There is evidence that the company has a publicly stated anti-corruption commitment, which details the company's stance against bribery and corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's leadership.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company publishes a comprehensive anti-bribery and corruption policy which specifically prohibits bribery, payments to public officials, commercial bribery and facilitation payments. There is evidence that this policy applies to all employees and board members as described in (a) and (b) in the question.<\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
Based on publicly available information, there is evidence that a designated board committee \u2013 the Audit Committee \u2013 is ultimately responsible for oversight of the company's anti-bribery and corruption programme. The Audit Committee\u2019s role includes reviewing reports from management on the company\u2019s risk assessment procedure and receiving reports on investigations. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear publicly available evidence that the Audit Committee receives reports on the overall performance of the company\u2019s anti-bribery and corruption programme, nor that it has the authority to require that changes to the programme are made as a result of reviews. <\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
Based on publicly available information, there is evidence that the company's Chief Compliance Officer and the General Counsel are jointly responsible for implementing and managing the company's anti-bribery and corruption programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because, although there is evidence of reporting activities between these persons and the Audit Committee, this appears to mostly relate to the presentations of risk assessments, rather than the status of the anti-bribery and corruption programme more broadly.<\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a formal bribery and corruption risk assessment procedure that informs the design of its anti-bribery and corruption programme. The company indicates that the results of risk assessments are reviewed by the Audit Committee on at least an annual basis. There is evidence that the results of such reviews are used to update specific parts of the company's anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company\u2019s anti-bribery and corruption programme is subject to regular review by an internal audit department. The company states that this process takes place regularly, no less than annually, and it is clear that the results of audits are used to make updates and improvements to the anti-bribery and corruption programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that high-level audit findings are presented to the board. Moreover, ownership of this process is unclear as the company does not publicly state which body or senior individual is responsible for using the audit findings to make updates to the company\u2019s programme. There is also no clear evidence that \u2013 in addition to ensuring the proper functioning of the company\u2019s internal controls \u2013 these audits are used to ensure that the programme is consistent with best practice and the business risks facing the company.<\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
There is evidence that the company publicly commits to investigating allegations and incidents of bribery and corruption, including those reported through whistleblowing channels. For whistleblowing cases, there is a procedure in place that stipulates documentation and actions to be taken at every step of the case, from receipt to final outcome, and the company indicates that it will inform whistleblowers of the outcome of investigations. although the company does not explicitly state that the Audit Committee receives reports concerning investigations on an annual basis, there is sufficient evidence of regular and ongoing reporting systems for the company to receive a score of \u20182\u2019.<\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company assures itself of the quality of its internal investigations. There is evidence that investigators are appropriately qualified to perform the function.<\/p>\n
However, there is no evidence that the company has a system in place to handle complaints about the investigation process, nor which individual would be responsible for the handling such complaints. It is also not clear that the company assures itself of the quality of both incident investigations and whistleblowing cases. In addition, 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.<\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company reports findings of corruption investigations to the Audit Committee of the board of directors. However, the company receives a score of \u20181\u2019 because there is no evidence that the company publicly commits to disclose criminal offences to the relevant authorities if necessary, nor does it indicate that a specific senior individual is responsible for ensuring such disclosures. <\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption investigations, or disciplinary actions involving its employees.<\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides training that outlines the principles of its anti-bribery and corruption policy, which covers the whistleblowing options available to employees. There is evidence that 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 must repeat the training on an annual basis. <\/p>\n"},{"question":65,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company tailors its anti-bribery and corruption training programme to the different levels of risk facing employees in different roles. The company makes specific reference to the categories of employee referred to in the question. There is evidence that employees working in high risk positions are required to refresh their training on at least an annual basis. <\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme on an annual basis. There is evidence that the results of such reviews are used to update the programme. <\/p>\n
However, the company receives a score of \u20191\u2019 because it does not provide any publicly available information to indicate how it measures effectiveness, and therefore it is unclear how the company does this in practice.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company\u2019s incentive schemes incorporate ethical or anti-bribery and corruption principles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company encourages employees to act ethically, even when it results in a loss of business for the company. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the company assures itself of its employees\u2019 confidence in this statement through anonymised surveys or other clearly stated means.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, which explicitly applies to all employees across the organisation, including those engaged by the group as third parties, suppliers and joint venture partners. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evi<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/428","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies"}],"about":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/types\/companies"}],"wp:attachment":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/media?parent=428"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=428"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}