9. High Risk Markets

There is no evidence that the company acknowledges the corruption risks of operating in different markets, nor that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company publishes a list of its subsidiaries in its 2018 Annual Report, which includes information on the percentages owned by the company and the country of incorporation of each subsidiary. However, the company receives a score of ‘1’ because this list does not indicate the countries of operation for each entity.

The company discloses some information on the entities with significant holdings in the company, indicating that it is a public joint stock company with a small proportion of shares held by the Government of Abu Dhabi. The company receives a score of ‘1’ because this information is disclosed on the company’s website and not on a freely accessible central public register or in open data format. The company also states that 50% of shares are held by individuals, but does not indicate or disclose whether any individual within this owns more than 25% of shares or voting rights.

There is some evidence that the company’s primary defence customers are the United Arab Emirates (UAE) Armed Forces and Navy. The company’s Annual Report also indicates that it has contracts with the governments of Kuwait and Saudi Arabia. However, the company receives a score of ‘0’ because it does not provide this information in sufficient detail to indicate the percentage breakdown for its major its defence customers.

There is some evidence that the company recognises the corruption risks of operating in different markets, however there is no clear evidence that risk assessment procedures are used to design tailored mitigation plans or to inform the company’s operations in high risk markets.

The company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings. It also publishes the country of incorporation alongside each entity. There is evidence that the data is updated on an annual basis.

However, the company receives a score of ‘1’ because it is unclear if the published list includes all of the company‘s holdings, including all joint ventures, or whether it just includes the company’s main subsidiaries. In addition, the list does not include the percentage owned or information on the country of operation for each entity.

There is evidence that the company is publilcy listed on the New York Stock Exchange (NYSE) and therefore it is not required to disclose further information on its beneficial ownership to receive a score of ‘2’. The company also indicates that it is publicly listed in its Annual Report.

There is no evidence that the company publishes a percentage breakdown of its major defence customers. The company provides some summary information on the portion of revenue generated from each industry group, but this does not specifically refer to aerospace and defence and does not provide any information on its main customers.

There is evidence that the company acknowledges the corruption risks associated with operating in different markets and there is evidence that it has a dedicated assessment process in place to assess such risks. There is some evidence that these assessments trigger the implementation of additional controls.

However, this does not include clear risk management procedures and there is no evidence to suggest that the results of these assessments have an impact on business decisions.

There is evidence that the company provides a list of its subsidiaries. This includes the countries of incorporation.

However, company does not include the percentages owned or the subsidiaries’ countries of operation. Additionally, the list is not accompanied by a statement that it is complete at the time of publication to the best of the company’s knowledge and it is not clear whether the list includes all the company’s holdings.

The company is publicly listed on the New York Stock Exchange (‘NYSE’) and therefore automatically receives a score of ‘2’.

The company publishes the customers of less than 50% of its defence sales.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, nor that risk assessment procedures are used to inform the company’s operations in any higher risk markets.

There is evidence that the company publishes a list of fully consolidated subsidiaries and non-consolidated holdings, which includes the countries of incorporation of these entities and the percentage of ownership.

However, the company receives a score of ‘1’ because there is no evidence that the company publishes the country or countries of operation for each entity. In addition, there is evidence to suggest that this list only shows majority owned subsidiaries; it is therefore not clear that this list includes all of the company’s affiliated companies, including all non-fully consolidated holdings.

There is evidence that the company is publicly listed on the New York Stock Exchange (NYSE) and therefore it is not required to disclose further information on its beneficial ownership to receive a score of ‘2’.

There is evidence that the company publishes a breakdown of its sales by customer, to indicate that the United States government accounts for 94% of its total sales. The company provides further information on the end users of its products and services, which include two branches of the U.S. military, NASA and other government departments. This information is published on an annual basis as part of the company’s corporate reporting.

Although the company does not distinguish between defence and commercial sales, there is sufficient evidence to indicate that its sales primarily derive from defence sales and therefore the company receives a score of ‘2’.

Based on publicly available evidence, the company acknowledges the risks associated with operating in different markets and there is evidence that a risk assessment procedure is in place to account for specific risks associated with anti-money laundering/counter terrorism financing risks. There is evidence that these assessments impact business decisions to some extent. However, there is no evidence to suggest that the company’s risk assessment procedures cover bribery and corruption risks in different markets.

Based on publicly available evidence, the company discloses its fully consolidated and non-fully consolidating holdings, its percentage of ownership and their country of incorporation. This information is published annually. However, there is evidence that the company has other holdings which are not part of this list; it is therefore not clear that the company has disclosed a full list of its holdings and subsidiaries. Additionally, the company does not publish countries of operation for each of its subsidiaries.

Based on publicly available evidence, the company is a publicly listed company on the Paris, London and other international stock exchanges. It therefore automatically receives a score of ‘2’.

The company publishes some information about its defence customers. The company publishes defence sales by customer and the total number of aircraft ordered, delivered and in operation for its Military Aircraft programme. However, there are three other programme lines falling under Defence and Space for which information is not published. It is therefore not possible to deduce a breakdown of defence sales per customer.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

There is no evidence that the company publishes information on its subsidiaries or affiliated entities.

There is some evidence to indicate that the company is a state-owned enterprise owned by the Russian Federation. However, the company receives a score of ‘1’ because it does not provide publish clear information to indicate that the Russian government is its sole beneficial owner, nor does it publish a statement that no individual owns 25% or more of shares or voting rights. There is no information available in a publicly available and freely accessible companies register, nor is the company listed in the global beneficial ownership register Open Ownership.

There is no evidence that the company publishes any information about its defence sales by customer.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company publishes some information about its subsidiaries on its website, through separate pages describing each company’s activities. However, the information published is insufficient to score ‘1’ since the company does not publish the percentage ownership, country of incorporation and country of incorporation for each entity. It is also not clear whether the information is current or updated on at least an annual basis.

There is evidence that the company is fully state owned by the state of Egypt. The company receives a score of ‘1’ because it does not provide further information on its ownership and this information is not disclosed in open data format. There is also evidence that the Kingdom of Saudi Arabia, the United Arab Emirates and the State of Qatar are involved in the company’s governance, though it is not clear how or whether this is current.

The company publishes some information on the companies with which it operates overseas, however it does not publish any details about its main defence customers or sales.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

There is no evidence that the company publishes a list of its subsidiaries and non-fully consolidated holdings.

There is no evidence that the company discloses any information about its beneficial ownership or control structure, nor a statement that no individual owns 25% or more of shares or voting rights.

There is no evidence that the company provides a percentage breakdown of its defence sales by customer.

Based on publicly available information, there is no evidence that the company acknowledges the corruption risks of operating in different markets, nor that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company publishes details of its fully consolidated subsidiaries and non-fully consolidated holdings, including associates, joint ventures and other related entities. For each entity, the company discloses its percentage ownership and the country of incorporation, while also providing descriptions to indicate the country of operation. There is evidence that this list is current and updated on at least an annual basis.

There is evidence that the company discloses information about its beneficial ownership. The company is partially listed on the Istanbul Stock Exchange and discloses all shareholders on its website with a stake of 25% or higher. There is evidence that the company’s major shareholder is the Turkish Armed Forces Foundation, which is associated with the Turkish government. The company also discloses its shareholders in a publicly accessible central register in Turkey.

The company discloses that the Turkish government and several Turkish companies account for over 90% of total orders, and that non-defence orders account for 6% of total orders. Based on this evidence, there is evidence that public and private customers in Turkey represent the main customers for over 80% of the company’s defence sales. There is evidence that this data is correct and up to date up to the most recently reported financial year.

There is no publicly available evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company publishes a list of its subsidiaries and joint ventures as part of its annual reporting documents. For each entity, the company discloses the country of incorporation and the percentage ownership that it holds.

However, the company receives a score of ‘1’ because it is not clear whether the list includes non-fully consolidated holdings or any other related entities. There is also no evidence that the company publishes the country of operation for each entity.

There is evidence that the company discloses all of its beneficial owners with an ownership in the company of 25% or above. These entities and/or individuals are referred to in the company’s Annual Report by name, along with their percentage of issued share capital. There is also evidence that ownership information is available on the Australian Securities & Investment Commission site and that the company is publicly listed on the Australian Securities Exchange.

However, the company receives a score of ‘1’ because the company’s beneficial ownership information is not published in open data or machine readable format. Although information is available through the Australian Securities & Investment Commission site, this information requires payment and is therefore not publicly available. In addition, although the company is listed on the Australian Securities Exchange, this is not one of the specific regulated markets listed in the scoring guidance.

There is no evidence that the company publishes information about its defence sales in the form of a percentage breakdown by customer. The company mentions some of its main customers in its Annual Report and on its website, but it is not clear whether these represent commercial or defence customers (or both), nor does it provide further information to indicate the percentage sales per customer.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, nor that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company publishes a list of its subsidiaries, which includes information about the country of incorporation for each entity. However, the company receives a score of ‘1’ because it is not clear whether the companies listed are principal subsidiaries or joint ventures, or if they represent all of the company’s holdings. In addition, the company’s data does not include information on percentage ownership or country of operation. There is also no evidence to indicate whether the data is updated on at least an annual basis.

There is evidence to indicate that the company is a state-owned enterprise, with all shares held by Chinese government.

The company states that it is a major provider to the Chinese armed forces, without providing detail on sales figures or data representing a percentage of its overall sales. The company receives a score of ‘0’ because it does not disclose the countries or customers that represent at least 50% of its defence sales.

There is evidence the company acknowledges the corruption risks associated with operating in different markets, and there is evidence that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. The company indicates that the results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. The company provides examples of such possible controls, such as enhanced due diligence checks and a requirement for approval by the Group Chief Executive for seeking business in new markets.

There is evidence that the company publishes a list of its fully consolidated subsidiaries and non-fully consolidated holdings, including associated companies, joint ventures and other related entities. For each entity, the company discloses its percentage ownership and the country of incorporation.

However, the company receives a score of ‘1’ because there is no evidence that it publishes any clear information on the country or countries of operation for each entity.

There is evidence that the company is publicly listed, trading on the London Stock Exchange (LSE) and therefore it is not required to disclose further information on its beneficial ownership to receive a score of ‘2’.

The company publishes some information on its defence sales, indicating that the United Kingdom Ministry of Defence (MOD) is its single biggest customer. In addition, the company’s financial statements indicate that the United Kingdom accounted for approximately 66% of its sales in the most recently reported financial year; however this figure appears to include both commercial and defence sales.

The company receives a score of ‘1’ because it publishes its major customers that account for over 50% of its sales, despite not disaggregating commercial and defence sales, and there is some indication that the UK is its most significant defence customer.

Based on publicly available information, there is evidence that the company acknowledges the corruption risks associated with operating in different markets. There is evidence that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. There is some indication that the results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls.

There is evidence that the company publishes a list of its fully consolidated subsidiaries and non-fully consolidated holdings, including any associates, joint ventures and other related entities. For each entity, the company discloses its percentage ownership and for most entities the company provides the country of incorporation by publishing its registered address. There is evidence that this list is current and updated on at least an annual basis.

However, the company receives a score of ‘1’ because it does not publish the country of operation for each entity.

There is evidence that the company is publicly listed on the London Stock Exchange. Therefore, it is not required to disclose further information on its beneficial ownership structure and automatically receives a score of ‘2’, as per the scoring criteria.

There is evidence that the company publishes information about its defence sales in the form of a percentage breakdown per customer. The company provides a percentage breakdown of its major customers that account for 80 percent of its sales in its Annual Report. Although the company does not explicitly state that these percentages account for defence sales, it is sufficiently clear from the accompanying information that the figures provided primarily represent sales in the defence sector.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company publishes a full list of its fully consolidated subsidiaries and non-fully consolidated holdings, including associates, joint ventures and other related entities. For each entity, the company discloses its percentage ownership, and the country of incorporation. There is evidence that this list is current and updated on at least an annual basis. The list is accompanied by a statement that it is complete at the time of publication to the best of the company’s knowledge.

However, the company receives a score of ‘1’ because it does not list countries of operation for each subsidiary.

The company’s parent is publicly listed on the New York Stock Exchange and it therefore automatically receives a score of ‘2’.

The company does not publish the customers of its defence sales.

There is no readily available evidence that the institute is engaged in supplying goods or services, nor that it operates in markets or jurisdictions outside of the United States of America.

There is no evidence that the institute publishes a list of its subsidiaries or affiliated entities.

The institute is a non-profit organisation and therefore does not have shareholders.

There is no readily available evidence that the company engages in commercial or industry sales in the defence sector.

There is evidence that the company acknowledges the corruption risks associated with operating in different markets, and there is evidence that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. The results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls.

There is no evidence that the company discloses details of its fully consolidated subsidiaries or non-fully consolidated holdings.

Based on publicly available information, there is some evidence to suggest that the company may have subsidiaries or joint venture partners; however the company does not provide a list with percentages owned or further details necessary to satisfy the requirements of score ‘1’.

There is evidence that the company is privately owned; however, there is no publicly available evidence that the company discloses any information about its beneficial ownership or control structure. As such, it is not clear whether any individual owns 25% or more of its shares or voting rights. There is also no evidence that information about its shareholders is accessible in a publicly available and freely accessible companies register or in a global beneficial ownership register such as Open Ownership.

The company publishes information about its defence sales by customer, to indicate that over 90% of its defence contracts for the previous year were with the United States. There is evidence that this data is correct up to the most recently reported financial year. The company includes some additional information about its major projects in its Annual Report, however there is evidence to indicate that this includes all contracts and not just defence sales.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

There is no evidence that the company publishes a list of subsidiaries or other affiliated entities.

There is no evidence that the company publishes any information about its beneficial ownership or control structure, nor does it publish a statement that no individual owns 25% or more of shares or voting rights. Beneficial ownership information for the company does not appear to be available via the OpenOwnership register.

The company indicates on its website that it is an “authorised state exporter” and that it is part of the military industrial complex in Belarus, but does not provide any further information on whether this indicates state ownership or another ownership structure.

There is no evidence that the company publishes information about its defence sales in the form of a percentage breakdown by customer. The company provides a list of the countries with which it has “partnerships” on its website, but it does not provide further information on how this relates to defence sales and there is no evidence that this information is updated regularly.

There is no publicly available evidence that the company acknowledges the corruption risks of operating in different markets.

The company publishes a clear statement that it does not have any subsidiaries, joint ventures or associate companies. There is evidence that this statement is complete at the time of publication as it appears in the company’s Annual Report, and therefore it is understood that the statement is updated on an annual basis.

The company publishes details of its beneficial ownership structure, to indicate that it is partially state-owned with the President of India holding 87.75% of shares. The company also discloses the types of entities that hold the remaining shares.

The company receives a score of ’1’ because there is no evidence that the company discloses its beneficial ownership information in a freely-accessible central public register. There is evidence that the company has some shares listed on the National Stock Exchange of India, however this is not specified in the list of regulated markets outlined in the scoring criteria.

There is no evidence that the company publishes any information about its defence sales in the form of a percentage breakdown by customer. The company publishes high level figures of its total sales of products and services, and indicates that the Indian Ministry of Defence is its primary customer; however it does not provide this information in the form of an amount or percentage of the total sales, nor does it provide any information on its other significant customers.

There is some indication that the company acknowledges the risks associated with entering into new markets, however there is no evidence that the company acknowledges or manages the corruption risks associated with different markets, so the company receives a score of ‘0’.

There is some evidence that the company publishes a list of its consolidated and non-fully consolidated holdings. This list is updated on an annual basis and is accompanied by the date and signatures of the company’s leadership. The information includes the percentages owned, the country of incorporation and the country of operation for one entity. The company lists the “place of business” for the other two entities, which is understood to represent the country of incorporation.

The company publishes information about the beneficial ownership of shareholders with at least 5% of shares up to March 2019. The company’s publicly available information does not provide the names of the specific shareholding entities, and indicates that the Government of India holds between 58.83% and 68.19% of shares.

Furthermore, the company does not disclose its ownership in a freely-accessible central public register. It is noted that the company publicly lists shares on the National Stock Exchange of India and the Bombay Stock Exchange, however these exchanges are not specified on the list of regulated markets outlined in the scoring criteria.

There is evidence that the company publishes some information about its customers. However, this information is not provided in a format from which the percentage breakdown of defence sales by customer can be deduced, so the company receives a score of ‘0’.

There is no publicly available evidence that the company acknowledges the corruption risks of operating in different markets, nor is there evidence that risk assessment procedures are used to inform the company’s operations in high risk markets.

There is evidence that the company publishes a list of its significant subsidiaries as part of its annual corporate reporting documents. This list includes the country of incorporation for each entity.

However, the company receives a score of ‘1’ because there is evidence to indicate that this list only includes significant holdings as opposed to all of the company’s affiliates or holdings. There is also no evidence that the company publishes information on its percentage ownership or the countries of operation for each subsidiary.

There is evidence that the company is publicly listed on a regulated market in the United States, and therefore it is not required to disclose further information on its beneficial ownership in order to receive a score of ‘2’.

The company publishes some information on its sales per customer, to indicate that the United States government accounted for 31% of its revenue in 2018. In addition, the company publishes information in its Annual Report on its revenues by customer with reference to China and Canada, which combined with the United States figures accounts for 60% of the company’s major customers.

However, the company receives a score of ‘1’ because the information provided does not distinguish between revenue generated from defence and commercial customers.

There is evidence that the company acknowledges the corruption risks associated with operating in different markets, and there is evidence that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. The results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. The company provides some examples of possible controls.

There is evidence that the company publishes a list of subsidiaries, which includes details of the jurisdiction or country of incorporation for each entity. This list is published on an annual basis as part of the company’s reporting and is accompanied by a statement that it is complete at the time of publication to the best of the company’s knowledge.

However, there is no publicly available evidence that the company publishes further details of its percentage ownership in each entity, nor the relevant country or countries of operation. It is therefore not clear from publicly available information that this list represents all of the company’s fully and non-fully consolidated holdings such as associates, joint ventures and other entities.

There is evidence that the company is publicly listed on the New York Stock Exchange (NYSE) and therefore it is not required to disclose further information on its beneficial ownership to receive a score of ‘2’.

There is evidence that the company provides some information about its major customers, to indicate that the United States government and branches of the military account for a substantial portion of its defence sales. The company indicates that revenue from customers in the defence and intelligence sectors accounts for approximately 70% of its overall sales. There is evidence that this information is updated and published on an annual basis as part of the company’s annual corporate reporting.

However, the company receives a score of ‘1’ because it does not provide further publicly available information to indicate the major customers for 80% or more of its defence sales.

There some evidence that the company acknowledges some of the corruption risks of operating in different markets as part of its international business. However, there is no clear publicly available evidence to indicate that it has a risk management system in place to identify and address these corruption risk, nor is there clear evidence that the results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls.

There is some evidence that the company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings which is updated on an annual basis. This information includes a jurisdiction for each entity, which is understood to represent the country of incorporation.

However, the company receives a score of ‘1’ because there is no evidence that the company publishes its percentage ownership or the relevant country or countries of operation for each entity. In addition, the publicly available information indicates that this list includes significant subsidiaries, so therefore it is not clear that this list represents all of the company’s fully and non-fully consolidated holdings, joint ventures and other associates.

There is evidence that the company is publicly listed on the New York Stock Exchange (NYSE) and therefore it is not required to disclose further information on its beneficial ownership to receive a score of ‘2’. The company also indicates that it is publicly listed on the NYSE in its documents for investors.

There is evidence that the company publishes some information on its sales by customer, to indicate that the United States government is its most significant defence customer. The company indicates that U.S. Department of Defence (DoD) is its main departmental customer, accounting for 66% of total sales in the 2016 financial year. Since the other entities listed appear to be non-defence or commercial sales, there is sufficient evidence to indicate that the United States represents the majority of the company’s defence sales.

There is evidence that the company acknowledges the risks associated with operating in different markets, including some corruption risks. There is evidence that the company has a risk assessment process in place to account for these risks, with clear risk management procedures in place.

However, there is no clear evidence that risk assessment procedures which account for corruption risks are used to inform the company’s operations in high risk markets.

The company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings. For each entity, the company discloses its percentage ownership and the country of incorporation. This list includes all the company’s subsidiaries and non-wholly owned holdings, and is updated annually. The list is accompanied by an indication that it is complete at the time of publication.

However, the company receives a score of ‘1’ because the published information does not disclose the countries of operation of each entity.

The company is publicly listed on the New York Stock Exchange and is automatically awarded a score of ‘2’.

The company publishes information regarding its overall sales, however there is no evidence that it publishes a percentage breakdown of its defence sales by customer.

There is no evidence that the company acknowledges the corruption risks of operating in different markets.

The company does not publish a list of subsidiaries.

The company does not disclose any information about its beneficial ownership or control structure, nor a statement that no individual owns 25% or more of shares or voting rights. There is also no evidence that the company’s beneficial ownership information is available on a global register such as OpenOwnership or that the company is registered in any markets outside of Australia.

The company does not publish any details about its customers; however it appears that the company primarily supplies the Australian military (the Navy in particular). There is also evidence to suggest that the company supplies other international customers. Since the company does not disclose this information directly to indicate its major customers, it receives a score of ‘0’.

The company acknowledges the corruption risks associated with operating in different markets, and there is evidence that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. The results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. The company provides examples of such possible controls.

There is evidence that the company publishes a full list of its fully consolidated subsidiaries and non-fully consolidated holdings. For each entity, the company discloses its percentage ownership, the country of incorporation and countries of operation. There is evidence that this list is current and updated on at least an annual basis. The list is accompanied by a statement that it is complete at the time of publication to the best of the company’s knowledge.

The company is publicly listed on the London Stock Exchange and therefore automatically receives a score of ‘2’.

The company publishes a breakdown of its defence sales by customer, in the form of the percentage of its total defence sales by customer per year. The company publishes the customers of more than 80% of its defence sales.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company publishes a list of subsidiaries, and states that they are all registered in China.

However, the company receives a score of ‘1’ because it does not clearly state that the data presented represents all of the company’s holdings and it does not identify which companies are principal or significant subsidiaries and which are affiliates and joint ventures. The company also does not provide information regarding the country of operation of each entity or the company’s percentage ownership in each entity. Additionally, it is unclear if the information is updated on at least an annual basis or if it is current. The list is also not accompanied by a statement that it is complete at the time of publication to the best of the company’s knowledge.

There is no evidence that the company discloses any information regarding its beneficial ownership or control structure, nor a statement that no individual owns 25% or more of shares or voting rights.

The company receives a score of ‘0’ because it does not clearly disclose the customers of at least 50% of its defence sales. Although the company states that it is a supplier to China’s armed forces, it provides no specific information regarding an overall percentage of its sales and does not clarify if the Chinese military is its sole customer.

There is no publicly available evidence that the company acknowledges the corruption risks of operating in different markets or that risk assessment procedures are used to inform its operations in high risk markets. Although the company primarily operates in China, there is no clear evidence to suggest that this is the only market in which it operates. There is some indication that the company has risk management procedures in place for employees in certain positions, but there is no evidence that this is based on an assessment of the market risk.

There is evidence that the company publishes a list of its subsidiaries on its website, which all appear to be based in China.

However, the company receives a score of ‘1’ because it does not publish accompanying details for each entity such as percentage ownership, country of operation or country of incorporation. As a result, it is not clear whether the companies listed are principal or significant subsidiaries, joint ventures or other affiliated entities, and it is not clear that this list represents all of the company’s holdings. In addition, the company’s data includes no information on percentage ownership, incorporation or countries of operation. There is also no clear indication that the data is updated on an annual basis.

There is some evidence that the company is a state-owned enterprise in China. The company receives a score of ‘1’ because it does not provide further information on its beneficial ownership and this information is not disclosed in open data format.

There is no evidence that the company publishes information about its major defence sales or customers.

There is evidence that the company acknowledges the corruption risks associated with operating in different markets and there is evidence that it has a dedicated assessment process in place to assess such risks. In addition, there is evidence that the results of risk assessments have an impact on business decisions or trigger the implementation of additional controls as part of the annual Cobham Ethics & Compliance Programme Plan (CECP).

There is evidence that the company publishes a list of its fully consolidated subsidiaries and non-fully consolidated holdings, including associates, joint ventures and all other related entities. For each entity, the company discloses its percentage ownership and the country of incorporation. There is evidence that this list is current and updated on at least an annual basis and is accompanied by a statement that it is complete at the time of publication to the best of the company’s knowledge.

However, the company receives a score of ‘1’ because there is no evidence that it publishes the country or countries of operation for each entity.

There is evidence that the company discloses all beneficial owners with an ownership stake or voting rights of 25% or above. The company’s disclosure refers to all individuals and entities by name. There is evidence that this information is available in a freely accessible national corporate register.

However, the company receives a score of ‘1’ because there is no evidence that its beneficial ownership is available in open data format that is machine readable and structured.

The company publishes some information on its defence sales by customer, to indicate that the United States accounts for 38% of its defence and security sector revenue in the most recently reported financial year. The company indicates that a further 26% of its revenue is generated from defence and security sales to the United Kingdom and rest of the world.

The company receives a score of ‘1’ because it does not provide further information on the major customers that account for at least 50% of its defence and security revenue. The company provides some information on its overall revenue by geographic region, but this does not indicate specific countries/customers nor does it show defence sales specifically.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

There is evidence that the company, in its annual filing to the Securities and Exchange Commission, provides a list of its subsidiaries. This includes the company’s ownership percentage of the subsidiary and the country of incorporation.

However, the list is not accompanied by a statement that it is complete at the time of publication to the best of the company’s knowledge; it is consequently not clear whether the list includes all of the company’s holdings. Additionally, the company does not provide information on the subsidiaries’ countries of operation.

The company is a publicly listed company listed on the New York Stock Exchange (‘NYSE’) and therefore automatically receives a score of ‘2’.

There is no evidence that the company publishes details of its defence sales by customer. The company indicates that for its Cubic Global Defence segment, sales to international customers constituted 52% of its sales. However, the company provides no specific details with regard to these customers, and its assumed domestic sales do not meet the 50% threshold for the company to receive a score of ‘1’.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, nor that risk assessment procedures are used to inform the company’s operations in high risk markets.

There is no evidence that the company publishes a list of subsidiaries or affiliated entities.

The company is a publicly listed company on the New York Stock Exchange and is therefore not required to disclose information about its beneficial ownership. The company is automatically awarded a score of ‘2’.

There is evidence that the company publishes the total value and percentage breakdown of sales by business segment, with reference to defence sales. The company also publishes that 34% of its net sales were derived from the U.S. Government. However, the company receives a score of ‘0’ because it does not indicate the percentage breakdown of customers for the defence business segment specifically.

There is no publicly available evidence to indicate that the company acknowledges the corruption risks of operating in different markets.

The company publishes some information about its subsidiaries and joint ventures. There is evidence that this information is updated on an annual basis.

However, the company receives a score of ‘1’ because it is not clear that this list includes all of the company’s holdings. The company’s publicy available information also does not indicate the percentages owned, country of incorporation or countries of operation for each entity.

The company publishes information about its beneficial ownership in corporate reporting documents and in a freely accessible public register. In each case, identifiable information about the company’s significant shareholders is made publicly available.

The company is also publicly traded on the Korea Stock Exchange, though it is noted that this is not on the list of regulated markets mentioned in the scoring criteria.

The company publishes a percentage breakdown of its sales by product type and also discloses a number of its clients in the defence sector. However, the company does not provide a percentage breakdown to indicate at least 50% of its defence sales by customer.

There is no publicly available evidence that the company acknowledges the corruption risks of operating in different markets, nor that it has a risk assessment procedure in place to identify such risks.

Based on publicly available information, there is evidence that the company publishes a list of all of its consolidated subsidiaries and non-fully consolidated holdings. For each entity, the company lists a country which is understood to represent the headquarters and country of incorporation. There is evidence that the list is updated on an annual basis.

However, there is no evidence that the company’s list includes the percentage of ownership or the country of operation for each entity.

There is no publicly available evidence that the company publishes any information about its beneficial ownership or control structure. There is no evidence that the company publishes a statement that no individual owns 25% or more of its shares or voting rights, nor that its ownership information is available in a freely accessible national or global corporate register.

There is no publicly available evidence to indicate that the company publishes the customers of its defence sales.

Based on publicly available information, there is some evidence that the company has a risk assessment procedure in place that informs its operations and anti-corruption measures. However, there is no clear publicly available evidence that this process includes an assessment of the corruption risks of operating in different markets, nor is it clear that has risk management procedures that are used to inform the company’s operations in high risk markets.

There is some evidence that the company publishes information on its organisational structure on its website. The company indicates that it has three wholly-owned subsidiaries and that it holds some shares in one other company. For each entity, the company indicates its percentage ownership and a country, which is understood to represent the country of incorporation.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it provides details on the country or countries of operation for each entity. In addition, it is not clear that this list is updated on an annual basis, nor is there evidence to confirm that this chart represents all of the company’s fully consolidated and non-fully consolidated holdings such as associates, joint ventures and other related entities.

There is evidence that the company is publicly listed on multiple stock exchanges in the European Economic Area, and therefore it does not need to disclose further information on its beneficial ownership to receive a score of ‘2’. In addition, there is evidence that the company publishes information on its significant shareholding entities on its website and in its Annual Report.

There is no evidence that the company publishes clear information on its defence sales by customer. The company publishes some information on its significant orders and deliveries of certain products, however in publicly available evidence it does not indicate the customers of these orders nor does it provide a percentage breakdown of its defence sales by customer.

There is evidence that the company acknowledges the corruption risks associated with operating in different markets and that it has a dedicated assessment process in place to assess such risks.

However, there is no evidence that the policy includes clear risk management procedures. There is additionally no clear evidence to suggest that the results of the company's high risk market assessments have an impact on business decisions or trigger the implementation of additional controls.

There is no evidence that the company publishes a consolidated list of its subsidiaries. The company publishes a list of its ‘locations’ and it mentions its ‘businesses’, but it is not clear what relationship these entities have with the parent company.

There is no evidence that the company discloses its beneficial ownership on its own website. Company ownership information cannot be found through a publicly accessible corporate register. The company states that it is family-owned but does not clearly disclose the identities of its shareholders on its website.

There is no evidence that the company publishes any information about its major defence sales by customer.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets. There is no reference to high risk markets for corruption in the company’s description of its risk management procedures.

The company publishes a list of subsidiaries and non-fully consolidated holdings in its annual report. The list includes the countries of incorporation of the subsidiaries and percentages owned. However, the company receives a score of ‘1’ because the list does not include the countries of operation. The list is not accompanied by a statement that it is complete at the time of publication to the best of the company’s knowledge and it is therefore not clear whether this is a complete list of subsidiaries.

The company discloses its ownership by the South African state on its website. The company does not disclose details in an open data format, nor does it disclose its ownership in a freely available central public register.

There is no evidence that the company publishes details of its defence sales by customer. The company provides some information on sales by destination – which includes 45% of sales to South Africa – but does not provide details of other customers beyond regional percentages.

There is evidence that company acknowledges the corruption risks associated with operating in different markets, and there is evidence that it has a risk assessment process in place to account for these specific risks. The company indicates that the results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. The company also provides examples of these possible controls, such as on-site visits by the CCO or country-specific training.

The company publishes a list of its fully consolidated subsidiaries and non-fully consolidated holdings, including associates, and other related entities. For each entity, the company discloses its percentage ownership and the country of incorporation. There is evidence that this list is current and updated on at least an annual basis.

However, the company receives a score of ‘1’ because there is no evidence that it publishes details of the country or countries of operation for each entity.

The company indicates that it is a limited partnership entity managed by Diehl Verwaltungs-Stiftung. However, there is no evidence that the company publicly discloses information about its beneficial ownership or control structure, nor a statement that no individual owns 25% or more of shares or voting rights. There is some evidence that the company’s ownership information is available via a national corporate register, but there is no evidence that this information is freely accessible without a charge.

There is no evidence that the company discloses a percentage breakdown of its defence sales by customer. The company indicates that its defence business accounts for approximately 14% of its total sales, however it does not provide any publicly available information on its major customers.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company provides a list of its subsidiaries. This list includes the subsidiaries’ countries of incorporation.

However, the company does not include the percentages of ownership of the subsidiary, nor is the list accompanied by a statement that it is complete at the time of publication to the best of the company’s knowledge. It is consequently not clear whether the list includes all of the company’s holdings. Additionally, the company does not provide information on the subsidiaries’ countries of operation.

The company discloses information on its controlling shareholder on its website.

However, it does not disclose full details regarding beneficial owners of the company and the information is not disclosed in an open data format or in a freely accessible public register.

The company discloses that the United States government accounted for 96% of its revenue for the year ended 31 December 2018. There is evidence that this information is published on an annual basis.

Based on publicly available information, there is evidence that the company acknowledges the corruption risks associated with operating in different markets. There is some evidence that the company has mechanisms to assist in identifying such risks and that it has a management system in place which involves reporting red flags to the Legal Department or CCO.

However, the company receives a score of ‘1’ because it is not clear from publicly available information that the results of risk assessments have a direct impact on business decisions and are used to inform the development and implementation of additional controls.

There is evidence that the company publishes a list of its major subsidiaries on an annual basis. However, the company receives a score of ‘1’ because this list does not include public details of the percentage ownership, country of incorporation and country or countries of operation for each entity. It is also not clear that this list includes all of the company’s fully and non-fully consolidated holdings including all associates, joint ventures and other related entities.

There is evidence that the company is publicly traded on the Tel Aviv Stock Exchange. Based on the scoring criteria, the company is not required to provide further details of its beneficial ownership to receive a score of ‘2’.

There is evidence that the company publishes some information about its defence sales by customer. The company indicates that, for its most recently reported financial year, Israel accounted for 20.1% of its sales and it provides further information on the rest of its sales in the form of percentages per geographic region.

However, the company receives a score of ‘0’ because it does not publish information about its customers for at least 50% of its defence sales. The company also does not indicate whether this data represents defence or non-defence sales, or both.

Based on publicly available information, there is no clear evidence that risk assessment procedures are used to inform the company’s operations in markets at high risk of corruption.

There is evidence that the company publishes a list of its subsidiaries, holdings and joint venture partnerships, including information on the percentage ownership and the country of incorporation. There is evidence that this evidence is published and updated on an annual basis, as part of the company’s Financial Statements.

However, the company receives a score of ‘1’ because there is no evidence that the list includes the countries of operation for each entity.

There is evidence that the company is publicly listed on several global markets, including the New York Stock Exchange. Based on the scoring criteria, the company is therefore not required to provide further details of its beneficial ownership and automatically receives a score of ‘2’.

In addition, the company indicates that the Brazilian government holds one “golden share”, which provides it with veto rights in certain circumstances. This is understood to represent a meaningful minority of shareholder value.

There is evidence that the company publishes some information about its defence sales by customer. The company indicates that, for its most recently reported financial year, the Brazilian government accounted for 48.1% of its sales.

However, the company receives a score of ‘0’ because there is no evidence that it publishes information about its customers for at least 50% of its defence sales, nor that it indicates whether this data represents defence or non-defence sales, or both.

Based on publicly available information, there is some evidence that the company acknowledges the corruption risks associated with operating in different markets. The company indicates that its sales representatives take certain risks into account in the conduct of business, such as those related to ownership structures and country of operation.

However, the company receives a score of ‘0’ because there is no further evidence that risk assessment procedures are used to inform the company’s operations in high risk markets. There is also no evidence that assessments have an impact on business decisions or trigger the implementation of additional controls.

There is evidence that the company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings. However, the company receives a score of ‘1’ because there is no evidence that the company discloses the percentage ownership for each entity, nor the countries of incorporation and operation for each entity. There is also no clear evidence that this information is published and updated on an annual basis.

The company discloses the name of its controlling shareholder and parent company, CSG Holding, and provides shareholding information for this entity to indicate that it is privately owned.

However, the company receives a score of ‘1’ because it does not provide further information on its beneficial ownership. There is no evidence that the company publishes a complete breakdown of its ownership structure to confirm whether it might have other shareholders, nor is there evidence that this information is available in a freely accessible public register.

There is no evidence that the company publishes any information about its defence sales.

Based on publicly available information, there is evidence that the company acknowledges the corruption risks associated with operating in different markets and there is evidence that it has a process in place to assess such risks. However, it is not clear whether the results of these assessments have an impact on business decisions or trigger the implementation of additional controls.

The company publishes a list of all of its consolidated subsidiaries and non-fully consolidated holdings. The list includes the percentages owned and countries of incorporation and operation for each entity. It is updated on at least an annual basis.

There is evidence that the company is a publicly listed company with voting shares admitted to trading on a regulated market in the European Economic Area. Based on the scoring criteria, the company therefore automatically receives a score of ‘2’.

In addition, it is noted that the company provides a breakdown of its shareholding structure on its website. There is evidence that a company by the name of CDP Industria S.p.A. holds 71.32% of its share capital, and that this entity is majority owned by Italy’s Ministry of Economy and Finance.

There is evidence that the company publicly discloses some of its major customers. However, the company does not publish any data or percentages in relation to its defence sales.

There is evidence that the company acknowledges the corruption risks associated with operating in different markets and there is evidence that it has a dedicated assessment process in place to assess such risks. The company indicates that the results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls, which are reviewed and updated as needed throughout the duration of the project or business relationship.

There is evidence that the company publishes a list of its fully consolidated subsidiaries and non-fully consolidated holdings, including any associates, joint ventures and other related entities. For each entity, the company discloses its percentage ownership and the country of incorporation. There is evidence that this list is current and updated on at least an annual basis, since it is published as part of the company’s annual reporting documents.

However, the company receives a score of ‘1’ because there is no evidence that it clearly publishes the country or countries of operation for each entity.

There is evidence that the company is publicly listed, trading on regulated markets in the United States, United Kingdom and elsewhere, and is therefore not required to disclose further information on its beneficial ownership. In addition, the company publishes information on its significant shareholders as part of its annual reporting documents.

There is no evidence that the company publishes any information on its defence sales by customer. The company publishes some information to indicate the main geographic regions in which it generated revenue in the most recently reported financial year, which suggests that the United States is the company’s biggest customer. However, the company identifies the customers for less than 50% of this revenue and the information does not distinguish between defence and commercial projects, so the company receives a score of ‘0’.

In publicly available information the company acknowledges the corruption risks associated with operating in different markets, and there is evidence that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures. The results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls.

The company publishes a list of its major subsidiaries and associated companies on an annual basis. The company lists its percentage voting rights in each entity.

However, the evidence suggests this is not a full list of all the company’s holdings. While the company lists the country of each entity, it is unclear whether this relates to the country of incorporation or operation.

The company is a publicly listed on the Tokyo and Nagoya stock exchanges and therefore automatically receives a score of ‘2’. The company also publishes a list of its major shareholders on its website.

There is no evidence that the company publishes a breakdown of its defence sales by customer.

There is evidence that the company acknowledges the corruption risks associated with operating in different markets, and there is evidence that it has an assessment process in place to account for these specific risks, with risk management procedures in place. There is evidence that the results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. The company provides examples of such controls.

There is evidence that the company publishes a list of its fully consolidated subsidiaries. For each entity, the company publishes information on the percentage ownership and country of incorporation. There is evidence that this information is published and updated on an annual basis.

However, the company receives a score of ‘1’ because there is no evidence that it publishes the country or countries of operation for each entity. There is also evidence to indicate that this list only shows principal affiliates as opposed to a comprehensive list of all of the company’s fully consolidated and non-fully consolidated holdings.

There is evidence that the company is a subsidiary of General Electric, which is publicly listed on the New York Stock Exchange. The company is therefore not required to disclose further information on its beneficial ownership to receive a score of ‘2’. In addition, the company publishes details of its two major shareholders with a stake over 5% in its corporate reporting documents.

There is evidence that the company publishes some information on its defence sales, to indicate that the United States government accounts for 5% of its total revenue and that defence-related sales account for 5% of its total revenue. There is some indication that the company provides products and services for Airbus and Boeing.

The company receives a score of ‘0’ because it does not publish clear information about the main recipients of its defence sales, to indicate the customers for approximately 50% of its defence sales.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, nor that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company publishes a list of affiliated companies, which appears to include consolidated subsidiaries and non-fully consolidated holdings.

However, the company receives a score of ‘1’ because this list does not include the percentage ownership, country of incorporation and/or countries of operation for each entity. There is also no evidence that the list is updated on an annual basis, nor is it accompanied by a statement that it is complete at the time of publication to the best of the company’s knowledge.

There is no evidence that the company publishes any information about its beneficial ownership or control structure, nor a statement that no individual owns 25% or more of shares or voting rights.

There is no evidence that the company publishes any information about its defence sales in the form of a percentage breakdown by customer.

There is no clear evidence that the company acknowledges the corruption risks of operating in different markets, nor is there evidence that it has a risk assessment procedure in place to identify such risks. The company acknowledges the financial and legal risks from operating internationally, but there is no evidence that this recognition goes beyond compliance with regulations or that it specifically includes corruption risks.

There is evidence that the company publishes details of its fully consolidated subsidiaries. For each entity, the company discloses its percentage voting power – which is understood to also reflect the percentage ownership – and the country or place of incorporation.

However, the company receives a score of ‘1’ because there is no evidence that the company publishes the country of operation for each entity. It is also not clear whether this list includes all of the company’s holdings, since it does not appear to include non-fully consolidated entities such as joint ventures or associates.

There is evidence that the company is publicly listed on the New York Stock Exchange and is therefore not required to further disclose information on its beneficial ownership. Based on the scoring criteria, the company receives a score of ‘2’.

The company publishes information on its sales by customer to indicate that the U.S. Government accounted for 66% of its sales in the most recently reported financial year. There is evidence that this information is published annually, as part of the company’s Annual Report.

However, the company receives a score of ‘1’ because it does not clearly provide figures to distinguish between defence and commercial sales and does not indicate its main defence customers for 80% of its sales. Although the company identifies the U.S. Deoartment of Defense as its primary customer, it is not clear whether the remaining U.S. government sales are defence or commercial. In addition, the company provides information on its revenue by geographic region, but this appears to include total sales across divisions.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company does not publish a list of its subsidiaries.

The company is a wholly-owned subsidiary of a UK-listed company, Melrose Industries Plc. It therefore automatically receives a score of ‘2’.

The company publishes a percentage breakdown of its sales by customer, accounting for 71% of its sales. The company indicates that 29% of its total sales are defence-related.

However, it is not clear which customers comprise its defence sales. It is also unclear whether this data is updated on an annual basis.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

There is no evidence that the company publishes a list of its subsidiaries or affiliated entities.

There is no evidence that the company discloses any information about its beneficial ownership or control structure, nor a statement that no individual owns 25% or more of shares or voting rights.

There is some evidence on both the company’s website and on OpenOwnership that Gaston Glock – the company’s founder and managing director – may be the beneficial owner of an entity affiliated with the company, which suggests that this individual may be a beneficial owner of Glock Ges.m.b.H. However, this evidence is insufficiently detailed to provide clarity on the company’s beneficial ownership and therefore the company receives a score of ‘0’.

There is no evidence that the company publishes any information about its defence sales.

Based on publicly available information, there is evidence that the company acknowledges the corruption risks associated with operating in different markets. There is evidence that it has a designated risk assessment process to account for these specific risks, with clear risk management procedures in place. The results of risk assessments inform the development and implementation of additional controls and there is evidence the company provides examples of such possible controls.

Based on publicly available information, there is evidence that the company publishes a list of its fully consolidated subsidiaries and non-fully consolidated subsidiaries. For each entity, the company discloses its percentage ownership and the country of incorporation and operation. There is evidence that this list is current and updated on at least an annual basis.

There is evidence that the company discloses all entities with an ownership in the company of 5% or above. In addition, there is evidence to indicate that the company is publicly traded on the Korea Exchange (KEX).

However, the company receives a score of ’1’ because there is no evidence that this information is available in open data format or in a freely accessible public register. Although the company is publicly traded, there is no evidence that it trades on one of the regulated markets with beneficial ownership requirements as listed in the scoring criteria.

There is evidence that the company publishes some information on its major customers. The company lists its major customers for each significant business division (aviation and defence) and provides information on the total revenue generated from each division as part of its finanical statements.

However, the company receives a score of ’0’ because it does not publish clear information to show the percentage breakdown of its defence sales or revenue per major customer.

Based on publicly available information, there is evidence that the company acknowledges the corruption risks associated with operating in different markets and that it has a dedicated assessment process in place to assess such risks. There is evidence to suggest that the results of these assessments have an impact on business decisions and trigger the implementation of additional controls.

There is evidence that the company publishes a list of its principal consolidated subsidiaries and affiliates on an annual basis. This list includes information on the country of incorporation for each entity.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it discloses the percentage ownership and the country or countries of operation for each entity. The company’s publicly available evidence also indicates that the list only contains information on principal subsidiaries and affiliates, and therefore it is not clear that the list represents all of the company’s holdings.

There is evidence that the company is a publicly listed entity trading on the New York Stock Exchange (NYSE) and therefore it is not required to disclose further information on its beneficial ownership in order to receive a score of ‘2’.

There is no evidence that the company publishes any information on its defence sales by customer.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company’s parent company publishes a list of the company’s subsidiaries. The list does not include percentage ownership data so it is unclear whether these companies are 100% owned by the company or whether they are joint ventures or non-fully consolidated holdings. In its most recent published Annual Report from 2014, the company publishes a list of its wholly-owned subsidiaries alongside ownership data on all its holdings and information on these companies’ incorporation.

The company receives a score of ‘1’ because there is no evidence that the company has made more recent information on its shareholdings publicly accessible and the list of subsidiaries is not clear regarding the type of incorporation.

The company discloses that it is a subsidiary of Rostec, a state-owned entity, without providing further details. According to information published by Rostec, it owns 100% of the company’s share capital. The company does not publish ownership data on a central public register.

There is no evidence that the company publishes the customers of at least 50% of its defence sales.

There is no publicly available evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets

The company publishes a full list of its fully consolidated subsidiaries and non-fully consolidated holdings, including joint ventures and related entities. For all entities, the company discloses its percentage ownership, the country of incorporation and countries of operation. There is evidence that this list is current and updated on at least an annual basis. The data is also accompanied by a statement that it is complete at the time of publication to the best of the company’s knowledge.

The company discloses all shareholders with a stake in the company or voting rights of 25% or above, alongside each entity’s percentage ownership in the company. The company is also publicly traded on two Indian stock exchanges.

However, the company receives a score of ‘1’ because the company does not disclose its beneficial ownership information on a freely available and accessible public register.

There is no evidence that the company discloses the customer of at least 50% of its defence sales.

There is some evidence that the company acknowledges the risks of operating in different markets. However, there is no clear publicly available evidence that the company has a corruption risk assessment and management procedure in place to identify these specific risks, nor is it clear that the results of risk assessments have a direct impact on business decisions.

There is evidence that the company publishes a list of its fully consolidated and majority-held subsidiaries. For each entity, the company provides details of its percentage ownership and the country of incorporation. The company publishes this information on at least an annual basis.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it publishes information on its non-fully consolidated or minority holdings, nor is there evidence that it discloses the country or countries of operation for each entity.

There is evidence that the company is publicly listed on the New York Stock Exchange (NYSE), and therefore it does not need to disclose further information on its beneficial ownership to receive a score of ‘2’. In addition, the company publicly discloses all shareholders that own over 5% stakes in the company in its Proxy Statement, indicating that no natural person owns 25% or more of shares or voting rights in the company.

The company publishes some information on its defence sales, to indicate that its sales to the United States Department of Defense (DoD) accounted for US$2,832 million in sales in 2018. The company publishes figures on its overall sales to indicate that the United States is its biggest customer across all divisions.

However, the company receives a score of ‘0’ because it does not publish further information on its major customers, nor does it distinguish between defence and commercial sales. It is therefore not clear whether the United States accounted for more than 50% of the company’s defence sales in 2018.

The company acknowledges the corruption risks associated with operating in different markets and there is evidence that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. The results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. The company provides examples of such possible controls.

In its annual filing to the Securities and Exchange Commission the company provides a list of its subsidiaries. This includes the company’s ownership percentage of the subsidiary and the jurisdiction of incorporation.

However, there is no evidence that the list is complete or up to date. Additionally, the company does not provide information on the subsidiaries’ countries of operation.

The company is listed on the New York Stock Exchange and therefore automatically receives a score of ‘2’.

In its annual report, the company indicates that in each of the last three years its contracts with the US government accounted for over 95% of its revenues both where it is the prime contractor and when it is a subcontractor. The company is only active in the defence sector.

There is no publicly available evidence that the company acknowledges the corruption risks of operating in different markets, nor that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company publishes some information on its affiliates, ordered by industry. However, the company receives a score of ‘0’ because it does not provide further details of these entities, such as the percentage ownership, country of incorporation and country/countries of operation. There is also no evidence to clearly indicate how frequently this information is updated.

The company publishes some information about its beneficial ownership, which identifies major shareholders with a stake of 25% or higher; however, there is evidence to indicate that this information dates from 2016 and 2017, so therefore it is not clear that this ownership structure is up-to-date. The company has not published more recent beneficial ownership information on its website, and there is no indication that the company discloses its ownership in a freely available central public register.

It is noted that the company is publicly listed, however it does not have voting shares admitted to trading on one of the regulated markets listed in the scoring criteria so is not eligible for a score of ‘2’.

There is no evidence that the company publishes any information on its defence sales by customer.

Based on publicly available information, there is some evidence that the company acknowledges the corruption risks associated with operating in different markets. However, there is no clear evidence that the company has procedures in place to conduct corruption-specific risk assessments, nor that such assessments have a direct impact on business decisions or inform the company’s operations in high risk markets.

The company publishes some information on its main affiliates and associated companies, including domestic and overseas entities. The company makes specific reference to a country for each overseas entity, which is understood to reflect the country of incorporation.

However, there is no publicly available evidence that the company publishes further information such as its percentage ownership and country or countries of operation for each entity. It is also not clear based on publicly available information whether this represents a complete list of the company’s subsidiaries, and there is also no evidence that the information is updated on an annual basis.

There is evidence that the company is publicly listed on the Tokyo Stock Exchange (TYO) and therefore it is not required to disclose further information on its beneficial ownership in order to receive a score of ‘2’. The company also publishes information about its major shareholders on its website.

There is evidence that the company publishes some information on its sales by region, to indicate that Japan accounts for a significant proportion (though less than 50%) of its total sales. However, the company does not disaggregate defence and commercial sales, and as such there is no evidence that the company publishes information on the customers of its defence-specific sales.

There is no publicly available evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

There is evidence company publishes some information about its subsidiaries, including some information about their countries of incorporation. The company indicates that at least two of its subsidiaries are fully-owned.

However, the company receives a score of ‘1’ because there is no publicly available evidence that the company publishes information on the percentage ownership and country or countries of operation for each entity. It is also not clear whether this represents a complete list of the company’s fully and non-fully consolidated holdings, including associates and joint ventures, or whether this list is updated on an annual basis.

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.

There is no publicly available evidence that the company publishes information on its major customers.

There is no publicly available evidence to indicate that the company acknowledges the corruption risks of operating in different markets.

The company publishes a list of its factories but there is no evidence it publishes a list of its corporate subsidiaries.

There is evidence indicating the company falls under the control of the Indian Ministry of Defence. However, the company receives a score of ‘1’ because there is no evidence that it publishes specific details concerning its control structure, nor is there evidence that it provides clear information to indicate that the Ministry is its sole beneficial owner.

The company publishes some information on its defence sales by customer. However, there is no evidence that this information is provided as a percentage and it is therefore unclear whether this constitutes at least 50 percent of its defence sales.

There is evidence the company acknowledges the corruption risks associated with operating in different markets, and that it has a risk assessment process in place to account for these specific risks, with procedures in place. The results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. The company indicates that it reviews the country of delivery and customer reputation when reviewing bids.

There is evidence that the company publishes a list of its fully consolidated subsidiaries and non-fully consolidated holdings, including associates, joint ventures and other related entities. For each entity, the company discloses its percentage ownership. There is evidence that this list is current and updated on an annual basis.

However, there is no evidence that the company publishes the country or countries of operation for each entity. In addition, although the company also publishes the country of incorporation for some affiliated entities, there is no evidence that it discloses such details for all relevant entities.

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 to receive a score of ‘2’.

The company also publishes information on its major shareholders in its Annual Report, which indicates that the company is partially owned by the Sociedad Estatal de Participaciones Industriales S.A., a Spanish state holding company.

There is some evidence that the company publishes any information on its sales by customer. The company provides some information on its total sales by geographic area to indicate that its two largest clients are Spain and the United States, which account for approximately 70% of its sales. However, the company receives a score of ‘1’ because in publicly available evidence the company does not distinguish between defence and commercial sales.

Based on publicly available information, there is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company does not publish a list of subsidiaries.

The company discloses that it is wholly-owned by the State of Israel.

The company publishes the customers of less than 50% of its sales.

There is no publicly available evidence that the company acknowledges the potential corruption risks of operating in different markets, nor that it conducts risk assessments to identify such risks.

There is evidence that the company publishes a list of its subsidiaries and affiliates on its website. The company publishes the registered address for each entity, which is understood to represent the country of incorporation.

However, the company receives a score of ‘1’ because it is not clear whether this list includes joint ventures and it does not include further details such as the percentage ownership and countries of incorporation for each entity. In addition, there is no evidence that the list is updated on an annual basis and therefore it is not clear whether the list is complete at the time of publication, to the best of the company’s knowledge.

The company publishes information about its beneficial owners on its website, indicating that three major shareholders.

However, the company receives a score of ‘1’ because this information is not disclosed in an open data format and it is only disclosed on its website. Company data may be disclosed on a national corporate register, but this platform requires payment to access the information so is not considered ‘accessible’. To score ‘2’, the company should disclose its information on a global public register such as OpenOwnership.

There is no evidence that the company publishes information about its defence sales in the form of a percentage breakdown by customer.

There is no clear publicly available evidence that the company acknowledges the corruption risks of operating in different markets, nor that risk assessment procedures are used to inform the company’s operations in high risk markets. The company publishes some information on its risk management procedures, but there is no evidence that these procedures address market risk.

There is evidence that the company publishes a list of its major subsidiaries and associated companies, which is updated on an annual basis.

However, the company receives a score of ‘1’ because the it does not provide full details of its subsidiaries and associates, such as the percentage ownership, country of incorporation or country of operation for each entity.

There is evidence that the company is publicly listed on the Tokyo Stock Exchange and Nagoya Stock Exchange, so therefore it is not required to further disclose its beneficial ownership information and automatically scores ‘2’ as per the scoring criteria. The company also publishes information about its major shareholders in its Annual Report.

The company publishes some information about its sales, to indicate that Japan and the United States are its two major customers. The company also indicates that the Japanese Ministry of Defense is its major customer. However, the company receives a score of ‘0’ because it is not clear whether the geographic information provided relates to defence sales specifically or total company sales for defence and non-defence products and services.

There is evidence that the company acknowledges the corruption risks associated with operating in different markets and there is evidence that it has a dedicated assessment process in place to assess such risks. The company suggests that the results of such assessments may impact business decisions.

However, there is no publicly available evidence that the company publishes details of its clear risk management procedures nor is it clear that the results of risk assessments trigger the implementation of additional controls.

There is evidence that the company publishes details of its fully consolidated subsidiaries and non-fully consolidated holdings. There is evidence that this list includes all of the company’s material subsidiaries and significant joint ventures, along with its percentage ownership for some entities and the country or jurisdiction of incorporation for all entities. It is clear that this information is published annually as part of the company’s annual corporate reporting.

However, the company receives a score of ‘1’ because it is not clear that this list represents all of the company’s holdings and associates, including entities in which the company has non-significant ownership or control. There is also no publicly available evidence that the list includes the percentage ownership and country or countries of operation for each associated entity.

There is evidence that the company is publicly listed on the New York Stock Exchange (NYSE) and therefore it is not required to disclose further information on its beneficial ownership to receive a score of ‘2’. The company also discloses all beneficial owners with ownership or voting rights of 5% or above on its website.

There is evidence that the company publishes a breakdown of its sales per customer, to indicate that the United States and United Kingdom governments accounted for 65% of its total sales in the most recently reported financial year. There is evidence that this data is correct up to the most recently reported financial year.

However, he company receives a score of ‘1’ because there is no evidence that it publishes information on its defence sales specifically nor is it clear that it publishes details of its customers for more than 80% of its sales.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company publishes a list of its subsidiaries along with links to their respective websites. However, the company receives a score of ‘0’ because the information published is insufficient to satisfy the requirements of score ‘1’. For example, the company does not distinguish between fully and non-fully consolidated holdings by publishing the percentages owned for each entity, nor does it provide information on the country of incorporation or country of operation for each entity. It is also not clear whether this list is a complete or up-to-date list of all the company’s holdings.

The company does not disclose detailed information about its beneficial ownership and control structure. However, there is evidence that the company is a government entity affiliated with the Jordan Armed Forces and this information is sufficient to indicate state ownership. The company therefore receives a score of ‘1’.

The company does not publish information about its defence sales by customer. Although there is some evidence that the company’s main customer is the Jordan Armed Forces, this evidence is in the form of a simple statement rather than a percentage breakdown. The company therefore receives a score of '0'.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

There is evidence that the company publishes a list of its consolidated and non-fully consolidated holdings. For each entity, the company publishes its percentage voting rights – which is understood to reflect percentage ownership – as well as the country of operation and incorporation. There is evidence that this list is current and updated on an annual basis due to the fact that the information is published in the Annual Report.

The company is a publicly listed entity at the Tokyo Stock Exchange and therefore automatically receives a score of ‘2’. There is also evidence that the company publishes general information on its beneficial ownership in its Annual Report.

There is no evidence that the company publishes a percentage breakdown of its defence sales by customer.

Based on publicly available information, there is evidence that the company acknowledges the corruption risks associated with operating in different markets and that it has an assessment process in place to assess such risks. This includes clear risk management procedures and there is evidence that the results of these assessments have an impact on business decisions and trigger the implementation of additional controls.

Based on publicly available information, there is evidence that the company publishes a list of its consolidated subsidiaries and some of its non-fully consolidated holdings. The lists include percentage of holdings, countries of incorporation and are updated on at least an annual basis.

However, it is not clear that the company has included all of its joint ventures and associated companies, or the countries of operation for each entity.

Based on publicly available information, the company is listed on the Oslo Stock Exchange, along with several other stock exchanges in the European Economic Area. It therefore automatically receives a score of ‘2’.

There is no publicly available evidence to indicate that the company publishes a percentage breakdown of its defence sales by customer.

There is no publicly available evidence to indicate that the company acknowledges the corruption risks of operating in different markets, nor that it has a risk assessment procedure in place to identify such risks.

Based on publicly available information, there is evidence that the company publishes lists of its consolidated subsidiaries and non-fully consolidated holdings. The company’s lists indicate the percentage ownership and the countries of incorporation for each entity. There is evidence that these lists are updated on an annual basis.

However, the company receives a score of ‘1’ because there is no evidence that it publishes the country or countries of operation for each entity.

There is evidence that the company publishes information on the entities with significant holdings in the company. In its annual report the company states that approximately 60% of its equity is held by institutional investors, with only one shareholder having a stake higher than 25%.

However, the company receives a score of ‘1’ because it does not disclose this information in an open data format and there is no evidence that its information is available through a national or global corporate register. Although the company is publicly listed in South Korea, its voting shares are not admitted to one of the regulated markets specified in the guidance.

There is no evidence that the company publishes information on its defence sales by customer. The company publishes some information on its overall revenue from its defence business, however there is no evidence that it provides any details on its major customers.

There is no publicly available evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company publishes some information regarding its subsidiaries on its website but the information published is insufficiently detailed to satisfy the requirements to receive a score of ‘1’.

The company does not disclose information about its beneficial ownership or control structure, nor a statement that no individual owns 25% or more of shares or voting rights.

The company does not publish a percentage breakdown of its defence sales.

There is some evidence that the company acknowledges the increased corruption risks of operating in different markets. However, the company scores ‘0’ because there is no clear publicly available evidence that risk assessments are used to develop tailored mitigation plans or to inform the company’s operations in high risk markets.

There is evidence that the company publishes a list of its fully consolidated subsidiaries and non-fully consolidated holdings on an annual basis. For each entity, the company indicates its full registered name and country of incorporation. The list indicates which subsidiaries are not wholly-owned by the company.

However, there is no evidence that the company publishes the specific percentage ownership for each entity that is not wholly-owned, nor does it publish information on the country or countries of operation for each entity. It is also not clear that this list represents all of the company’s holdings.

There is evidence that the company is publicly listed on the New York Stock Exchange (NYSE) and therefore it is not required to publish further information on its beneficial ownership in order to receive a score of ‘2’. The company also discloses all shareholders with a stake greater than 5% in its Annual Report.

There is evidence that the company publishes some information on its sales by customer, to indicate that the United States government accounted for 77% of its total sales in its most recently reported financial year. The company indicates that its sales primarily relate to defence products and services, though it does not clearly distinguish between its defence and commercial sales.

However, the company receives a score of ‘1’ because there is no evidence that it publishes information on its major customers for defence sales specifically.

There is evidence to indicate that the company performs enhanced due diligence checks on intermediaries in high risk markets. The company, however, receives a score of ‘1’ because it does not clearly state that it uses corruption risk assessments more broadly to inform its operations in high risk markets.

There is evidence that the company publishes a list of its subsidiaries, which provides information on the country or jurisdiction/state in which the company is incorporated. There is evidence that the company publishes this information on an annual basis.

However, the company receives a score of ‘1’ because there is no publicly available evidence that it publishes information on its percentage ownership of each subsidiary or holding, nor information on the country of operation of each company. It is also not clear that the data published represents all of its holdings nor does it indicate which companies are significant subsidiaries or joint venture partners.

There is evidence that the company is publicly traded on the New York Stock Exchange (NYSE) and therefore it is not required to disclose information on its beneficial ownership. The company also discloses information of all its shareholders holding a stake greater than 5% in its annual reporting documents.

There is some evidence that the company publishes information on its major customers, to indicate that the United States government accounted for 85% of its total sales for the most recently reported financial year. However, the company receives a score of ‘1’ because it is clear from public available information whether these figures represent defence sales or overall company sales in commercial or other areas.

Based on publicly available evidence, the company acknowledges the corruption risks associated with operating in different markets, and there is evidence that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. The results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. The company provides examples of these controls.

Based on publicly available information, the company publishes a list of all of its consolidated subsidiaries and non-fully consolidated holdings. The list includes the percentages owned and countries of incorporation for each entity. The list is complete and updated on at least an annual basis. The company also published information in the most recent financial year on the countries of operation of its largest subsidiaries.

The company is publicly listed on the Milan Stock Exchange and therefore automatically receives a score of ‘2’. The company also discloses some information on its beneficial owners on its website.

The company publishes some information on its defence sales by market and geographical area. The company mentions specific customers (Italy, the US, the UK) representing 53% of its defence sales.

The remaining 47% is an aggregate figure of the reminder of its defence clients by geographical area, and therefore is insufficiently detailed for the company to receive a score of ‘2’.

There is no publicly available evidence that the company acknowledges the corruption risks associated with operating in different markets, nor that it has a risk assessment process in place to account for these specific risks.

There is no evidence that the company publishes a list of consolidated subsidiaries and non-fully consolidated holdings on its website.

There is no evidence that the company publishes any information about its beneficial ownership or control structure, nor a statement that no individual owns 25% or more of shares or voting rights. The company states that its beneficial ownership and control structure can be checked on an external electronic disclosure system, but it was not possible to identify relevant information from a search of this system. In addition, although the company indicates that it is publicly listed, it does not have voting shares admitted to a regulated market as specified in the guidance.

There is no evidence that the company publishes any information about its defence sales by customer on its website. The company indicates that this information can be accessed through an external portal, however it was not possible to identify relevant information from a search of this system.

The company acknowledges the corruption risks associated with operating in different markets, and there is evidence that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. The results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. The company provides examples of such possible controls.

The company discloses a list of its subsidiaries in its annual filing to the U.S. Securities and Exchange Commission.

However, the company receives a score of ‘1’ because this disclosure does not show the percentage ownership for each entity, and there is evidence to suggest that the list is not complete. While the company refers to the place of incorporation of the subsidiaries listed, it does not provide information on the subsidiaries’ countries of operation.

The company is publicly-listed on the New York Stock Exchange and therefore automatically receives a score of ‘2’.

The company publishes a percentage breakdown of the customers that account for 60% of its defence sales for the most recently reported financial year. The company also discloses that approximately 12% of its commercial sales go to the U.S. Government, but it does not provide any additional detail on the remaining 28% of its international sales (i.e. customer or defence/commercial).

The company receives a score of ‘1’ because it does not publish at least 80% of its sales.

There is some evidence that the company acknowledges the corruption risks of operating in different markets. However, there is no evidence that risk assessment procedures are used to inform the company’s operations in high risk markets, nor is it clear that the results of such assessments have an impact on business decisions.

There is evidence that the company publishes a list of its significant subsidiaries as part of its annual reporting documents. However, the list does not include the percentages owned, country of incorporation and countries of operation for each entity. Since it is not clear whether this list includes both fully consolidated subsidiaries and any non-fully consolidated holdings, there is no evidence that this list is represents all of the company’s affiliates and therefore it receives a score of ‘0’.

There is evidence that the company is publicly listed, trading on regulated markets in the United States and European Economic Area. The company is therefore not required to disclose further information on its beneficial ownership and receives a score of ‘2’. The company also publishes some information regarding its beneficial ownership on its own website as part of its annual corporate reporting documents.

The company publishes information on its defence sales to indicate that the United States government accounts for 98% of its total revenue, 73% of which stems from defence sales. There is evidence that this information accounts for the most recently reported financial year.

However, the company receives a score of ‘1’ because it does not publish information on its customers that account for more than 80% of its defence sales.

There is no readily available evidence that the institute is engaged in supplying goods or services, nor that it operates in markets or jurisdictions outside of the United States of America.

There is no evidence that the institute publishes a list of its subsidiaries or affiliated entities.

The institute is a non-profit organisation and therefore does not have shareholders. The organisation is governed by a board of trustees known as the MIT Corporation.

There is no readily available evidence that the company makes commercial and industry sales in the defence sector. However, the institute does publish a complete breakdown of the federal grants that it receives.

There is no clear publicly available evidence that the company acknowledges the corruption risks of operating in different markets. The company indicates that its risk assessment procedures includes assessments of market conditions and changes in the regulatory environment, however, it is not clear whether this includes corruption risks and it does not provide any further information on its risk management procedures for different markets. There is also no evidence to suggest that the results of these assessments have an impact on business decisions or trigger the implementation of additional controls.

There is no evidence that the company publishes a list of its subsidiaries and affiliated entities. The company indicates in its Business Ethics policy that it operates through several national companies, however it does not provide publicly available details of these fully and/or non-fully consolidated holdings.

There is evidence that the company publishes information on its major shareholders on its website, indicating that it is owned by three major European companies. There is evidence that all three of these companies are publicly listed on regulated markets as identified in the scoring criteria, and therefore the company is not required to disclose further information on its beneficial ownership to receive a score of ‘2’.

There is no evidence that the company publishes information on its defence sales by customer. The company indicates that its customers are mainly government authorities or international bodies, but it does not provide a breakdown of its defence sales by customer to any degree of detail.

There is evidence that the company acknowledges the corruption risks associated with operating in different markets and there is evidence that it has a dedicated assessment process in place to assess such risks. There is evidence that the results of these assessments have an impact on business decisions and trigger the implementation of additional controls.

There is evidence that the company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings, including joint ventures. For each entity, the list shows the company’s percentage ownership and country of incorporation. There is evidence to indicate that this list is updated on an annual basis.

However, the company receives a score of ‘1’ because there is no evidence that it publishes the country or countries of operation for each entity.

There is evidence that the company is publicly listed, with voting shares admitted to trading on the London Stock Exchange (LSE), and therefore it is not required to disclose further information on its beneficial ownership to receive a score of ‘2’.

There is no evidence that the company publishes any information on its defence sales by customer. The company states that its defence business accounts for 36% of its total revenue, and indicates that it has a diverse portfolio of customers around the world. However, there is no evidence that the company publishes any further details regarding these customers.

There is no readily available evidence that the organisation is engaged in supplying goods or services, nor that it operates in markets or jurisdictions outside of the United States of America.

There is no evidence that the organisation publishes a list of subsidiaries or affiliated entities. The organisation operates Federally Funded Research and Development Centers and publishes details of these entities, but these are considered to be different from subsidiaries.

The organisation is a non-profit organisation and therefore does not have shareholders.

There is no readily available evidence that the company engages in commercial or industry sales in the defence sector.

There is evidence that the company acknowledges the corruption risks associated with operating in different markets. The company indicates that it has a risk assessment procedure in place to account for business related risks, with clear risk management procedures in place. There is evidence that the results of these risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls.

However, the company receives a score of ‘1’ because it does not provide examples of such possible controls. In addition, the publicly available evidence on risk management procedures is not explicitly related anti-bribery and corruption, instead focusing on ‘business-related risks’ more widely.

There is evidence that the company publishes a list of its consolidated subsidiaries and affiliates. Since this information is published in the company’s Annual Report, there is evidence that this list is updated on an annual basis.

However, the company receives a score of ‘1’ because the list does not include joint ventures or the country of incorporation and operation for each entity.

There is evidence that the company is publicly listed on the Tokyo and London stock exchanges and is therefore required to disclose information on its beneficial ownership to the relevant bodies, so it is automatically awarded a score of ‘2’.

There is some evidence that the company publishes a percentage breakdown of its defence sales by customer. The company publishes a breakdown of its revenue from external customers by geographic region, which indicates that Japan accounts for approximately 58% of its sales. However, the company receives a score of ‘1’ because its publicly available evidence indicates that these figures relate to overall sales rather than defence-specific sales.

There is no publicly available evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets. There is evidence that the company has an overall risk management system in place, but it is not clear that this accounts for market risk or anti-bribery and corruption specifically.

There is evidence that the company publishes a list of its subsidiaries in its annual report and on its website. The company provides details of the full names of each entity, as well as an indication of the country and region of incorporation.

However, the company receives a score of ‘1’ because there is no evidence that it publishes further information such as its percentages ownership and the country or countries of incorporation and operation for each entity. The company publishes some details on its website, but it is not clear how frequently this list is updated or published.

There is evidence that the company is a publicly listed entity on the Tokyo Stock Exchange (TYO) and therefore it does not need to disclose further information about its beneficial ownership to receive a score of ‘2’. There is also evidence that the company discloses information on its major shareholders in its annual report.

There is no evidence that the company publishes any information on its defence sales by customer.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company publishes a list of all its holdings, including subsidiaries, non-fully consolidated holdings and joint ventures. This data includes an indication of percentage of ownership and country of incorporation, and is updated on an annual basis. The list is accompanied by a statement that it is accurate at the time of publication, to the best of the company’s knowledge.

However, the company receives a score of ‘1’ because it does not include the country of operation for each entity.

The company is a publicly listed on the New York Stock Exchange and is therefore automatically awarded a score of ‘2’.

Although the company discloses that the US government is a major source of its total sales, there is no evidence that the company provides a percentage breakdown of at least 50% of its defence sales by customer.

Based on publicly available information, there is evidence that the company acknowledges the corruption risks associated with operating in different markets and it is clear that the company has a risk management procedure in lace to account for these risks. There is evidence that the company conducts enhanced due diligence and risk evaluation procedure for end users and countries identified as medium or high risk of corruption. The company’s publicly available information also indicates that the results of these assessments have a direct impact on business decisions, which may include a decision not to proceed in some cases.

There is evidence that the company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings on an annual basis. For each entity, the company clearly publishes the name of the subsidiary or other affiliated entity, as well as the country of incorporation. This list is published in the company’s most recently published Annual Report, and is therefore understood to reflect a complete list of the company’s holdings at the time of publication.

However, the company receives a score of ‘1’ because it does not clearly provide the country of operation for each entity.

There is evidence that the company publishes information on its beneficial ownership. The company indicates that it has two major shareholders, Patria Oyj (50%) and the Norwegian Ministry of Trade, Industry and Fisheries (50%); thereby indicating that it is partially state-owned. The company publishes this information in its corporate reporting documents and in the publicly accessible Norwegian corporate register.

Based on publicly available information, there is no evidence to indicate that the company publishes a breakdown of its defence sales by customer. The company provides a breakdown of sales per region, but there is no evidence that the company distinguishes defence sales from overall sales, nor that it identifies specific countries or customers within these regions.

The company acknowledges the corruption risks associated with operating in different markets, and there is evidence that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. The results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls.

In its annual Financial Report, the company publishes a list of its consolidated and non-fully consolidated subsidiaries and the percentages owned.

However, the company does not indicate that the list is complete at the time of publication to the best of the its knowledge and does not provide details on the countries of incorporation and operation for all entities.

The company discloses its shareholders in its annual Financial Report.

Although there is evidence that it files this information with the French commercial registry, this is not freely publicly accessible, and the company therefore does not meet the criteria for a score of ‘2’.

In its annual Financial Report, the company says it has 50 naval customers worldwide. However, it does not provide any further details on these customers as a percentage of its defence sales.

There is evidence that the company acknowledges the corruption risks associated with operating in different markets, and that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. There is evidence that the results of risk assessments inform the development and implementation of additional controls. The company provides examples of such possible controls.

The company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings, including the percentage owned and country of incorporation for each entity. There is evidence to suggest that the information is complete at the time of publication to the best of the company’s knowledge.

However, the company receives a score of ‘1’ because it is unclear whether the list includes all of the company’s non-fully consolidated holdings, and the company does not provide information about the countries of operation for all of its subsidiaries.

The company publishes a statement to indicate that is a Spanish state-owned enterprise, with 100% of shares owned by the Spanish State-Owned Industrial Holding Company (SEPI).

Details of the company’s ownership are also disclosed in the global beneficial ownership register Open Ownership, available through www.openownership.org.

The company publishes some information regarding its major customers for its defence sales. There is evidence that the company’s main customer is the Spanish military and that export sales accounted for 38% of its revenue in the most recently reported year. It is understood that the company is only active in the defence sector and therefore that this information represents its defence sales.

However, whilst the company discloses high-level details in relation to some of its export markets, it receives a score of ‘1’ because it does not provide a clear breakdown of at least 80% of its defence sales by customer.

There is evidence that the company acknowledges the corruption risks associated with operating in different markets, and that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. The results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. The company provides examples of such possible controls.

Based on public evidence, the company publishes a list of its consolidated subsidiaries on an annual basis.

However, the list does not include all of the company’s holdings and it is not accompanied by a statement that it is complete at the time of publication to the best of the company’s knowledge. Additionally, the company does not provide the percentage of ownership or the countries of incorporation and operation for each entity.

The company is publicly listed on the Tokyo Stock Exchange and therefore automatically receives a score of ‘2’.

There is no evidence that the company publishes a breakdown of its defence sales by customer.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets. The description of the company’s risk assessment procedure does not explicitly refer to country risk.

The company publishes a list of subsidiaries on its website.

However, it is not clear whether this is a complete list of the company’s holdings. The list also does not include the percentages owned, country of incorporation and/or countries of operation for each entity, nor is it accompanied by a statement that it is complete at the time of publication to the best of the company’s knowledge. It is unclear how frequently it is updated.

The company discloses some details on persons or entities with significant holdings in the company.

However, it does not refer to relevant individuals by name along with their percentage ownership in the company or any accompanying details necessary to identify natural persons. The company only discloses its ownership on its website and not in a freely available central public register or in open data format; it is also not publicly listed on a stock exchange.

The company does not publish details of its defence sales by customer. On its website, the company says that over 100 armies use its equipment, but details regarding its customer base are not publicly available.

Based on publicly available information, there is evidence that the company acknowledges the corruption risks associated with operating in different markets and that it has a dedicated process in place to assess such risks.

However, the company receives a score of ‘1’ because there is no publicly available evidence on the risk management procedures that it has in place, nor is there evidence to suggest that the results of these assessments have an impact on business decisions or trigger the implementation of additional anti-corruption controls.

There is no evidence that the company publishes a clear list of its fully consolidated subsidiaries and non-fully consolidated holdings, including details such as its percentage ownership, the country of incorporation and country or countries of operation of each entity. The company provides some information on a subsidiary and on its business divisions, however there is no evidence that this represents all of the company’s holdings nor that it includes details of each entity.

There is evidence that the company is a publicly listed entity on the New York Stock Exchange (NYSE) and therefore it is not required to disclose further information on its beneficial ownership to receive a score of ‘2’. The company also publishes ownership information in annual its Proxy Statement, which is available on its website.

There is evidence that the company publishes information on its defence sales by customer, to indicate that the United States government accounts for more than 80% of its sales. Although the company does not explicitly state that this figure relates to defence sales, there is sufficient evidence to indicate that the company’s primary products and services relate to the defence and security sector. There is evidence that this information is published as part of the company’s annual corporate reporting, which reflects the most recently reported financial year.

There is evidence that the company acknowledges the corruption risks associated with operating in different markets, and there is evidence that it has a risk assessment process in place to account for these risks, with risk management procedures in place.

However, the company receives a score of ‘1’ because there is no evidence to suggest that the results of these assessments have an impact on business decisions or trigger the implementation of additional controls.

There is no evidence that the company publishes a list of its subsidiaries.

The company discloses information on its beneficial ownership structure on its website. However, the company receives a ‘1’ because there is no evidence that it also discloses its ownership in an open data format.

There is no evidence that the company publishes any data on its defence sales or customers.

There is some evidence that the company acknowledges the risks of operating in different countries. However, there is no evidence that the company considers bribery and corruption risks specifically, nor is there evidence that it has a dedicated assessment procedure in place to assess such risks and inform the company’s operations in high risks markets.

Based on publicly available information, there is evidence that the company publishes a list of its affiliated companies. However, the company receives a score of ‘1’ because it is not clear whether the list covers all consolidated subsidiaries or holdings, and it does not include further details such as the percentage ownership, country of incorporation and country of operation for all entities.

There is an indication that the information is complete at the time of publication, but it is unclear how frequently the company updates this information.

There is evidence that the company is publicly listed on the Tokyo Stock Exchange and is therefore automatically eligible for a score of ‘2’. In addition, the company publishes information on its major shareholders in its Annual Report.

There is evidence that the company publishes a percentage breakdown of its sales by geographic region, with the exception of Japan and China identified on a country/customer level. The company receives a score of ‘1’ because it is apparent from this data that Japan accounts for approximately 70% of the company’s sales, however there is evidence to indicate that this includes overall sales rather than defence specifically.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company publishes a list of its consolidated subsidiaries on an annual basis. This includes the country of incorporation of each entity.

However, it is not clear that the list includes all of the company’s holdings. The list also does not include the percentages owned and countries of operation for each entity.

The company is publicly listed on the New York Stock Exchange and therefore automatically receives a score of ‘2’.

The company publishes a percentage breakdown for at least 80% of its defence sales by customer. There is evidence that this data is correct to the most recently reported financial year.

Based on publicly available information, there is some evidence that the company acknowledges the corruption risks of operating in different markets. There is evidence that it assesses country risk as part of its due diligence processes, which it conducts when operating internationally.

However, the company receives a score of ‘1’ because there is no clear evidence that that the results of these assessments have an impact on business decisions or trigger the implementation of additional controls.

Based on publicly available information, there is evidence that the company publishes lists of its consolidated subsidiaries and non-fully consolidated holdings. The publicly available lists include the percentages owned and the countries of incorporation for each entity. There is evidence that the company publishes this information on an annual basis.

However, there is no evidence that the company publishes further information on the country or countries of operation for each entity.

Based on publicly available information, there is evidence that the company discloses its control structure and beneficial ownership on its website. The company indicates that the State of Finland owns 50.1% of its shares, while the remaining 49.9% of shares are held by a company affiliated with the Norwegian defence company Kongsberg Gruppen ASA.

The company receives a score of ‘1’ because there is no evidence that its ownership information is disclosed in a freely available and readily accessible central public register. Basic information on the company can be found in the Finnish corporate register, but further details on its ownership and shareholders is not freely accessible.

There is evidence that the company publishes some information on its major customers, indicating that defence products and maintenance account for 92% of its net sales and that Finland accounted for approximately 67% of its sales in the most recently reported financial year. Within Finland, the company states that its main customer is the Finnish Defence Forces.

However, the company receives a score of ‘1’ because the company does not provide further information on its major customers for defence sales specifically. The company provides some information on its sales outside of Finland, but not in the form of percentages or figures to indicate the extent of these relationships.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company publishes a list of its subsidiaries on an annual basis. This list includes the country and U.S. state of incorporation for each entity.

However, it is unclear whether the list includes all of the company’s holdings. The list also does not include the percentages owned or countries of operation for each entity.

The company is publicly listed on the New York Stock Exchange and therefore automatically receives a score of ‘2’.

The company does not publish the customers of at least 50 percent of its defence sales.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

There is no evidence that the company publishes a list of its subsidiaries or other affiliated entities.

There is evidence that the company discloses information about its beneficial owners with a stake higher than 25%. The company’s ownership information indicates that two national state bodies in Poland hold more than 99% of its shares, indicating that it is a partially state-owned enterprise.

However, the company receives a score of ‘1’ because there is no evidence that this information is published in a freely accessible corporate register or global beneficial ownership database.

There is no evidence that the company publishes any information on its major defence sales or customers.

There is no publicly available evidence to indicate that the company acknowledges the corruption risks of operating in different markets, nor that it has a risk assessment procedure in place to identify such risks.

The company publishes a list of its fully consolidated subsidiaries. For each entity, the company discloses its percentage ownership and the country of incorporation. This list is published alongside a statement that it is accurate to the best of the company’s knowledge at the time of publication. There is evidence that this list is current and updated on at least an annual basis.

The company receives a score of ‘1’, however, because for each entity it does not include clear information on their countries of operation. Additionally, the list provides details of the company’s subsidiaries but it is not clear that this represents all of the company’s holdings, including joint ventures and non-fully consolidated holdings.

There is evidence that the company publishes information on the entities with significant holdings in the company, but this information is disclosed its corporate reports and not in a central public register. It is noted that the company is a publicly listed company on the Korea Stock Exchange, but it does not have voting shares admitted to a regulated market specified in the guidance.

There is no evidence that the company publishes any information about its defence sales or customers.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

There is some publicly available evidence to indicate that the company publishes some information on its subsidiaries. The company provides an address for each entity, which is understood to represent the country of incorporation.

However, the company receives a score of ‘1’ because this list does not provide further details such as the percentage ownership or country of operation for each entity. It is also not clear whether this list includes all of the company’s holdings and there is no evidence that the list is updated on at least an annual basis.

The company provides some information on its ownership structure, to indicate that it is a state owned enterprise operating in the Indonesian aerospace industry.

However, the company receives a score of ‘1’ because it does not provide publish clear information to indicate that the government of Indonesia is its sole beneficial owner. There is also no evidence that ownership information about the company is available in a freely accessible corporate register or global beneficial ownership register.

There is no evidence that the company publishes information about its defence sales in the form of a percentage breakdown by customer. The company provides a map on its website with details of the products or services delivered to each country, however this information is in the form of ‘units’ and does not provide an indication of the company’s major customers. There is also no evidence that this data is updated on an annual basis.

The company acknowledges the corruption risks associated with operating in different markets, and there is evidence that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. The results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls.

The company publishes a list of its subsidiaries and other related undertakings in its annual report, which includes percentages owned and countries of incorporation. There is evidence that the list is complete at the time of publication to the best of the company’s knowledge.

However, the company does not provide the country of operation for each subsidiary.

The company is publicly listed on a regulated market in the UK and therefore automatically receives a score of ‘2’.

The company discloses the customers that account for 88% of its sales, which are predominantly in the defence sector. This data is correct up to the most recently reported financial year.

There is evidence that the company acknowledges the corruption risks associated with operating in different markets, and there is evidence that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. The company’s publicly available evidence indicates that the results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls.

The company publishes the corporate logos of its subsidiaries or affiliated entities and their relevant geographic region. However, the company receives a score of ‘0’ because the company does not publish clear information about its subsidiaries and non-fully consolidated holdings, such as the percentage ownership, country of incorporation and countries of operation. There is also no indication that the list is current or updated on an annual basis.

There is some evidence that the company is a state-owned enterprise owned by the government of Israel. However, the company receives a score of ‘1’ because it does not provide publish clear information to indicate that the government of Israel is its sole beneficial owner.

There is no evidence that the company publishes information on its defence sales.

Based on publicly available information, there is evidence that the company acknowledges the corruption risks associated with operating in different markets, and that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. The company indicates that the results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls, and the company provides examples of such controls.

The company publishes some information about its significant subsidiaries as part of its annual regulatory filings in the United States. This information includes the name and country of incorporation of the subsidiary.

However, the company receives a score of ‘1’ because there is evidence to indicate that the company has other international subsidiaries not included on this list, which indicates that this does not represent a full list of all the company’s holdings. There is also no evidence that the company discloses the country of operation nor its percentage ownership for each entity.

There is evidence to indicate that the company is publicly traded on the New York Stock Exchange and it is therefore not required to disclose beneficial ownership further, so the company receives a score of ‘2’. There is also evidence that the company discloses details of its shareholders with a stake of 5 percent or more on its public website.

Based on publicly available information, there is evidence that the company publishes details about its defence sales by customer. In its Annual Report, the company discloses that the United States government accounts for 69 percent of its sales in the most recently reported financial year; while an additional 13 percent of sales were made through the United States government to foreign militaries. The company indicates that the U.S. Department of Defence is its principal customer, noting that it also sells to U.S. intelligence agencies, the Department of Homeland Security, the Federal Aviation Authority and the National Aeronautics and Space Administration (NASA). The company also discloses that defence sales to Saudi Arabia constitute approximately five percent of its sales.

There is evidence that the company acknowledges the corruption risks associated with operating in different markets, and there is evidence that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. The results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls.

There is evidence that the company publishes a list of its fully consolidated subsidiaries and non-fully consolidated holdings. For each entity, the company discloses its percentage ownership. There is evidence that this list is current and updated on at least an annual basis. The list is accompanied by a statement that it is complete at the time of publication to the best of the company’s knowledge.

However, it is unclear whether the locations listed are the countries of incorporation or operation or both.

The company is publicly listed on the Berlin Stock Exchange and therefore receives a score of ‘2’.

While the company publishes a breakdown of its defence sales by region, there is no evidence that the company publishes a breakdown of its defence sales by customer. The company indicates that its sales in the German market account for 40.6% of its sales, but this does not meet the minimum threshold of the 50% required to receive a score of ‘1’.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

There is no evidence that the company publishes a list of subsidiaries.

The company discloses all beneficial owners with a stake in the company. All individuals or entities are referred to by name, along with their percentage ownership in the company.

However, the company receives a score of ‘1’ because it does not disclose details of its ownership in a corporate register.

There is no evidence that the company publishes information on its defence sales by customer.

The company acknowledges the corruption risks associated with operating in different markets, and there is evidence that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. The results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. The company provides examples of such possible controls.

The company publishes a list of its subsidiaries in its Annual Report, which includes the percentage ownership of each entity. This list covers fully consolidated and non-fully consolidated holdings, including any associates, joint ventures and other related entities. The list includes information on the registered addresses of each entity.

However, the company does not list the subsidiaries’ countries of operation. Supporting information on the company’s website provides information on the country of operation for only some of the entities listed in the annual report.

The company is publicly-listed on the London Stock Exchange and therefore automatically receives a score of ‘2’.

There company does not publish information regarding its main defence sales by customer. Although the company disaggregates its defence sales from other business segments, it does not provide any information on its customers.

The company states that it has procedures to ensure that its activities in foreign countries do not infringe local anti-corruption laws. However, there is no evidence that this involves an assessment of the corruption risks prevalent in different markets.

The company publishes information regarding its main subsidiaries and joint ventures, alongside information on the location of each of these companies. However publicly available information about the company shows that this information is incomplete and does not include all of its holdings. Furthermore there is no evidence that the company provides information such as the countries of operation for each company, or the percentages owned. It is also not clear how frequently this information is published or updated.

The company states that it is a state-owned entity, and although it is not explicitly stated, it is assumed that this means that the company is 100% owned by the state. However, the company only discloses its ownership on its website instead of a central public register and therefore a score of ‘1’ applies.

There is no evidence that the company publishes a percentage breakdown of its defence sales by customer.

The company states that employees must adhere to anti-corruption legislation of the countries in which they do business. However, the company receives a score of ‘0’ because there is no evidence that it acknowledges the corruption risks of operating in different markets. There is also no evidence that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company publishes a list of subsidiaries and holdings, however, it is unclear if this represents all of the company’s holdings. There is no evidence that the company publishes information on percentage ownership or countries of operation and incorporation for each entity. In addition, it is not clear how frequently the list of subsidiaries and holdings is updated.

The company discloses that it is part of another company, but there is no further evidence with regards to its ownership. Furthermore, the company does not disclose details of its ownership in an open data format and there is no ownership information published in a central public register.

There is no evidence that the company publishes a percentage breakdown of its defence sales by customer.

There is some evidence that the company has a dedicated assessment process in place to assess the risks of operating in different markets. However, there is no evidence that the company provides further information on its risk management procedures, nor is it clear that the results of these assessments have an impact on business decisions or trigger the implementation of additional controls.

There is evidence that the company publishes a list of its fully and non-fully consolidated holdings, along with its percentage ownership for each entity. For each entity, the company publishes the location of its head office and country of incorporation. In addition, the company provides information in narrative form on the countries of operation for its major holdings. Since this information is published in the company’s Annual Report, there is evidence that this list is current and updated on at least annual basis.

The company publishes a clear statement that it is wholly owned by the Swiss Confederation, indicating that it is the sole shareholder.

There is evidence that the company publishes some information about its defence sales, to indicate that the Swiss Federal Department of Defence is its largest customer. The company indicates that Switzerland accounts for 38% of its net sales, with customers in Europe accounting for 50% of its sales.

However, the company receives a score of ‘0’ because there is no clear evidence that it publishes a breakdown of defence sales per customer for at least 50% of its sales.

Based on publicly available information, there is some evidence that the company acknowledges the corruption risks of operating in different markets. However the company scores ‘0’ as there is no clear evidence that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company publishes a list of all of its consolidated subsidiaries and non-fully consolidated holdings in its Financial Statements and Annual Reports. The company provides the percentage of the share capital it holds in all its subsidiaries as well as the country of incorporation. There is evidence that this data is updated annually, and that the data provided represents all of the company’s holdings and not just principal subsidiaries. According to the company’s statements, all of its holdings operate in the Russian Federation.

The company discloses 97.58% of its shareholding, including its sole major shareholder, which is listed as holding 95.83% of the company’s share capital. This information is included in the company’s financial statements. However, there is no evidence that the company’s ownership information is available in a freely available central public register.

There is no evidence that the company publishes information concerning any of the customers of its defence sales.

There is evidence that the company acknowledges the corruption risks associated with operating in different markets and has a risk assessment process and management procedures in place to account for these specific risks. There is evidence that the results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. The company provides some examples of these controls.

Based on publicly available information, there is evidence that the company publishes full lists of its fully consolidated subsidiaries and non-fully consolidated holdings, including any associates, joint ventures and other related entities. For each entity, the company discloses its percentage ownership. There is also evidence that the lists are current, updated on at least an annual basis and complete at the time of publication to the best of the company’s knowledge. The company publishes the country of incorporation for each entity.

However, the company does not publish the countries of operation for each entity.

The company is publicly listed on a regulated marked in the European Economic Area and therefore automatically receives a score of ‘2’.

The company does not publish the customers of at least 50% of its defence sales and therefore cannot receive a score of ‘1’.

There is evidence that the company acknowledges the corruption risks associated with operating in different markets and that it has a dedicated assessment process in place to assess such risks.

However, this does not include clear risk management procedures and there is no evidence to suggest that the results of these assessments have an impact on business decisions or trigger the implementation of additional controls.

The company publishes a list of its consolidated companies and subsidiaries, along with the percentage ownership for each.

However, the company receives a score of ‘1’ because there is no evidence that the list includes non-fully consolidated holdings. Additionally, although the company lists the country of the subsidiary, it is unclear whether this relates to the country of operation or incorporation.

The company is publicly-listed on multiple stock exchanges – including London, Paris and Euronext – and therefore automatically receives a score of ‘2’.

The company does not publish details of its defence sales by customer.

There is no publicly available evidence that the company acknowledges the corruption risks of operating in different markets, beyond abiding with applicable laws and regulations. There is also no evidence that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company publishes a direct link to its annual 10-K filing to the United States Securities and Exchange Commission, which includes a list of its subsidiaries. The list includes the jurisdiction of incorporation for each entity.

However, the company receives a score of ‘1’ because there is no clear evidence to indicate that this represents a comprehensive list of all the company’s fully and non-fully consolidated holdings. There is also no evidence that the company publishes its percentage ownership for each entity, nor the country or countries of operation.

There is evidence that the company is publicly listed on the New York Stock Exchange (‘NYSE’) and therefore it is not required to disclose further information on its beneficial ownership in order to receive a score of ‘2’.

There is evidence that the company publishes a breakdown of its sales by major customer, to indicate that the United States government accounted for 97% of its sales in the most recently reported financial year. The company discloses that the main agencies it supplies are the U.S. Army, U.S. Navy and “other” entities within the U.S. Department of Defence, thereby indicating that this figure includes defence sales.

Based on publicly available information, there is evidence that the company acknowledges the corruption risks associated with operating in different markets and there is evidence that it has a dedicated assessment process in place to assess such risks. There is evidence to suggest that the results of these assessments trigger the implementation of additional controls and have an impact on business decisions.

There is evidence that the company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings. The list includes all of the company’s holdings, showing the percentage ownership and country of incorporation for each entity. There is evidence that this list is updated on an annual basis due to its inclusion in the company’s Annual Report.

However, the company receives a score of ‘1’ because the list does not include the countries of operation for each entity.

There is evidence to indicate that the company is publicly traded on the London Stock Exchange, a regulated market in the UK, and it is therefore not required to disclose beneficial ownership further, so the company receives a score of ‘2’. The company publishes a statement to confirm this in its corporate reporting documents.

The company publishes some information on its customers, indicating that 55 percent of its order intake for the most recently reported financial year came from the United Kingdom. However, the company receives a score of ‘0’ because there is evidence to indicate that this figure includes both defence and non-defence orders, so there is no clear indication of the company’s percentage of defence sales by customer.

There is no publicly available evidence that the company acknowledges the corruption risks of operating in different markets.

There is evidence that the company publishes a list of its fully consolidated subsidiaries and non-fully consolidated holdings, including any associates, joint ventures and other related entities. For each entity, the company discloses its percentage ownership, the country of incorporation and countries of operation. There is evidence that this list is current and updated on at least an annual basis, and the fact that the information is included in the Annual Report indicates that that the list is complete at the time of publication.

There is evidence that the company is publicly listed in the United States and Germany and is therefore not required to disclose its beneficial ownership as outlined in the scoring criteria, so automatically receives a score of ‘2’.

There is no evidence that the company publishes details of its defence sales by customer. The company publishes some information on its defence and commercial revenue by geographical area, but it does not indicate customers.

There is no evidence that the company acknowledges the corruption risks of operating in different markets.

There is no evidence that the company publishes a list of its subsidiaries or other affiliated entities.

The company does not disclose detailed information about its beneficial ownership and control structure. It does not disclose whether any individual owns 25% or more of shares or voting rights, and does not publish information on a global register such as OpenOwnership. However, there is some evidence to indicate that the company is an entity established by the Defence Industry Executive Committee of the government of Turkey and affiliated with the Turkish Armed Forces, and this information is sufficient to indicate a degree of state ownership. The company therefore receives a score of ‘1’.

There is no evidence that the company publishes a breakdown of its defence sales by customer. There is some evidence to indicate that the company exists primarily to serve the Turkish Armed Forces (TAF) and Undersecretariat for Defence Industries (SSM), but it is not clear whether these are the company’s only customers or whether it also makes other foreign or domestic sales.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company publishes a list of Group Companies. However, it is not expressly clear if the list provided represents all of the company’s holdings, rather than just the company’s principal or significant subsidiaries, associates and joint ventures. In addition, there is no evidence that the company publishes the percentages owned, country of incorporation or countries of operation for each entity. There is also no evidence that the company makes a statement that it is complete at the time of publication to the best of the company’s knowledge, and there is no publicly available information regarding when the list was last updated.

The company’s publicly available charter, which was written in 2002, states that the company was 100 percent state owned, and there is no evidence to suggest that this has changed. However, the company does not disclose details of its ownership in an open data format and there is no ownership information published in a central public register.

The company states that a major area of its activities is servicing the Russian defence ministry. However, the company receives a score of ‘0’ because there is no evidence that it discloses at least 50% of its defence sales by customer.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, nor that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings. The company states that the list represents all of the company’s holdings. The list also includes information on percentage ownership and country of incorporation for each entity. There is some evidence that this list is updated on an annual basis since the information appears in the company’s Annual Report.

However, the company receives a score of ‘1’ because the data does not clearly specify the country of operation for each entity.

There is no evidence that the company discloses clear information on its beneficial ownership. The company indicates that the Uzbek national rail company owns over 20% of its shares, without providing further information on its precise shareholding or other possible shareholders. There is some indication that the company is either partially or fully state-owned.

There is no evidence that the company publishes data on the identity of any of its defence customers.

There is some evidence that the company acknowledges the corruption risks associated with operating in different markets, however there is no clear evidence that the company has risk assessment procedures in place to identify such risks. There is also no evidence that the results of risk assessments are used to inform the company’s operations in high risk markets.

There is no evidence that the company provides a list of its fully consolidated subsidiaries and non-fully consolidated holdings. The company provides information on one subsidiary, but it is not clear whether this represents all of the company’s holdings, nor is there evidence that the company provides further details such as its percentage ownership or country of incorporation/operation for the entity.

There is no evidence that the company publishes information about its beneficial ownership or control structure on its website. There is no evidence that the company states that no individual owns 25% or more of shares or voting rights. In addition, although some information about the company appears to be available via the global beneficial ownership register openownership.org, there is no evidence that this data includes percentage ownership information.

There is some evidence that the company publishes information on its main markets, however there is no evidence that it provides a percentage breakdown of its defence sales by customer.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

There is no evidence that the company publishes a list of its subsidiaries or affiliated entities.

There is evidence that the company is a wholly-owned subsidiary of Griffon Corporation, a company publicly listed on the New York Stock Exchange. The company is therefore not required to disclose information on its ownership and automatically receives a score of ‘2’.

There is no evidence that the company publishes any details of its defence sales by customer.

Based on publicly available information, there is evidence that the company acknowledges the corruption risks associated with operating in different markets and there is evidence that it has a dedicated assessment process in place to assess such risks.

However, the company receives a score of ‘1’ because it does not provide further information on its risk management procedures and there is no evidence to suggest that the results of these assessments have an impact on business decisions or trigger the implementation of additional controls.

Based on publicly available information, there is evidence that the company publishes a list of its fully consolidated subsidiaries and non-fully consolidated holdings, including any associates, joint ventures and other related entities. For each entity, the company discloses its percentage ownership and the country of incorporation. There is evidence that this list is current and updated on at least an annual basis and complete at the time of publication.

However, the company receives a score of ‘1’ because there is no evidence that this list includes the country or countries of operation for each entity.

There is evidence that information about the company’s beneficial ownership is publicly available. The company discloses the name of the entity that is its legal owner in its publicly available reporting documents. In addition, there is evidence that the company’s full beneficial ownership information – including the names, addresses and voting rights of all individuals with an ownership stake – is available in a freely accessible national corporate register and through a global corporate register. This information indicates that the company has six beneficial owners, each with a 20% share of voting rights.

The company publishes some information on its defence sales per geographic region and per business division. However, there is no evidence that the company publishes any information on its defence sales by major country or customer.

Based on publicly available information, there is no evidence that the company acknowledges the corruption risks of operating in different markets, nor that risk assessment procedures are used to inform the company’s operations in high risk markets.

There is evidence that the company publishes a list of its subsidiaries in its annual 10-K regulatory filing. The company discloses information on its percentage ownership of each subsidiary and its country of incorporation.

However, the company scores ‘1’ as the list only covers certain subsidiaries and there is no evidence that the company discloses details of all of its holdings. There is also no evidence that the company discloses the countries of operation for each entity in its list.

The company is a publicly listed company trading on the New York Stock Exchange and therefore is automatically awarded a score of ‘2’.

The company publicly discloses that sales to the United States Department of Defense constituted approximately 24% of its consolidated revenues in 2018. However, the company receives a score of ‘0’ because there is no evidence that it publishes information on the customers of at least 50% of its defence sales.

There is no readily available evidence that the organisation is engaged in supplying goods or services, nor that it operates in markets or jurisdictions outside of the United States of America.

The organisation publishes some information about the locations in which it operates; however, it does not provide details about its corporate structure to indicate whether these locations represents offices or subsidiaries or other holdings.

The organisation is a non-profit organisation and therefore does not have shareholders.

There is no readily available evidence that the company engages in commercial or industry sales in the defence sector.

There is evidence that the company acknowledges the corruption risks associated with operating in different markets, and has a risk assessment process in place to account for these specific risks, with clear risk management procedures. The results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. The company provides examples of such possible controls.

The company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings on an annual basis. The list provides information on the company’s percentage ownership and the country of incorporation of each entity.

However, the company does not publish information on the countries of operation for each entity.

The company is publicly listed on a regulated marked in the European Economic Area. It therefore automatically receives a score of ‘2’.

The company publishes some information about its defence customers. However, the data the company provides does not make reference to specific government customers or provide a percentage breakdown of its sales.

There is no publicly available evidence that the company acknowledges the corruption risks associated with operating in different markets, nor that it has a risk assessment procedure in place to account for these specific risks.

There is evidence that the company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings. The company’s list indicates whether each entity is domestic or overseas.

However, the company receives a score of ‘1’ because there is no evidence that the company publishes further information for each entity, such as its percentage ownership, or the country of incorporation and country or countries operation. There is also some indication that this list is not complete and therefore does not represent all of the company’s subsidiaries and holdings.

There is evidence that the company is publicly listed on the Tokyo Stock Exchange (TYO) and Nagoya Stock Exchange (NSE) and therefore it is not required to disclose further information about its beneficial ownership in order to score ‘2’. In addition, the company publishes information on its major shareholders in its Annual Report.

There is no publicly available evidence that the company publishes a breakdown of its defence sales by customer. The company provides some information to indicate that Japan accounts for more than 50% of its net sales, however it does not distinguish between commercial and defence revenues, nor is it clear that this data relates specifically to Toshiba Infrastructure Systems and Solutions rather than the group as a whole.

There is no clear publicly available evidence that the company acknowledges the corruption risks of operating in different markets.

The company publishes a list of its subsidiaries in its annual 10-K regulatory filing. However, there is no evidence that the company publishes the percentages owned, country of incorporation and countries of operation for each entity. It is also not clear whether the list of subsidiaries published constitutes a full list of the company’s holdings.

The company is a publicly listed company with shares admitted on the New York Stock Exchange and therefore automatically scores ‘2’.

Based on publicly available information, there is evidence that the company publishes 42% of its defence sales by customer for the most recently reported financial year. The company therefore does not meet the minimum required threshold to receive a score of ’1’.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company publishes a list of its subsidiaries and holdings, alongside its percentage ownership. Evidence indicates that the data represents all of the company’s holdings.

However, the company receives a score of ‘1’ because it is unclear that the company’s data is updated at least annually. The company’s data is also not accompanied by a statement that it is complete at the time of publication to the best of the company’s knowledge. There is also no evidence that the list includes the countries of incorporation and operation for each entity.

The company discloses all beneficial owners with an ownership interest in the company. All entities are referred to by name, along with their percentage ownership in the company. The company’s ownership information indicates that the Turkish government holds 45.45% of shares through the Undersecretariat for Defence Industries, making the company partially state-owned.

However, the company receives a score of ‘1’ because this information is published only on the company’s website and not in a freely accessible public register.

There is no evidence that the company publishes any information on its defence sales by customer.

Based on publicly available information, there is some evidence the company acknowledges the corruption risks associated with operating in different markets. The company uses Transparency International’s Corruption Perceptions Index as part of its risk-based approach to due diligence in order to identify risks.

However, the company receives a score of ‘1’ because there is no evidence that it has risk management procedures related to high risk markets. There is also no clear evidence that the results of these assessments have an impact on business decisions.

The company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings. This list includes the percentage owned and country of incorporation of each entity, and is updated on an annual basis.

However, the company receives a score of ‘1’ because there is no evidence that the list includes the countries of operation of each entity. It is also unclear whether joint venture partnerships would be included in the list.

There is evidence that the company is publicly listed on the London Stock Exchange, and therefore it is not required to disclose further information on its beneficial ownership to receive a score of ‘2’. The company also publishes information on its website about its shareholders with interests in the company in excess of 3%.

The company publishes a percentage breakdown of its sales by costumer, comprising 57% of its sales. There is also evidence that the data is correct up to the most recently reported financial year.

However, the company receives a score of ‘1’ because it does not publish information on its customers to account for at least 80% of its sales. It is also not clear whether these figures represent defence sales or overall company sales including from commercial products.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, nor that risk assessment procedures are used to inform the company’s operations in high risk markets.

There is evidence that the company publishes a list of its subsidiaries and holdings on its website. However, the company does not publish further details such as the percentage ownership, country of incorporation or countries of operation for each entity. It is therefore not clear which companies are material (principal/significant/main) subsidiaries, and which are associated or joint ventures. In addition, there is no indication that this list is complete or up-to-date for the most recently reported financial year; the company’s Annual Report indicates that some information on subsidiaries may be restricted due to national legislation.

The company discloses some information on its major shareholders to indicate that it is majority owned by the Russian government through the Federal Property Management Agency and state corporation “Rostec”. However, there is no evidence that the company’s ownership information is available in open data format, nor that it is published in a freely accessible central public register, so the company receives a score of ’1’.

It is noted that this information was correct as of March 2019; the company indicates that it no longer publishes information on its ownership due to a change in national legislation.

There is no evidence that the company publishes any information on its defence sales by customer.

There is no evidence that the company acknowledges the corruption risks of operating in different markets.

The company publishes some information about its affiliated companies, however based on publicly available information the company only publishes the name of the companies. There is no evidence that the company publishes further information such as whether the companies are subsidiaries or other associates, joint ventures or related entities, nor does it publish details such as percentage ownership, country of incorporation and country of operation for each entity. In addition, there is no evidence to indicate whether this is a full list of the company’s holdings, or how frequently this list is updated.

There is no evidence that the company discloses clear information on its beneficial ownership and control structure.

The company indicates that it does not disclose its ownership information pursuant to legislative developments in the Russian Federation. Prior to this, until 2018 the company disclosed the identity of one major shareholder and noted that this entity was the only shareholder with an ownership stake greater than 5%. In its Annual Report, the company indicates that it belongs to the Rostec Corporation group.

There is no evidence that the company publishes a percentage breakdown of its defence sales by customer.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, nor is there evidence to suggest that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company publishes a list of its subsidiaries and affiliated companies on its website. However, from the data provided it is not clear whether the companies are joint ventures, subsidiaries or affiliated companies in which the company holds a minority stake, nor is it clear whether the companies listed represent a complete list of all of its subsidiaries and holdings.

There is no evidence that the company discloses the percentages ownership or countries of operation for each entity, although it is stated that all the companies listed are registered in Russia. There is also no indication that the evidence is correct and up-to-date for the most recent reporting period. The company’s 2015 Auditor’s Report contains ownership information for some affiliated companies, but there is no evidence that this list is comprehensive nor that it has been updated since 2015.

There is evidence in the company’s most recently published Annual Report that it is wholly owned by “Rostec”, a state-owned corporation, and the company’s website appears to confirm this. However, the company receives a score of ‘1’ because there is no clear evidence that this ownership information is current and up-to-date. It is noted the company does not disclose details of its ownership on a national public register or global ownership database.

There is no evidence that the company publishes any information about its major defence sales or customers.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

There is evidence that the company publishes a list of its fully consolidated subsidiaries and non-fully consolidated holdings, including any associates, joint ventures and other related entities. For each entity, the company discloses its percentage ownership and the country of incorporation. There is evidence that this list is current and updated on at least an annual basis, as part of the company’s Annual Report.

Although the company does not publish details of the country of operation for each entity, there is sufficient evidence from publicly available information that the entities are based in Russia and operate in this jurisdiction as part of the function of the state-owned enterprise.

There is evidence that the company is 100% owned by the Russian Federation, through an agency referred to as the Federal Property Management Agency. The company provides a clear indication that it does not have any other shareholders. There is evidence that information on the company’s ownership is available on its website and in annual reporting documents.

There is evidence that the company’s main purpose is to provide products and services for the Ministry of Defence of the Russian Federation. However, it is not clear from publicly available information that the Russian government is the company’s only customer or that it accounts for all of its defence sales.

There is some evidence that the company acknowledges the corruption risks of operating in different markets, however there is no publicly available information which suggests that risk assessment procedures are used to inform the company’s operations in high risk markets.

The company does not publish a list of fully consolidated subsidiaries and non-fully consolidated holdings (associates, joint ventures and other related entities).

The company discloses the identity of its majority shareholder as of March 2019; it is assumed that this information is still accurate.

However, the company does not disclose details in an open data format and there is no ownership information published in a central public register.

The company does not publish a percentage breakdown of its defence sales by customer.

There is some evidence that the company’s acknowledges the possible corruption risks of operating in different markets, and there is evidence that its risk assessment process includes considerations of geographic location and interactions with various government officials.

However, there is no clear publicly available evidence that the results of risk assessments have a direct impact on business decisions in certain locations or inform the development and implementation of additional controls to mitigate such risks.

The company publishes a list of the holdings in its corporate group, alongside information on the jurisdictions in which they are registered. The company updates this information on an annual basis.

However, the company receives a score of ‘1’ because there is no evidence that it publishes its percentage ownership for each entity, nor does it publish the country or countries of operation for each entity. As there is no information on the percentage ownership, it is not clear whether the companies listed are major subsidiaries, affiliates or joint ventures and therefore it is not clear that the list published represents all of the company’s holdings.

There is evidence that the company is publicly listed on the New York Stock Exchange (NYSE) and therefore it is not required to disclose further information on its beneficial ownership to receive a score of ‘2’. The company also publishes information on its major institutional shareholders on its website.

There is evidence that the company publishes information on its defence sales by customer, to indicate that all of its contracts are with different branches of the United States government. The company indicates that its primary customer is the United States Department of Defence (DoD) and that it provides products and services to all three branches of the military. There is evidence that this information is published and updated for the most recently reported financial year.

There is no evidence that the company acknowledges the corruption risks of operating in different markets, nor that risk assessment procedures are used to inform the company’s operations in high risk markets.

There is evidence that the company provides a list of its subsidiaries in its annual filing to the U.S. Securities and Exchange Commission. For each entity, the company lists the country of incorporation. Since this information is published in an annual reporting document, it is understood that this list is updated on an annual basis.

However, the company receives a score of ‘1’ because the company does not provide further details for each entity such as the percentage ownership and country of operation. Although it the list forms part of an annual reporting document, this list is not accompanied by a statement that it is complete at the time of publication so it is not fully clear whether the list includes all of the company’s holdings such as joint ventures or associates.

There is evidence that the company is publicly listed on the Nasdaq Stock Market and therefore it automatically receives a score of ‘2’. The company also indicates that it is publicly listed in its report to the U.S. Securities and Exchange Commission.

There is evidence that the company provides some information on its major customers in its filing to the U.S. Securities and Exchange Commission. The company indicates that the U.S. government comprised approximately 25% of its revenue in 2019 but this figure is understood to represent a portion of overall company sales rather than defence specifically. The company does not provide a percentage breakdown of sales for other customers and therefore does not reach the minimum threshold of 50% to receive a score of ‘1’.

There is no publicly available evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company’s operations in high risk markets.

There is no evidence that the company publishes a list of subsidiaries or affiliated entities.

There is some evidence that the company is owned, at least partially, by the government of Serbia. However, the company receives a score of ‘1’ because it does not provide further details to clarify its beneficial ownership or control structure, nor does it disclose information to indicate whether any individual owns 25% or more of shares or voting rights. Based on publicly available evidence, it is not clear that the government of Serbia is the company’s sole beneficial owner.

There is no evidence that the company publishes a percentage breakdown of its defence sales by customer. The company publishes some information on its major partners but there is no evidence that this list is complete.