5. Customer Engagement

There is no evidence that the company has a policy on corporate political contributions.

There is no evidence that the company publishes any details of its political contributions.

There is no evidence that the company has a policy or procedure covering charitable donations and sponsorships.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy or procedure on gifts or hospitality.

Based on publicly available information, there is evidence that the company has a policy that prohibits corporate political contributions to any parties, candidates or campaigns. The company indicates that this policy extends to any payments on its behalf, both financial and in-kind. In addition, there is evidence that the company is associated with a Political Action Committee (PAC) in the United States. The company states that its PAC is managed by the Office of Government Relations and that all relevant activities are overseen by a committee composed of senior leaders from across the U.S. business.

Since it is associated with a PAC in the United States, the company receives a score of ‘0’ in line with the scoring criteira.

The company publishes some information on its political expenditures, including a list of all membership dues paid to trade associations in the United States. However, the company receives a score of ‘0’ because there is no evidence that it publishes details of the donations made through any Political Action Committee (PAC).

It is noted that the company states that its PAC contributions are published on the United States Federal Election Commission (FEC) website, however there is no direct link on the company’s website to relevant disclosures.

There is evidence that the company has a policy and procedure covering both charitable donations and sponsorships. There is also evidence that the company discloses the causes it supports and provides summaries of its financial donations to charitable and social causes.

However, the company receives a score of ‘0’ because there is no evidence that its policy incorporates anti-corruption controls to ensure that donations and sponsorships are not used as vehicles for bribery and corruption, such as specifying criteria for donations or due diligence on recipients. There is also no evidence that the company provides full details of its charitable donations, such as the name, amount and location of each recipient entity.

There is evidence that the company has a policy on lobbying, which applies to all employees, board members and third parties engaged to work on its behalf. There is also evidence that the company’s Audit Committee, senior management and Office of Government Relations provide oversight of the company’s lobbying activities.

However, the company receives a score of ‘1’ because the company’s policy does not define responsible lobbying, and it does not mention specific standards of conduct or oversight mechanisms that apply to all lobbyists.

It is noted that the company makes reference to a policy entitled Contacts with Public Officials, but this document is not publicly available.

The company publishes some information on its lobbying topics and activities in the United States by making its quarterly federal lobbying reports publicly available via a direct link on its website.

However, the company does not provide details about its broader public policy aims or positions. The company also does not publish any information about its lobbying activities outside of the United States, nor does it indicate that it does not engage in lobbying elsewhere.

There is evidence that the company publishes summary information of its lobbying expenditure in the United States, alongside a breakdown of how the total expenditure was calculated, on an annual basis. In addition, the company’s website includes a direct link to its federal quarterly lobbing reports, which include a lobbying expenditure figure.

However, this expenditure data is not broken down into internal, external or association lobbyists and does not include an explanation of how these figures have been calculated. Furthermore, there is no evidence that the company publishes its lobbying expenditure for other jurisdictions around the world in which it conducts lobbying, nor a statement that it does not lobby outside of the United States.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality to ensure that such promotional expenses are not used as vehicles for bribery and corruption, which includes approval procedures. There is also evidence that the company specifically addresses the risks associated with gifts and hospitality given to/received from domestic and foreign public officials.

However, the company receives a score of ‘1 because it does not publicly indicate that it implements financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

It is noted that the company appears to make reference to a ‘Gifts, Meals, Entertainment and Travel’ policy which may contain more information, but this is not publicly available.

The company allows political contributions, and therefore receives a score of ‘0’.

The company does not disclose details of its political contributions on its website.

There is evidence that the company has a policy covering both charitable donations and sponsorships. It states that it conducts due diligence on recipients and refers to a group approvals process.

However, the company receives a score of ‘1’ because it is not explicitly stated that there is a requirement for senior sign-off. Also, the company does not specify criteria for donations or publish full details of its donations.

There is no evidence that the company has a policy and/or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure on its website.

There is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. This addresses the risks associated with gifts and hospitality to public officials. There is also evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process. There is also evidence that the company’s policy includes monetary limits and approval procedures.

Based on publicly available information, there is evidence that the company has a policy on corporate political donations. The company indicates that political donations, whether made directly or indirectly, are prohibited unless clearly delegated and approved in writing. In cases where donations may be authorised, the company states that they must be approved by its Vice President of Communications. In addition, there is evidence that the company is associated with a Political Action Committee (PAC) in the United States, which is overseen by a committee and board of directors.

Since the company does not prohibit political contributions and is associated with a PAC, it receives a score of ‘0’ in line with the scoring criteria.

There is no evidence that the company publishes details of political contributions made on its website.

There is evidence that the company has a policy regarding charitable donations to prevent donations being used for undue influence or corrupt intent. However, the company does not have publicly available policy regarding sponsorships; although its foundation states that it does not fund sponsorships, it is not clear whether this is a company-wide policy.

There is no evidence that the company has a publicly available policy covering responsible lobbying.

There is no evidence that the company publishes any information on its website regarding its lobbying aims, topics or activities.

There is evidence that the company provides some details on its lobbying expenditure. The company publishes a high-level figure on its lobbying costs as part of its Annual Report, which appears to indicate that the company did not incur any such costs in the most recently reported financial year.

However, the company does not publish further information to explain how this figure was calculated and there is no evidence that the company provides a breakdown of these costs by corporate entity, geography, or internal lobbyists versus external lobbyists versus association lobbying. There is also no publicly available evidence to confirm that the company has not engaged in any lobbying activities in the most recently reported financial year, either directly or indirectly, in any jurisdictions.

There is evidence that the company has a policy on gifts and hospitality, which includes financial thresholds and approval processes for different types of gift and promotional expenses. The policy addresses the risks associated with gifts and hospitality given to and/or received from government personnel, by specifying a different financial threshold and requiring that these be approved in advance by ethics and compliance. The policy also includes several examples of potential red flags around the giving and receipt of gifts and hospitality.

However, there is no evidence to confirm that gifts and hospitality above a certain threshold are recorded in a dedicated register or central database that is accessible to those responsible for oversight of the process.

There is publicly available evidence to indicate that the company has a policy on corporate political donations, where by such contributions are permitted subject to prior review and approval.

There is no evidence that the company discloses details of its political contributions.

There is evidence that the company has a policy covering both charitable donations and sponsorships. This policy specifies criteria for the type of donations and states that authorisation is required for donations over a certain threshold. Examples of charitable donations and sponsorships are mentioned on the company’s website and in the Annual Report. However, the company does not publish full details of the donations made by the company, such as the recipient, amount, country and corporate entity that made the payment. The relationship between the company’s Sponsorships, Donations and Corporate Memberships Directive and the activities of the Airbus Foundation is also unclear.

There is some publicly available evidence that the company has a policy on lobbying. This policy requires due diligence checks on lobbyists and compliance with all relevant laws, and states that lobbying is overseen jointly by the Ethics and Compliance and Government Relations teams. However, these provisions are not sufficient to constitute a responsible lobbying policy. Although the company mentions an internal Lobbyist & Special Advisors Due Diligence Directive, there is no publicly available evidence of guidelines to establish certain standards of conduct for lobbyists, beyond a broad commitment to integrity.

The company publishes a list of the topics on which it lobbies, including a description of its core positions, their importance or relevance to the company and stakeholders, and the activities it carries out. The company provides specific aims and topics for in the main jurisdictions in which it lobbies.

There is no evidence that the company publishes details of its global lobbying expenditure.

There is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. The policy addresses the risks associated with gifts and hospitality given to and received from domestic or foreign government officials. The policy also indicates that there are specific financial limits and different approval procedures for different types of promotional expenses. However, there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

There is no evidence that the company has a policy to regulate corporate political contributions.

There is no evidence that the company publishes any details of its corporate political contributions.

There is no evidence that the company has a policy and/or procedure covering both charitable donations and sponsorships.

There is no evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy on gifts or hospitality.

There is no evidence that the company has no policy on corporate political contributions.

There is no evidence that the company discloses details of its political contributions.

There is no evidence that the company has a policy and/or procedure covering both charitable donations and sponsorships.

There is no evidence that the company has a policy or procedure on lobbying.

The company does not publish any information relating to its lobbying aims, topics or activities.

The company does not provide any details about its global lobbying expenditure.

There is no evidence that the company has a policy or procedure on gifts or hospitality.

There is no evidence that the company has a policy on corporate political contributions.

There is no evidence that the company discloses details of its political contributions.

There is no evidence that the company has a policy or procedure covering charitable donations and sponsorships.

There is no evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy or procedure on gifts or hospitality.

The company publishes a clear statement that it prohibits corporate political contributions, whether made directly or indirectly. There is evidence that this applies to all employees of the company including directors, third parties, suppliers and joint venture partners.

There is evidence that the company prohibits corporate political contributions so the company is exempted from scoring on this question.

Based on publicly available information, there is evidence that the company has procedures covering both charitable donations and sponsorships. There is evidence that these include measures to ensure that donations are not used as vehicles for bribery and corruption, for example, by specifying criteria for donations and a requirement for the board to sign-off on donations. In addition, the company publishes some details of donations made on an annual basis.

However, the company receives a score of ‘1’ because it does not disclose full details of charitable donations made, such as the entity which made the donation or details of recipient organisations.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any information on its global lobbying expenditure.

Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality. There is some evidence to suggest that the company records gifts in a register.

However, the company receives a score of ‘1’ because the policy does not specify financial or proportional limits or different approval procedures for different types of promotional expenses, nor does it specifically address the risks associated with gifts and hospitality given to/received from public officials.

There is no evidence that the company has a policy on corporate political contributions.

Based on publicly available information, there is no evidence that the company has a policy to regulate corporate political contributions. The company indicates that employees engaged in political activities must receive approval from the company’s leadership, but there is no evidence that the company has a formal policy in place at corporate level.

There is no evidence that the company has a policy or procedure covering charitable donations and sponsorships, The company publishes some information on its charitable activities but does not publish any details of specific procedures for such activities to ensure that such donations are not used as vehicles for bribery or corruption. Although the company provides some information on the charitable causes it supports on its website, there is no evidence that it publishes full details of its donations – including details of the recipient, amount, country of recipient and which corporate entity made the payment – on at least an annual basis.

Based on publicly available information, there is no evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is some evidence that the company has a policy on the giving and receipt of gifts and hospitality, which specifies senior manager approval for certain proportionate gifts.

However, the company receives a score of ‘1’ because there is no evidence that the policy specifies financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no evidence that the policy addresses the risks associated with gifts and hospitality given to or received from domestic or foreign public officials. There is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.

Based on publicly available information, there is no evidence that the company has a policy or procedure to regulate corporate political contributions.

There is no evidence that the company publishes details of its political contributions.

The company discloses information on its charitable activities but receives a score of ‘0’ because there is no clear evidence that it has policies and procedures to protect against charitable donations being used as vehicles for bribery or corruption. There is no evidence that the company has procedures in place to stipulate criteria for donations or oversight mechanisms for any charitable expenditures.

There is no evidence that the company has a policy and/or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes details of its global lobbying expenditure.

There is no evidence that the company has a policy or procedure on gifts and hospitality, to ensure that such promotional expenses are not used as vehicles for corruption. The company publishes a document which states that Chinese Communist Party members will face punishment for giving and/or receiving lavish or inappropriate gifts or cash; however, the company receives a score of ‘0’ because there is no clear evidence that these principles are incorporated into the company’s own anti-corruption policies or apply to all employees across the company.

Based on publicly available information, there is evidence that the company has a policy that clearly all corporate prohibits political donations, whether made directly or indirectly. The company that this police includes both financial expenditures and in-kind donations to political parties, campaigns or candidates. There is evidence that any requests to deviate from this policy would be handled by the Group CEO, and indicates that it has not made any such donations in the past two years.

The company publishes a clear statement that it does not make political contributions, and therefore it is exempt from scoring on this question.

Based on publicly available information, there is evidence the company has a policy covering charitable donations and sponsorships, to ensure that such donations are not used as vehicles for bribery and corruption. There is evidence that these procedures include measures to ensure this, by specifying criteria for donations, procedures for senior sign-off and due diligence on donation recipients.

However, the company receives a score of ‘1’ because there is no evidence that it publishes details of its charitable donations and sponsorships made in the most recently reported financial year, such as the recipient, amount, country of recipient and which corporate entity made the payment.

Based on publicly available information, there is evidence that the company has a policy that defines lobbying and outlines certain practices which constitute legitimate lobbying activity. The company indicates that all lobbying activity undertaken by the company must receive the prior approval of the Group CEO.

However, the company receives a score of ‘1’ because there is no evidence that its policy describes certain standards of conduct or specific oversight mechanisms that apply to all types of lobbyists. The company does not publish further information on controls to prevent and reduce corruption risks in lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details of its global lobbying expenditure.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, which stipulates procedures to ensure that such promotional expenses are bona fide and not used for bribery. There is evidence that the company requires all business units to establish specific financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The company also explicitly addresses the risks associated with gifts and hospitality given to and/or received from public officials. There is evidence that all gifts and hospitality are recorded centrally and this information is held by the Group General Counsel.

Based on publicly available information, there is evidence that the company has a policy which prohibits corporate political contributions, whether by the company itself or by any other entity or individual acting on its behalf. However, there is evidence that the company has a Political Action Committee (PAC) in the United States, so the company therefore receives a score of ‘0’ as per the scoring criteria.

There is evidence to indicate that the company did not make any political contributions in 2018. Since this evidence is included in the company’s Annual Report, it is under that the data is updated on an annual basis.

However, the company receives a score of ‘0’ because it has a Political Action Committee (PAC) in the United States and there is no evidence that it publishes any information in relation to the PAC’s disbursements on its website or that it provides a direct link to its official disclosures.

Based on publicly available information, there is evidence that the company has a policy covering both charitable donations and sponsorships to ensure that such donations are not used as vehicles for bribery and corruption. There is evidence that company’s policies stipulate measures to ensure this, including sign-off procedures and a requirement to record the donation.

However, although the company publishes the total amount of contributions to charities and not-for-profit organisations made by the company in 2018, it does not publish full details of all the charitable donations made, such as details of the recipients, amounts, country of recipients and which corporate entity made the payments.

Based on publicly available information, there is evidence that the company has a policy that defines lobbying and that clearly outlines the values and behaviours that constitute ‘responsible’ lobbying. There is evidence that the company acknowledges the corruption risks associated with lobbying and it provides clear guidelines on the behaviours that are acceptable and unacceptable for individuals engaged in lobbying activities. The company’s policy applies to all employees, board members and third parties engaged in lobbying on the company’s behalf.

There is evidence that the company publishes a description of the topics on which it lobbies and the type of activities that it conducts to advance these aims. The company provides details of its core positions and their relevance to its business development plan, and there is evidence to indicate that these aims apply to the company’s lobbying activities in multiple jurisdictions around the world. The extent of the evidence provided is deemed sufficient for a score of ‘2’, though it is noted that the company appears to produce an annual report with further details on its lobbying activities which is not available in the public domain.

There is no evidence that the company publishes details about its global lobbying expenditure on its website, either directly or via a link to official filing reports.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with clear procedures designed to ensure that such promotional expenses are not used as vehicles for bribery or corruption. There is evidence that the company’s policy establishes financial limits, along with an approval procedure, for promotional expenses. The company’s policy also explicitly addresses the risks associated with gifts and hospitality given to and received from domestic and foreign public officials, by indicating that specific rules and regulations may apply. The company's policy includes a statement that all gifts and hospitality above certain thresholds are recorded in a dedicated register.

The company operates a political action committee and therefore receives a score of ‘0’.

The company discloses the political candidates that it supports. There is evidence that this information is updated annually.

There is no clear evidence that the company has a policy and/or procedure covering both charitable donations and sponsorships. The company also does not publish detailed data on its charitable contributions.

There is no evidence that the company has a policy and/or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides details about its global lobbying expenditure.

There is evidence that the company has a policy and/or procedure on the giving and receipt of gifts and hospitality. The policy covers gifts and hospitality given to and received from government officials.

However, the company receives a score of ‘1’ because the policy does not specify financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

There is no readily available evidence that the institute is able to make political contributions due to its nature as a non-profit, tax-exempt organisation in the United States of America.

There is no readily available evidence that the institute is able to make political contributions due to its nature as a non-profit, tax-exempt organisation in the United States of America.

There is no evidence that the institute has a policy or procedure to address the potential bribery and corruption risks arising from charitable donations and sponsorships. The institute publishes some information about type of organisations that it sponsors and provides an estimate figure of the amount it donates annually, but this information is insufficiently detailed to receive a score of ‘1’.

There is no evidence that the institute has a policy or procedure on lobbying.

There is no evidence that the institute publishes any information on its lobbying aims, topics or activities.

There is no evidence that the institute provides any details about its global lobbying expenditure.

There is some evidence that the institute recognises the potential risks posed by gifts and hospitality by listing it as a reporting category on the EthicsPoint portal and providing a broad definition. However, the institute receives a score of ‘0’ because there is no evidence that the company has a formal policy on the giving and receiving of gifts and hospitality to ensure that such promotional expenses are not used as vehicles for bribery and corruption.

There is evidence that the company has a policy on political contributions, which states that such donations are generally prohibited but permissible in certain circumstances with appropriate authorisation and sign-off. There is also evidence that the company is associated with a Political Action Committee (PAC) in the United States.

There is evidence that the company publishes details of its political contributions in the United States by including direct links on its website to official reporting documents and to the Open Secrets website. There is evidence that this data is updated and published on at least an annual basis. These details include the recipient and amount, and whether the contribution was made by an individual or a Political Action Committee (PAC).

There is evidence that the company has a clear policy covering both charitable donations and sponsorships, whether made directly or through corporate foundations, to ensure that such donations are not used as vehicles for bribery and corruption. There is evidence that this policy include measures to ensure this, such as specifying criteria for donations, procedures for senior sign-off, and due diligence on recipients.

However, while the company publishes some details of the company’s charitable activities, there is insufficient evidence that it publishes details of all donations as described in score ‘2’. There is also no evidence that the company updates this information on at least an annual basis.

It is noted that the company has an internal policy – Bechtel Policy 404, Corporate Contributions and Memberships – but it does not appear to be publicly accessible.

Based on publicly available information, there is evidence that the company has a policy on lobbying. There is evidence that the policy applies company-wide to all employees, board members and third parties engaged in lobbying activities on the company’s behalf. There is evidence of specific controls and oversight mechanisms that apply to all types of lobbyists, which are ensured through clear terms in all contractual agreements. The company provides guidelines on the types of behaviours that are acceptable by requiring that lobbyists abide by its Code of Conduct, Vision, Values and Covenants document, as well as all appropriate regulations.

The company publishes some information on its lobbying topics and activities in the United States by providing a direct link to its quarterly federal lobbying reports on its website. These disclosures provide high-level information on the topics on which the comany conducts lobbying activities.

However, the company receives a score of ’1’ because it does not provide details about its broader public policy aims or positions. The company also does not publish any information about its lobbying activities outside of the United States.

There is evidence that the company publishes some details of its lobbying expenditure, by providing direct links on its website to details of all of its lobbying expenditure, up to the most recently reported financial year. This expenditure data is broken down by corporate entity, geography, and internal, external and association lobbying.

However, the company receives a score of ‘1’ because the data provided only accounts for company’s lobbying activities in the United States and therefore it is not clear that this covers all of the company’s lobbying activities in all applicable jurisdictions.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality with clear procedures designed to ensure that such promotional expenses are not used as vehicles for bribery and corruption. There is evidence that the policy specifies financial and proportional limits for different types of promotional expenses and addresses the risks associated with gifts and hospitality given to public officials. There is evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.

There is no publicly available evidence that the company has a policy on corporate political contributions.

There is no evidence that the company publishes any details of its political contributions.

There is no evidence that the company has a policy or procedure covering charitable donations or sponsorships.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

There is no publicly available evidence that the company has a policy on gifts or hospitality.

Based on publicly available information, there is no evidence that the company has a policy to prohibit or regulate corporate political contributions. The company’s publicly available information indicates that political contributions may be permitted in certain unspecified circumstances, and notes that such donations are not considered a CSR activity.

There is no evidence that the company publishes any details of its political contributions.

There is evidence that the company has policies and procedures covering both charitable donations and sponsorships. This policy specifies criteria for the types of causes that may receive donations and there is evidence that the company has procedures in place to monitor projects. The company also publishes full details of all charitable donations made, including details of the recipient, amount and location. The data is included in the company’s Annual Report, and is therefore updated and released on an annual basis.

However, the company receives a score of ‘1’ because there is no clear evidence that the company addresses and has specific measures in place to ensure that donations are not used as vehicles for bribery and corruption.

Based on publicly available information, there is no evidence that the company has a policy on responsible lobbying. The company states in its annual report that any businesses involved in influencing public policy must behave responsibly, however the company does not provide further details on the specific controls or oversight mechanisms in place to ensure this.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

Based on publicly available information, there is some evidence that the company addresses gifts and hospitality. The company’s policy indicates that board members and senior individuals must not solicit gifts or hospitality in order to influence business.

However, the company receives a score of ‘0’ because there is no evidence that the company’s policy addresses the potential bribery and corruption risks associated with gifts and hospitality. There is also no evidence that the company’s policy includes specific controls or measures to mitigate these risks.

The company publishes a clear statement that it does not make any political contributions under any circumstances to any party, candidate or campaign.

The company publishes a clear statement that it does not make any political contributions, and is therefore exempt from scoring on this question.

There is no evidence that the company has a policy or procedure covering charitable donations and sponsorships. There is some publicly available evidence that the company undertakes CSR activities and aims to ensure that they are conducted in an ethical manner, however this information is insufficiently detailed to receive a score of ‘1’.

There is no publicly available evidence that the company has a policy or procedure on lobbying.

There is no publicly available evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details about its global lobbying expenditure.

Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts. The company’s Code of Business Conduct and Ethics for Board Members and Senior Management specifies a financial limit for gifts for special events.

However, the company receives a score of ‘1’ because its policy does not address the risks associated with gifts and hospitality given to/received from domestic or foreign public officials. In addition, there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.

Based on publicly available information, there is evidence that the company has a policy on corporate political contributions. The company’s policy indicates that it may make political contributions when approved by the company’s Executive Vice President, Government Operations and other relevant senior managers from the Government Operations office. In addition, there is evidence that that the company is associated with a Political Action Committee (PAC) in the United States, which is overseen and managed by an advisory committee.

Since the company does not prohibit political donations and is associated with a PAC, it receives a score of ‘0’ in line with the scoring criteria.

The company publishes a statement that it has not made any corporate political corporate contributions to state or local candidates since 2010. The company also indicates that it has not contributed to ballot initiatives since 2011, nor to section 527 entities since 2012. In addition, the company provides a direct link to the United States Federal Election Commission website where full details of its Political Action Committee disbursements can be found.

Based on publicly available information, there is evidence that the company has a policy on charitable donations and sponsorships, which covers both financial and in-kind donations. The company states that all donations must follow ethical guidelines and must be overseen by the Law Department. There is some evidence that the company has procedures in place to conduct due diligence on recipients..

Although the company publishes some details of the recipients of its grants, the company receives a score of ‘1’ because there is no evidence that it publish full details of all donations made, such as the country and amount given to each recipient, as well as which corporate entity made the payment, for both financial and in-kind donations.

Based on publicly available information, there is evidence that the company has a policy on lobbying, which includes specific controls and oversight provisions to regulate the activities of lobbyists. The company states that it provides training on responsible lobbying behaviours and indicates that all lobbying activities are conducted in accordance with its high standards of ethical conduct. The company also states that the Government Operations department is responsible for oversight of all lobbying and political activities.

However, the company receives a score of ‘1’ because it does not provide further information on the standards and types of behaviours that constitute ‘responsible’ lobbying.

The company publishes some details of the topics on which it lobbies on its website and in more detail in the Lobbying Disclosure Reports which are available to the United States Congress and Senate. These reports are made available via a direct link on the company’s website and they include information on the specific legislation on which the company has lobbied in the United States.

However, the company receives a score of ‘1’ because it does not provide further details of its lobbying activities, such as a description of its core positions and their importance or relevance to the company and stakeholders. In addition, the information provided only relates to lobbying activities in the jurisdiction in which the company is headquartered (the United States); there is no evidence that the company discloses this information for other jurisdictions, nor does it publish a statement that it does not conduct lobbying activities outside of the United States.

The company publishes some details of its lobbying expenditure in its annual Proxy Statement, as well as in its Lobbying Disclosure Reports for the United States Congress and Senate. These reports are made available via a direct link on the company’s website and include information on total lobbying expenditure relating to activities in the United States.

However, the company receives a score of ‘1’ because it does not provide further details of its lobbying expenditure, such as a breakdown in expenditure between internal, external and association lobbying, and an explanation of how the figures in the data have been calculated. Furthermore, the information provided only relates to lobbying activities in the jurisdiction in which the company is headquartered (the United States); there is no evidence that the company discloses this information for other jurisdictions, nor does it publish a statement that it does not conduct lobbying activities outside of the United States.

There is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality, which addresses the risks associated with gifts and hospitality given to public officials. The company states that certain thresholds are in place for specific types of gifts and hospitality, and that it has a procedure in place which stipulates prior approval from the Law Department.

However, the company receives a score of ‘1’ because there is no evidence that gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process. It is noted that the company has separate policies on accepting and offering promotional expenses which may outline further control measures, but this does not appear to be publicly available.

There is evidence that the company does not make corporate contributions to support political organisations, and this policy applies company-wide to all employees. There is evidence that the company is associated with a Political Action Committee (PAC) in the United States, which is managed and overseen by a board of directors.

Since the company is associated with a PAC in the United States, it receives a score of ‘0’ in line with the scoring criteria.

There is evidence that the company publishes information on the donations made through its Political Action Committee (PAC) in the United States, by providing a direct link to the Federal Election Commission website where full details of such expenditure can be found. There is evidence that the company does not make corporate political contributions through direct expenditures.

There is some evidence that the company has policies covering charitable donations and sponsorships, which specifies criteria for donations. There is also evidence that the company discloses some summary information on its total charitable contributions, specifically those made through a related foundation.

However, the company receives a score of ‘1’ because there is no publicly available evidence that its policy has specific controls in place to reduce the risk of bribery and corruption in its charitable activities, such as procedures for senior sign-off or due diligence on recipients. There is also no publicly available evidence that the company publishes full details of its charitable contributions and sponsorships, such as details of the recipient, amount, country of recipient and which corporate entity made the payment.

There is evidence that the company has a policy and procedure on lobbying, which applies company-wide to all employees, board members and third parties engaged as lobbyists on the company’s behalf. The company's policy includes procedures to identify any conflicts of interest associated with engagements in the political process and this approach is outlined in the company’s Code of Business Ethics and Conduct which describes certain standards of conduct for all employees and third parties.

However, it is not clear from publicly available information that the company’s approach to lobbying includes further details such as specific guidelines or standards of conduct that apply to all types of lobbyists (internal, external and association) or clear oversight mechanisms to monitor activities. It is noted that the company references a separate policy document which may contain more information on its lobbying practices, but this does not appear to be publicly available.

There is evidence that the company publishes some information on its lobbying topics and activities in the United States, by making its quarterly federal lobbying reports publicly available via a direct link on its website.

However, there is no evidence that the company provides further publicly available details about its broader public policy aims or positions. There is also no evidence that the company publishes any information on the activities that it has conducted in other jurisdictions nor does it clearly state that it has not engaged in lobbying elsewhere in the most recently reported financial period.

There is evidence that the company publishes summary information of its lobbying expenditure in the United States, by making its quarterly federal lobbying reports publicly available via a direct link on its website.

However, the company receives a score of ‘1’ because there is no evidence that it provides a breakdown of its expenditure data to show costs relating to internal, external or association lobbyists. There is also no evidence that the company publishes information on its lobbying expenditure in other jurisdictions nor does it clearly state that it has not engaged in lobbying elsewhere in the most recently reported financial period.

There is evidence that the company has a policy and/or procedure on the giving and receipt of gifts and hospitality with clear procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. There is evidence that this policy has financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy also addresses the risks associated with gifts and hospitality given to and/or received from domestic and foreign public officials.

However, there is no evidence indicating that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

Based on publicly available information, there is evidence that the company has a policy that clearly prohibits corporate political contributions. The company indicates that this applies to any contributions to government officials or politicians, whether made directly or indirectly. There is evidence that this policy applies company-wide in the United States and in other jurisdictions. In addition, the company clearly states that it is not associated with a Political Action Committee (PAC) in the United States, and no publicly available evidence was identified to contradict this statement.

The company publishes a clear statement that it does not make any forms of political contributions and therefore it is exempt from scoring on this question.

Based on publicly available information, there is evidence that the company has a policy on charitable donations and sponsorships. There is evidence that this policy includes criteria for donations and specific approval procedures for donations, as well as separate financial thresholds and sign-off requirements for any donations to organisations where the recipient is associated with a company director. The company also provides some information on the charities that it supports, including the names of the organisations.

However, there is no evidence that the company’s policy includes further controls such as due diligence on recipients, nor is there evidence that the company publishes full details of its charitable donations made in the last 12 months, including details of the recipient, amount, country of recipient and which corporate entity made the payment.

There is no publicly available evidence that the company has a clear policy or procedure on lobbying. The company provides publicly available information on the regulations in the United States that it must follow when undertaking any lobbying activities, for example the disclosure of payments and avoiding improper influence on the political process; however, there is no evidence that the company outlines specific standards of conduct or oversight mechanisms to ensure that all internal, external and association lobbyists comply with these regulations.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company publishes any details of its global lobbying expenditure.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with clear procedures designed to ensure that such promotional expenses are not used as vehicles for bribery. The company’s policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy also addresses the risks associated with gifts and hospitality given to and/or received from domestic and foreign public officials.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it has a procedure in place to record gifts and hospitality in a dedicated central register or database that is accessible to those responsible for oversight of the process. It is noted that the company has a separate policy covering gifts and gratuities, which may contain more information on its procedures in this area, but this document does not appear to be publicly available.

There is evidence that the company has a policy on political contributions, which states that such donations are generally prohibited. However, the company receives a score of ‘0’ because there is evidence that political donations are permissible in certain circumstances.

The company publishes details of its political contributions, and there is evidence that this data is updated and published on at least an annual basis. The company discloses that it made no political donations during the last two reporting years.

There is evidence that the company has a policy covering both charitable donations and sponsorships, whether made directly or through corporate foundations, to ensure that such donations are not used as vehicles for bribery and corruption. There is evidence that this policy includes measures to ensure this, for example, by specifying criteria for donations and procedures for senior sign-off. The company also provides limited details of specific causes that it has supported, as well as high level summary of its total charitable donations, published on an annual basis.

However, the company receives a score of ‘1’ because it does not publish a detailed breakdown of all charitable donations made, including details of the recipient, amount, country of recipient and which corporate entity made the payment.

There is evidence that the company has a policy that defines lobbying, broad enough to cover the spirit of the term as described in the guidance, and sets out the values and behaviours that constitute ‘responsible’ lobbying. There is evidence that lobbyists are required to comply with the company’s Code of Business Conduct and Anti-Corruption Policy, which set out what behaviours are acceptable in risk areas such as gifts and hospitality, undue influence and conflicts of interest. There is evidence of oversight mechanisms, including due diligence on lobbyists and provisions for senior sign off on lobbying activities. This policy applies to all employees, board members and third parties lobbying on the company’s behalf.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

There is evidence the company has a policy on the giving and receipt of gifts and hospitality with procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. There is evidence that this policy specifies financial limits and different approval procedures for different types of promotional expenses, and that it also explicitly addresses the risks associated with gifts and hospitality given to and/or received from domestic and foreign public officials. There is evidence that all gifts and hospitality worth over a certain threshold are logged in a dedicated register accessible to those responsible for oversight of the process.

There is no evidence that the company has a policy on corporate political contributions.

The company does not disclose full details of its political contributions.

There is no evidence that the company has a policy or procedure covering charitable donations or sponsorships.

There is no evidence that the company has a policy and/or procedure on lobbying.

The company does not publish any information on its lobbying aims, topics or activities.

The company does not provide any details about its global lobbying expenditure.

There is no publicly available evidence of a policy or procedure on gifts or hospitality.

The company states in its code of conduct that it does not make political contributions. This is also reflected in the company’s annual report.

The company publishes a clear statement that it does not make any political contributions, and is therefore exempt from scoring on this question.

There is some evidence that the company has a policy covering charitable donations; however, there is no evidence that the company has a policy or procedure covering also sponsorships.

There is evidence that the company has a policy covering responsible lobbying. It includes some standards of conduct and provides some guidelines on what behaviours are considered acceptable. This policy applies to all employees, board members and third parties lobbying on the company’s behalf.

However, the company receives a score of ‘1’ because it does not provide guidelines on the corruption risks associated with lobbying and it does not mention specific oversight mechanisms that apply to all types of lobbyists.

There is no evidence that the company publishes any information on its lobbying aims, topics or activities.

There is no evidence that the company provides any details about its global lobbying expenditure.

There is evidence that the company has a policy on the giving and receipt of gifts and hospitality with clear procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes some limits, along with an approval procedure. The company's policy incl