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State-Owned Enterprises Commitment: Limited commitment
Score:
38/100

10. State-Owned Enterprises

View full assessment

Score

38/100

38/100

Points

3/8

10.1 Does the SOE publish a breakdown of its shareholder voting rights?

Points

POINTS: NA

This is a transparency question

This question is looking for evidence that the company is transparent about voting power that each of its major shareholders possesses, in relation to their percentage ownership of the company. This information should be published in the form of percentage voting rights, in a way that is clear, updated on an annual basis, and sufficiently detailed so that it is comparable to the company’s beneficial ownership information, if disclosed.

For most companies, the share of voting rights that any given shareholder retains will be equal to the number of shares owned. However, in some cases, voting rights and ownership may be disproportionate and thereby increase the company’s exposure to undue influence from particular shareholders or state actors. Although all companies should be encouraged to publish this information, it is particularly important that state-owned enterprises maintain transparency in this area. A state-owned company often has an intrinsically close relationship with the ownership entity – in this case, the state – which can expose the company to political interference if not appropriately managed.

Transparency around the relationship between ownership and voting rights provides non-state shareholders with an assurance that their views are being proportionally represented and gives observers the necessary tools to scrutinise the company’s decision-making.

If the company is a fully state-owned enterprise and therefore only has one shareholder, as identified in question 9.3 on beneficial ownership transparency, this question should be scored N/A.

If the company is not a state-owned enterprise as defined in this assessment, this question should be scored N/A.

Score: 2/2

The company publishes information about its shareholder voting rights, broken down by percentage allocated to each shareholder. At a minimum, it publishes beneficial ownership and voting rights of shareholders with at least 25% of shares or 25% of voting rights. It publishes ownership and voting rights by one or more state entities over 10%. This data is published side-by-side to reflect the relationship between ownership and voting rights.

If no natural person owns 25% or more of shares or voting rights, or no state entity owns 10% or more of shares or voting rights, the company needs to state so publically to be awarded a score of ‘2’.

Publicly listed companies – with voting shares admitted to trading on a regulated market in the UK or European Economic Area (other than the UK) or on specified markets in Switzerland, the USA, Japan and Israel – including wholly-owned subsidiaries of publicly listed entities, are not required to disclose information on their beneficial owners and will be awarded a ’2’ as long as they publish the required voting rights.

Score: 1/2

The company publishes some information about its shareholder voting rights, but this information is incomplete or lacking in some way. For example, specific shareholders are not referred to by name or the thresholds for disclosure are higher than the ones specified in score ‘2’.

Score: 0/2

The company scored 0/2 for this question

There is no evidence that the company publishes details of its shareholder voting rights.

Comments

The company states that shareholders are granted the same proportion of voting rights. The evidence also suggests that the company is 100% owned by the Russian Federation and therefore there are no other shareholders. The company is therefore exempt from scoring on this question.

10.2 Are the SOE's commercial and public policy objectives publicly available?

Points

POINTS: 1/2

This is a transparency question

This question is looking for evidence that the company is open and transparent about its objectives, both in terms of commercial and public policy aims and mandate.

As a result of their ownership structure, state-owned enterprises often exist to fulfil both commercial and non-commercial objectives. This adds an additional layer of complexity to their operations. State-owned enterprises with public policy objectives – whether well-defined or unclear – are exposed to higher levels of corruption risk than private or public companies, since they are required to interact with policymakers on a necessarily regular and in-depth basis. This relationship, when not properly managed, can expose the company to undue influence by the state or put the SOE in a position of exercising undue influence.

Transparency around the key aims, objective and mandate of state-owned enterprises is therefore an essential mechanism to counter such risks. This information should be published on the company’s website in a way that is clear, regularly updated, and sufficiently detailed so as to allow an external observer to discern the company’s commercial and public policy objectives in practice.

If the company is not a state-owned enterprise as defined in this assessment, this question should be scored N/A.

Score: 2/2

The company’s commercial and/or public policy objectives are made publicly available on its website, and are updated on at least an annual basis or whenever there is a change in objectives.

Score: 1/2

The company scored 1/2 for this question

The company publishes some information about its commercial and/or public policy objectives, but these are either unclear or there is no evidence that they are updated on at least an annual basis.

Score: 0/2

There is no evidence that the company publishes information on its commercial or public policy objectives.

Comments

The SOE's commercial and public policy objectives are made publicly available on its website. However there is no clear evidence that this information is updated on at least an annual basis or whenever there is a change in objectives.

10.3 Is the SOE open and transparent about the composition of its board and its nomination and appointment process?

Points

POINTS: 1/2

This is a transparency question

This question is looking for evidence that the state-owned enterprise makes information about the design and structure of its board available to the public. In particular, it should provide details about the way in which potential board members are nominated, the process for their appointment, and for information about the board members.

One of the ways that a state’s influence can manifest in a state-owned enterprise is through influence or control over the appointment of board members. While this characteristic doesn’t automatically present a corruption risk, the ability of the state to make decisions in this process can expose the company to heightened risk of undue influence. Publishing details around the criteria for nomination, the company representatives involved in the nomination, and who makes the final appointment decision would mitigate this risk and help ensure appropriately qualified and accountable individuals are selected. Moreover, transparency around the individual members of a company’s board – for example, whether that person is a financial beneficiary, an executive, a state representative or an independent director – would also significantly reduce the risk of undue influence.

If the company is not a state-owned enterprise as defined in this assessment, this question should be scored N/A.

Score: 2/2

The company publishes clear information about the nomination process, appointment and composition of its board and provides details of its board members. The company discloses details of its nomination process, including the criteria for nomination, which company representatives are involved in the nomination, and who makes the final appointment decision. For each board member, the company discloses whether that person has any connection to the company or the state or is an independent director.

Score: 1/2

The company scored 1/2 for this question

The company publishes information about the composition of its board, for example whether each board member is: a financial beneficiary; an executive; a state representative; or an independent director. However, further information about the nomination and appointment process is unclear or not published.

Score: 0/2

There is no evidence that the company makes information about its board members publicly available or, the information disclosed is sufficiently unclear that it cannot satisfy the requirements of score ‘1’.

Comments

The SOE publishes clear information about the composition of its board, identifying each director as either a state official or a company executive. It also discloses some details of its nomination process, however there is evidence that the selection criteria is given in a separate document entitled Regulations on the Board of Directors, which is not publicly available.

10.4 Is the company's audit committee composed of a majority of independent directors?

Points

POINTS: 0/2

This is a split question

This question is looking for evidence that the company publishes details of the composition of its executive-level audit committee, in such a way that the assessor can determine the ratio of independent directors.

The composition of executive-level committees in state-owned enterprises should allow for exercise of independent judgement. As executives who do not represent the state, independent directors provide expertise and technical knowledge, and act as a balancing force should there be any attempts by the state to interfere unduly in the governance of the SOE. Such individuals should be free of any conflicts of interest, pecuniary or martial interests, or relationships that could jeopardise – or could be interpreted by stakeholders as jeopardising – their exercise of effective judgement. They should serve on board committees, including the committee that oversees the anti-bribery and corruption programme, the remuneration committee and the audit committee.

In this case, the assessor is looking for evidence that more than 50% of the SOE’s audit committee are independent directors; in other words, non-company, non-executive and non-state representative.

If the company is not a state-owned enterprise as defined in this assessment, this question should be scored N/A.

Score: 2/2

There is evidence that the company has an executive-level audit committee which is composed of a majority of independent directors; in other words, non-company, non-executive and non-state affiliated. The company can do this by either disclosing the name and/or job title and status (independent or non-independent) of each member.

Score: 1/2

The company publishes a statement that it has an executive-level audit committee which is composed of a majority of independent directors, but there is no evidence of this in practice. In other words, it is unclear, for each member of the committee, whether they are independent or non-independent and/or no job titles are published for each member.

Score: 0/2

The company scored 0/2 for this question

There is no evidence that the company’s audit committee is composed of majority independent directors; for example, the structure of the company’s audit committee is not disclosed or it is disclosed and a majority of directors are not independent. Or, there is no evidence that the company has an audit committee, or there is some evidence that the company has an audit committee but this is vague and/or the committee is not at executive level.

Comments

There is no evidence that the SOE has an audit committee.

10.5 Does the company have a system in place to assure itself that asset transactions follow a transparent process to ensure they accord to market value?

Points

POINTS: 1/2

This is a split question

Asset transactions include mergers, acquisitions, divestments, refinancing, sales and write-offs. Asset transactions can be a high-risk area for SOEs. Corruption risks can include the following:

  • Politicians or public officials manipulate valuations and decisions in transactions to extract value from the SOE for their own or another’s benefit or to launder money.
  • During privatisation, SOEs – or portions of their operations – are sold at less than market value.
  • Assets are bought or sold at non-market prices.
  • Benefits are given to political parties or politicians through loans of assets or giving access to an SOE’s resources, such as the use of premises or facilities.

These risks can be countered by rigorous and transparent processes for vulnerable areas, including requiring business cases for transactions, ring-fencing those people involved in transactions, carrying out due diligence on counterparties, monitoring for abnormalities in transactions, and obtaining an independent review of transactions and valuations.

A board committee comprised of independent directors should make an independent assessment of asset transactions. High-level management of assets should be subject to independent oversight by a board committee or external monitor, and to internal and external audits. These audits should be open and transparent, to deter corruption (subject to confidentiality restrictions for commercial reasons).

If the company is not a state-owned enterprise, this question should be scored N/A.

Score: 2/2

There is evidence that the company has a system in place to manage asset transactions, with responsibility held at board-level. Asset transactions, for which a minimum value threshold may be specified, are scrutinised by an audit body. The company states that all transactions are documented, including those between the company and government departments or the military, or if any of the latter make asset transactions on the company’s behalf. Financial results from asset acquisitions or disposals are made publicly available in the company financial reports.

Score: 1/2

The company scored 1/2 for this question

There is some evidence that the company has a system in place to manage asset transactions, however this procedure is lacking in some way. For example:

  • There is no evidence that responsibility for managing asset transactions is held at board-level, or it is clear that responsibility is not held at board-level;
  • It is unclear or there is no evidence that asset transactions are subject to scrutiny by an audit body;
  • It is unclear or there is no evidence that all transactions are documented, including those between the company and government departments or the military; or
  • The financial results from asset acquisitions or disposals are not published in the company’s reports.

Score: 0/2

There is no evidence that the company has a system in place to manage asset transactions; or the company does not publish any details about its process for managing this; or the information provided is insufficient to satisfy the requirements of score ‘1’.

Comments

There is evidence that the SOE has a system in place to manage asset transactions, with responsibility held at board level. However, it is unclear whether asset transactions are subject to scrutiny by an audit body. Furthermore, the company does not clearly state that all transactions are documented, and there is no evidence that the company publishes the financial results from asset acquisitions in its reports.

Compare scores by company

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AAR Corporation /2
/2
/2
/2
/2
Abu Dhabi Shipbuilding 0/2

There is no evidence that the company publishes details of its shareholder voting rights. The company publishes information about its significant shareholders – which includes the Government of Abu Dhabi – but does not provide any accompanying details to indicate the percentage voting rights held by each individual or entity.

1/2

The company publishes some information about its objectives to serve and grow its customer base, noting that its main priority is to support the United Arab Emirates (UAE) Navy. However, the company receives a score of ‘1’ because its objectives beyond that are unclear and there is no evidence that these objectives are updated on at least an annual basis.

0/2

The company publishes some information about its board of directors on its website, including the name and position of each individual. However, the company receives a score of ‘0’ because it does not provide any further information about each board member, such as whether they are financial beneficiary, an executive, a state representative, or an independent director. There is also no evidence that the company makes any information on the board nomination or appointment process publicly available.

0/2

The company publishes some information to indicate which of its board members form part of its Audit Committee, however there is no evidence to indicate which (if any) individuals are independent board members and therefore there is no evidence that the committee is composed of a majority of independent directors.

0/2

There is no publicly available evidence that the company has a system in place to manage asset transactions.

Accenture PLC NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

AECOM NA
NA
NA
NA
NA
Aerojet Rocketdyne NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Airbus Group 2/2

The company publishes a breakdown of its shareholder voting rights, including where this relates to the French, German and Spanish states that each own minority shares. Evidence suggests that the voting rights for these states are equivalent to the percentage of shares held in the company and that no shareholder may retain more than 15% of the capital or voting rights.

2/2

The commercial and public policy objectives of the company are made publicly available on its website, and are updated on an annual basis.

2/2

Based on publicly available information, there is evidence that the company is open and clear about the nomination process, appointment and composition of its board and provides details of its board members. The company discloses details of its nomination process, including the criteria for nomination, which company representatives are involved in the nomination, and who makes the final appointment decision. For each board member, the company discloses whether that person has any connection to the company or the state or is an independent director.

2/2

According to publicly available evidence, the company’s audit committee is fully composed of independent directors.

1/2

Based on publicly available evidence, the company has a system in place to manage asset transactions. However, there is no evidence that responsibility for managing asset transactions is held at board level or that asset transactions are subject to scrutiny by an audit board. The company does not publish financial information from its asset acquisitions and there is no evidence that all transactions are documented.

Almaz-Antey 0/2

There is no evidence that the company publishes any details of its shareholders or their voting rights.

1/2

The company publishes some information about its objectives, which primarily include servicing the needs of the Russian armed forces and supporting the domestic defence industry. However, the company receives a score of ‘1’ because there is no clear evidence that these objectives are updated on at least an annual basis.

0/2

There is no evidence that the company makes any information about its board members or their nomination and appointment process publicly available. The company’s website provides the name of the Chairman of the Board – along with a list of others who have held the post – but it does not provide further details about other members.

0/2

There is no evidence that the company has an audit committee which is composed of majority independent directors.

0/2

There is no evidence that the company publishes any details about its management of asset transactions.

Arab Organization for Industrialization (AOI) 0/2

There is no evidence that the company publishes details of its shareholder voting rights.

1/2

The company provides some information about its commercial and public policy objectives, stating that its main purpose is to support the development of a domestic industrial base. However, these objectives are unclear and there is no evidence that they are updated on an annual basis, so the company receives a score of ‘1’.

0/2

The company provides some information about the composition of its board of directors, by stating the public positions and responsibilities of each individual. Their titles indicate that they are all state representatives, however this evidence is indirect and unclear. The information published is insufficient to receive a score of ‘1’ because the company does not provide the names of each member, nor does it provide any further information on the nomination and appointment process.

0/2

There is no evidence that the SOE has an audit committee.

0/2

The SOE does not publish any details about its management of asset transactions.

Arsenal JSCo. NA
NA
NA
NA
NA
Aselsan A.Ş. 2/2

There is evidence that the company publishes information about its shareholder voting rights, broken down by the percentage allocated to each shareholder. The company publishes the beneficial ownership and voting rights of shareholders with at least 25% of voting rights.

2/2

The company publishes some information about its commercial and public policy objectives and there is evidence to suggest that these are updated on an annual basis. Although these objectives are relatively broad and high-level, they provide sufficient insight into the company’s aims and objectives to receive a score of ‘2’.

2/2

There is evidence that the company publishes clear information about the nomination process, appointment and composition of its board and provides details of its board members. The company discloses the process by which directors are nominated by shareholders. For each board member, the company discloses whether that person has a connection to the company or the state or is an independent director.

2/2

There is publicly available evidence that the company’s Audit Committee is composed entirely of independent directors.

1/2

Based on publicly available information, there is evidence that the company has a system in place to manage asset transactions, with responsibility held at board level.

However, there is no clear public evidence that asset transactions are subject to scrutiny by an audit body. It is unclear whether all transactions are documented, including those between the company and government departments or the military. In addition, the financial results from asset acquisitions are not published in the company’s reports.

Austal NA
NA
NA
NA
NA
Aviation Industry Corporation of China (AVIC) 0/2

There is no evidence that the company publishes information on shareholder voting rights.

0/2

The company publishes some information on its areas of activity in the national defence industry. However, the company receives a score of ‘0’ because there is no evidence that it publishes clear information on its commercial or public policy objectives.

0/2

There is no evidence that the company publishes any information about its board members or the process for their nomination and appointment.

0/2

There is no evidence that it is composed of a majority of independent directors. The company publishes information to indicate that it has an audit committee, but provides no further information on the composition of the committee.

0/2

There is no evidence that the company publishes any information regarding its management of asset transactions.

Babcock International Group NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

BAE Systems PLC NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Ball Aerospace & Technologies Corporation NA
NA
NA
NA
NA
Battelle Memorial Institute NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Bechtel Corporation NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

BelTechExport Company JSC 0/2

There is no evidence that the company publishes any details of its shareholder voting rights. The company’s beneficial ownership and control structure is also unclear from publicly available evidence, but there is some information to indicate that the company may be at least partially state-owned.

0/2

There is no evidence that the company publishes clear information on its commercial or public policy objectives. There is some indication on the company’s website that its primary goal is to produce military products and services for the republic of Belarus, but it does not provide any further information.

0/2

There is no evidence that the company makes any information about its board members publicly available.

0/2

There is no publicly available evidence that the company has an audit committee.

0/2

There is no evidence that the company has a system in place to manage asset transactions.

Bharat Dynamics 2/2

There is evidence that the company publishes information about its shareholder voting rights, broken down by percentage allocated to each shareholder. The company publishes beneficial ownership and voting rights of all of its shareholders, and it also publishes ownership and voting rights by state entity over 10%. This data is published alongside each other to reflect the relationship between ownership and voting rights.

2/2

There is evidence that the company’s commercial and public policy objectives are made publicly available on its website. The company also makes information on its objectives available in its Annual Report, which therefore indicates that its objectives are updated on at least an annual basis.

1/2

There is evidence that the company publishes clear information about the composition of its board and whether each board member is an executive, a state representative or an independent board member. There is information that the Government of India appoints the Functional Directors, Government Directors and Independent Directors.

However, the company receives a score of ‘1’ because further information about the nomination process is unclear.

2/2

Based on publicly available information, there is evidence that the company’s executive-level Audit Committee is composed of a majority of independent directors. The company discloses the name and status of each member in its Annual Report.

1/2

Based on publicly available information, there is evidence that the company has a system in place for managing assets transactions with responsibility assigned at board level. There is evidence that asset valuations are subject to scrutiny by an audit body.

However, the company receives a score of ’1’ because there is no evidence that all transactions are documented and there is no evidence that financial results from asset acquisitions are made publicly available in the company’s reports.

Bharat Electronics 1/2

The company publishes information about the beneficial ownership of shareholders with at least 5% of shares up to March 2018, and it appears that the share of voting rights that any given shareholder retains is equal to the number of shares owned. However, the information published for March 2019 only provides shareholder by category and does not refer to specific shareholders by name, so the company receives a score of ‘1’.

2/2

Based on publicly available information, there is evidence that the company publishes information about its objectives on its website and in the Annual Report. The company states that its primary objectives are to generate growth, fuel technological development and support national defence exports. Although the company does not directly state that these objectives are updated and reviewed on an annual basis, the inclusion of this information in the company’s Annual Report is sufficient to satisfy this criterion.

1/2

There is evidence that the company publishes clear information about the composition of its board and whether each board member is an executive, a state representative or an independent board member. There is information that the Government of India appoints the Directors and Independent Directors.

However, the company receives a score of ‘1’ because it does not provide further information about the nomination process for board members, such as which individuals are involved in the nomination and who makes the final appointment decision.

2/2

Based on publicly available information, there is clear evidence that the company’s executive-level audit committee is composed of a majority of independent directors. The company discloses the name and status of each member.

0/2

Based on publicly available information, there is insufficient evidence to suggest that the company has a system in place to manage asset transactions. The company makes some reference to the role of the vigilance organisation in reviewing asset acquisitions and the role of directors in maintaining proper accounting records, but this information does not satisfy the requirements of score ‘1’.

Boeing NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Booz Allen Hamilton Inc. NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

CACI International Inc. NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

CAE Inc. NA
NA
NA
NA
NA
CEA Technologies NA
NA
NA
NA
NA
Chemring Group PLC NA
NA
NA
NA
NA
China North Industries Group Corporation (NORINCO) 0/2

There is no evidence that the SOE publishes details of its shareholder voting rights.

1/2

There is some evidence that the SOE publishes its commercial and public policy objectives.

However, there is no evidence that these are updated on an annual basis.

1/2

The SOE identifies each board member as either an executive or an independent director.

However, the company does not provide information on whether each board member is a state representative or financial beneficiary. The company also publishes no clear information on its nomination and appointment process for directors.

0/2

There is no evidence that the SOE’s audit committee is composed of a majority of independent directors.

0/2

There is no evidence that the SOE publishes any details about its management of asset transactions.

China State Shipbuilding Corporation 0/2

There is no evidence that the company publishes details of its shareholder voting rights. Although the company states that it is a state-owned enterprise, it does not provide clear ownership information and therefore it is not clear whether the Chinese government is the sole owner of shares or voting rights.

0/2

The company publishes some information on its areas of business activity and services. However, the company receives a score of ‘0’ because it does not publish clear details of its commercial or public policy objectives and there is no evidence that this information is updated on an annual basis.

0/2

There is no evidence that the company makes any information about its board members or the nomination and appointment process publicly available.

0/2

There is no evidence that the company has an audit committee that is composed of a majority of independent directors.

0/2

There is no evidence that the company publishes any information about its management of asset transactions.

Cobham Ltd. NA
NA
NA
NA
NA
Cubic Corporation NA
NA
NA
NA
NA
Curtiss-Wright Corporation NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Daewoo Shipbuilding & Marine Engineering NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Damen Schelde Naval Shipbuilding NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Dassault Aviation NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Day & Zimmermann NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Denel SOC NA

The company publishes a statement that it is a state-owned enterprise, with 100% of shares held by the South African Government. Therefore, it can be inferred that the company does not have shareholders and that the South African Government also holds 100% of its voting rights.

2/2

The company provides details of its commercial and public policy objectives on its website, and there is evidence in the Annual Report to indicate that these objectives are updated and reviewed on an annual basis. This includes reporting against an annual performance plan agreed with the shareholder. Although there is no direct evidence that the objectives on the company’s website are updated annually, the inclusion of key objectives in the Annual Report is considered sufficient to receive a score of ‘2’.

1/2

The SOE publishes clear information about the composition of its board, for example whether each board member is an independent director or an executive. It states that independent board members are appointed by the Minister for Public Enterprises, acting on behalf of the company’s sole shareholder, the Ministry for Public Enterprises. However, the company receives a score of ‘1’ because on its website it does not provide any further information on the nomination and appointment process for executive and non-executive directors.

2/2

There is evidence that the company’s executive-level audit committee is composed of a majority of independent directors. The company provides clear information about the independence of directors alongside their committee membership.

0/2

The company does not publish any details about its management of asset transactions.

Diehl Stiftung & Co. KG NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

DynCorp International NA
NA
NA
NA
NA
Elbit Systems NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Embraer S.A 2/2

The company publishes clear information about its shareholder voting rights to indicate the percentage allocated to each shareholder. The company indicates that the Brazilian government holds a meaningful minority of voting rights though one golden share.

2/2

There is evidence that the company publishes information on its commercial objectives for both its commercial and defence businesses. There is evidence that these objectives are published and updated on an annual basis, as part of the company’s annual Financial Statements.

2/2

There is evidence that the company publishes information about the nomination process, appointment and composition of its board and provides details of its board members. The company discloses details of its nomination process, including the criteria for nomination, which company representatives are involved in the nomination, and who makes the final appointment decision. For each board member, the company discloses whether that person has any connection to the company or the state or is an independent director.

2/2

There is evidence that the company's board-level audit committee is composed of a majority of independent directors; in other words, non-company, non-executive and non-state affiliated. The company discloses the name and status of each member.

1/2

Based on publicly available information, there is evidence that the company has a system in place for asset transactions with related parties. The company indicates that responsibility for these transactions is held at board level, and that all transactions are documented and subject to scrutiny by the Audit, Risk and Ethics Committee. The values of these transactions are made public in the company’s financial reports.

However, the company receives a score of ‘1’ because it is not clear whether this policy applies to all asset transactions or if it is applicable only in transactions with related parties.

Excalibur Army NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Fincantieri S.p.A NA
NA
NA
NA
NA
Fluor Corporation NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Fujitsu Ltd. NA
NA
NA
NA
NA
GE Aviation NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

General Atomics NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

General Dynamics Corporation NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

GKN Aerospace NA
NA
NA
NA
NA
Glock NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Hanwha Aerospace NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Hewlett-Packard Enterprise Company NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

High Precision Systems 2/2

In its most recent publicly available annual report, published in 2015, the company publishes information about its shareholder voting rights, broken down by percentage allocated to each shareholder.

It is noted that this information was correct as of 2015 and is possibly out of date.

2/2

The company's commercial and public policy objectives are made publicly available on its website. There is evidence that these policies are updated whenever there is a change in objectives.

0/2

The company makes insufficient information about its board members publicly available.

0/2

There is no evidence to suggest that the company has an audit committee.

0/2

The company does not publish sufficient details about its management of asset transactions to merit a score of ‘1’.

Hindustan Aeronautics Ltd. 2/2

The SOE publishes a percentage breakdown of its shareholder voting rights for its sole shareholder with a stake greater than 25%.

1/2

There is evidence that the SOE publishes some information about its commercial and public policy objectives.

However, the detail around them in publicly available information is limited and it is unclear if they are updated on at least an annual basis.

1/2

The SOE is open and clear about the composition of its board and provides details of its board members, identifying each member as a state representative, executive or an independent director. The company also states that all directors are appointed directly by India’s Ministry of Defence. The company additionally discloses, as per regulatory requirements, that no newly-appointed director holds shares in the company.

The SOE receives a score of ‘1’ because there is no evidence that it discloses information regarding directors’ nomination process or the criteria for nomination. Additionally, there is no evidence to clarify if existing directors are shareholders.

2/2

The SOE discloses the composition of its audit committee and indicates that it is composed solely of independent directors.

0/2

There is no evidence that the SOE publishes any details about its management of asset transactions.

Honeywell International NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Huntington Ingalls Industries, Inc. NA
NA
NA
NA
NA
Hyundai Rotem Company NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

IHI Corporation NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

IMI Systems Ltd. NA

The company publishes a clear statement on its website to indicate that it is wholly-owned by the State of Israel, thereby indicating that the state holds 100% of its shares and voting rights.

0/2

The company publishes some details of its global vision, however there is no clear evidence that the company publishes any information on its commercial or public policy objectives.

0/2

There is no publicly available evidence that the company publishes information on the composition of its board, nor that it publishes details of the board nomination and appointment process.

0/2

There is no publicly available evidence to indicate that the company has an audit committee, nor that such a committee would be composed of a majority of independent directors.

0/2

There is no publicly available evidence that the company has a system in place to manage asset transactions.

Indian Ordnance Factories 0/2

There is no evidence that the company publishes details of its shareholder voting rights. Although there is evidence to indicate that the company is government-owned, it is not clear from this evidence that the government is the sole entity that holds shares or voting rights in the company.

1/2

The company publishes some information about its public policy objectives. However, there is no evidence that these are updated on at least an annual basis.

0/2

There is evidence that the company publishes an incomplete list of its board members. There is no evidence that the company publishes information on whether each board member is a financial beneficiary, an executive, a state representative or an independent director and therefore it cannot satisfy the requirements of score ’1’.

0/2

There is no publicly available evidence to indicate that the company has an audit committee.

0/2

There is no evidence that the company publishes any details about its management of asset transactions.

Indra Sistemas S.A. 2/2

There is evidence that the company publishes information on the voting rights of its major shareholders as part of its annual corporate reporting. There is evidence that the company is publicly listed on the Madrid Stock Exchange and the London Stock Exchange, among others, and therefore it does not need to disclose further information on its beneficial ownership or shareholder voting rights to receive a score of ‘2’.

2/2

There is evidence that the company publishes information on its commercial objectives for the whole business. In addition, there is evidence to indicate that these objectives are updated on an annual basis or whenever there is a change in the company’s Strategic Plan.

2/2

Based on publicly available information, there is evidence that the company provides clear information on the nomination process, appointment and composition of its board and provides details of its board members. The company discloses details of its criteria for nomination, the company representatives that are involved in the nomination, and who makes the final appointment decision. For each board member, the company discloses whether that person has any connection to the company, the state or is an independent director.

2/2

Based on publicly available information, there is evidence that the company’s Audit and Compliance Committee is composed of a majority of independent directors.

2/2

Based on publicly available information, there is evidence that the company has a system in place for asset transactions with related parties. The company indicates that responsibility for scrutinising these transactions is held at board level and that information on transactions are made public in the company’s financial reports.

Israel Aerospace Industries (IAI) 2/2

In publicly available evidence, the SOE states that it is wholly-owned by the State of Israel. As the company has a single shareholder, there is no requirement to publish information about its shareholder voting rights.

1/2

The SOE publishes some information about its objectives.

However, the information provided is not detailed and there is no publicly available evidence that the SOE updates its objectives on at least an annual basis.

1/2

The SOE publishes some details about the nomination process to the board and the composition of its current board, and also publishes the names of all board members.

However, based on publicly available evidence, it is not clear which company directors are independent directors or state representatives. The company also does not provide specific information on its criteria for director appointees other than stating that they must be professionally qualified.

1/2

The company states that, in accordance with Israeli law, its audit committee is composed of a majority of independent directors.

However, the company receives a score of ‘1’ because there is no further evidence to support this statement as the company does not disclose which directors sit on its audit committee.

0/2

The SOE does not publish any details about its management of asset transactions.

Japan Marine United Corporation NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Kawasaki Heavy Industries Ltd. NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

KBR Inc. NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

King Abdullah II Design and Development Bureau 0/2

The SOE does not publish details of its shareholder voting rights, and since it does not provide clear percentage information on its beneficial ownership, the company receives a score of ‘0’.

1/2

There company publishes some limited information about its objectives to provide support to the Jordan Armed Forces. However, the company receives a score of ‘1’ because its objectives beyond that are unclear and there is no evidence that these objectives are updated on at least an annual basis.

0/2

The company provides the names of the members of its board of directors on its website. However, it does not provide any further information about each board member, such as whether they are financial beneficiary; an executive; a state representative; or an independent director. It also does not publish information on the nomination and appointment process to the board.

0/2

There is no publicly available evidence that the company has an audit committee.

0/2

The company does not publish any details about its management of asset transactions.

Komatsu Ltd. NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Kongsberg Gruppen ASA 2/2

The SOE publishes information about its shareholder voting rights, indicating that its voting rights are proportionate to the shares held and are not differentiated. The company is also publicly listed and therefore receives ‘2’ because it publishes the required voting rights.

2/2

Based on publicly available information, there is evidence that the company’s commercial and public policy objectives are made publicly available on its website and are updated on at least an annual basis.

2/2

The SOE is open and clear about its nomination process, appointment and composition of its board and provides details of its board members. The SOE discloses details of its nomination process, including the criteria for nomination, which company representatives are involved in the nomination, and who makes the final appointment decision. For each board member, the SOE discloses whether that person has any connection to the company or the state or is an independent director.

1/2

Based on publicly available information, the company does not explicitly state that the majority of its audit committee members are independent directors, although information provided elsewhere suggests that they are.

To score ‘2’ the company would need to state that the Audit Committee comprises a majority of independent and non-state affiliated directors by design at all times.

1/2

Based on publicly available information, there is evidence that the company has a system to manage asset transactions. The company indicates that responsibility for auditing and approving the company’s financial statements is held by the board of directors.

However, there is no evidence that the responsibility for managing asset transactions is held at board level. It is unclear and not specified whether asset transactions are subject to scrutiny by an audit body. Furthermore, there is no evidence that all transactions are documented or that the financial results from asset acquisitions are made publicly available in the company’s reports.

Korea Aerospace Industries Ltd. NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Krauss-Maffei Wegmann (KMW) NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

L3 Harris Technologies Inc. NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Leidos Inc. NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Leonardo S.p.A 2/2

The company is a publicly listed company with voting shares admitted to trading on a regulated market in the European Economic Area. The company publishes ownership and voting rights for the state entity which has a stake of over 10%.

2/2

The SOE's commercial and public policy objectives are made publicly available on its website and are updated on at least an annual basis or whenever there is a change in objectives.

2/2

The company is open and clear about the nomination process, appointment and composition of its board and provides details of its board members. The company discloses details of its nomination process, including the criteria for nomination and which company representatives are involved in the nomination. For each board member, the company discloses whether that person has any connection to the company, is an independent director, or whether they are a state representative.

2/2

Based on publicly available information, there is evidence that the company’s Control and Risks Committee is composed of a majority of independent directors. The company discloses the names and the status of each member.

2/2

Based on publicly available evidence, the SOE has a clear system in place for asset transactions, with responsibility assigned at board level for managing transactions. There is evidence indicating that asset transactions are scrutinised by an audit body. The SOE states that all transactions are documented. Financial results from asset acquisitions or disposals are made publicly available in the SOE’s financial reports.

LIG Nex1 Co. NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Lockheed Martin Corporation NA
NA
NA
NA
NA
ManTech International Corporation NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Massachussetts Institute of Technology (MIT) NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

MBDA NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Meggitt PLC NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

MITRE Corporation NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Mitsubishi Electric Corporation NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Mitsubishi Heavy Industries NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Moog Inc. NA
NA
NA
NA
NA
Nammo AS 2/2

There is evidence that the company publishes a breakdown of its voting rights by percentage allocated to each shareholder, alongside the percentage ownership. The company indicates that it has two major shareholders who hold equal percentages of ownership and voting rights.

1/2

The company provides some details of its commercial and public policy objectives in its corporate reporting documents and on its website. There is evidence that the company’s key objectives are to serve the Norwegian national armed forces and to continue growing in profitability.

However, the company receives a score of ‘1’ because there is no clear evidence that these objectives are updated on an annual basis or whenever there is a change in objectives. Although some information is published in the company’s Annual Report, this mainly relates to its strategy for growth rather than its core objectives, which are published on a webpage without a date.

2/2

The company is open and clear about the composition of its board, as well as providing details about the appointment and nomination process. The company states that its two largest shareholders nominate three board members each, with the remaining positions filled by elected employee representatives. From this information, it is clear which members are independent and which are state representatives. Although the company does not provide further details on the criteria for nomination, the evidence provided is deemed sufficient to receive a score of ‘2’.

0/2

There is no publicly available evidence that the company has a board-level audit or risk committee.

1/2

Based on publicly available information, there is evidence that the company has a system to manage asset transactions. The company also publishes the final report from its independent auditors, which indicates that transactions have been scrutinised by an audit body and notes that the company’s financial statements reflect all relevant Norwegian laws and regulations.

However, the company receives a score of ‘1’ because there is no evidence that a board-level individual or committee holds responsibility for managing asset transactions, nor does the company make it clear that all transactions are appropriately documented.

Naval Group 0/2

The SOE does not publish sufficient details of its shareholder voting rights either in the public materials on its website or in freely available commercial registries.

2/2

The SOE's commercial and public policy objectives are made publicly available on its website, and there is evidence that they are updated on an annual basis or whenever there is a change in objectives.

2/2

The SOE is open and clear about the nomination process, appointment and composition of its board and provides details of its board members. The SOE discloses details of its nomination process, including the criteria for nomination, which company representatives are involved in the nomination and who makes the final appointment decision. For each board member, the SOE discloses whether that person has any connection to the company or the state or is an independent director.

0/2

There is no evidence that the SOE's Audit, Accounts and Risks Committee is composed of a majority independent directors.

0/2

The SOE does not publish any details about its management of asset transactions.

Navantia S.A 2/2

The company publishes a statement that 100% of shares owned by the Spanish State-Owned Industrial Holding Company (SEPI). Therefore, it is understood that the company does not have any other shareholders and that the Spanish state holds 100% of voting rights.

2/2

There is evidence that the company publishes details of its commercial and public policy objectives in its Annual Report and on its website. There is evidence that these objectives are updated on an annual basis.

1/2

The company publishes clear information about the composition of its board. For each board member, the company discloses whether that person has any connection to the company or the state or is an independent director.

The company, however, receives a score of ‘1’ because its nomination and appointment process is not entirely clear. For instance, the company does not publish criteria for nomination, which company representatives are involved in the nomination, and who makes the final appointment decision.

0/2

There is no evidence that the company’s audit committee is composed of majority independent directors. While there is evidence that the company’s executive-level audit committee is composed of non-company directors, the information provided shows that that all three of its members represent the state and therefore a score of ‘0’ applies.

0/2

The evidence in relation to whether the company has a system in place to manage asset transactions is insufficient to satisfy the requirements of score ‘1’.

NEC Corporation NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Nexter Group 0/2

The company does not publish details of its shareholder voting rights. On its website, the company indicates that the French state has a golden share in the company. However, it does not provide further information on the shareholder voting rights this confers and how this might differ from other shareholders.

0/2

The company does not publish its commercial or public policy objectives.

0/2

On its website, the company provides the names of its senior management team only and does not list any board members. The governance structure between the company and its parent company, KNDS, is not fully clear from the public domain. Neither the company nor KNDS provide information on their websites regarding the nomination and appointment processes for directors. KNDS does not provide clear information about the composition of its board, for example whether each board member is: a financial beneficiary; an executive; a state representative; or an independent director.

0/2

Based on publicly available information, it is unclear whether the company has an audit committee. Although the company refers to audit reviews of its compliance programme, the company does not disclose information regarding its audit governance structure on its website.

0/2

The company does not publish any details about its management of asset transactions.

Northrop Grumman Corporation NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

OGMA – Indústria Aeronáutica de Portugal SA 0/2

There is no evidence that the company publishes any details of its shareholder voting rights. Although the company publishes information on its shareholders, it cannot be assumed that these percentages automatically translate to voting rights.

0/2

There is no evidence that the company publishes any information on its commercial or public policy objectives.

0/2

There is no evidence that the company publishes any information about its board members or the composition, nomination and appointment process.

0/2

There is no evidence that the company has an audit committee.

0/2

There is no evidence that the company publishes any details about its management of asset transactions.

Oki Electric Industry NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Oshkosh Corporation NA
NA
NA
NA
NA
Patria Oyj 2/2

There is evidence that the company publishes information about its shareholder voting rights alongside its ownership information.

2/2

There is evidence that the company publishes its commercial and public policy objectives on an annual basis.

2/2

There is evidence that the company publishes details about the composition of its board of directors. For each board member, the company discloses whether that person has any connection to the company or the state or is an independent director. The company also publishes information on the director nomination and appointment process. There is evidence that the Nomination and Compensation Committee has responsibility for this process and is composed of non-company and non-executive directors

2/2

Based on publicly available information, there is evidence that the company’s audit committee is composed of a majority of independent directors.

2/2

Based on publicly available information, there is evidence that the company has a system in place to manage asset transactions, with transactions being documented and subject to audit. There is evidence that the financial results from asset acquisitions are published in the company’s reports. There is also evidence suggesting that responsibility for managing asset transactions is held at board level.

Perspecta NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Polish Defence Holding 0/2

There is no evidence that the company publishes any details of its shareholder voting rights. The company indicates that over 99% of its shares are held by Polish state bodies and states that the Minister of National Defence exercises “ownership rights” over the company, but it is not clear that this relates to voting rights.

1/2

The company publishes some information about its objectives, which include commercial objectives to be an industry leader as well as national objectives to serve the Polish state.

However, the company receives a score of ‘1’ because its objectives are unclear and there is no evidence that they are updated on an annual basis.

0/2

There is evidence that the company publishes some information about its board members, including the name and position of each individual. However, the company receives a score of ‘0’ because it does not provide further details such as whether each board member is a financial beneficiary, an executive, a state representative or an independent director. In addition, there is no evidence that the company publishes information on the board nomination or appointment process.

0/2

There is no evidence that the company has an audit committee which is composed of a majority of independent directors.

0/2

There is no evidence that the company publishes any information about its management of asset transactions.

Poongsan Corporation NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

PT Dirgantara Indonesia (Indonesian Aerospace) 0/2

There is no evidence that the company publishes information about its shareholder voting rights. The company indicates that it is a state-owned enterprise, but does not provide percentage details to indicate that the government of Indonesia is its sole holder of shares or voting rights.

1/2

The company publishes some information on its commercial objectives, which include delivering competitive services and becoming a leader in the global aerospace industry. However, the company receives a score of ‘1’ because these objectives are high-level and there is no evidence that they are reviewed or updated on an annual basis.

0/2

The company publishes some information about its board members, including the names and positions of several individuals. However, the company receives a score of ‘0’ because it is not clear that this includes all of the company’s directors and there is no evidence that the company publishes any further information about the board nomination or appointment process.

0/2

There is no evidence that the company has an audit committee which is composed of a majority of independent directors.

0/2

There is no evidence that the company publishes any details about its management of asset transactions.

QinetiQ Group NA
NA
NA
NA
NA
Rafael Advanced Defense Systems Ltd. 0/2

There is no evidence that the company publishes details of its shareholder voting rights. Although there is evidence to indicate that the company is government-owned, it is not clear from this statement that the government is the sole entity that holds shares or voting rights in the company.

1/2

There is evidence that the state-owned enterprise publishes some information about its objectives. However, the company receives a score of ‘1’ as there is no evidence that they are updated on at least an annual basis.

0/2

There is no evidence that the state-owned enterprise makes information about its board members publicly available.

0/2

There is no publicly available evidence that the state-owned enterprise has an audit committee.

1/2

There is some evidence that the state-owned enterprise has a system in place to manage asset transactions, which must be documented.

However, the company receives a score of ‘1’ as there is no evidence that responsibility for managing asset transactions is held at board level. It is also unclear whether asset transactions are subject to scrutiny by an audit body. There is no evidence that the financial results from asset acquisitions are made publicly available in the company’s reports.

Raytheon Technologies NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Rheinmetall A.G NA
NA
NA
NA
NA
Roketsan A.Ş. 1/2

The SOE publishes some information that can be inferred to relate to shareholding voting rights.

However, the company receives a score of ‘1’ because the information is inconclusive and incomplete.

0/2

There is no evidence that the SOE publishes its commercial or public policy objectives.

0/2

The SOE publishes limited information on its board members. However, the information disclosed is insufficient to satisfy the requirements of a score of ‘1’.

0/2

There is no evidence that the SOE's audit committee is composed of majority independent directors or that the company has an audit committee.

0/2

There is no evidence that the SOE publishes any details about its management of asset transactions.

Rolls Royce PLC NA
NA
NA
NA
NA
Rostec State Corporation JSC NA

The company publishes a statement that it is 100% owned by the Russian Federation and is a State Corporation. Therefore, it can be inferred that the company only has one shareholder. It is therefore exempt from scoring on this question.

1/2

The SOE publishes some information about its objectives but receives a score of ‘1’ because there is no evidence that this information is updated on at least an annual basis.

1/2

There is evidence that the SOE publishes clear information about the composition of its Supervisory Board, including that each member is a state representative. However, there is no evidence that the company publishes information on the nomination and appointment process.

0/2

While there is evidence that the company’s subsidiaries have audit committees, it is unclear from publicly available information whether Rostec itself has an executive-level audit committee, or how this is composed.

0/2

There is no evidence that the SOE publishes details about its management of asset transactions.

RTI Systems Inc. NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

RUAG Holding AG NA

There is evidence that the company is wholly owned by the Swiss Confederation, and the company states that this entity holds 100% of its voting rights. Since one single entity holds all of the company’s voting rights, there is no requirement for the company to publish a percentage breakdown and therefore it is exempt from scoring on this question.

2/2

There is evidence that the company publishes information on its commercial and public policy objectives on its website. There is evidence that these objectives are updated on at least an annual basis or whenever there is a change in objectives.

2/2

There is evidence that the company publishes some information about the nomination and appointment process and composition of its board. The company indicates that none of its board members have a material business relationship with the group, and it discloses any other relevant mandates or interests that each member might have. In addition, the company provides publicly available information on how the board is elected and who manages the appointment process, in line with all national regulations.

2/2

There is evidence that the company’s Audit Committee is composed entirely of independent directors. The company indicates this by stating that none of its board members have a material business relationship with the group.

1/2

There is evidence that the company has a system in place to manage asset transactions. The company indicates that it has controls in place to ensure that asset transactions correspond with fair market value. The company also publishes the financial results from asset acquisitions in its annual corporate reporting documents.

However, there is no clear publicly available evidence that responsibility for managing asset transactions is held at board level. It is also not clear whether asset transactions are subject to scrutiny by an audit body.

Russian Helicopters JSC 0/2

The company publishes some information about the rights of shareholders in its company statutes. There is evidence that the company is 95.83% state-owned by the government of Russia, however there is no indication from this statement that the government is the sole entity that holds shares or voting rights. There is no evidence that the company provides a breakdown of its shareholder voting rights of its shareholders, so it therefore receives a score of '0'.

1/2

The SOE publishes information about its objectives. However, the company receives a score of ‘1’ because it is not clear whether these objectives are updated on at least an annual basis.

1/2

The SOE publishes information about the composition of its board, stating the current and previous state and commercial affiliations of individual board members. In publicly available information, the company also states that three of its board of directors are independent, although it is unclear which directors this status applies to.

The company scores ‘1’ as there is no evidence that it publishes information on the nomination and appointment process for board members.

0/2

In publicly available evidence the company states that where possible an independent member of the board will be elected as Chairman of the Audit Committee. However, there is no evidence that the company discloses any further information on the composition of its Audit Committee and there is no evidence that a majority of directors are independent.

0/2

Based on publicly available evidence, there is no evidence that the SOE published any details about its management of asset transactions.

Saab AB NA
NA
NA
NA
NA
Safran S.A 2/2

The company is publicly-listed on multiple stock exchanges, and therefore is not required to disclose information on its beneficial owners. The company nevertheless provides information on shareholder voting rights in its public materials.

2/2

There is evidence that the company publishes information on its commercial and public policy objectives. There is evidence that this information is updated on an annual basis or whenever there is a change in objectives.

2/2

There is evidence that the company is open and clear about the nomination process, appointment and composition of its Board of Directors and provides details of its board members. The company discloses details of its nomination process, including the criteria for nomination, which company representatives are involved in the nomination, and who makes the final appointment decision. For each board member, the company discloses whether that person has any connection to the company or the state or is an independent director.

2/2

There is evidence that the company’s Audit Committee is composed of a majority of independent directors.

2/2

There is some evidence that the company has a system in place to manage asset transactions. The company states that transactions above a certain financial threshold are subject to prior board approval, and there is evidence that these decisions are documented. Financial results from asset acquisitions or disposals are made publicly available in the company’s accounts. There is evidence that the company’s Audit and Risk Committee is responsible for reviewing financial statements relating to asset acquisitions and disposals.

Science Applications International Corporation (SAIC) NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Serco Group PLC NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

ST Engineering NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

STM Savunma Teknolojileri Muhendislik ve Ticaret A.S. 0/2

There is no evidence that the company publishes details of its shareholder voting rights. There is some evidence to indicate that the company is, at least partially, owned by the government of Turkey but it is not clear whether any other individuals or entities may hold shares or voting rights in the company.

1/2

There company publishes some limited information about its objectives to become a leading defence company and provide support to the Turkish Armed Forces (TAF). However, the company receives a score of ‘1’ because its objectives beyond that are unclear and there is no evidence that these objectives are updated on at least an annual basis.

0/2

The company publishes some information about its board members, including their name and position. However, the company receives a score of ‘0’ because it does not publish further details about which (if any) board members are independent, nor does it make any information on the board nomination and appointment process publicly available.

0/2

There is no publicly available evidence that the company has an audit committee, nor that is composed of a majority of independent directors.

0/2

There is no evidence that the company publishes any details about its management of asset transactions.

Tactical Missiles Corporation JSC NA

The company states that shareholders are granted the same proportion of voting rights. The evidence also suggests that the company is 100% owned by the Russian Federation and therefore there are no other shareholders. The company is therefore exempt from scoring on this question.

1/2

The SOE's commercial and public policy objectives are made publicly available on its website. However there is no clear evidence that this information is updated on at least an annual basis or whenever there is a change in objectives.

1/2

The SOE publishes clear information about the composition of its board, identifying each director as either a state official or a company executive. It also discloses some details of its nomination process, however there is evidence that the selection criteria is given in a separate document entitled Regulations on the Board of Directors, which is not publicly available.

0/2

There is no evidence that the SOE has an audit committee.

1/2

There is evidence that the SOE has a system in place to manage asset transactions, with responsibility held at board level. However, it is unclear whether asset transactions are subject to scrutiny by an audit body. Furthermore, the company does not clearly state that all transactions are documented, and there is no evidence that the company publishes the financial results from asset acquisitions in its reports.

Tashkent Mechanical Plant (TMZ) 0/2

There is no evidence that the company publishes information on its shareholder voting rights.

1/2

The company publishes some limited information about its objectives, which is primarily to support the Ministry of Defence of Uzbekistan. However, there is no evidence that these objectives are updated on an annual basis.

0/2

The company publishes some information on the nomination and appointment process for its board.

However, the company receives a score of ‘0’ because it does not make sufficient information about its board members or the process publicly available. The company discloses the identities of board members but does not indicate whether a board member is a financial beneficiary, an executive, a state representative, or an independent director.

0/2

The company publishes a statement that its audit committee may include independent and executive directors.

However, the company receives a score of ‘0’ because there is no clear evidence that the committee is, or must be, composed of a majority of independent directors. Although the company publishes some sample information on audit committee regulations, it indicates that these are not enforced or in place.

1/2

There is some evidence that the company has a system in place to manage asset transactions, with responsibility for the management of transactions held at board level. There is evidence that the company’s major transactions are subject to scrutiny by an audit body.

However, the company receives a score of ‘1’ because there is no clear evidence that all transactions are documented, nor that the company publicly discloses the financial results from asset acquisitions.

Tatra Trucks A.S. NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Telephonics Corporation  NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Terma A/S NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Textron Inc. NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Thales Group 2/2
2/2
2/2
0/2
1/2
The Aerospace Corporation NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

ThyssenKrupp AG NA
NA
NA
NA
NA
Toshiba Infrastructure Systems & Solutions Corporation NA
NA
NA
NA
NA
Triumph Group Inc. NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Turkish Aerospace Industries Inc. 0/2

There is no evidence that the SOE publishes details of its shareholder voting rights. The company publishes information on its major shareholders, but does not provide any accompanying details of the voting rights for each entity.

1/2

The company publishes its commercial and public policy objectives on its website. The company indicates that its primary objectives are to meet the country’s national security requirements, serve the Turkish Air Force and become a leader in the aerospace industry.

However, the company receives a score of ‘1’ because there is no evidence that these objectives are updated on at least an annual basis or whenever there is a change in objectives.

0/2

There is evidence that the company publishes some information on the composition of its board, including the names and positions of each board member. However, the company receives a score of ‘0’ because it does not provide any further information on the nomination and appointment process, nor does it indicate whether each board member is independent, non-executive or a state representative.

0/2

There is no evidence to indicate that the company has an audit committee.

0/2

There is no evidence that the company publishes any details about its management of asset transactions.

Ukroboronprom NA

The company publishes information to indicate that it is wholly-owned by the Ukrainian state and there is no evidence that any other entities hold shares or voting rights, so the company is exempt from scoring on this question.

1/2

There is evidence that the company publishes some information about its objectives, however it receives a score of ‘1’ because there is no clear evidence that these objectives are updated on at least an annual basis.

0/2

The company discloses the names of members of its board of directors but does not publish any further information about their roles or the nomination and appointment process.

0/2

There is no evidence that the company’s audit committee is composed of a majority of independent directors.

1/2

There is evidence that the company has a system in place to manage asset transactions, with responsibility held at board level.

However, it is unclear and not specified in publicly available evidence whether asset transactions are consistently subject to scrutiny by an audit body. There is also no clear evidence that all major asset transactions are documented. There is also no evidence that financial results from asset acquisitions are made publicly available by the company.

Ultra Electronics Holdings PLC NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

United Aircraft Corporation PJSC 0/2

There is no evidence that the company publishes details of its shareholder voting rights. The company’s shareholding structure indicates that the Russian government is the main controlling entity, but the company does not provide a percentage breakdown of voting rights per shareholder.

2/2

There is evidence that the company’s commercial and public policy objectives are made publicly available on its website and in its Annual Reports. There is also evidence that these objectives are updated on an annual basis.

0/2

The company publishes some information on the selection process for choosing board members and provides some details on the steps that it takes to verify independence. The company also publishes some information on the number of independent members and the number of state representatives on its board, however it should be noted that this information has not been updated due to a change in national legislation.

The company receives a score of ‘0’ because there is no evidence that it provides clear information on the board nomination and appointment process, nor is there evidence that it publishes current information on the status of its board members.

1/2

The company publishes a statement that its Audit Committee is composed exclusively of independent directors. However, there is no evidence that the company provides further details to support this statement in its most recently published Annual Report, such as the names and status of each board member on the Audit Committee.

0/2

There is no evidence that the company publishes any details about the management of asset transactions.

United Engine Corporation JSC 0/2

There is no evidence that the company publishes details of its shareholder voting rights.

1/2

The company publishes some information about its corporate objectives and activities, which include producing and developing products, services and research for the Ministry of Defence of the Russian Federation. However, the company receives a score of ‘1’ because there is no evidence that these objectives are updated at least on an annual basis.

0/2

There is no evidence that the company makes information about the composition, nomination and appointment of its board publicly available.

The company provides some information on its website to indicate which board members are executives and state employees, but does not disclose whether any individuals are financial beneficiaries. The information only identifies the General Director as a shareholder and does not disclose whether other members of the board are shareholders. In addition, there is no evidence that the company publishes any further information on the board nomination or appointment process.

0/2

There is no evidence that the company’s audit committee is composed of majority independent directors.

The company indicates that the Audit Committee must consist of at least three individuals and if independent directors are elected to the board, that at least one should be elected to the Audit Committee; however there is no evidence that the company has any independent directors nor does it state that its Audit Committee must be majority independent.

0/2

There is no evidence that the company publishes any details about its management of asset transactions, beyond noting that it complies with all laws as stipulated by the Russian Federation.

United Instrument Manufacturing Corporation 2/2

The company publishes a statement that it is wholly owned by “Rostec”, a Russian state-owned corporation, and clearly indicates that this entity is the sole owner of its shares and voting rights.

1/2

There is evidence that the company publishes some information about its strategic goals and objectives. However, the company receives a score of ‘1’ because there is no evidence that this information is current or updated on an annual basis.

0/2

There is evidence that the company publishes some information about the composition of the board on its website, however it does not provide details to indicate whether each individual has any connection to the company or the state, or whether they are an independent director. The company’s 2015 Annual Report provides some information on the composition of the board, however there is no indication that this is correct and up-to-date. There is also no evidence that the company publishes any information about the board nomination and appointment process.

0/2

There is no evidence that the company has an audit committee that is composed of a majority of independent directors.

1/2

Based on publicly available information, there is evidence that the company has a system in place to manage asset transactions, with responsibility for managing major transactions held at board level. There is evidence that all major transactions are recorded and documented. However, the company receives a score of ‘1’ because it is not clear whether asset transactions are subject to scrutiny by an audit body, nor is there evidence that the financial results from asset acquisitions are made publicly available in reporting documents.

United Shipbuilding Corporation JSC NA

There is evidence that the company is 100% owned by the Russian Federation, through an agency referred to as the Federal Property Management Agency. Since there is no evidence that any other entity holds shares or voting rights in the company, it is exempt from scoring on this question.

2/2

There is evidence that the company’s commercial and public policy objectives are made publicly available on its website. There is evidence that these objectives are updated on an annual basis or whenever there is a change in objectives.

1/2

The company publishes information about the composition of its board and provides details to indicate whether each board member is a financial beneficiary, executive or state representative. The company also provides publicly available information regarding the nomination and appointment process for board members, including how the final election decision is made.

The company indicates in its 2018 Annual Report that each board committee is chaired by an independent director, however it is not clear from publicly available information which board members (if any) are independent.

1/2

There is no clear evidence that the company’s audit committee is composed of a majority of independent directors. The company publishes information on the identity of those on the Audit Committee and publishes a statement that all board committees are chaired by independent directors, however it does not provide any further details on which members are independent so it is not clear that the committee is composed of a majority independent directors.

1/2

There is evidence that the company has a system in place, with responsibility assigned at board level, for managing asset transactions. The company provides information to indicate that all such transactions are documented, including those between the company and government departments or military, or if any of the latter make asset transactions on the company’s behalf. In addition, there is some evidence that financial results from asset acquisitions or disposals may be made available in the company’s financial reports, though the company notes that it has not conducted major transactions in the last two reporting years.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that its system for managing asset transactions includes oversight measures, for example through an audit body.

Uralvagonzavod JSC 0/2

The SOE does not publish a breakdown of its shareholder voting rights.

2/2

The SOE's commercial and public policy objectives are made publicly available on its website. There is evidence that these objectives are updated on an annual basis.

0/2

The company discloses insufficient information about the composition of its board of directors to satisfy the requirements to receive a score of ‘1’.

0/2

There is no evidence that the SOE's Audit Committee is composed of a majority of independent directors, as the structure of the company's Audit Committee is not disclosed.

0/2

The company states that independent appraisers should be involved in asset transactions. However, it is not clear from publicly available evidence whether responsibility for managing asset transactions is always held at board level, and there is no further detail regarding whether the company has a system to assure itself that asset transactions follow a transparent process to ensure they accord to market value.

Vectrus Inc. NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

ViaSat Inc. NA

N/A

NA

N/A

NA

N/A

NA

N/A

NA

N/A

Zastava Arms 0/2

There is no evidence that the company publishes details of its shareholder voting rights. Although there is some evidence that the company is at least partially owned by the government of Serbia, it is not clear whether other entities may hold shares or voting rights in the company.

1/2

The company publishes some information on its objectives, stating that its primary mission is to maintain a leading position in the market. However, the company receives a score of ‘1’ because these objectives are unclear and there is no evidence that they are comprehensive or updated on an annual basis.

0/2

There is no evidence that the company makes information about its board members publicly available.

0/2

There is no publicly available evidence that the company has an audit committee.

0/2

There is no evidence that the company publishes details about its management of asset transactions.