DCI Indicators

The DCI is composed of 56 distinct questions, grouped into 10 key categories where stronger controls and greater transparency within defence companies can reduce corruption risk.

Due to significant changes in the aim, focus, methodology, and question set of the 2020 index, any comparison with previous indices is not possible or appropriate.

The filter below allows the user to view any or all of the questions and scoring criteria, without any data, to get a better understand of the Index subject matter. Navigate the indicators by risk area or use the search function to identify which indicators correspond to the themes below.

For further details on how exactly the DCI 2020 questionnaire was designed and implemented, see the Methodology page and the DCI Methods Paper.

Click here to download the DCI 2020 questionnaire in PDF format.

Commitment Categories
Tags
1.1 Does the company have a publicly stated anti-bribery and corruption commitment, which is authorised by its leadership?

Score: 2/2

The company publishes a clear statement on its anti-bribery and corruption commitment, which details the company’s stance against any form of bribery or corruption within the organisation. There is evidence that this commitment was authorised and endorsed by the company’s leadership, for example the Chairman, President or CEO.

Score: 1/2

The company publishes a clear statement on its anti-bribery and corruption commitment, however it is lacking in one of the following ways:

  • The company publishes a statement on its anti-bribery and corruption commitment, however there is evidence that this statement is authorised and endorsed by a relevant senior figure other than the company leadership. This could include, for example, a statement from a relevant senior vice president or compliance manager; or,
  • The company publishes a statement on its anti-bribery and corruption commitment and there is evidence that this commitment is authorised and endorsed by the company’s leadership; however, this statement is indirect or unclear in some way. This could include, for example, a general commitment to comply with anti-bribery laws or a mention of anti-corruption as part of a list of company values that is authorised and endorsed by the Chairman or CEO.

Score: 0/2

There is no evidence that the company publishes a commitment to ethical or anti-bribery and corruption standards. Or:

  • The company publishes a statement on its anti-bribery and corruption commitment but there is no evidence that this statement is authorised or endorsed by the company’s leadership or another relevant senior figure;
  • The company publishes a general commitment to ‘integrity’, ‘high ethical standards’ or equivalent, but there is no evidence that this statement is authorised or endorsed by a senior leadership figure;
  • The company publishes a general commitment to comply with anti-bribery laws but there is no evidence that this statement is authorised or endorsed by the company’s leadership or a relevant senior figure.
Policy Leadership and Organisational Control
1.2 Does the company have a comprehensive anti-bribery and corruption policy that explicitly applies to both of the following categories:

a) All employees, including staff and leadership of subsidiaries and other controlled entities;
b) All board members, including non-executive directors.

Score: 2/2

The company publishes a clear anti-bribery and corruption policy, which specifically defines and prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members as described in (a) and (b) in the question.

Score: 1/2

The company publishes an anti-bribery and corruption policy. However, it is lacking in some way, for example:

  • The company’s policy does not extend beyond a general commitment to comply with anti-bribery laws;
  • The company states that it has an anti-bribery and corruption policy, but does not define or specify that it prohibits bribery, payments to public officials, commercial bribery, and/or facilitation payments;
  • The company’s policy does not apply to all groups as specified in (a) and (b) in the question.

Score: 0/2

There is no evidence that the company publishes an anti-bribery and corruption policy, or the information published is insufficiently detailed to be considered a formal policy or programme; for example, the company publishes a general set of prohibited behaviours. Alternatively, the company publishes a policy but it does not explicitly apply to at least (a) all employees.

Policy Leadership and Organisational Control
1.3 Does the board or a dedicated board committee provide oversight of the company's anti-bribery and corruption programme?

Score: 2/2

There is evidence that the board or a designated board committee (such as an ethics or risk committee) is ultimately responsible for the oversight of the company’s anti-bribery and corruption programme. This includes reviewing reports from management on the programme’s performance, including for example the results of internal and external audits, and there is evidence that the board or designated board committee has the authority to require that changes to the programme are made.

Score: 1/2

There is evidence that the board or a designated board committee oversees the company’s anti-bribery and corruption programme. However, there is no evidence to suggest that it engages in formal oversight functions, such as reviewing reports from management on, for example, the results of internal and external audits, or that it has the authority to require that changes to the programme are made.

Score: 0/2

There is no evidence that the company has a designated board committee or individual board member responsible for oversight of its anti-bribery and corruption programme.

Oversight Policy Leadership and Organisational Control
1.4 Is responsibility for implementing and managing the company’s anti-bribery and corruption programme ultimately assigned to a senior executive, and does he or she have a direct reporting line to the board or board committee providing oversight of the company’s programme?

Score: 2/2

There is evidence that a designated senior executive has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the board or designated board committee that provides oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this person and the board as part of the company’s reporting structure; for example, attendance or participation at board-level committee meetings.

Score: 1/2

There is evidence that a designated managerial-level individual has been assigned ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme, but they are not a senior executive and/or there is no evidence that this individual has a direct reporting line to the board or board committee that provides oversight of the anti-bribery and corruption programme.

Score: 0/2

There is no evidence that a designated senior executive or managerial-level employee has ultimate responsibility for implementing and managing the company’s anti-bribery and corruption programme.

Oversight Policy Leadership and Organisational Control
2.1 Is the design and implementation of the anti-bribery and corruption programme tailored to the company based on an assessment of the corruption and bribery risks it faces?

Score: 2/2

There is evidence that the company has a formal bribery and corruption risk assessment procedure in place that informs the design of its anti-bribery and corruption programme. The results of risk assessments are reviewed by the board on at least an annual basis, or when the results of the risk assessments reveal significant findings. There is evidence that the results of such reviews are used to develop tailored mitigation plans and to update specific parts of the company’s anti-bribery and corruption programme.

Score: 1/2

There is evidence that the company has a formal bribery and corruption risk assessment procedure in place that informs the design of the anti-corruption and bribery programme, but this is lacking in one or more of the following ways:

  • There is no evidence that risk assessments are reviewed on at least an annual basis;
  • There is no evidence that the results are reviewed at board level; or
  • There is no evidence that the results of risk assessments are used to develop tailored mitigation plans or to update the company’s anti-bribery and corruption programme.

Score: 0/2

There is no evidence that the company has a formal risk assessment procedure in place that informs the company’s anti-bribery and corruption programme. This can mean that either there is no evidence that the company conducts risk assessments, or there is no evidence that the anti-bribery and corruption programme is designed and adapted based on an assessment of bribery or corruption risk.

Policy Internal Controls
2.2 Is the company’s anti-bribery and corruption programme subject to regular internal or external audit, and are policies and procedures updated according to audit recommendations?

Score: 2/2

There is evidence that the company’s anti-bribery and corruption programme is subject to a regular audit process (or equivalent wording, for example, “assurance”) to ensure the entire programme is consistent with best practice and the business risks facing the company. This includes provisions for continuous improvement, supplemented by an internal or external audit at least every two years. There is also evidence that high-level audit findings are presented to the board, with clear ownership assigned to units and/or individuals for planned updates and improvements to the anti-bribery and corruption programme.

Score: 1/2

There is evidence that the company’s anti-bribery and corruption programme is subject to regular audit or review, but this information is unclear or lacking in some way. For example:

  • There is evidence that the company has a process to conduct audits every two years but it is not clear this covers the entire programme to ensure that it is consistent with high standards of best practice and the business risks facing the company;
  • There is evidence that the company has a process to conduct audits every two years but it is not clear that this covers the whole programme (whether all at once or in stages); or
  • There is no evidence that audit findings are presented to the board, or ownership of the process is unclear.

Score: 0/2

There is no evidence that the company’s anti-bribery and corruption programme is subject to audit or review, or there is evidence that the company conducts such reviews but the information is insufficiently clear to satisfy the requirements for score ‘1’. For example, it is not clear how frequently audits or reviews are conducted or whether the findings are used to update the company’s anti-bribery and corruption programme.

Policy Internal Controls
2.3 Does the company have a system for tracking, investigating and responding to bribery and corruption allegations or incidents, including those reported through whistleblowing channels?

Score: 2/2

There is evidence that the company commits to investigating incidents promptly, independently and objectively. There is evidence that the company takes steps to ensure the independence of its investigations. The company commits to put in place remediation plans and to report investigative findings to senior management and the board. For whistleblowing cases, there is evidence that the company has a procedure in place that stipulates documentation and actions to be taken at every step, from receipt to final outcome, and the company commits to ensure whistleblowers are informed of the outcome, if they so wish. A senior central body of the holding or parent company receives and reviews summary information of all incidents and their status in the organisation and its subsidiaries, on a regular or at least annual basis.

Score: 1/2

There is evidence that the company commits to investigating incidents, and there is a specific procedure in place to deal with whistleblowing cases, which stipulates documentation and actions to be taken at each step. However, this procedure is lacking in some way, for example:

  • There is no evidence or it is unclear that the company takes steps to ensure the independence of its investigations, for example by stipulating that investigations are handled by an independent team and/or report to an independent board member;
  • There is no evidence of a commitment to inform whistleblowers of the outcome of investigations, if they so wish;
  • The information provided does not cover the whole investigation process from receipt to final outcome;
  • There is no evidence that the information on each investigation is documented; or
  • There is no evidence that a central body reviews information on cases or the central body reviews the status of investigations less frequently than an annual basis.

Score: 0/2

There is no evidence that the company has a publicly-stated procedure for dealing with bribery and corruption allegations, incidents or whistleblowing reports. Or, the information provided is insufficiently detailed to satisfy the scoring criteria for ‘1’; for example, it is not clear whether the company has procedures for whistleblowing cases or there is clear evidence that the procedures described do not apply to whistleblowing cases.

Policy Internal Controls
2.4 Does the company have appropriate arrangements in place to ensure the quality of investigations?

Score: 2/2

There is evidence that the company assures itself of the quality of its internal investigations, including those reported through whistleblowing channels. The company explicitly states that staff tasked with conducting investigations are properly qualified and/or trained to perform the function. Any complaints about the handling of concerns and investigations are overseen by an appropriate senior management officer and a procedure is in place to handle the escalation of complaints. There is evidence that the investigations procedure is subject to review at least every three years, or in response to any relevant changes in the regulatory environment.

Score: 1/2

There is evidence that the company assures itself of the quality of its internal investigations. However, this assurance process is lacking in some way, for example:

  • There is no evidence that the company assures itself of the quality of both incident investigations and whistleblowing cases;
  • It is unclear or there is no evidence that staff conducting investigations are properly trained/qualified;
  • There is no mention of how complaints about the investigation process are handled;
  • It is unclear who is responsible for handling such complaints and/or that person is not of an appropriately senior level or function within the company; or
  • There is no evidence that the company reviews its investigations procedure at least every three years or in response to any changes in the regulatory environment.

Score: 0/2

There is no evidence that the company assures itself of the quality of its internal investigations, or the information provided is insufficiently detailed to satisfy the requirements of score ‘1’.

Policy Internal Controls
2.5 Does the company's investigative procedure include a commitment to report material findings of bribery and corruption to the board and any criminal conduct to the relevant authorities?

Score: 2/2

There is clear evidence that the company commits to report material findings of bribery and corruption from investigations to the board. An appropriate senior individual is ultimately responsible for ensuring that the disclosure of criminal offences to relevant authorities is evaluated and acted upon, if necessary.

Score: 1/2

There is evidence that the company commits to report material findings of bribery and corruption from investigations to the board; however, there is no evidence that an appropriate senior individual is responsible for ensuring that the disclosure of criminal offences to relevant authorities is evaluated and acted upon, if necessary. Or, there is evidence that the company has an appropriate senior individual who is responsible for ensuring the disclosure of criminal offences to the relevant authorities is evaluated and acted upon if necessary, but there is no evidence that the company commits to report material findings to the board.

Score: 0/2

There is no evidence that the company has an investigative procedure in place which includes a commitment to report material findings to the board or any other relevant external entity.

Policy Internal Controls
2.6 Does the company publish high‐level results from incident investigations and disciplinary actions against its employees?

Score: 2/2

The company publishes high-level data from ethical or bribery and corruption-related incidents and investigations involving company employees at all levels. This includes at a minimum: the number of reports received, including the number received through whistleblowing channels, the number of investigations launched, and the number of disciplinary actions as a result of investigation findings. This data is published at a regular intervals and/or at least on an annual basis covering cases from the past 12 months.

Score: 1/2

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

  • There is no evidence to suggest that this ethics and compliance-related data would include details of bribery or corruption related incidents, investigations or disciplinary actions;
  • The information that the company publishes does not cover all of the specific measures described in score ‘2’;
  • There is reason to believe that the information does not apply to employees at all levels, i.e. board members or other executives are exempted for some reason;
  • The data is not updated on at least an annual basis and/or does not cover the past 12 months.

Score: 0/2

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

Transparency Internal Controls
3.1 Does the company provide training on its anti-bribery and corruption programme to all employees across all divisions and geographies, and in all appropriate languages?

Score: 2/2

There is evidence that the company provides training – either as a standalone programme or embedded in other ethics and compliance courses – that outlines the principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees. The company provides this training to all employees across all divisions and countries of operation, and in all appropriate languages. The company states that employees are required to undertake refresher courses or modules on the anti-bribery and corruption programme at least every three years.

Score: 1/2

There is evidence that the company provides a training module that outlines the basic principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees. However, the evidence suggests training is not provided to all employees across all divisions, all countries regions of operation or in all appropriate languages. Or, it is unclear how frequently employees are required to undertake or refresh their training on anti-bribery and corruption, or there is evidence that the company only provides this training on an ad hoc or infrequent basis.

Score: 0/2

There is no evidence that the company provides anti-bribery and corruption training to all employees. Or, the information provided is insufficiently detailed to satisfy the requirements of score ‘1’; for example, the company states that it provides training on compliance but it is not clear whether it specifically covers anti-bribery and corruption standards or the whistleblowing options available to employees.

Policy Support to Employees
3.2 Does the company provide tailored training on its anti-bribery and corruption programme for at least the following categories of employees:

a) Employees in high risk positions;
b) Middle mangement;
c) Board members.

Score: 2/2

There is evidence that the company provides tailored anti-bribery and corruption training to employees in different roles based on their exposure to corruption risk, with specific reference to at least the three categories of employee referred to in (a), (b) and (c) of the question. There is evidence that employees in high risk positions are required to undertake and refresh their training in this area on at least an annual basis.

Score: 1/2

There is evidence that the company provides tailored anti-bribery and corruption training to employees in different roles, but either these positions are unclear or the evidence does not make specific reference to all three categories of employee referred to in (a), (b) or (c) of the question. Or, there is no evidence that employees in high risk positions are required to undertake and refresh their training on at least an annual basis; for example by stating that training is provided ‘regularly’, less frequently than once a year, or by not stipulating a timeframe.

Score: 0/2

There is no evidence that the company provides tailored anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.

Policy Support to Employees
3.3 Does the company measure and review the effectiveness of its anti-bribery and corruption communications and training programme?

Score: 2/2

There is evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme (whether stand-alone or embedded). There is evidence that the company has a system to do this, for example through dedicated questions in staff surveys, KPIs measuring effectiveness, the number of compliance-related inquiries received, scenario-testing interactions, audits, or face-to face conversations. The company commits to assuring itself of this on a continuous basis or, if periodically, on at least an annual basis. There is evidence that the results of such reviews are then used to update specific parts of the company’s anti-bribery and corruption communications and training programme, with a review of the programme taking place at least every three years.

Score: 1/2

There is some evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme. However, this is lacking in some way; for example:

  • The measures are too simplistic, for example, limited to the number of personnel trained or completion rates;
  • The company does not assure itself of this on at least an annual basis;
  • It is unclear or there is no evidence that results are used to update specific parts of the company’s anti-bribery and corruption communications and training programme; or
  • It is unclear or there is no evidence that the company conducts a full review of its anti-bribery and corruption programme at least every three years.

Score: 0/2

There is no evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption communications or training programme, or the information provided is insufficiently detailed to satisfy the requirements of score ‘1’.

Policy Support to Employees
3.4 Does the company ensure that its employee incentive schemes are designed in such a way that they promote ethical behaviour and discourage corrupt practices?

Score: 2/2

There is evidence that the company’s incentive schemes for employees are designed in such a way that they simultaneously promote ethical behaviour and discourage corrupt practices. This can be done in a number of ways, but in all cases it must be clear to the assessor that the company incentivises its employees based on ‘how’ they achieve their goals, through tools such as performance appraisals and ethical conduct in the workplace. Where financial rewards are part of an incentive scheme, the company notes that in high-risk departments, such as sales, they must be proportionate to the employee’s salary.

Score: 1/2

There is evidence that the company’s incentive schemes for employee incorporate ethical and anti-bribery and corruption principles. However, the description of how the company achieves this is lacking in some way, for example:

  • There is no evidence that incentives are designed to reward behaviour in line with the company’s ethical values as identified through performance appraisals or conduct in the workplace; in other words, the company’s incentive scheme focuses solely on the achievement of business or financial targets;
  • Where there is evidence that the company includes financial rewards as part of its incentive schemes, there is no evidence that the company acknowledges that they must be proportionate to the base salary in the case of high risk employees, such as sales roles;
  • The company’s evidence only applies to certain employees and does not acknowledge those in high risk positions or departments.

Score: 0/2

There is no evidence that the company’s incentive schemes incorporate ethical or anti-bribery and corruption principles, or  the company’s approach to incentives is unclear to the extent that it cannot satisfy the requirements of score ‘1’.

Financial Policy Support to Employees
3.5 Does the company commit to and assure itself that it will support and protect employees who refuse to act unethically, even when it might result in a loss of business?

Score: 2/2

The company clearly states that any employee who refuses to act unethically, in keeping with the company’s ethical and anti-bribery and corruption values and policy, will be protected and supported even where such actions result in a loss of business or another disadvantage to the company. There is evidence that the company assures itself of its employees’ confidence in this commitment through anonymised surveys or other clearly stated means.

Score: 1/2

The company clearly states that any employee who refuses to act unethically, in keeping with the company’s anti-corruption commitments, will be protected and supported, even where such actions result in a loss of business or another disadvantage to the company. However, there is no evidence that the company assures itself of its employees’ confidence in this statement through anonymised surveys or other clearly stated means.

Score: 0/2

There is no evidence that the company commits to support or protect employees who refuse to act unethically. Alternatively, it does not specify that it will support employees even where such actions result in a loss to the company, or the information provided is unclear to the extent that it cannot satisfy the requirements of score ‘1’.

Policy Support to Employees
3.6 Does the company have a clear policy of non-retaliation against whistleblowers and employees who report bribery and corruption incidents?

Score: 2/2

There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. This policy applies to all employees across the organisation, including those engaged by the group as third parties, suppliers and joint venture partners. The company commits to assure itself of its employees’ confidence in this commitment through surveys or other clearly stated means; this may include monitoring the usage statistics of whistleblowing channels across different parts of the organisation or conducting independent anonymised employee surveys.

Score: 1/2

There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents that applies to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners. However, there is no evidence that the company assures itself of its employees’ confidence in this commitment through surveys, usage data, or other clearly stated means.

Score: 0/2

There is no evidence that the company promotes a policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents. Or, the information provided is lacking in one of the following ways:

  • It is not clear that this policy includes both whistleblowers and employees who report bribery and corruption incidents; or
  • It is not clear that this policy applies to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners.
Policy Support to Employees
3.7 Does the company provide multiple whistleblowing and advice channels for use by all (e.g. employees and external parties), and do they allow for confidential and, wherever possible, anonymous reporting?

Score: 2/2

There is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company’s anti-bribery and corruption programme. These channels are sufficiently varied to allow employees to raise concerns across the management chain, as well as through an external channel operated by an independent third party. These channels allow for confidential and, wherever possible, anonymous reporting. They are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners, and in all relevant languages.

Score: 1/2

There is some evidence that the company has whistleblowing and advice channels, but they fall short in some way. For example:

  • There is no mention of any channels that allow for anonymous or confidential reporting;
  • The company only offers internally operated channels;
  • There are only whistleblowing channels and no advice channels; or
  • The channels are not explicitly available to all employees in any country of operation, or in multiple languages, or to any employees of third parties, suppliers or joint venture partners.

Score: 0/2

There is no evidence that the company has either whistleblowing or advice channels; or this evidence is sufficiently unclear that it cannot satisfy the requirements of score ‘1’.

Policy Support to Employees
4.1 Does the company have a policy defining conflicts of interest – actual, potential and perceived – that applies to all employees and board members and that covers the following categories of possible conflict:

a) Employee relationships;
b) Government relationships;
c) Financial interests; and
d) Other employment.

Score: 2/2

There is evidence that the company formally addresses conflict of interest as a corruption risk, and has a clear policy and/or procedure that defines conflicts of interest, including actual, potential and perceived conflicts. This policy explicitly covers all of the categories of possible conflicts listed in the guidance. The company states that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities.

Score: 1/2

There is evidence that the company has a policy for conflicts of interest, however, it is lacking in some way. For example:

  • It does not explicitly cover all of the categories of possible conflicts listed in the question;
  • It does not clearly define the types of relationships or conflicts covered under its policy; or
  • It is not clear or there is no evidence that the policy apply to all employees and board members.

Score: 0/2

There is no evidence to suggest that the company has a policy on conflict of interest. Or, the information provided is sufficiently unclear that it cannot satisfy the requirements of score ‘1’; for example, the company publishes a sentence about approach to conflicts of interest without further details.

Policy Conflict of Interest
4.2 Are there procedures in place to identify, declare and manage conflicts of interest, which are overseen by a body or individual ultimately accountable for the appropriate management and handling of conflict of interest cases?

Score: 2/2

There is evidence that the company has clear procedures to identify, declare and manage conflicts of interest, actual, potential and perceived. This includes a statement that all employee and board member declarations of actual and potential conflicts of interest are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process. Potential or actual conflict of interest declarations are reviewed and overseen by a designated body or individual with ultimate accountability for its implementation and handling of individual cases. The description of this procedure also includes examples of criteria for recusals and a description of the potential punitive measures for breaches of the policy.

Score: 1/2

There is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. However, this is lacking in some way, for example:

  • The company does not state that all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process;
  • There is no reference to a specific body or individual with oversight and accountability for handling cases; or
  • The company’s policy does not mention examples of criteria for recusals or does not state that disciplinary measures will apply if breached.

Score: 0/2

There is no evidence that the company has procedures to manage conflicts of interest or their oversight. Or, information about these procedures is sufficiently unclear that it cannot satisfy the requirements of score ‘1’.

Policy Conflict of Interest
4.3 Does the company have a policy and procedure regulating the appointment of directors, employees or consultants from the public sector?

Score: 2/2

There is evidence that the company has a policy and/or procedure which includes controls to assess and regulate employment and offers of employment or consultancy engagement to current and recently departed public officials, including politicians. As a minimum, the policy requires senior compliance officer (or equivalent) approval for the initiation of any employment discussions with former or current public officials, a review of actual, potential or perceived conflict of interest and restrictions on their activities if such conflicts of interest are identified. There is also evidence that the company has a policy to implement a cooling-off period of at least 12 months before such public officials are permitted to have any form of contact or relationship with their former organisation on the company’s behalf.

Score: 1/2

There is evidence that the company has a policy that addresses the risks associated with the employment of public officials. However, the policy does not include any specific controls to assess and regulate the employment of current or former public officials, such as requiring senior approval for the initiation of employment discussions, undertaking a conflict of interest review and imposing restrictions on activities if risks are identified, or stipulating a cooling-off period of 12 months.

Score: 0/2

There is no evidence that the company has a policy regulating the employment of current or former public officials, or the company’s policy is insufficiently detailed to satisfy the requirements of score ‘1’.

Political Policy Conflict of Interest
4.4 Does the company report details of the contracted services of serving politicians to the company?

Score: 2/2

The company reports details of contracted and retained services of serving politicians, including the name and position of the individual, the services for which they have been retained and any fees paid or benefit in kind provided to each politician. There is evidence that this list is updated on at least an annual basis, listing all such relationships that are active or have been active in the past 12 months.

Or, the company publishes a clear statement that it does not contract, or has not contracted in this period, any serving politicians.

Score: 1/2

The company reports some details of contracted and retained services of serving politicians, however the information that it reports is lacking in some way. For example, it does not report names or services retained; or it provides only high-level statements about the number of serving politicians retained. Or, the company reports all relevant information but there is no evidence or it is not clear that the list is up-to-date and all covers relationships in the past 12 months.

Score: 0/2

There is no evidence that the company reports details of the contracted services of serving politicians; or, the details that the company reports are sufficiently unclear that it cannot satisfy the requirements of score ‘1’.

Transparency Political Conflict of Interest
5.1.1 Does the company have a clearly defined policy and/or procedure covering political contributions?

Score: 2/2

There is evidence that the company has a policy or clear statement that it prohibits political contributions, to ensure that these payments are not used as vehicles for bribery and corruption. Corporate political contributions whether by the company itself or by any other entity or individual acting on the company’s behalf are prohibited under any circumstance, whether made directly or indirectly.

There is no readily available evidence to suggest that the company is associated with a Political Action Committee (PAC); this applies to any companies headquartered or operating in the USA. It is insufficient for the company to state that it complies with relevant laws and regulations, or to state that in it has not made political contributions in a certain period without a general policy to prohibit such expenditures.

Score: 1/2

Score: 0/2

The company’s approach to political contributions is unclear or lacking in some way. For example:

  • There is no evidence that the company has a policy or procedure on political contributions, and therefore the company’s position on the subject is unclear;
  • There is evidence that the company has a policy on political contributions, however it states that such donations are generally prohibited but permissible in certain circumstances with appropriate authorisation and sign-off;
  • There is evidence that the company has a policy or procedure prohibiting political contributions, however it is not clear or it does not explicitly apply across the organisation to all employees, board members, third parties and/or other entities controlled by the company;
  • There is evidence that the company has a policy which does not prohibit political contributions or indicates that political contributions are permitted or encouraged; or
  • The company prohibits corporate political contributions but there is evidence that the company is associated with a Political Action Committee (PAC) in the USA.
Political Financial Policy Customer Engagement
5.1.2 Does the company publish details of all political contributions made by the company and its subsidiaries, or a statement that it has made no such contribution?

Score: 2/2

The company publishes details of its political contributions, and there is evidence that this data is updated and published on at least an annual basis. These details should include, in line with good practice, details of the recipient, amount, country of recipient and the name of the corporate entity that made the contribution. The company also discloses details of the contributions and disbursements made through any Political Action Committee (PAC) that it might be associated with, either by publishing this information on its website or through a direct link to official reporting documents.

Score: 1/2

Score: 0/2

The company does not publish details of its political contributions, or this data is unclear or lacking in some way. For example:

  • The company publishes a high-level total of all political contributions made in a given time period but does not provide any further details such as details of the recipient, amount, country of recipient and the name of the corporate entity that made the contribution;
  • The company publishes full details of its corporate political donations but there is no evidence that it publishes details of the contributions or disbursements made through any Political Action Committee (PAC) with which it is associated, if relevant; or
  • The company publishes details of its political contributions and PAC contributions, if relevant, but there is evidence that this data is not updated on an annual basis and/or correct to the most recently reported financial year.
Transparency Political Financial Customer Engagement
5.1.3 Does the company have a clearly defined policy and/or procedure covering charitable donations and sponsorships, whether made directly or indirectly, and does it publish details of all such donations made by the company and its subsidiaries?

Score: 2/2

There is evidence that the company has a clear policy and/or procedure covering both charitable donations and sponsorships, whether made directly or through corporate foundations, to ensure that such donations are not used as vehicles for bribery and corruption. There is evidence that these policies and/or procedures include measures to ensure this, for example, by specifying criteria for donations, procedures for senior sign-off, or due diligence on recipients. The company also publishes full details of all charitable donations made, including details of the recipient, amount, country of recipient and which corporate entity made the payment; this includes donations made, financial or in-kind, to corporate foundations. The data is updated and released on at least an annual basis to cover the past 12 months.

Or, the company publishes a clear statement that it does not make charitable donations or sponsorships as a matter of policy, and there is evidence that the company has not made such donations in the past 12 months.

Score: 1/2

There is evidence that the company has a policy and/or procedure covering both charitable donations and sponsorships; however, this policy is lacking in some way. For example:

  • There is evidence that the company’s policy and/or procedure includes measures to ensure that donations are not used as vehicles for bribery and corruption, but these are vague or unclear;
  • The company publishes some details on the charitable donations and sponsorships made, but it does not publish sufficient details as described in score ‘2’; or
  • There is no evidence that the company publishes and updates this information on at least an annual basis to cover the past 12 months.

Score: 0/2

There is no evidence that the company has a policy on charitable donations or sponsorships. Alternatively:

  • There is evidence that the company has a policy and/or procedure on charitable donations or sponsorships, but there is no evidence that the company formally addresses both; or
  • There is evidence that the company has a policy and/or procedure on charitable donations and sponsorships, but there is no evidence that these policies include measures to ensure donations are not used as vehicles for bribery and corruption.
Transparency Political Financial Policy Customer Engagement
5.2.1 Does the company have a policy and/or procedure covering responsible lobbying?

Score: 2/2

There is evidence that the company has a policy and/or procedure that defines lobbying, broad enough to cover the spirit of the term as described in the guidance, and sets out the values and behaviours that constitute ‘responsible’ lobbying. A ‘responsible’ lobbying policy includes, at minimum, certain standards of conduct and clear oversight mechanisms that apply to in-house, external and association lobbyists. This policy provides clear guidelines on what behaviours are acceptable and unacceptable and on the corruption risks associated with lobbying (e.g. gifts and hospitality, undue influence, conflicts of interest, etc.). This policy and/or procedure applies to all employees, board members and third parties lobbying on the company’s behalf.

Score: 1/2

There is some evidence that the company has a policy and/or procedure on lobbying, however it is lacking in some way. For example:

  • The company’s policy does not define lobbying and/or responsible lobbying or the definition is not broad enough to cover the requirements of score ‘2’;
  • The company’s policy is unclear and/or does not mention certain standards of conduct or specific oversight mechanisms that apply to all types of lobbyists;
  • Specific controls or guidelines are not provided or are unclear; or
  • The policy does not apply company-wide to all employees, board members and third parties engaged in lobbying activities on the company’s behalf.

Score: 0/2

There is no evidence that the company has a policy and/or procedure on lobbying, or the evidence that the company provides is insufficiently detailed to satisfy the requirements of score ‘1’.

Political Policy Customer Engagement
5.2.2 Does the company publish details of the aims and topics of its public policy development and lobbying activities it carries out?

Score: 2/2

The company publishes a list of the topics on which it lobbies, including a description of its core positions, their importance or relevance to the company and stakeholders, and the activities it carries out, or which are carried out on its behalf by others. It is clear that these points represent the aims and topics on which the company conducts lobbying activities worldwide; in other words, it provides specific aims and topics for every jurisdiction in which it lobbies or it publishes a statement to clarify that it has only conducted lobbying activities in the countries in which it has publicly stated aims and topics.

Score: 1/2

The company publishes some details of the topics on which it lobbies, but the information provided is incomplete, unclear, out of date, or does not include supporting details of the aims and significant topics or activities that were carried out. Or, the company publishes information on its lobbying aims and topics as described in score ‘2’, but it is not clear that this covers every jurisdiction in which the company lobbies and/or it is not clear whether the company conducts lobbying activities in more than one jurisdiction.

Score: 0/2

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

Transparency Political Customer Engagement
5.2.3 Does the company publish full details of its global lobbying expenditure?

Score: 2/2

The company provides details of all of its global lobbying expenditure, up to the most recently reported financial year. Expenditure data is broken down by corporate entity, geography, internal lobbyists/external lobbyists/association lobbying and an explanation of how the figures in the data have been calculated. It is clear that the figure reported represents the company’s expenditure on all lobbying activities worldwide; in other words, it provides data for every jurisdiction in which it lobbies or it publishes a statement to clarify that it has only conducted lobbying activities in the countries in which it has disclosed expenditure.

Score: 1/2

The company provides some details of its global lobbying expenditure, however this information is lacking in some way. For example:

  • The expenditure data provided does not include all details mentioned in score ‘2’; instead, for example, this data may appear in the form of a summary total expenditure and/or a lack of information on the methodology used to calculate expenditure;
  • The company provides expenditure data but it is not clear that these figures represent global expenditure for all jurisdictions in which the company has conducted lobbying activities; or
  • It is not clear or there is no evidence that the data is correct up to the most recently reported financial year.

Score: 0/2

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

Transparency Political Financial Customer Engagement
5.3.1 Does the company have a policy and/or procedure on gifts and hospitality to ensure they are bona fide to prevent undue influence or other corruption?

Score: 2/2

There is evidence that the company has a policy and/or procedure on the giving and receipt of gifts and hospitality with clear procedures designed to ensure that such promotional expenses are not used as vehicles for bribery and corruption. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy also explicitly addresses the risks associated with gifts and hospitality given to and/or received from domestic and foreign public officials, for example by specifying a different financial threshold or approval procedure. The company’s policy includes a clear statement that all gifts and hospitality above certain thresholds are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.

Score: 1/2

There is evidence that the company has a policy and/or procedure on the giving and receipt of gifts and hospitality to ensure that such promotional expenses are not used as vehicles for bribery and corruption; however this policy is lacking in some way. For example:

  • There is no evidence that the company’s policy specifies financial or proportional limits or different approval procedures for different types of promotional expenses;
  • There is no evidence that the company’s policy addresses the risks associated with gifts and hospitality given to/received from domestic or foreign public officials; or
  • There is no evidence that gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository and/or there is no evidence that this register is accessible to those responsible for oversight of the process.

Score: 0/2

There is no evidence that the company has a policy or procedure on gifts or hospitality, or there is evidence that the company has a policy on gifts and hospitality but it is insufficiently detailed to satisfy the requirements of score ‘1’.

Financial Policy Customer Engagement
6.1 Does the company require the involvement of its procurement department in the establishment of new supplier relationships and in the oversight of its supplier base?

Score: 2/2

There is evidence that the company requires and ensures the involvement of its procurement department in the establishment of new supplier relationships, over a specified threshold if so preferred. The procurement department is ultimately responsible for providing oversight of the company’s supplier base. The company assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means, such as an audit or other assurance process, at least every three years.

Score: 1/2

There is evidence that the company’s procurement department is involved, in some capacity, in the establishment and oversight of supplier relationships; however, this is lacking in some way. For example:

  • The company does not state or provide evidence to suggest that it requires the involvement of its procurement department in the establishment of any new suppliers or those over a specific threshold;
  • It is not clear that the procurement department is the main body responsible for oversight of the company’s supplier base; or
  • There is no evidence that the company assures itself of the procurement department’s involvement at least every three years through clearly stated means, such as an audit or other assurance process.

Score: 0/2

There is no evidence that the company has a procurement department that is involved in and responsible for the establishment and/or oversight of its supplier base.

Oversight Policy Supply Chain Management
6.2 Does the company conduct risk-based anti-bribery and corruption due diligence when engaging or re-engaging with its suppliers?

Score: 2/2

There is evidence that the company has formal procedures to conduct risk-based due diligence when engaging and re-engaging with any suppliers. The due diligence process explicitly includes, at minimum, establishing the ultimate beneficial ownership of the supplying company. There is evidence that highest risk suppliers are subject to enhanced due diligence. This process is conducted at least every two years or when there is a significant change in the business relationship. The company’s due diligence procedure is accompanied by a clear statement that supplier relationships will be subject to review, and potential termination, if any red flags highlighted in the due diligence cannot be mitigated, for example, where beneficial ownership cannot be established.

Score: 1/2

There is evidence that the company has formal procedures to conduct due diligence on its suppliers; however, the procedures are lacking in some way. For example:

  • The company only conducts due diligence on certain types of suppliers, or it is not clear that it conducts due diligence on all suppliers;
  • The company’s due diligence procedures do not include checks on, at least, beneficial ownership;
  • There is no evidence to suggest that highest risk suppliers are subject to enhanced due diligence;
  • The company only conducts due diligence before engaging with suppliers and not at least every two years or in response to a change in the business relationship, or it is not clear how frequently the company conducts due diligence; or
  • There is no evidence to suggest that the company might be willing to review and/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.

Score: 0/2

There is no evidence that the company conducts due diligence on its suppliers. Or, the company’s statement is insufficiently clear to satisfy the requirements of score ‘1’; for example, the company simply states that it conducts due diligence on its suppliers, without providing any further details.

Due Diligence Policy Supply Chain Management
6.3 Does the company require all of its suppliers to have adequate standards of anti-bribery and corruption policies and procedures in place?

Score: 2/2

There is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. It is explicitly stated that all suppliers must have, at minimum, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, as well as policies and procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. There is evidence that the company takes active steps to ensure this, for example by requiring that all suppliers follow its own anti-bribery policies and procedures, or by assessing suppliers’ anti-bribery and corruption programme and ensuring any other appropriate equivalent standards are implemented where gaps are identified. The company assures itself of this when onboarding new suppliers or when there is a significant change in the business relationship.

Score: 1/2

There is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place; however, this is lacking in some way. For example:

  • The company does not clearly state that all suppliers must have, at least, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, and/or policies that cover conflicts of interest, gifts and hospitality, or whistleblowing;
  • There is no evidence to suggest that the company takes active steps to ensure that its suppliers have adequate anti-bribery and corruption policies and procedures in place, or it is unclear how the company ensures this in practice, for example through measures as described in score ‘2’;
  • It is not clear that the company ensures that these standards for all of its suppliers and/or that it assures itself of this for all suppliers; or
  • It is unclear or not specified that this assurance is conducted when onboarding new suppliers and/or when there is a significant change in the business relationship.

Score: 0/2

There is no evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard. Or, the company states that suppliers must meet a certain standard of ethical business conduct, but does not specifically refer to any of the anti-bribery and corruption measures mentioned in score ‘1’.

Oversight Policy Supply Chain Management
6.4 Does the company ensure that its suppliers require all their sub-contractors to have anti-corruption programmes in place that at a minimum adhere to the standards established by the main contractor? 

Score: 2/2

There is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place, and that the substance of its anti-corruption and bribery programme and standards are included in sub-contracts throughout the supply chain. This evidence appears in the form of a clear statement, short description or set of supplier principles that sets the minimum standards of ethical behaviour expected throughout the supply chain.

Score: 1/2

There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. However, this evidence is in the form of a simple statement or it is unclear how the company does this in practice.

Score: 0/2

There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.

Oversight Policy Supply Chain Management
6.5 Does the company publish high-level results from ethical incident investigations and disciplinary actions against suppliers?

Score: 2/2

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

Score: 1/2

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

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

Score: 0/2

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

Transparency Supply Chain Management
7.1.1 Does the company have a clear policy on the use of agents?

Score: 2/2

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

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

Score: 1/2

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

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

Score: 0/2

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

Policy Agents, Intermediaries and Joint Ventures
7.1.2 Does the company conduct risk-based anti-bribery and corruption due diligence when engaging or re-engaging its agents and intermediaries?

Score: 2/2

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

Score: 1/2

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

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

Score: 0/2

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

Due Diligence Policy Agents, Intermediaries and Joint Ventures
7.1.3 Does the company aim to establish the ultimate beneficial ownership of its agents and intermediaries?

Score: 2/2

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

Score: 1/2

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

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

Score: 0/2

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

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

Score: 2/2

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

Score: 1/2

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

Score: 0/2

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

Oversight Policy Agents, Intermediaries and Joint Ventures
7.1.5 Does the company ensure that its incentive schemes for agents are designed in such a way that they promote ethical behaviour and discourage corrupt practices?

Score: 2/2

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

Score: 1/2

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

Score: 0/2

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

Financial Policy Agents, Intermediaries and Joint Ventures
7.1.6 Does the company publish details of all agents currently contracted to act with and on behalf of the company?

Score: 2/2

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

Score: 1/2

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

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

Score: 0/2

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

Transparency Agents, Intermediaries and Joint Ventures
7.1.7 Does the company publish high-level results from incident investigations and sanctions applied against agents?

Score: 2/2

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

Score: 1/2

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

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

Score: 0/2

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

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

Score: 2/2

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

Score: 1/2

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

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

Score: 0/2

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

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

Score: 2/2

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

Score: 1/2

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

Score: 0/2

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

Oversight Policy Agents, Intermediaries and Joint Ventures
7.2.3 Does the company commit to take an active role in preventing bribery and corruption in all of its joint ventures?

Score: 2/2

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

Score: 1/2

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

Score: 0/2

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

Oversight Policy Agents, Intermediaries and Joint Ventures
8.1 Does the company explicitly address the corruption risks associated with offset contracting, and is a dedicated body, department or team responsible for oversight of the company's offset activities?

Score: 2/2

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

Or, the company addresses the corruption risks associated with offset contracting by explicitly stating that it does not enter into contracts that require an offset obligation.

Score: 1/2

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

Score: 0/2

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

Oversight Policy Offsets
8.2 Does the company conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations, which includes an assessment of the legitimate business rationale for the investment?

Score: 2/2

There is clear evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations. This process specifically includes checks on the beneficial ownership of any offset brokers or beneficiaries, and any conflict of interest risks associated with the brokers or beneficiaries. As part of this process, the company’s policy also commits to establishing and verifying that the offset obligation proposed is founded on a legitimate rationale. The company refreshes this due diligence at least every two years or whenever there is a significant change in the business relationship or nature of the partner.

Score: 1/2

There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations; however, this process is lacking in some way. For example;

  • There is no evidence that due diligence includes checks on beneficial ownership and/or conflict of interest;
  • There is no evidence that the company seeks to assure itself of the legitimacy of the investment; or
  • There is no evidence that the company refreshes this due diligence continuously or when there is a significant change in the business relationship or nature of the partner.

Score: 0/2

There is no evidence that the company conducts due diligence on its offset obligations, or the information provided is sufficiently unclear that it cannot satisfy the requirements of score ‘1’.

Due Diligence Policy Offsets
8.3 Does the company publish details of all offset agents and brokers currently contracted to act with and/or on behalf of the company?

Score: 2/2

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

NB: A company may publish offset brokers and agents in an integrated list with all agents it employs, so long as it is possible to identify the agents that are used as part of offset business.

Score: 1/2

The company publishes a list of offset brokers or agents that are contracted to act with and/or on behalf of the company’s offset programme; however, this information is lacking in some way. For example:

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

Score: 0/2

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

Transparency Offsets
8.4 Does the company publish details about the beneficiaries of its indirect offset projects?

Score: 2/2

The company publishes details about the beneficiaries of its indirect offset projects, to a sufficient level of detail that the beneficiary may be identified. These details may include, for example: the name of the company or organisation receiving the investment and the country in which the recipient entity is based. This data is updated on at least an annual basis and covers any obligations from the past 12 months or most recently reported financial year.

Score: 1/2

The company publishes some information about the beneficiaries of its indirect offset projects, however this is lacking in some way. For example:

  • The information is not published to a sufficient level of detail that the beneficiary may be identified, for example only the project name or type of investment is published;
  • The company only publishes aggregate information about its indirect offset projects, for example the number of projects currently underway;
  • It is not clear that these details relate specifically to the beneficiaries of indirect offsets;
  • There is evidence to suggest that not all of the company’s indirect offset projects are included in this list; or
  • The data is not updated regularly and/or has not been updated within the past 12 months or most recently reported financial year.

Score: 0/2

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

Transparency Offsets
9.1 Does the company have enhanced risk management procedures in place for the supply of goods or services to markets or customers in countries identified as at a high risk of corruption?

Score: 2/2

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.

Or, the company has an explicitly stated policy of not operating in high risk markets due to the associated corruption risks. In this case, the company provides a definition of the markets that it considers to be at high risk of corruption.

Score: 1/2

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 this includes clear risk management procedures and/or 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.

Score: 0/2

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

Policy High Risk Markets
9.2 Does the company disclose details of all of its fully consolidated subsidiaries and non-fully consolidated holdings (associates, joint ventures and other related entities)?

Score: 2/2

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. The list is accompanied by a statement or other indication that it is complete at the time of publication to the best of the company’s knowledge.

Score: 1/2

The company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings, but this data is lacking in some way. For example:

  • The list only includes material (principal/significant/main) subsidiaries, associates and joint ventures, rather than a full list of all the company’s holdings;
  • The list does not include the percentages owned, country of incorporation and/or countries of operation for each entity;
  • The list is out of date and/or there is no evidence that it is updated on at least an annual basis; or
  • The list is not accompanied by a statement or other indication that it is complete at the time of publication, to the best of the company’s knowledge.

Score: 0/2

There is no evidence that the company publishes a list of subsidiaries or non-fully consolidated holdings; or the detail published is insufficiently detailed to satisfy the requirements of score ‘1’.

Transparency High Risk Markets
9.3 Does the company disclose its beneficial ownership and control structure?

Score: 2/2

The company discloses all beneficial owners with an ownership in the company or voting rights of 25% or above. All individuals or entities are referred to by name, along with their percentage ownership in the company and any accompanying details necessary to identify the natural person as listed in the guidance or as specified by the public register in which it is disclosed. The data needs to be published in an open data format that is machine readable and structured (for example, as a spreadsheet, rather than just a PDF). The beneficial ownership information may be disclosed in a publicly available and freely accessible companies register or in jurisdictions where one is not available, in the global beneficial ownership register Open Ownership, available through www.openownership.org.

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

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

Score: 1/2

The company discloses some persons or entities with significant holdings in the company, but either does not disclose sufficiently full details in order to score ‘2’, or does not disclose ownership for all owners with a stake of 25% or higher, or does not disclose details in an open data format, or only discloses its ownership on its website instead of a central public register.

Score: 0/2

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.

Transparency High Risk Markets
9.4 Does the company publish a percentage breakdown of its defence sales by customer?

Score: 2/2

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. To score ‘2’ on this question, the company must disclose the customers of at least 80% of its defence sales, and there must be evidence that this data is correct up to the most recently reported financial year.

Score: 1/2

The company publishes a percentage breakdown of its sales by customer, however this information is lacking in some way. For example:

  • The company discloses the customers that account for 50-80% of its defence sales;
  • The company publishes a percentage breakdown of its sales, but it is unclear whether these figures represent defence sales or overall company sales; or
  • The data is not correct up to the most recently reported financial year.

Score: 0/2

There is no evidence that the company publishes any information about its defence customers, or the company publishes information about its customers that account for less than 50% of its defence sales.

Transparency High Risk Markets
10.1 Does the SOE publish a breakdown of its shareholder voting rights?

Score: 2/2

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

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

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

Score: 1/2

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

Score: 0/2

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

Transparency State-Owned Enterprises
10.2 Are the SOE's commercial and public policy objectives publicly available?

Score: 2/2

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

Score: 1/2

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

Score: 0/2

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

Transparency Political State-Owned Enterprises
10.3 Is the SOE open and transparent about the composition of its board and its nomination and appointment process?

Score: 2/2

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

Score: 1/2

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

Score: 0/2

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

Transparency Oversight State-Owned Enterprises
10.4 Is the company's audit committee composed of a majority of independent directors?

Score: 2/2

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

Score: 1/2

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

Score: 0/2

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

Transparency Oversight Policy State-Owned Enterprises
10.5 Does the company have a system in place to assure itself that asset transactions follow a transparent process to ensure they accord to market value?

Score: 2/2

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

Score: 1/2

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

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

Score: 0/2

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

Transparency Financial Oversight Policy State-Owned Enterprises