8. Offsets

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.

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

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations and/or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for managing the company’s offset activities.

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

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its indirect offset obligations and/or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting. There is no evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is no evidence that the company has a procedure in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations and/or contracts.

There is no evidence that the corruption risks associated with offset contracting are addressed or that there is a dedicated body, department or team responsible for monitoring the company’s offset activities.

There is no evidence that the company has procedures in place to conduct anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and/or on its behalf.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is evidence that the company recognises the corruption risks associated with offset contracting, and that it has a dedicated team involved in managing offset obligations. However, there is little evidence of policies and processes in place, and it is not clear that this team is responsible for monitoring the company’s offset activities throughout the lifecycle of each project. There is also no evidence that all employees within the team receive tailored anti-bribery and corruption training.

There is publicly available evidence that the company conducts due diligence on its offset activities. There is evidence that the company takes steps to ensure the legitimacy of the investment and that the due diligence checks include beneficial ownership. However, there is no evidence that the due diligence checks include conflict of interest risks. There is also no evidence that the company refreshes its due diligence continuously or when there is a significant change in the business relationship or nature of the partner.

The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

The company does not publish any details of its offset obligations or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting and there is no evidence that a dedicated body, department or team is responsible for monitoring of its offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its indirect offset obligations or contracts.

There is no evidence that the corruption risks associated with offset contracting are addressed and there is no evidence that a dedicated body is responsible for monitoring the company's offset activities.

There is no evidence that the company conducts due diligence on its offset obligations.

The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

The company does not publish any details of its offset obligations and/or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

Based on publicly available information, there is no evidence that the company addresses the corruption risks associated with offset contracting or that a dedicated body, department or team is responsible for monitoring the company's offset activities.

Based on publicly available information, there is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is evidence that the company publishes some information about the beneficiaries of its offset projects. The company indicates that its main offset or industrial participation commitments stem from the Presidency of Defense Industries in Turkey; the company provides some other information about its industrial cooperation projects associated with the Electronic Warfare Business but it is not clear whether these represent direct or indirect offsets.

The company receives a score of ‘1’ because it does not provide full details about the beneficiaries of its indirect offsets in a clear way; for example, the company does not list the name of the company or organisation receiving the investment and the country in which the recipient entity is based. The information provided is briefly mentioned in the Annual Report, so there is also no evidence that this represents a complete list of all the company’s indirect offset projects.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations and contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting and there is no evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations and/or contracts.

Based on publicly available information, there is clear evidence that the company formally recognises the corruption risks associated with offset contracting. The company indicates that all offset projects must be approved by the Group through a formal process. However, the company receives a score of ‘1’ because there is no evidence that a dedicated body, department or team with appropriate qualifications is responsible for monitoring of the company's offset activities.

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 its offset agents. There is also evidence indicating that due diligence includes checks on the beneficial ownership of offset agents and that the company seeks to assure itself of the legitimacy of the investment. The company refreshes due diligence on agents at least every two years.

However, the company receives a score of ‘1’ because there is no clear evidence that it conducts due diligence on offset beneficiaries nor that the process includes checks on conflicts of interest.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

Based on publicly available information, there is evidence that the company has policies and procedures in place to address corruption risks associated with offset contracting. The company indicates that a dedicated team is responsible for the monitoring and oversight of the company’s offset activities throughout the lifecycle of each project. There is evidence that all relevant employees receive tailored anti-bribery and corruption training based on the potential corruption risks associated with offsets. In addition, the company indicates that it ensures that its offset partners adhere to its anti-bribery and corruption standards through appropriate contractual clauses.

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 its offset obligations with evidence that the company assures itself of the legitimacy of the investment. There is evidence that the company conducts checks on the beneficial ownership of offset brokers and indicates that it may conduct similar checks on the beneficiaries of offset projects, and there is evidence that it repeats due diligence on brokers every two years.

Although the company does not specifically state that it conducts conflict of interest checks on its offset brokers, the company indicates that it seeks to identify any areas of concern or unethical behaviour through extensive due diligence, and this is deemed sufficient for a score of ‘2’.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations and contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, and there is no evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is no evidence that the company has such a procedure.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations and/or contracts.

There is no readily available evidence that the institute engages in offset contracting.

There is no readily available evidence that the institute engages in offset contracting.

There is no readily available evidence that the institute engages in offset contracting.

There is no readily available evidence that the institute engages in offset contracting.

The company publishes a clear statement to indicate that it does not enter into contracts that require an offset obligation, as a matter of policy.

The company publishes a clear statement that it does not enter into offset contracts, and is therefore exempt from scoring on this question.

The company publishes a clear statement that it does not enter into offset contracts, and is therefore exempt from scoring on this question.

The company publishes a clear statement that it does not enter into offset contracts, and is therefore exempt from scoring on this question.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is no evidence that the company conducts anti-bribery and corruption due diligence on its offset obligations or that it assesses the legitimate business rationale for such investments.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations and/or contracts.

There is publicly available evidence to indicate that the company engages in offset projects; however, there is no evidence that it addresses the corruption risks associated with offset contracting. There is no evidence that a dedicated body, department or team is responsible for monitoring the company’s offset activities.

There is no evidence that the company has a formal procedure in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting.

There is no publicly available evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no publicly available evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is evidence that the company publishes some information on its offset obligations. However, the information published is insufficiently detailed to satisfy the requirements of score ‘1’.

Based on publicly available information, there is evidence that the company has a policy to address the corruption risks associated with offset contracting. The company has a dedicated department involved in managing offset obligations and there is evidence that all its employees receive dedicated anti-bribery and corruption training on the particular risks associated with offset contracting.

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations. There is also evidence indicating that the company includes anti-bribery and corruption provisions in its contracts with offset partners.

However, the company receives a score of ‘1’ because there is no evidence that this due diligence includes checks on beneficial ownership or conflicts of interest. In addition, it is not clear that the company seeks to assure itself of the legitimacy of the investment, nor is there evidence that due diligence is refreshed continuously throughout the business relationship.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

The company publishes some information about its offset projects, in the form of an aggregate figure of the value of its offset obligations that extend until 2030. This information is published in the company’s Annual Report, which indicates that it is correct for the most recently reported financial year.

The company receives a score of ‘1’ because it does not publish further information on the beneficiaries of its indirect offset projects, such as the name of the company or organisation receiving the investment or the country in which the recipient entity is based. The company does not indicate whether the aggregate figure includes both direct and indirect offset obligations.

There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for oversight of its offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations. The company provides some information on its approach to due diligence in relation to third parties, but it is not clear from publicly available information that this process applies to offset partners or to other aspects of an offset obligation.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations, nor does it publicly indicate that it has not engaged in such activities in the most recently reported financial year.

There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor that a dedicated body, department or team is responsible for managing the company’s offset activities.

There is no publicly available evidence that the company conducts risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, or that it has a dedicated body, department or team responsible for monitoring of the company's offset activities.

There is no evidence that the company conducts due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations and/or contracts.

There is no evidence that the corruption risks associated with offset contracting are addressed, and there is no evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is no evidence that the company has a due diligence procedure for its offset obligations.

The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

The company does not publish any details of its offset obligations.

There is no evidence that the company addresses the corruption risks associated with offset contracting, and there is no evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations and contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, and there is no evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is no evidence that the company conducts risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations and/or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor that a dedicated department, body or team is responsible for oversight of the company’s offset programme.

There is no evidence that the company conducts risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf its offset programme.

There is no evidence that the company publishes any details of its offset obligations and/or contracts.

There is evidence that the company recognises the corruption risks associated with offset contracting. There is further evidence that the company has a dedicated team charged with managing its offset obligations, and that this team is responsible for monitoring these activities throughout the lifecycle of each project.

However, the company receives a score of ‘1’ because there is no evidence that those responsible for monitoring its offset activities receive tailored anti-corruption training.

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset partners, which it conducts at the start of the agreement and repeats on a continuous basis throughout the lifecycle of the project. There is evidence that this process includes checks on beneficial ownership and that the company takes steps to assure itself of the legitimacy of the investment. The also company indicates that its due diligence process includes checks on key personnel; although the company does not explicitly state that this includes checks on conflicts of interest, the company provides sufficient detail on the process to receive a score of ‘2’.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations, whether direct or indirect.

There is no evidence that the company addresses the corruption risks associated with offset contracting. There is no evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

The company does not publish any details of its offset obligations and/or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations and/or contracts.

There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.

There is no publicly available evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations and contracts.

Based on publicly available information, there is some evidence that the company addresses the corruption risks with offset contracting. However, there is no evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities, nor is there evidence that employees involved in managing the company’s offset activities receive tailored anti-corruption training on the potential corruption risks associated with offsets.

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 its offset obligations. The company clearly indicates that this process includes checks on beneficial ownership and that takes steps to verify the business rationale of the relationship or transaction.

However, there is no evidence that the company refreshes due diligence continuously or when there is a significant change in the business relationship or nature of the partner.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details on its offset obligations or contracts.

There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.

There is no publicly available evidence that the company conducts risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any clear details of its offset obligations or contracts. The company provides some information on one particular offset project associated with the Indian government which represented 50% of the contract value, however in publicly available ifnromation the company does not provide any further details nor does it provide details of any other indirect or direct offset contracts or projects.

There is some evidence that the company recognises the corruption risks associated with offset contracting. The company requires suppliers to conduct due diligence on offset agreements.

However, the company receives a score of ‘0’ because there is no evidence that the company itself has specific policies and procedures to address the corruption risks associated with offset contracting. There is also no evidence that the company has a dedicated body, department or team responsible for managing and monitoring the company's offset obligations. The company does not state publicly that it has no offset agreements.

There is some evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations. The company states that it conducts anti-corruption due diligence into its broker partners at the beginning of a proposed business relationship and updates due diligence on a periodic basis.

However, the company does not specifically mention checks on beneficial ownership and/or conflicts of interest. There is also no clear evidence that the company seeks to assure itself of the legitimacy of the investment nor that due diligence is refreshed at least every two years.

There is no evidence that the company publishes details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes details of its offset obligations and/or contracts.

There is no evidence that the corruption risks associated with offset contracting are addressed. There is no evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is no evidence that the company has a formal procedure to conduct anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations and/or contracts.

There is evidence that the company acknowledges the corruption risks associated with offset contracting. There is evidence that dedicated individuals within the company are responsible for managing its offset activities, and the company indicates that these individuals receive tailored anti-bribery and corruption training. Although the company does not explicitly state that these individuals form part of a dedicated body, department or team, there is sufficient evidence that the company has procedures in place to monitor and review its offset projects, so it receives a score of ‘2’.

There is no publicly available evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting.

There is no evidence that the company has such a procedure.

The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

The company does not publish any details of its offset obligations and/or contracts.

There is no publicly available evidence that the company addresses the specific corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.

There is no publicly available evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

The company publishes some high-level information on its offset projects to indicate the total value of its outstanding offset obligations. However, it is not clear from publicly available information that the company publishes any further information on the beneficiaries of these projects nor is it clear whether this figure includes both direct and indirect obligations for all jurisdictions in which the company operates.

There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that the company has a dedicated body, department or team responsible for monitoring of its offset activities.

Based on publicly available information, there is no evidence that the company conducts risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is some evidence that the company recognises the bribery and corruption risks associated with offset contracting. However, based on publicly available information, there is no clear evidence that the company has policies or procedures in place to address these risks. The company receives a score of ‘0’ because there is no evidence it has a dedicated body, department or team responsible for managing offset obligations.

Based on publicly available information, there is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on its behalf.

There is no evidence that the company publishes any details of its offset obligations or contracts.

Based on publicly available information, there is evidence that the company recognises the corruption risks associated with offset contracting. The company has a dedicated body, the Offset Committee, which is involved in managing its offset obligations. There is evidence that this body is responsible for monitoring the company’s offset activities throughout the lifecycle of each project. However, there is no evidence that committee members receive tailored anti-bribery and corruption training.

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 its offset obligations. There is evidence that the company refreshes this due diligence on an annual basis. The process mentions checks on beneficial ownership and conflict of interest and there is evidence indicating that the company seeks to assure itself of the legitimacy of the investment.

The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

The company does not publish any details of its offset obligations or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.

There is no publicly available evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations and/or contracts.

Based on publicly available information, there is no evidence that the company addresses the corruption risks associated with offset contracting. There is also no evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.

Based on publicly available information, there is no evidence that the company has a procedure to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations and contracts.

There is evidence that the company has policies and procedures in place to address the corruption risks associated with offset contracting. The company states that it has a dedicated Offset Team responsible for the monitoring and oversight of the company’s offset activities and any potential risks throughout the lifecycle of the project. In addition, there is also evidence that all employees within this team receive tailored anti-bribery and corruption training to perform this function.

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations. As part of this process, the company commits to establishing and verifying the legitimacy of the proposed offset activity or investment and to mitigating any possible conflicts of interest. There is evidence that the company refreshes due diligence when there is a significant change in the business relationship. Although the company does not explicitly mention beneficial ownership, it provides sufficient evidence that it checks the beneficiaries of projects and there is accompanying information on beneficial ownership checks as part of its third party due diligence processes, so the company can receive a score of ‘2’.

The company publishes a statement that it does not engage brokers or agents as part of its offset activities. The company is therefore exempt from scoring on this question.

There is no evidence that the company publishes any details of its offset obligations or contracts. The company states that it may communicate this information on a case by case basis, but there is no evidence that it has made such disclosures.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.

There is no publicly available evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting. There is no evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.

There is no evidence that the company has a procedure in place for conducting due diligence on its offset obligations.

The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company.

The company does not publish any details of its offset obligations and/or contracts.

There is no evidence that the corruption risks associated with offset contracting are addressed, and there is no evidence that a dedicated body is responsible for monitoring the company's offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company.

There is no evidence that the company publishes any details of its offset obligations or contracts.

The company indicates that it does not currently, and has not in the past, entered into any kind of offset contract with purchasing government. The company is therefore exempt from scoring on this question.

The company indicates that it does not currently, and has not in the past, entered into any kind of offset contract with purchasing government. The company is therefore exempt from scoring on this question.

The company indicates that it does not currently, and has not in the past, engaged the services of offset agents or brokers. The company is therefore exempt from scoring on this question.

The company indicates that it does not currently, and has not in the past, entered into any kind of offset contract with purchasing government. The company is therefore exempt from scoring on this question.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring of its offset activities.

There is no publicly available evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is no evidence that the company has a procedure to conduct risk-based due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations and/or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracts, and there is no evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of the beneficiaries of its offset obligations.

There is no publicly available evidence that the company addresses the corruption risks associated with offsets contracting, nor is there evidence that a specific team or department is responsible for managing the company's offset activities. There is no evidence that the company publishes a statement that it does not engage in offset contracting.

There is no publicly available evidence that the company conducts risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations.

There is no evidence that the company publishes any details of agents, brokers or consultancy firms contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details about its offset projects.

The company states that it has never previously, and does not currently, engage in offset agreements but recognises the corruption risks they present. The company also indicates that should it enter into such an agreement in the future that it has a dedicated procedure requiring the input and coordination of several departments to manage and oversee offset obligations.

However, the company does not suggest that it would require tailored anti-corruption training for all associated employees. Additionally, the company does not specify that this internal grouping would manage the offset arrangement throughout the project lifecycle.

Based on public information, there is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on offset obligations. There is also evidence that these procedures stipulate assurance of the legitimacy of the investment.

However, there is no evidence that the company’s procedure stipulates refreshing this due diligence continuously or at least when there is a significant change in the business relationship or nature of the partner. Additionally, there is no evidence that this procedure includes checks on ultimate beneficial ownership of offset brokers or beneficiaries, or that it covers conflicts of interest.

The company publishes a statement that it does not, and has not historically, entered into any offset agreements, as well as a statement that it does not engage offset agents or brokers.

The company publishes a statement that it does not, and has not historically, entered into any offset agreements.

There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring its offset activities.

There is no publicly available evidence that the company has a procedure in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no publicly available evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the its offset programme.

There is no publicly available evidence that the company publishes any details of its indirect offset obligations or contracts.

There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body is responsible for monitoring the company's offset activities.

There is no publicly available evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on its behalf.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring its offset activities.

There is no publicly available evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no publicly available evidence to indicate that the company addresses the corruption risks associated with offset contracting. There is also no evidence that a dedicated body, department or team is responsible for monitoring the company´s offset activities.

There is no publicly available evidence to indicate that the company has a formal procedure in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no publicly available evidence to indicate that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company´s offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no evidence that the company has a policy in place to address the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company’s offset activities.

There is no publicly available evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with or on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is some evidence that the company recognises the corruption risks associated with offset brokers. However, there is no evidence that the company addresses the broader risks associated with offset contracting itself. There is also no evidence that the company has a dedicated body, department or team responsible for monitoring its offset activities.

There is evidence that the company has formal procedures to conduct due diligence on offset brokers. This includes checks on conflicts of interest and measures to evaluate the need for a broker. The company refreshes due diligence on its brokers every two years.

However, the company does not specifically mention checks on the beneficial ownership of brokers. There is also no evidence that the company conducts due diligence on offset beneficiaries.

The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

The company does not publish any details of its offset obligations and/or contracts.

There is no evidence that the company addresses the potential corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company’s offset activities.

There is no evidence that the company has a procedure to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and/or on its behalf.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for oversight of its offset activities. There is no evidence that the company publishes a statement to indicate that it does not engage in offset contracting.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme, nor does it indicate that it does not employ or engage such entities.

There is no evidence that the company publishes any details of its offset obligations or contracts, nor does it publish a statement that it does not engage in offset contracting.

There is no evidence that the company addresses the potential corruption risks associated with offset contracting, nor is there evidence that a dedicated body is responsible for monitoring the company's offset activities.

There is no evidence that the company has a procedure to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

The company does not publish any details of its offset obligations and/or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, or that a dedicated team is responsible for monitoring the company's offset activities.

There is no evidence that the company has a procedure in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is evidence that the company recognises the corruption risks associated with offset contracting. The company has a dedicated team involved in managing offset obligations, particularly in the establishment of offset suppliers.

However, there is little evidence of policies and process to address the risks associated with offset contracting. It is also not clear that the offset team is responsible for monitoring the company’s offset activities throughout the lifecycle of each project, and there is no evidence that all employees within the team receive tailored anti-bribery and corruption training.

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

However, the company does not specifically mention checks on beneficial ownership or conflict of interest, there is no evidence that the company seeks to assure itself of the legitimacy of the investment, and there is no evidence that the company refreshes this due diligence continuously or when there is a significant change in the business relationship or nature of the partner.

There is no publicly available evidence to indicate that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no publicly available evidence to indicate that the company publishes any details of its offset obligations or contracts.

There is evidence that the company makes a public statement that it does not engage in offset trades, however there is also evidence on the company’s website to indicate that it engages in industrial cooperation activities and strategic partnerships as part of offset requirements set by purchasing customers; as such, the company’s position on offsets is unclear.

Although there is some evidence that the company has a dedicated team to manage its industrial cooperation and offset projects, it is not clear from publicly available information that employees in this team receive dedicated anti-corruption or compliance training based on the possible risks associated with offsets. There is also no clear evidence that the company has a procedure in place to manage offsets, nor is there evidence that its industrial cooperation team is responsible for monitoring and oversight of the company’s offset activities throughout the lifecycle of each project.

There is no publicly available evidence that the company has procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations or industrial cooperation requirements.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset and industrial cooperation programme, nor does it publish a statement that it does not engage such entities.

There is evidence that the company provides some information on the types of offset or industrial cooperation projects that it may engage in, as well as indicating that it engages in relevant strategic partnerships. However, there is no clear public available evidence that the company publishes further details about its offset or industrial cooperation projects, whether direct or indirect, or about the beneficiaries of such projects.

There is no publicly available evidence that the company addresses the corruption risks associated with offset contracts. There is also no evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

The company does not publish any details about the beneficiaries of its indirect offset obligations.

There is some evidence that the company recognises the corruption risks associated with offset contracting, and there is evidence that it has a dedicated policy in place to regulate such activities. The company indicates that its Global Business Development team is responsible for implementing and monitoring compliance in relation to offset activities.

However, the company receives a score of ‘1’ because there is no publicly available evidence that employees within this team receive specific anti-corruption training on the potential corruption risks associated with offsets. It is noted that the company has a separate policy on offset obligations which may contain more information on its approach, but this does not appear to be publicly available.

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations, as part of its overall policy on third parties. There is evidence that the company conducts checks on beneficial ownership of the partner entity and seeks to assure itself of the legitimacy of the investment as part of this due diligence.

However, the company receives a score of ‘1’ because there is no publicly available evidence that its due diligence for offsets includes checks on conflicts of interest. While the company refers to periodic renewal reviews of third parties, there is also no evidence that the company refreshes due diligence at least every two years or when there is a significant change in the business relationship or nature of the partner.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its indirect offset obligations or contracts.

There is no evidence that the company makes a clear statement regarding offset contracting activities. There is no clear evidence that the company has a dedicated department overseeing and managing offset commitments.

There is no evidence that the company clearly states that it conducts anti-bribery and corruption due diligence on all aspects of its offset obligations.

There is no evidence that the company publishes details of offset agents and brokers involved in its offset activities.

There is no evidence that the company publishes details of the beneficiaries of indirect offset projects.

Based on publicly available information, there is evidence that the company has policies and procedures in place to address the corruption risks associated with offset contracting. The company requires offset partners to adhere to its anti-bribery and corruption standards through appropriate contractual clauses. The company has a dedicated body responsible for the monitoring and oversight of its offset activities throughout the lifecycle of each project. There is evidence that employees within this body receive anti-bribery and corruption training.

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 offset partners. This process specifically includes checks on the beneficial ownership of partners and any potential conflicts of interest. As part of this process, the company's policy also commits to establishing and verifying that the offset obligation proposed is founded on a legitimate rationale. The company refreshes this due diligence whenever there is a significant change in the business relationship.

The company publishes an aggregate figure of the number of offset agents it employs for the most recent financial year.

However, the list falls short of the minimum level of detail required for a score of ‘2’. The company does not publish the names of its offset agents and brokers.

The company publishes aggregate information about its indirect offset projects for the most recent financial year.

However, the list falls short of the minimum level of detail required for a score of ‘2’.

There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for managing its offset activities.

There is some evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations. The company indicates that its definition of third parties includes offset partners and that such entities are subject to the same due diligence procedures as other third parties.

However, there is no publicly available evidence that the company’s due diligence process in the case of offset projects and partners includes checks on beneficial ownership and conflicts of interest. There is also no evidence that the company seeks to assure itself of the legitimacy of the project, nor that the company refreshes the due diligence continuously or when there is a significant change in the business relationship.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is evidence that the company has policies and procedures in place to address the corruption risks associated with offset contracting and ensures any offset partners adhere to its anti-bribery and corruption standards through appropriate contractual clauses. The company has a dedicated body responsible for the monitoring and oversight of the company’s offset activities throughout the lifecycle of each project, and there is evidence that the employees in this department receive dedicated training on the specific risks associated with offsets.

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations. This process specifically includes checks on the beneficial ownership of any offset brokers or beneficiaries. As part of this process, the company's policy also commits to establishing and verifying that the offset obligation proposed is founded on a legitimate rationale.

However, the company does not specifically mention checks on conflicts of interest for offset brokers and beneficiaries. It is also not clear whether the company refreshes due diligence at least every two years or whenever there is a significant change in the business relationship or nature of the partner.

The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company.

The company does not publish any details of its offset obligations and/or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that it has a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no readily available evidence that the company engages in offset contracting.

There is no readily available evidence that the company engages in offset contracting.

There is no readily available evidence that the company engages in offset contracting.

There is no readily available evidence that the company engages in offset contracting.

There is no evidence that the company specifically addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring its offset activities. Although there is some evidence that the company has policies governing its use of agents for offset contracting, there is no evidence of broader policies and processes in place to mitigate the risks associated with offset contracting as a whole.

There is some evidence on the company has formal procedures in place to conduct due diligence on its offset advisors, through the same procedures outlined for business advisers. However, the company does not clearly indicate that such checks include establishing ultimate beneficial ownership or verifying that the use of an offset agent is based on a legitimate rationale. There is also no evidence that the company’s policy on due diligence extends to other aspects of its offset obligations, such as checks on any partner company or companies.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with or on its behalf.

The company publishes some information on its global offset activities on its website, providing some examples of projects. However, this information is not published to a sufficient level of detail that the beneficiary may be identified. It is also unclear whether this list includes all of the company’s offset activities, including indirect offset projects, or whether it is current and regularly updated.

Based on publicly avaialble information, there is some evidence that the company recognises corruption risks associated with offset contracting. The company states that its Commercial function is responsible for managing its offset activities, and indicates that any requests for offsets are subject to Group approval.

However, the company receives a score of ’1’ because there is no evidnece that employees within the Commercial function receive tailored anti-bribery and corruption training on the risks associated with offsets. There is also no indication that the company publishes further details about its specific processes or controls to mitigate risks when engaged in offsets.

There is no publicly available evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no readily available evidence that the organisation engages in offset contracting.

There is no readily available evidence that the organisation engages in offset contracting.

There is no readily available evidence that the organisation engages in offset contracting.

There is no readily available evidence that the organisation engages in offset contracting.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor that a dedicated body, department or team is responsible for monitoring its offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its indirect offset obligations or contracts.

There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team that is responsible for monitoring its offset activities. There is no evidence that the company publishes a statement to indicate that it does not engage in such practices.

There is no publicly available evidence that the company has a procedure in place to conduct due diligence on its offset obligations.

There is no evidence that the company publishes any details of offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracts, and there is no evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations and contracts.

There is some evidence that the company has a procedure in place to address the corruption risks associated with offset contracting. The company states that the Group-level Business Development Department handles all offset agreements and indicates that the Legal & Compliance department handles all due diligence and monitoring of such agreements.

The company receives a score of ‘1’ because there is no clear evidence that the employees responsible for handling offset agreements receive tailored anti-bribery and corruption training based on the potential corruption risks associated with offsets.

Based on publicly available information, there is evidence that the company has a formal procedure in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations. The company indicates that this due diligence process includes ensuring that any offset projects or partners align with its group business strategy. There is some evidence that the company’s offset due diligence process includes establishing and verifying beneficial ownership information, however it is noted that this evidence primarily relates to sales representatives and is therefore indirect.

However, the company receives a score of ‘1’ because there is no clear evidence that the due diligence process for offset obligations includes checks on any conflicts of interest associated with the beneficiaries. Moreover, although there is some evidence to indicate that due diligence is repeated every two years, the company’s publicly available information indicates that this primarily relates to sales representatives and therefore it is not explicitly clear that the same standards are upheld for all aspects of all offset obligations.

The company publishes a statement on its website to indicate that it does not employ offset agents or brokers as part of its industrial cooperation programme, choosing instead to operate directly with authorities and partner companies. Since the company has adopted this as its publicly available position, the company therefore receives a score of ‘2’.

Based on publicly available information, there is no evidence to indicate that the company publishes any details of its indirect offset obligations and/or contracts.

There is some evidence that the company addresses the corruption risks associated with offset contracting, however there is no evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities and therefore the company receives a score of ‘0’.

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

However, the process does not specifically mention checks on beneficial ownership and conflicts of interest and there is no evidence that the company seeks to assure itself of the legitimacy of the investment. In addition, it is not clear that the company refreshes this due diligence at least every two years or when there is a significant change in the business relationship or nature of the partner.

The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

In its 2017 and 2018 CSR Reports, the company publishes examples of its direct and indirect offset projects and the names of some of the beneficiaries. The level of detail provided is sufficient that the beneficiary of the offsets are identifiable. There is evidence that this information is updated annually.

However, it is unclear whether this is a complete list of the company’s offset beneficiaries.

There is some evidence that the company has a policy in place to address the corruption risks associated with offset contracting. The company indicates that it has a dedicated body involved in managing offset obligations, but it is not clear that this team is responsible for monitoring the company’s offset activities throughout the lifecycle of each project. There is also no evidence that all employees within the team receive tailored anti-bribery and corruption training.

There no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its indirect offset obligations and/or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, and there is no evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations and contracts.

There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting. There is no evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its industrial partners, as part of its offset obligations. This process includes checks on beneficial ownership.

However, the company does not specifically mention checks on conflicts of interest and there is no evidence that the company seeks to assure itself of the legitimacy of the investment. The company also does not state if or how frequently due diligence is repeated.

The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

The company does not publish any details of its offset obligations and/or contracts.

There is no clear evidence that the company addresses the possible corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for oversight of the company’s offset activities. The company provides some information on its due diligence and review processes, but there is no further indication that it addresses the specific risks or provides dedicated training for staff involved in the company’s offset activities.

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 its offset obligations. The company indicates that this process includes checks on the beneficial ownership of any offset brokers or beneficiaries, as well as conflict of interest risks associated with the brokers or beneficiaries.

In addition, there is evidence that the company refreshes this due diligence periodically or whenever there is a change in the business relationship or nature of the partner. There is evidence that the company has procedures in place to assess the business rationale of any proposed offset project prior to entering into binding agreements.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, and there is no evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring of the company’s offset activities.

There is no evidence that the company conducts risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations and contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting.

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

The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

The company does not publish any details of its offset obligations.

Based on publicly available information, there is evidence that the company recognises the ethical and compliance risks associated with offset contracting, but there is limited evidence of policies and processes to address these. There is evidence that the company has a dedicated department involved in managing its offset obligations, and this department is understood to be responsible for monitoring company’s offset activities throughout the lifecycle of each project.

However, the company receives a score of ‘1’ because there is no evidence that all employees within the team receive tailored anti-bribery and corruption training on the potential corruption risks associated with offsets.

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 its offset obligations.

However, there is no evidence that the process specifically includes checks on beneficial ownership and conflicts of interest. There is also no evidence that the company seeks to assure itself of the legitimacy of the investment or that the company refreshes due diligence continuously or at least when there is a significant change in the business relationship or nature of the partner.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

Based on publicly available information, there is evidence that the company participates in indirect offset arrangements. However, there is no evidence that the company publishes details about the beneficiaries of these projects.

There is no evidence that the company addresses the corruption risks associated with offset contracts, nor that the company has a dedicated body, department or team which is responsible for monitoring of the company's offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

The company does not publish any details of its offset obligations.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor that a dedicated body, department or team is responsible for oversight of the company’s offset activities.

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

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

Based on publicly available information, there is evidence that the company recognises the corruption risks associated with offset contracting. The company’s export department and its Compliance Officer are involved in the management of offset obligations.

However, it is not clear that they are responsible for monitoring the company’s offset activities throughout the lifecycle of each project and there is no evidence that all employees within the team receive tailored anti-bribery and corruption training. Furthermore, there is little evidence of other policies and processes to address the risks associated with offset contracting.

Based on publicly available information, there is evidence that the company conducts risk-based anti-corruption due diligence on third parties engaged as part of its offset activities. However, there is no evidence that the company refreshes this due diligence continuously or when there is a significant change in the business relationship or nature of the partner.

Furthermore, there is little evidence to indicate that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on other aspects of its offset obligations, such as checks on beneficial ownership and/or conflict of interest associated with the beneficiaries. There is also no evidence that the company seeks to assure itself of the legitimacy of the investment.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its indirect offset obligations and/or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is evidence that the company has policies and procedures in place to address corruption risks associated with offset contracting and ensures any offset partners adhere to its anti-bribery and corruption standards through appropriate contractual clauses. The company has a dedicated body, department or team responsible for the monitoring and oversight of the company’s offset activities throughout the lifecycle of each project.

However, there is no evidence that all employees within the team receive tailored anti-bribery and corruption training.

There is clear evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations. This process specifically includes checks on the beneficial ownership of any offset brokers or beneficiaries. As part of this process, the company's policy also commits to establishing and verifying that the offset obligation proposed is founded on a legitimate rationale.

However, it is unclear whether the company refreshes the due diligence every two years and whether it conducts conflict of interest checks as part of the process.

The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

The company does not publish any details of its offset obligations and/or contracts.

There is evidence that the company has a policy and procedure in place to address the corruption risks associated with offset contracting. There is also evidence that those involved in offsets (“offset facilitators”) are required to adhere to the company’s anti-bribery and corruption standards through appropriate contractual clauses. In addition, the company states that it provides tailored anti-bribery and corruption training to employees involved in offset arrangements.

However, the company receives a score of ‘1’ because it is not clear that this individual, or another body, department or team, is responsible for monitoring the company’s offset activities throughout the lifecycle of each project. The company states that the Compliance Officer is responsible for monitoring relationships with all business partners, but it is not clear whether this individual holds responsibility for all aspects of the company’s offset activities or if another body, department or team is involved.

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations. There is evidence that this process specifically includes checks on the beneficial ownership of any offset brokers or beneficiaries, and any conflict of interest risks associated with the brokers or beneficiaries. As part of this process, the company's policy also commits to reviewing the legitimacy and rationale of its offset projects. Furthermore, the company states that its partners are monitored on an ongoing basis and that high risk partners are subject to due diligence every two years, which is understood to include offset obligations. There is also evidence that the company requests information on any material changes to any previously agreed offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations and/or contracts.

Based on publicly available information, there is evidence that the company has a policy and procedure in place to address the corruption risks associated with offset contracting and ensures any offset partners adhere to its anti-bribery and corruption standards through appropriate contractual clauses. There is evidence that the company has a dedicated department responsible for the monitoring and oversight of its offset activities throughout the lifecycle of each project. The company indicates that all employees within this department receive anti-bribery and corruption training.

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 its offset obligations. The company indicates that it refreshes this due diligence once every two years, or whenever there is a significant change in the business relationship or nature of the offset partner. There is evidence that due diligence includes checks on beneficial ownership and conflicts of interest. As part of the process, the company also commits to assure itself of the legitimacy of the investment.

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

The company publishes some information about the total size of its offset investment obligations, as well as some information concerning its indirect offset beneficiaries.

However, the company receives a score of ‘1’ because there is no evidence that it publishes data to cover all of its indirect offset obligations and/or contracts on a regular basis, such as the name of the company or organisation receiving the investment and the country in which the recipient entity is based.

There is evidence that the company recognises corruption risks associated with offset contracting. The company has a dedicated body, department or team involved in managing offset obligations. There is evidence that this team is responsible for monitoring the company’s offset activities throughout the lifecycle of each project.

However, there is no evidence that all employees within the team receive tailored anti-bribery and corruption training. Additionally, there is little evidence of policies and processes to address the corruption risks associated with offset contracting.

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations, and that it assures itself of the legitimacy of the investment.

However, the process does not specifically mention checks on beneficial ownership and conflict of interest and there is no evidence that the company refreshes this due diligence continuously or at least when there is a significant change in the business relationship or nature of the partner.

The company indicates that in 2019 it contracted no offset brokers or agents.

The company does not publish any details about the beneficiaries of its indirect offset projects.

There is evidence that the company recognises corruption risks associated with offset contracting, and the company also has a dedicated department, the Corporate Offset Group, which oversees all the company’s offset obligations. There is evidence that this department is involved, at least partially, in the establishment and oversight of all the company’s offset obligations throughout the project lifecycle. The company states that this department works alongside the company’s Ethics and Compliance Team to scope and mitigate corruption risks.

However, there is no evidence that all employees within the Corporate Offset Group receive tailored anti-bribery and corruption training based on the potential corruption risks associated with offsets.

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations. There is evidence indicating that due diligence on all offset obligations includes checks on beneficial ownership. The company states that for all offset obligations it conducts assurance of the legitimacy of the investment. The company states that it continuously monitors offset projects for signs of risk, business misconduct and corruption and that due diligence is repeated when there is a significant change in the business relationship or nature of the partner. Due diligence is otherwise repeated every three to five years, depending on the risk profile of the project.

However, the company receives a score of ‘1’ because there is no evidence that its due diligence procedures include a review of potential conflicts of interest associated with brokers or beneficiaries.

The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company.

The company does not publish any details of its offset obligations and/or contracts.

There is no evidence that the corruption risks associated with offset contracting are addressed, and there is no evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no evidence that the corruption risks associated with offset contracting are addressed, or that the company has a dedicated body, department or team that is responsible for monitoring of the company's offset activities.

The company states that it performs due diligence on all business partners and third parties, but there is no evidence of specific reference to offset obligations or contracts.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no publicly available evidence that the company recognises the corruption risks associated with offset contracting, nor that it has a dedicated body, department or team responsible for monitoring of its offset activities.

There is some evidence that the company conducts reviews of its offset partners. However, the company does not provide further publicly available information to indicate whether this includes anti-bribery and corruption due diligence on all aspects of the obligation. There is also no publicly available evidence that the company assesses whether there is a legitimate business rationale for its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes information about the beneficiaries of its indirect offset projects. The company publishes some information about its involvement in one offset project, however there is no evidence that it provides comprehensive information on all offset obligations nor that it distinguishes between direct or indirect projects.

Based on publicly available information, there is no evidence that the corruption risks associated with offset contracting are addressed, or that a dedicated body, department or team is responsible for monitoring the company's offset activities.

Based on publicly available information, there is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations and contracts.

Based on publicly available information, there is evidence that the company addresses and has procedures in place to address the corruption risks associated with offset contracting. There is evidence that the company requires that its offset partners adhere to its anti-bribery and corruption standards through contractual clauses. The company states that the Group Industrial Co-operation team is responsible for managing offset obligations and monitoring the company’s offset activities throughout the lifecycle of each project. There is evidence that employees involved in industrial cooperation projects receive tailored anti-bribery and corruption training.

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations. The process specifically mentions checks on ownership and conflict of interest. There is also evidence that the company seeks to assure itself of the legitimacy of the investment.

However, there is no evidence that the company refreshes due diligence at least every two years or when there is a significant change in the business relationship or nature of the partner.

There is no publicly available evidence to indicate that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is evidence that the company publishes information some about the beneficiaries of its indirect offset projects.

However, this is insufficiently detailed and there is no evidence that this covers all of the company’s offset projects or meets the other criteria in the guidance.

There is no evidence that the company formally addresses the corruption risks associated with offset contracting, nor that a dedicated body, department or team is responsible for monitoring of the company's offset activities. Although the company addresses the corruption risks associated with agents and intermediaries, there is no evidence that this applies to offset activities or brokers.

There is no evidence that the company conducts risk-based anti-bribery and corruption due diligence on its offset obligations. The company states in its 2018 Registration Document that it conducts due diligence on all business partners, but it is not sufficiently clear whether agents working on offset agreements are included in this definition, nor whether it applies to all aspects of the obligation.

The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

The company does not publish any details of its offset obligations and/or contracts.

There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence to suggest that a dedicated body, department or team is responsible for the monitoring of the company's offset activities.

There is no publicly available evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations. There is evidence that the company expects its suppliers to conduct due diligence on offset agreements, however it is not clear whether the company has procedures in place to conduct checks on its own offset arrangements.

There is no evidence that the company publishes any details on the offset agents, brokers or consultancy firms currently contracted to act with and/or on its behalf.

There is no evidence that the company publishes any details on its offset obligations or contracts.

Based on publicly available information, there is evidence that the company has a policy of not entering into offset agreements. However, the company states that it has inherited an offset agreement as a result of a recent acquisition; the company indicates that it does not plan to enter into any further offset arrangements.

The company’s publicly available policies recognise the corruption risks associated with offset arrangements, and there is clear evidence that the company has undertaken due diligence on the process. The company also states that its Executive and Investment Committee is responsible for reviewing and approving offset arrangements. Although the company does not have a dedicated body, department or team responsible for offset activities, there is evidence to suggest that the company rarely enters into such agreements and therefore the measures stipulated are deemed sufficient for a score of ‘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 on offset obligations. There is also evidence that the company seeks to assure itself of the legitimacy of the investment.

However, the company receives a score of ‘1’ because there is no evidence that this process specifically includes checks on beneficial ownership or conflict of interest. There is also no evidence that the company refreshes this due diligence continuously or at least when there is a significant change in the business relationship or nature of the partner.

The company publishes a statement to indicate that it currently employs one consultant to provide compliance advice in relation to its offset programme. Although the company does not provide any further details of this individual or entity, there is sufficient evidence to indicate that no other consultants act for or on behalf of the company’s offset programme, so the company receives a score of ‘1’.

There is no evidence that the company publishes details of the beneficiaries of the offset project it has recently inherited as part of an acquisition. The company indicates that its ongoing offset arrangement contributes to a requirement placed on a local contractor under Canada’s Industrial and Technological Benefits Policy (ITB), but does not provide any further details about the project or direct beneficiary.

Based on publicly available information, there is no clear evidence that the company addresses the corruption risks associated with offset contracting, nor that it has a dedicated body, department or team responsible for monitoring the company's offset activities. The company indicates that offset contracts are reviewed by the Risk and Sustainability Committee, but it does not provide further information on the potential risks or team responsible for their oversight.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is no evidence that the company conducts anti-bribery and corruption due diligence on all aspects of its offset obligations.

The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the its offset programme.

There is no evidence that the company publishes any details of its offset obligations.

There is no evidence that the corruption risks associated with offset contracting are addressed, and there is no evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is some evidence that the company recognises the corruption risks associated with offset contracting. However, there is no evidence that the company has a dedicated body, department or team that is responsible for monitoring the company’s offset activities, nor does it indicate that employees within this department receive dedicated training on the possible corruption risks associated with offsets.

There is no publicly available evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

The company publishes a statement to indicate that it does not participate in indirect offset projects as a matter of policy, due to the possible corruption risks associated with such activities. The company is therefore exempt from scoring on this question.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.

There is no evidence that the company conducts anti-bribery and corruption due diligence on all aspects of its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on its behalf.

There is no evidence that the company publishes any details of its offset obligations and/or contracts.

Based on publicly available information, there is evidence that the company has policies and procedures in place to address corruption risks associated with offset contracting. The company indicates that it ensures any offset partners adhere to its anti-bribery and corruption standards through appropriate contractual clauses.

In addition, there is evidece that the company has a dedicated body, department or team responsible for the monitoring and oversight of the company’s offset activities throughout the lifecycle of each project. The company indicates that all employees within this body, department or team receive tailored anti-bribery and corruption training based on the potential corruption risks associated with offsets.

Based on publicly available information, there is evidence that the company conducts due diligence on all business partners as part of its involvement in an offset project. There is also evidence that the company seeks to assure itself of the legitimacy of offset obligations.

However, there is no evidence that the company’s due diligence includes checks on beneficial ownership or conflict of interest. It is also not clear that the company refreshes this due diligence continuously or when there is a significant change in the business relationship or the nature of the partner.

The company publishes a statement that it does not employ any agents or brokers as part of its offset programme. Since the company has adopted this as its publicly available position, the company therefore receives a score of ‘2’.

Based on publicly available information, the company publishes some information about the beneficiaries of its offset projects. However, the company receives a score of ‘1’ because there is no evidence that this represents a comprehensive list of its offset projects, nor is it clear that the details provided relate specifically to indirect offset projects. It is also not clear that this information is published and updated on at least an annual basis.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that that the company has a dedicated body, department or team responsible for monitoring of its offset activities.

There is some evidence that the company conducts risk-based anti-bribery and corruption due diligence on its offset providers and partners. However, the company receives a score of ‘1’ because there is no further evidence that this process includes checks on beneficial ownership or that it seeks to assure itself of the legitimacy of the investment.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no readily available evidence that the organisation engages in offset contracting.

There is no readily available evidence that the organisation engages in offset contracting.

There is no readily available evidence that the organisation engages in offset contracting.

There is no readily available evidence that the organisation engages in offset contracting.

The company recognises the corruption risks associated with offset contracting and there is evidence that there is a specific department, the Industrial Cooperation Department, involved in managing the company’s offset obligations across divisions and for the duration of the project lifecycle. The company also states that its business unit most commonly involved in offset contracting, the Marine Systems business unit, has a specific department dedicated to overseeing and managing all aspects of its offset obligations.

However, it is unclear whether the staff of this department is given anti-corruption training specific to their role.

The company states that it has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations, either carried out by the offset team within the Marine Systems Business Unit or by the company’s Compliance Department. The company states that the due diligence process includes checks on ultimate beneficial ownership, a screening of possible conflicts of interest and an assurance of the legitimacy of the investment. There is evidence that the company refreshes its due diligence on offset service providers every two years.

However, it is not clear that the company refreshes due diligence on all aspects of its offset obligations continuously or at least when there is a significant change in the business relationship or nature of the partner.

The company discloses that it does not currently contract any third party offset service providers or brokers. It is unclear if this is due to the introduction of a policy to no longer use these kinds of service providers.

The company receives a score of ‘1’ because it is unclear whether the company updates this information annually. Furthermore, the company suggests that it will not disclose information about its offset brokers going forward.

The company does not publish any details of its offset obligations and/or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company’s offset activities.

There is no evidence that the company has a procedure in place to conduct anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details on the offset agents, brokers or consultancy firms currently contracted to act with and/or on its behalf.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no publicly available evidence to indicate that the company addresses the corruption risks associated with offset contracting, or that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is no publicly available evidence to indicate that the company has formal procedures in place to conduct risk based anti-bribery and corruption due diligence on its offset obligations.

There is no publicly available evidence to indicate that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no publicly available evidence to indicate that the company publishes any details of its offset obligations and/or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations and/or contracts.

There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor that a dedicated body, department or team is responsible for oversight and management of the company’s offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

Based on publicly available information, there is evidence that the company recognises the corruption risks associated with offset contracting. There is evidence that the company has a dedicated team involved in managing and monitoring offset obligations throughout the lifecycle of each project.

However, the company receives a score of ‘1’ because there is no evidence that it provides further details on the processes that it has in place to address the risks associated with offset contracting. In addition, there is no clear evidence to suggest that all employees within the offset team receive tailored anti-bribery and corruption training.

Based on publicly available information, there is evidence that the company has formal procedures in place to conduct due diligence on its offset obligations. There is evidence that the company seeks to assure itself of the legitimacy of the investment.

However, the compay receives a score of ‘1’ because the company’s publicly available policy does not specifically mention checks on beneficial ownership and conflicts of interest. There is also no evidence that the company refreshes this due diligence continuously or when there is a significant change in the business relationship or nature of the partner.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations and contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations and/or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

There is no evidence that the company conducts anti-bribery and corruption due diligence on all aspects of its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.

There is no publicly available evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.

There is no evidence that the company publishes any details of its offset obligations or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting.

There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations.

The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

The company does not publish any details of its offset obligations or contracts.

The company publishes a clear statement that it does not engage in offset contracting and is therefore exempt from scoring on this question.

The company publishes a clear statement that it does not engage in offset contracting and is therefore exempt from scoring on this question.

The company publishes a clear statement that it does not engage in offset contracting and is therefore exempt from scoring on this question.

The company publishes a clear statement that it does not engage in offset contracting and is therefore exempt from scoring on this question.

There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.

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

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on its behalf.

There is no evidence that the company publishes any details of its offset obligations and/or contracts.

There is no evidence that the company addresses the corruption risks associated with offset contracting, and there is no evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.

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

There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company’s offset programme.

There is no evidence that the company publishes any details of its offset obligations and/or contracts.