.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for, or on its behalf.

0/2

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

1/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering into a joint venture. It is clear that the company’s due diligence includes checks on the ultimate beneficial ownership of the partner company.

However, there is no evidence to suggest that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence. Furthermore, there is no evidence that due diligence is repeated at least every two years or when there is a significant change in the business relationship.

2/2

Based on publicly available information, there is evidence that the company states that it accounts for anti-bribery and corruption considerations when entering into a joint venture. The company states that it will only enter into joint ventures if anti-bribery and corruption clauses are included in the contract, at minimum prohibiting foreign and domestic bribery and facilitation payments. There is evidence that the company takes steps to detect, control and prevent breaches through auditing compliance with anti-bribery and corruption principles, and that it may terminate relationships with business partners found not to be compliant with these principles.

0/2

Based on publicly available information, it is unclear whether the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. The company does not discuss any practical measures that it has in place to counter bribery and corruption risks.

PT Dirgantara Indonesia (Indonesian Aerospace) 0/2

There is no publicly available evidence that the company has a clear policy on the use of agents.

0/2

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

0/2

There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company considers incentive structures as a risk factor in agent behaviour, nor is there evidence that the company's incentive structures for agents are designed to minimise risks of anti-bribery and corruption.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

QinetiQ Group 2/2

There is evidence that the company has a clear policy to control the use of agents which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. This policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures.

2/2

The company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging any agents and intermediaries, at least every two years. All agents and highest risk intermediaries are subject to enhanced due diligence. The company commits to not engaging with agents or intermediaries where the risks identified in the due diligence cannot be mitigated.

1/2

There is evidence that the company asks of agents to disclose their beneficial ownership to the company, and it verifies this information, as part of its due diligence processes. The company suggests that it will not engage with agents or intermediaries if beneficial ownership cannot be established.

However, there is no evidence of a commitment to independently verify beneficial ownership information of high risk agents, nor does the company verify the information both before onboarding and over the course of the business relationship.

2/2

There is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. All agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include clear audit rights and termination rights to detect, control and prevent breaches.

1/2

There is evidence that incentive structures for agents are highlighted and addressed as a factor in bribery and corruption risk.

However, based on publicly available information, there is no evidence that the company imposes a threshold on the payment of sales commissions to agents, and there is no requirement that remuneration is paid in stage payments or into local bank accounts. The company refers to a Use of Commercial Intermediaries Group Procedure but this is not publicly acessible.

0/2

The company does not publish any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on all of its joint venture partnerships. At a minimum, the company states that this includes establishing the ultimate beneficial ownership of the partner company, with enhanced due diligence where required.

However, evidence suggests that due diligence is only conducted before engaging joint ventures and is not repeated at least every two years.

2/2

There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies and procedures in all of its joint ventures by requiring the adoption of its own anti-bribery and corruption programme. The company states that it will only enter into joint ventures if anti-bribery and corruption clauses are included in the contract, specifying clear audit and termination rights to detect, control and prevent breaches.

2/2

There is evidence that company commits to take an active role in preventing bribery and corruption in all of its joint ventures. There is some evidence to support the company's commitment, through a statement of possible controls that it may implement, dependent on the context.

Rafael Advanced Defense Systems Ltd. 2/2

There is evidence that the company has a procedure to control the use of agents which addresses the corruption risks associated with their use and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. There is evidence the policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures.

2/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging any business partners, which includes agents and intermediaries. The company states that due diligence may be adjusted for certain business partners based on the risks identified and recognises the risks associated with agents, indicating that agents and highest risk intermediaries are subject to enhanced due diligence. There is also evidence that the due diligence process is conducted at least every two years or when there is a significant change in the business relationship. Furthermore, the company’s policy includes a commitment to not engage or terminate its engagement with business partners where the risks identified in the due diligence cannot be mitigated.

2/2

There is evidence that the company has formal procedures to establish the beneficial ownership of agents prior to engaging them, and when there is a significant change in the business relationship. There is evidence that the company operates, as a minimum, a risk based beneficial ownership verification policy, whereby all agent provided information is independently verified. The company commits to not engaging or terminating its engagement with agents or intermediaries where ultimate beneficial ownership cannot be established.

2/2

There is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. The company states that all agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, with clear audit rights and termination rights to detect, control and prevent breaches.

1/2

There is evidence that incentive structures for agents are highlighted and addressed as a factor in bribery and corruption risk. The company lists a number of red flags which can lead to a termination of a relationship with business partners, which suggest that remuneration to agents is usually required to be paid in stage payments and into local bank accounts.

However, the company receives a score of ‘1’ as there is no evidence that it imposes a proportionate threshold on the payment of sales commissions to agents.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for, or on its behalf.

0/2

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

2/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on all of its business partners, which includes joint venture partnerships. The company states that this includes obtaining ownership information for business partners, although the company does not specifically commit to establishing ultimate beneficial ownership. There is evidence that the company has provisions in place to identify high risk business partners and to conduct enhanced due diligence on business partners located in high risk countries, which is understood to apply to joint ventures. Furthermore, there is evidence that the company conducts anti-bribery and corruption due diligence when entering into a joint venture and repeated at least every two years or when there is a significant change in the business relationship.

2/2

There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies and procedures in all of its joint ventures by requiring the adoption of its own anti-bribery and corruption programme. The company states that it includes anti-bribery and corruption clauses in its joint venture contracts, with clear audit and termination rights.

2/2

There is evidence the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. There is evidence to support the company's commitment through examples of the controls it implements in its affiliate companies and the provision of training on anti-bribery and corruption to business partners.

Raytheon Technologies 2/2

There is publicly available evidence that the company has a policy to control the use of agents, which addresses the associated corruption risks and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, based on a legitimate business need. The company states that this policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures where the company has a controlling interest.

2/2

Based on publicly available information, there is evidence the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging any agents and intermediaries, at least every two years, or when there is a significant change in the business relationship. There is evidence that agents and high-risk third parties and contractors are subject to enhanced due diligence.

In addition, the company indicates that it will not employ agents in cases where due diligence cannot rule out a foreign-government ownership interest, which indicates – though indirectly – that it commits to potentially terminating engagement with third parties where a red flag cannot be mitigated.

2/2

The company states that it has formal procedures to establish the beneficial ownership of agents prior to engaging them, and at least every two years and/or when there is a significant change in the business relationship. There is evidence that the company’s due diligence involves checks on foreign government ownership interests of third parties, which is assumed to also apply to beneficial ownership in general. In addition, there is evidence that the company undertakes to independently verify this beneficial ownership information. There is some indication that the company commits to not engaging or terminating its engagement with agents or intermediaries where ultimate beneficial ownership cannot be established.

2/2

Based on publicly available information, there is evidence the company’s Anti-Corruption Policy and Code of Conduct apply to all agents and intermediaries acting for or on behalf of the company. The company states that all agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include audit and termination rights.

1/2

There is some publicly available evidence that the company addresses incentive structures for agents as a factor in bribery and corruption risk. There is evidence that there are oversight processes to ensure that incentive structures are reasonable and commensurate with the services rendered.

The company, however, receives a score of ‘1’ because there is no clear evidence that it imposes a threshold on the payment of sales commissions to agents. There is also no clear requirement that remuneration is paid in stages or into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on behalf of the company.

1/2

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

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

2/2

Based on publicly available information, there is evidence the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on its joint ventures. For foreign joint ventures, this includes conducting anti-bribery and corruption due diligence on both the entity and its activities prior to entering into a partnership, and then every two years and/or when there is a significant change in the business relationship. There is also some indication that this due diligence process also applies to domestic joint venture partners (i.e. all prospective partners).

In addition, the company states that this process includes establishing ultimate beneficial ownership. There is evidence that the company conducts enhanced due diligence for high-risk joint ventures.

2/2

Based on publicly available information, there is evidence that the company’s Anti-Corruption Policy applies to joint venture partners. The company also states that it includes anti-corruption clauses in its contracts with all business partners, which include audit and termination rights.

2/2

Based on publicly available information, there is evidence that the company commits to take an active role in preventing bribery and corruption in all its joint ventures. There is evidence to support the company's commitment. The company states that it conducts regular activity reporting, deposit and expenditure reviews, site visits, quality control checks, and exercises its audit rights where appropriate.

Rheinmetall A.G 2/2

There is some evidence the company has a policy on the use of agents as part of its business partner management programme and addresses the corruption risks associated with the use of agents. The company’s controls include due diligence on agents. There is evidence that the company commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. The policy applies company-wide, to all subsidiaries and joint ventures.

1/2

There is evidence that the company conducts anti-bribery and corruption due diligence prior to engaging with its third parties and agents. There is evidence that highest risk intermediaries are subject to enhanced due diligence.

However, there is no evidence that due diligence is conducted at least every two years or when there is a significant change in the business relationship.

1/2

There is evidence that the company asks agents to disclose their beneficial ownership to the company, and it verifies this information, as part of its due diligence processes.

However, there is no evidence that it commits to independently verify beneficial ownership information of high risk agents, and it does not verify the information both before onboarding and over the course of the business relationship. The company does not commit to reviewing or potentially terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.

2/2

There is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. All agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include clear audit rights and termination rights to detect, control and prevent breaches.

1/2

There is some evidence that the company recognises renumeration structures for agents as a factor in bribery and corruption risk.

However, there is no evidence that it imposes a threshold on the payment of sales commissions to agents, and there is no evidence of a requirement that remuneration is paid in stage payments or into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on behalf of the company.

0/2

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

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering and while operating in a joint venture. There is evidence to suggest that higher-risk joint ventures are subject to enhanced due diligence.

However, it is not clear whether the due diligence process includes checks on beneficial ownership or whether due diligence is repeated at least every two years.

1/2

There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies in all of its joint ventures.

However, it is unclear how the company ensures this in practice.

2/2

There is evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. There is clear evidence to support the company's commitment, through practical examples and a statement of possible controls that it may implement.

Roketsan A.Ş. 0/2

There is no evidence that the company has a policy covering the use of agents.

0/2

There is no evidence that the company states that it conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company mentions incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Rolls Royce PLC 2/2

There is evidence that the company has a policy covering the use of agents and third parties, which extends to agents engaged by its suppliers and other entities acting on behalf of the company. The company’s policy stipulates various controls to mitigate the corruption risks presented by agents. These controls include: activity reporting procedures for agents, mandatory anti-corruption training, requirements for senior sign off, due diligence and ongoing monitoring of activities. The policy also commits to establishing that the use of agents is, in each case, necessary to perform a legitimate business function.

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging with all third parties. Due diligence on agents is repeated at least every three years. There is further evidence that all agents and highest risk intermediaries are subject to enhanced due diligence, which is repeated every one or two years. There is also evidence that the company will not engage, or will terminate an agent agreement if a risk identified in the due diligence process cannot be mitigated.

However, the company states that high risk third parties are subject to due diligence every three years and not at least every two years and/or when there is a significant change in the business relationship.

1/2

There is evidence that the company asks agents to disclose their beneficial ownership to the company, and it independently verifies this information, as part of its due diligence processes. It does so at least every three years, but for higher risk agents every one or two years. The company states that higher risk third parties are contractually required to inform the company of any beneficial ownership changes. There is also evidence that the company will review and potentially terminate an agent relationship if ultimate beneficial ownership cannot be established or if the ownership structure is seen to present too great a corruption risk.

However, there is no evidence that the company verifies beneficial ownership information for all agents at least every two years and/or when there is a significant change in the business relationship.

2/2

The company states that all agents and third parties must adhere to standards equivalent to standards equivalent to the company’s Anti-Corruption Policy. According to publicly available evidence, all agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include clear audit rights and termination rights to detect, control and prevent breaches.

1/2

The company addresses and highlights incentive structures for agents, namely commissions payments, as a factor in bribery and corruption risk. The company states that in some cases it will impose restrictions on agents’ payments and incentive structures, including a threshold on commissions. The company states that its Ethics and Compliance Team must approve all payments to agents. The company states that it will only pay agents into local bank accounts, unless there are exceptional mitigating circumstances, in which it requires approval from the Ethics and Compliance Team.

However, the company receives a score of ‘1’ because there is no evidence that the company imposes a threshold on the payment of sales commissions in all agent agreements, and there is no evidence the company requires that remuneration to agents is paid in stage payments.

0/2

The company does not publish any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering all joint venture partnerships. Evidence indicates that the due diligence process includes checks on the ultimate beneficial ownership of the partner company, and that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence.

However, the company receives a score of ‘1’ because it is unclear how frequently due diligence is repeated and whether this is at least every two years.

2/2

There is evidence that the company’s Code of Conduct includes anti-bribery and corruption provisions as well as a prohibition on facilitation payments, and applies to its controlled joint ventures. The company also states that it will work with other joint venture partners to adopt the same requirements. The company states that it will only enter into joint ventures if anti-bribery and corruption clauses are included in the contract, which include clear audit and termination rights to detect, control and prevent breaches.

2/2

The company explicitly commits to take an active role in preventing bribery and corruption in all of its joint ventures. There is clear evidence to support the company's commitment, by way of specialist training and ethics and compliance resources and guidance that the company provides for employees of joint ventures, as well as submitting the joint venture’s anti-corruption procedures to a regular audit and review process.

Rostec State Corporation JSC 0/2

There is no evidence that the company has a clear published policy covering the use of agents.

1/2

The company states that it has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging third parties and agents. However it is not clear based on publicly available information whether agents and high-risk intermediaries are subject to enhanced due diligence and there is no evidence that the company conducts due diligence on its agents at least every two years or when there is a significant change in the business relationship.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents.

1/2

The company states that it encourages third parties to adopt similar anti-corruption policies to its own; however, there is no evidence as to the contents and how it ensures this. There is also evidence to suggest that the company includes anti-corruption clauses in contracts with third parties, but there is no evidence that audit and termination rights are included.

0/2

There is no evidence that the company recognises incentive structures as a risk factor in agent behaviour and there is no evidence that the company's incentive structures for agents are designed to minimise risks of anti-bribery and corruption.

0/2

There is no evidence that the company publishes details of the agents currently contracted to act for or on behalf of the company.

0/2

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

0/2

There is evidence that the company conducts due diligence on third parties, but there is no evidence that it makes specific reference to joint ventures.

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures. Furthermore, there is no publicly available evidence to show that the company requires anti-bribery and corruption clauses specifically in its contracts with joint venture partners.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

RTI Systems Inc. 0/2

There is evidence that the company acknowledges the corruption risks associated with the use of agents. However, there is no evidence that it has a sufficiently clear policy covering the use of agents.

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging third parties, intermediaries and agents.

However, the company receives a score of ‘1’ because there is no clear evidence that agents and highest risk intermediaries are subject to enhanced due diligence, or that following onboarding due diligence is repeated at least every two years and/or when there is a significant change in the business relationship.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents. There is also no evidence that the company makes a commitment to not engaging or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.

1/2

The company states that it includes anti-corruption clauses in its contracts with agents and intermediaries. However, there is no evidence that the company explicitly includes audit and termination rights in its contracts with these entities.

0/2

Based on publicly available information, the company makes no specific mention of incentive structures as a risk factor in agent behaviour and there is no evidence that the company's incentive structures for agents are designed to minimise risks of anti-bribery and corruption.

0/2

The company does not publish any details of the agents currently contracted to act for or and on behalf of the company.

0/2

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

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence into joint venture partners. However, there is no evidence that the company’s due diligence procedures include checks on the ultimate beneficial ownership of the partner company. Also, there is no evidence to suggest that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence, or that due diligence is conducted at least every two years throughout the business relationship following the onboarding process.

2/2

There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies in all of its joint ventures and states that it will work alongside joint venture partners to implement an anti-corruption programme with policies equivalent to its own. There is evidence that the company includes anti-corruption clauses in counterparty contracts.

1/2

There is evidence that the company commits to take an active role in preventing bribery and corruption in its joint ventures but there is insufficient evidence with regards to the practical measures it has in place to achieve this.

RUAG Holding AG 2/2

There is evidence that the company has a clear policy to control the use of agents, which addresses the corruption risks associated with their use and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. This policy applies across the group, including associated companies in which the company has a controlling interest. The company states that it will strive to establish a comparable policy in any affiliated companies.

2/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging with its agents. The company states that high risk agents and intermediaries are subject to enhanced due diligence. The company commits to not engaging or terminating its engagement with agents or intermediaries where the risks identified in the due diligence process cannot be mitigated. In addition, the company indicates that it renews this due diligence at least every three years or whenever there is a change in the business relationship.

2/2

There is evidence that the company establishes the beneficial ownership of its agents and intermediaries as part of its due diligence process. The company indicates that its Compliance department conducts background checks on shareholders of any third parties involved in sales at the start of the contractual relationship and at least every three years or when there is a significant change in the business relationship.

Where a third party is identified as high risk, the company states that it may require the individual or entity to complete an external questionnaire and indicates that it may require an in-depth background check on affiliated legal entities from an independent organisation. In addition, the company indicates that it will not proceed with the contractual relationship if such information about the third party cannot be verified or if significant red flags are identified.

2/2

There is evidence that the company’s anti-bribery and corruption policies apply to all agents and intermediaries. The company publishes a ‘Code of Conduct for Business Partners of RUAG’, which outlines the anti-bribery and corruption standards applicable to all third parties, and the company’s information on contracts with third parties indicates that all third parties must adhere to its anti-corruption standards. In addition, there is evidence that it includes monitoring and termination rights in its contracts with these parties.

2/2

There is evidence that the company highlights and addresses remuneration to agents as a factor in bribery and corruption risk. The company indicates that it places a threshold on sales-based commissions to agents so that payments do not exceed a proportion of the net fee to the agent. In addition, there is evidence that agents are required to provide quarterly activity reports and payment is only released on submission of these reports. The company also commits to only paying agents into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

2/2

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all of its joint venture partnerships. The company states that this includes establishing the ultimate beneficial ownership of the partner company, with enhanced due diligence for joint ventures identified as posing higher corruption risks, such as state-owned enterprises. There is evidence that the company conducts anti-bribery and corruption due diligence both prior to entering into a joint venture and on the entity and its activities once established, at least every two years or when there is a significant change in the business relationship.

2/2

There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies and procedures in all of its joint ventures, by developing a programme jointly with the relevant partner company. In addition, the company indicates that it will only enter into joint ventures if anti-bribery and corruption clauses are included in the contract, which prohibit foreign and domestic bribery and facilitation payments, as well as specifying audit and termination rights to detect, control and prevent breaches.

2/2

There is evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. The company provides examples of possible controls that it may implement to do so, dependent on the context, such as secondment schemes for compliance officers, veto rights on certain transactions and training for relevant employees and management.

Russian Helicopters JSC 0/2

Based on publicly available information, there is no evidence that the company has a policy covering the use of agents.

0/2

Based on publicly available information, there is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no publicly available evidence that shows that the company aims to establish the beneficial ownership of its agents.

0/2

In publicly available evidence the company states that all counterparties must adhere to its anti-corruption policy. However, the company receives a score of ‘0’ because there is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

Based on publicly available information, there is no evidence that the company’s incentive structures for agents are designed to minimise risks of bribery and corruption.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on behalf of the company.

0/2

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

0/2

Based on publicly available information, there is no evidence that the company conducts anti-bribery and corruption due diligence on its joint ventures.

0/2

Based on publicly available information, there is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, or that it requires anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

Based on publicly available information, there is no evidence that the company commits to taking an active role in preventing bribery and corruption in all its joint ventures.

Saab AB 2/2

There is evidence that the company has a policy covering the use of agents, which also applies to those engaged by subsidiaries and joint ventures. The policy addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. The policy also explicitly commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function.

1/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with its third parties and agents. Agents and the highest risk intermediaries are subject to enhanced due diligence. The company states that due diligence is conducted before engaging agents and remains valid for two to four years, depending on the risk level.

However, the company receives a score of ‘1’ because it does not repeat due diligence for all of its agents and intermediaries at least every two years or when there is a significant change in the business relationship.

0/2

There is publicly available evidence that the company aims to establish the ultimate beneficial ownership of its agents and intermediaries, but the company makes no clear commitment to not engage or to terminate a third party relationship if beneficial ownership cannot be established.

2/2

There is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. All agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include clear audit rights and termination rights to detect, control and prevent breaches.

1/2

Based on publicly available information, there is evidence that the compensation structures for agents are highlighted and addressed as a factor in bribery and corruption risk. There is also evidence that the company has specific controls in place to manage the risk, which include a threshold on the payment of sales commissions to agents and requiring that payments are only be made into local bank accounts.

However, there is no evidence that the company requires that payments be staged over the course of their contracts and based on clear milestones.

0/2

There is no publicly available evidence to indicate that the company publishes any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

There is no publicly available evidence to indicate that the company publishes any data on ethical or bribery and corruption-related investigations, incidents or the associated disciplinary actions involving agents.

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering into a joint venture. There is evidence that this due diligence is conducted for every joint venture partnership and it is clear that the company’s due diligence includes checks on the ownership of joint venture partners.

However, there is no evidence to suggest that high-risk joint ventures (i.e. those operating in high risk markets or with high risk partners) are subject to enhanced due diligence and that due diligence is repeated at least every two years.

1/2

Based on publicly available information, there is evidence that the company commits to establishing and implementing anti-bribery and corruption policies in all of its joint ventures. The company requires joint ventures in which it has a controlling interest to apply the company’s rules and procedures for corruption prevention. Joint ventures in which the company has a minority stake are required to adhere to Saab’s Supplier Code of Conduct or commit to follow an equivalent set of core principles. The company includes termination rights in its contracts with joint venture partners.

However, the company receives a score of ‘1’ because there is no publicly available evidence that the company includes audit rights in its joint venture contracts.

1/2

The company explicitly commits to take an active role in preventing bribery and corruption in all of its joint ventures.

However, the company does not provide any further information or practical details to support this statement.

Safran S.A 2/2

There is evidence that the company has a clear policy and procedure to control the use of agents, which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. This policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures.

1/2

There is some evidence that the company conducts due diligence on its agents and intermediaries. The company states that it conducts an annual review of business partner due diligence throughout the contractual relationship, as well as undertaking a methodical selection process prior to engagement.

However, the company receives a score of ‘1’ because it does not specify that high risk agents or intermediaries are subject to enhanced due diligence.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents as part of its due diligence. There is no evidence that the company commits to not engaging or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.

0/2

There is no clear evidence that the company’s anti-bribery and corruption policy applies to its agents and intermediaries, nor that the company includes clauses in its contracts with such entities to detect and prevent bribery and corruption. The company addresses business partners in its Code of Conduct, but does not explicitly state that all agents must abide by these standards when acting for or on behalf of the company.

1/2

There is some evidence that the company considers its payments and compensation as a risk factor in agent behaviour. The company indicates that agent compensation should be appropriate and consistent with market price. There is also evidence that payments are properly documented and authorised by the appropriate department.

However, the company receives a score of ‘1’ because there is no evidence that the company imposes a threshold on the payment of sales commissions to agents. The company does not state that it makes stage payments nor that agents must be paid into local bank accounts.

0/2

The company does not publish any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

0/2

There is some evidence that the company conducts due diligence on its joint ventures at the start of the relationship, but provides no further information about its due diligence procedures beyond that. There is also no indication that the company conducts due diligence throughout the relationship, nor that this process is based on an assessment of corruption risks.

0/2

There is no clear evidence that the company commits to incorporating anti-bribery and corruption policies and procedures in its joint venture partnerships, nor that it requires anti-bribery and corruption clauses in its contracts with such partners. The company states that its Code of Conduct may be adopted by its joint venture partners, but this is not a requirement and there is no evidence that the company takes action if not adopted.

0/2

There is no evidence that the company commits to taking an active role in preventing bribery and corruption in its joint ventures. The company states that its Code of Conduct may be adopted by its joint venture partners, but this is not a requirement and there is no evidence that the company takes action if not adopted.

Science Applications International Corporation (SAIC) 0/2

There is no evidence that the company has a policy covering the use of agents. There is some indication that the Risk Oversight Committee monitors the company’s policies and practices with regard to third-party risk but it does not provide further publicly available information on these policies. Although there is evidence that the Risk Oversight Committee Charter covers the retention of advisors, it is not clear whether this covers business agents and intermediaries as defined in this assessment.

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries. The company states that its Risk Oversight Committee monitors the company’s policies and practices with regard to third-party risk, but it does not provide further publicly available information on these policies and practices.

0/2

There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents and intermediaries. There is no evidence that the company commits to not engaging or terminate its engagement with agents or intermediaries if beneficial ownership cannot be established.

0/2

There is no evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. The company provides some information on the standards of conduct that it expects from its suppliers, but it is not clear that this definition includes agents and intermediaries, nor does the company provide further information on contractual clauses with these entities.

0/2

There is no evidence that the company's incentive structures for agents are designed to minimise risks of anti-bribery and corruption, nor that incentive structures are recognised as a risk factor in agent behaviour. The company’s publicly available Risk Oversight Committee Charter includes some information on the retention of agents but it is not clear whether this covers business agents and intermediaries as defined in this assessment.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its joint ventures. The company indicates that its Risk Oversight Committee monitors its policies relating to third-party risk, however there is no further publicly available information regarding this policy or whether it includes joint ventures.

0/2

There is no publicly available evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in its joint ventures.

Serco Group PLC 2/2

Based on publicly available information, there is evidence that the company has a policy covering the use of agents. The policy addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. There is evidence that the company commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. In addition, there is evidence that this policy applies to subsidiaries and owned joint ventures.

2/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-
based anti-bribery and corruption due diligence prior to engaging and re-engaging with its third parties and agents. There is also evidence to indicate that higher risk agents and third parties are subject to enhanced due diligence. The company indicates that it undertakes due diligence on all third parties during the onboarding process and that it refreshes these checks every three years, with ongoing monitoring throughout the lifecycle of the contract; the level of information provided on these checks is sufficient to receive a score of ‘2’.

It is noted that the company references a document called “Third Party Legal and Ethical Compliance Due Diligence” but this does not appear to be accessible in the public domain.

1/2

Based on publicly available information, there is evidence that the company seeks to establish the beneficial ownership of its agents and intermediaries as part of its due diligence process. The company indicates that it undertakes such checks regularly and that any red flags identified may trigger additional reviews.

However, the company receives a score of ‘1’ because it does not specifically commit to not engaage or terminate an agreement if beneficial ownership cannot be established.

1/2

Based on publicly available information, there is evidence that the company’s anti-bribery and corruption policy applies to agents and that it includes anti-corruption clauses in its contracts with such entities or individuals. There is some evidence that the company includes termination rights in its contracts with these entities.

However, the company receives a score of ‘1’ because there is no clear evidence that the company includes audit rights in its contracts with all agents and intermediaries.

1/2

Based on publicly available information, there is some evidence that the company addresses incentive structures for agents as a factor in bribery and corruption risk. The company indicates that fees must be reasonable and not provide an incentive to act improperly, as well as stipulating specific sign off procedures for all agent payments. In addition, the company commits to only provide payments as specified in the contract and to making all payments into a designated bank account.

However, the company receives a score of ‘1’ because there is no evidence that the company imposes a proportional or other threshold on the payment of sales commissions to agents. There is also no clear evidence that remuneration is made in stage payments throughout the lifecycle of the contract.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on behalf of the company.

0/2

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

2/2

Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering and while operating in a joint venture. There is evidence that this due diligence is conducted for every joint venture partnership (“strategic partners”) and that this includes checks on the beneficial ownership of the partner company. The company indicates that it undertakes due diligence on all strategic partners during the onboarding process and that it refreshes these checks every three years, with ongoing monitoring throughout the lifecycle of the contract for high-risk partners; the level of information provided on these checks is sufficient to receive a score of ‘2’.

1/2

Based on publicly available information, there is some evidence that the company commits to establishing and implementing anti-bribery and corruption policies in its joint ventures. The company states that it includes anti-bribery and corruption provisions in its joint venture contracts and there is evidence indicating that contracts include termination rights.

However, the company receives a score of ‘1’ because there is no clear evidence that it takes steps to detect, control and prevent breaches through the inclusion of audit rights in all its joint venture contracts.

1/2

Based on publicly available information, there is some evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. However, the company receives a score of ‘1’ because it does not provide any further information on the steps that it takes to assure itself of this.

ST Engineering 0/2

There is no publicly available evidence that the company has a policy covering the use of agents. The company indicates that it communicated its anti-corruption policies to intermediaries; however there is no clear evidence that the company formally addresses the corruption risks associated with the use of agents or that it provides details of specific controls to mitigate these risks.

0/2

There is no clear evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging with its third parties. The company indicates that it evaluates and screens third party intermediaries, but there is no evidence that high risk intermediaries are subject to enhanced due diligence, nor that highest risk intermediaries are subject to enhanced due diligence and there is no evidence that the process is repeated at least every two years.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is evidence that the company’s anti-bribery and corruption policy applies to agents and intermediaries, and that it includes anti-bribery and corruption clauses in its contracts with such entities.

However, the company receives a score of ‘0’ because there is no evidence that it explicitly includes audit and termination rights in its contracts with these entities.

0/2

There is no publicly available evidence that the company has incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or and on its behalf.

0/2

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

0/2

Based on publicly available information, there is some evidence that the company conducts due diligence (“screening”) on its business partners. However, the company receives a score of ‘0’ because it is not clear whether this includes joint venture partners, nor is there evidence to indicate that this screening covers anti-corruption principles or is based on an assessment of risk.

0/2

There is no publicly available evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

STM Savunma Teknolojileri Muhendislik ve Ticaret A.S. 0/2

There is no publicly available evidence that the company has a policy covering the use of agents.

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company addresses incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on its behalf.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Tactical Missiles Corporation JSC 0/2

While the company acknowledges the corruption risks associated with having business relations with external consultants and other persons, there is no evidence of a clear policy which covers the use of agents.

0/2

While the company states that it checks the willingness of third parties to comply with ethical business conduct, there is no evidence which suggests that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company aims to establish the ultimate beneficial ownership of its agents or intermediaries.

1/2

There is some evidence that the company requires third parties to comply with its own business ethics and that it conducts checks on the strength of third parties’ anti-corruption procedures and policies. The company states that counterparties are subject to anti-corruption clauses in their contracts, however there is no evidence that it includes audit and termination rights in contracts with agents and intermediaries.

0/2

There is no evidence that the company acknowledges incentive structures as a risk factor in agent behaviour and there is no evidence that the company's incentive structures for agents are designed to minimise risks of anti-bribery and corruption.

0/2

There is no evidence that the company publishes details of the agents contracted to work for the company.

0/2

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

0/2

While the company states that it checks the willingness of third parties to comply with ethical business conduct, there is no evidence which suggests that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on its joint ventures.

0/2

There is some evidence that the company requires third parties to comply with its own business ethics and that it conducts checks on the strength of third parties’ anti-corruption procedures and policies. The company states that counterparties are subject to anti-corruption clauses in their contracts, however it is not clear whether this includes joint ventures. Overall, there is insufficient evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Tashkent Mechanical Plant (TMZ) 0/2

There is no evidence that the company publishes any information regarding its approach to the use of agents.

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company commits to establish the beneficial ownership of its agents.

0/2

There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company considers incentive schemes as a risk factor in agent behaviour.

0/2

The company does not publish any details of the agents currently contracted to act for and/or on its behalf.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures and there is no evidence it requires anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Tatra Trucks A.S. 0/2

Based on publicly available information, there is no evidence that the company publishes a policy on the use of agents.

0/2

There is some evidence that the company has procedures in place to conduct risk-based anti-bribery and corruption due diligence on its external partners, however there is no clear evidence to indicate that this includes agents. In addition, there is no evidence that agents and highest risk intermediaries are subject to enhanced due diligence, nor that due diligence is repeated every two years and/or when there is a significant change in the business relationship.

0/2

There is no publicly available evidence that the company aims to establish the ultimate beneficial ownership of its agents and intermediaries as part of its due diligence procedure.

0/2

There is some evidence that the company’s Code of Ethics applies to sales representatives; however there is no clear evidence that this includes agents and intermediaries, nor is it clear that the company includes anti-bribery and corruption clauses in its contracts with these individuals or entities.

0/2

There is no publicly available evidence that the company considers incentive structures as a risk factor in agent behavior.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

0/2

There is no publicly available evidence that the company has formal procedures in place to conduct anti-bribery and corruption due diligence on its joint venture partners. The company indicates that it conducts checks on its external partners, however there is no clear evidence to suggest that this includes joint ventures.

0/2

There is no publicly available evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures. In addition, there is no evidence that the company requires anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Telephonics Corporation  0/2

There is no publicly available evidence that the company has a policy on the use of agents.

0/2

There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents, nor does the company commit to not engaging or terminate its engagement with agents or intermediaries if beneficial ownership cannot be established.

0/2

There is no clear evidence that the company’s anti-bribery and corruption policy applies to agents or that it includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company's incentive structures for agents are designed to minimise risks of bribery and corruption or that incentive structures are recognised as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for and/or on its behalf.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in its joint ventures.

Terma A/S 2/2

Based on publicly available information, there is evidence that the company has a clear policy to control the use of agents which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. There is evidence that this policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures.

2/2

Based on publicly available evidence, the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging or re-engaging any agents and intermediaries. The company states that it conducts this due diligence at least every two years or when there is a significant change in the business relationship, and indicates that all agents and highest risk intermediaries are subject to enhanced due diligence. There is evidence that the company commits to not engaging or terminating its engagement with agents or intermediaries where the risks identified in the due diligence cannot be mitigated.

2/2

There is evidence that the company has formal procedures in place to establish the beneficial ownership of agents prior to engaging them, and that it repeats this process at least every two years or when there is a significant change in the business relationship. The company idicates that it operates a risk based beneficial ownership verification policy, whereby all agent provided information is verified and high risk agent’s information is verified. There is evidence that the company commits to not engaging or terminating its engagement with agents or intermediaries where ultimate beneficial ownership cannot be established.

2/2

There is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. In addition, there is evidence that all agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include clear audit rights and termination rights to detect, control and prevent breaches.

2/2

There is evidence that incentive structures for agents are explicitly highlighted and addressed as a factor in bribery and corruption risk. The company commits to only paying agents into local bank accounts, and indicates that its payments reflect the value they create for the company.

However, the company receives a score of ‘1’ because there is no evidence that the company’s approach to agent incentives includes a clear threshold on sales-based commissions to agents so that payments do not exceed a proportion of the net fee to the agent. There is also no evidence that remuneration to agents is paid in staged payments over the course of their contract, based on clear milestones.

1/2

There is evidence that the company publishes an aggregate figure of the number of marketing consultants or agents that it currently employs. However, the company receives a score of ‘1’ because it does not provide further information on its agents, nor is there evidence that this list is published or updated on an annual basis.

0/2

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

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering and while operating in a joint venture. There is evidence that the company conducts enhanced due diligence for joint ventures operating in high risk countries or with high risk partners.

However, it is not clear that the company’s due diligence includes checks on the ultimate beneficial ownership of the partner company. In addition, there is evidence that its due diligence is only conducted before engaging joint ventures and is not repeated at least every two years.

2/2

Based on publicly available information, there is evidence that the company requires its joint ventures to maintain its own ethics and compliance program and requires anti-bribery and corruption clauses in its contracts with joint venture partners. The company states that it includes audit and termination rights in its contracts with business partners.

0/2

There is no publicly available evidence that the company commits to taking an active role in the prevention of bribery and corruption in all of its joint ventures.

Textron Inc. 1/2

Based on publicly available information, there is evidence that the company has a policy covering the use of agents. There is evidence that the company provides limited details of the controls it has in place to mitigate the risks associated with agents.

However, the company receives a score of ‘1’ because there is no evidence that it makes a clear commitment to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function, nor that it provides details of the corruption risks associated with the use of agents. There is also no evidence that the company specifies that its policy covering agents applies to subsidiaries and joint ventures.

0/2

In publicly available evidence, the company states that it conducts risk-based due diligence on agents. However, the information provided is insufficiently detailed to satisfy the requirements for score ‘1’.

0/2

Based on publicly available information, there is no evidence that the company aims to establish the ultimate beneficial ownership of its agents and intermediaries.

0/2

Based on publicly available information, there is evidence that the company requires agents to adhere to its Code of Conduct for Suppliers and Other Business Partners. There is also evidence that the company includes anti-bribery and corruption compliance clauses in its contracts with these entities.

However, the company receives a score of ‘0’ because there is no evidence that it includes audit and termination rights in its contracts with agents and intermediaries.

0/2

Based on publicly available information, there is no evidence that the company recognises incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or and on behalf of the company.

0/2

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

0/2

In publicly available evidence, the company states that it conducts risk-based due diligence on joint venture partners. However, the information provided is insufficiently detailed to satisfy the requirements for score ‘1’.

1/2

Based on publicly available information, there is evidence that the company requires joint venture partners to comply with its Business Conduct Guidelines. There is also evidence that the company requires anti-bribery and corruption clauses in its contracts with joint venture partners.

However, the company scores ‘1’ as it is unclear based on publicly available information how it ensures that these standards are implemented by joint venture partners in practice. There is also no evidence that the company includes audit and termination rights in its contracts with joint venture partners.

0/2

Based on publicly available information, there is no evidence that the company makes a clear commitment to take an active role in preventing bribery and corruption in all of its joint ventures.

Thales Group 1/2
1/2
0/2
0/2
1/2
0/2
0/2
1/2
0/2
1/2
The Aerospace Corporation NA

There is no readily available evidence that the organisation engages agents in the conduct of business due to its nature as a non-profit.

NA

There is no readily available evidence that the organisation engages agents in the conduct of business due to its nature as a non-profit.

NA

There is no readily available evidence that the organisation engages agents in the conduct of business due to its nature as a non-profit.

NA

There is no readily available evidence that the organisation engages agents in the conduct of business due to its nature as a non-profit.

NA

There is no readily available evidence that the organisation engages agents in the conduct of business due to its nature as a non-profit.

NA

There is no readily available evidence that the organisation engages agents in the conduct of business due to its nature as a non-profit.

NA

There is no readily available evidence that the organisation engages agents in the conduct of business due to its nature as a non-profit.

0/2

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

0/2

There is no evidence that the organisation commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, and it does not require anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no evidence that the organisation commits to take an active role in preventing bribery and corruption in all of its joint ventures.

ThyssenKrupp AG 2/2

There is evidence that the company has a policy covering the use of agents, which highlights the corruption risks associated with agents and provides details of controls to mitigate these risks, including due diligence on agents. The company also states that its policy applies to all companies in its corporate group, including subsidiaries and joint ventures. The company indicates that it commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function.

2/2

There is some evidence that the company conducts due diligence on its agents, and enhanced due diligence on highest-risk agents. The company commits to termination of the relationship if the highlighted risks cannot be mitigated. The company states that it conducts due diligence both before establishing a relationship with a new agent, and when re-engaging with an existing agent. Additionally, the company states that due diligence on all agents is repeated every two years.

2/2

There is evidence that the company has formal procedures to establish the beneficial ownership of business partners before forming a relationship with a new agent, and when re-engaging with an existing agent. The company commits to not engaging with an agent if there are concerns around beneficial ownership. There is some evidence that the company independently verifies the beneficial ownership of the highest-risk agents. The company additionally states that the due diligence process for all agents, including checks on ultimate beneficial ownership, is repeated every two years.

0/2

There is evidence that the company’s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. All agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include audit rights.

However, the company does not explicitly state that it includes termination rights in its contracts with agents and therefore receives a score of ‘0’.

2/2

There is evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. There is evidence the company has a threshold regarding maximum commission payments to agents and requires compensation to be proportionate and reasonable in relation to the activities carried out. The company states that it prohibits cash payments and will only make payments into local bank accounts, apart from in exceptional circumstances where the agent provides sufficient justification.

0/2

The company states that it publishes its business relationships with agents only in case of mutual agreement. However, there is no evidence that the company has published any details of the agents currently contracted to act for or and on behalf of the company.

0/2

The company publishes limited information in relation to certain investigations involving agents. However, there is no evidence the company publishes data on all ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving agents.

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering and while operating in a joint venture. There is also evidence that the company’s due diligence process includes checks on ultimate beneficial ownership.

However, there is no evidence that joint ventures operating in high-risk markets or with high-risk partners, such as state-owned enterprises, are subject to enhanced due diligence. There is no evidence that due diligence is repeated at least every two years or when there is a significant change in the business relationship

1/2

There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies in all of its joint ventures. The company states that it ensures robust policies and procedures are implemented in all joint ventures, by incorporating the venture into its own anti-corruption programme if the company is the majority shareholder. Otherwise the company states that it works jointly to develop a programme based on the same anti-corruption principles. The company states that all joint venture contracts contain anti-corruption clauses and that audit and termination rights are applied in joint venture agreements if it is deemed necessary.

However, the company receives a score of ‘1’ because it does not include audit and termination rights as standard in all of its joint venture partnerships.

2/2

The company explicitly commits to take an active role in preventing bribery and corruption in all of its joint ventures. There is clear evidence to support the company's commitment through practical examples.

Toshiba Infrastructure Systems & Solutions Corporation 0/2

Based on publicly available information, there is no clear evidence that the company has a policy on the use of agents that recognises the corruption risks associated with their use or provides details of specific controls to mitigate these risks. The company indicates that employees must ensure that agents and intermediaries observe all applicable laws and regulations, but it does not provide further information on the procedures that it has in place to ensure such compliance.

0/2

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

0/2

There is no publicly available evidence that the company aims to establish the ultimate beneficial ownership of its agents and intermediaries.

0/2

There is publicly available evidence that the company’s anti-bribery and corruption policy applies to its agents and intermediaries. However, the company receives a score of ‘0’ because there is no further information to indicate that it includes anti-bribery and corruption clauses in its contracts with agents and intermediaries, nor that such clauses stipulate audit and termination rights.

1/2

Based on publicly available information, there is some evidence that the company considers incentive structures and compensation for agents as a factor in bribery and corruption risk. The company indicates that compensation must be reasonable, specified in advance and in compliance with all applicable laws and regulations.

However, the company receives a score of ‘1’ because there is no evidence that it imposes a threshold on the payment of sales commissions to agents, nor that remuneration is paid in stage payments or into local bank accounts.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

0/2

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

0/2

There is no evidence that the company publicly commits to establishing anti-bribery and corruption policies or procedures in its joint ventures, nor that it requires anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no evidence that the company commits to taking an active role in preventing bribery and corruption in all of its joint ventures.

Triumph Group Inc. 0/2

There is some evidence that the company recognises the risks associated with agents. However, based on publicly available information, there is no evidence that the company has a policy covering the use of agents.

0/2

There is no publicly available evidence to indicate that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no publicly available evidence to indicate that the company aims to establish the beneficial ownership of its agents.

0/2

There is no publicly available evidence to indicate that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no mention in publicly available evidence of incentive structures as a risk factor in agent behaviour.

0/2

There is no publicly available evidence to indicate that the company publishes any details of the agents currently contracted to act for or on behalf of the company.

0/2

There is no publicly available evidence to indicate that the company publishes any data on ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving agents.

0/2

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

0/2

There is no publicly available evidence to indicate that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures. There is also no evidence that it requires anti-bribery and corruption clauses in its contracts with joint venture partners.

0/2

There is no publicly available evidence to indicate that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Turkish Aerospace Industries Inc. 0/2

There is no evidence that the company has a policy covering the use of agents.

0/2

There is no evidence that the company states that it conducts anti-bribery and corruption due diligence on its agents or intermediaries.

0/2

There is no evidence that the company aims to establish the beneficial ownership of its agents.

0/2

There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.

0/2

There is no evidence that the company mentions incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company pubilshes any details of the agents currently contracted to act for or on behalf of the company.

0/2

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

0/2

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

0/2

There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in its joint ventures.

Ukroboronprom 0/2

There is no publicly available evidence that the company has a policy covering the use of agents or intermediaries.

1/2

There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with third parties.

However, the company states that it conducts due diligence on third parties, without specifying agents or high risk intermediaries. Additionally, it is not clear that agents and highest risk intermediaries are subject to enhanced due diligence. There is also no evidence that due diligence is repeated at least every two years or when there is a significant change in the business relationship.

0/2

There is evidence that the company aims to independently verify the beneficial ownership of third parties through the use of corporate registries and databases. The company conducts these checks prior to engaging. However, there is no evidence due diligence is repeated at least every two years or when there is a significant change in the business relationship.

The company scores ‘0’ as it does not explicitly state that it would be willing to not engage or terminate an agent relationship in the event that beneficial ownership cannot be established.

0/2

The company states that it may include anti-corruption clauses in contracts with third parties, without mentioning agents and intermediaries specifically. There is no evidence that this applies to all agent agreements nor that the company includes audit and termination rights in its contracts with these entities.

0/2

The company makes no mention of incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

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

0/2

There is evidence the company conducts due diligence on its business partners but in publicly available evidence it makes no specific reference to joint ventures.

0/2

The company states that it may include anti-corruption clauses in contracts concluded with third parties, without specifying joint venture partners. There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.

0/2

There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.

Ultra Electronics Holdings PLC 1/2

Based on publicly available information, there is evidence that the company has a policy covering the use of agents. The company provides some information on controls to mitigate corruption risks associated with the use of agents.

However, the company receives a score of ‘1’ because there is no evidence that it clearly commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function.

2/2

Based on publicly available information, there is evidence that the company has procedures in place to conduct risk-based anti-bribery and corruption due diligence on agents. The company indicates that due diligence on agents is risk based and repeated at least every two years. The company’s bid approval process includes an assessment of anti-bribery compliance risks.

0/2

There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents as part of its due diligence.

0/2

There is evidence that the company’s anti-bribery and corruption policy applies to agents. There is also evidence that the company’s agreements with third parties contain anti-bribery provisions which provide for termination in the event of policy breaches.

However, the company receives a score of ‘0’ because there is no evidence that it includes audit rights in its contracts with agents.

0/2

There is no publicly available evidence that the company addresses incentive structures as a risk factor in agent behaviour.

0/2

There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.

0/2

There is no evidence that the company publishes any data on ethical or bribery and corruption related investigations, incidents or disciplinary actions involving agents.

1/2

Based on publicly available information, there is some evidence that the company has procedures in place to conduct risk-based anti-bribery and corruption due diligence on its joint venture partners. The company states that due diligence is repeated on all third parties every two years, although it does not mention joint venture partners specifically. There is also evidence that higher risk partners are subject to enhanced due diligence.

The company receives a score of ‘1’ because there is no evidence that the due diligence process includes checks on the ultimate beneficial ownership of the partner company.

0/2

There is evidence tha