The company\u2019s Code of Conduct, which includes sections addressing its anti-bribery and corruption commitments, is endorsed by the CEO. <\/p>\n
However, the company receives a \u20181\u2019 because the CEO does not specifically mention anti-bribery and corruption in their statement. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
The company publishes an explicit anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees, including in subsidiaries, and board members. <\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is evidence that the board and designated board committees, namely the Audit Committee and Nominating\/ Governance Committee, oversee the company's anti-bribery and corruption programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide any further information regarding what reporting is made to these committees and how oversight is exercised in practice. Also, whilst the company refers briefly to a Global Ethics & Compliance Committee, this appears to be a managerial-level committee.<\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
There is evidence that a designated senior executive, the Chief Ethics and Compliance Officer, has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because further information on their role, seniority, responsibilities and reporting lines is not provided in public materials. Additionally, the company\u2019s Chief Operating Officer and Chief Legal Officer head the company\u2019s Global Ethics Committee and it is not clear whether they report on the company\u2019s anti-bribery and corruption programme to the board or designated board committees.<\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company has a formal risk assessment procedure which is used to inform the company\u2019s anti-bribery and corruption programme. The company indicates that risk assessments form part of its ethics and compliance programme, but provides no further information in its public materials regarding the nature of these procedures.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
The company states that it conducts periodic audits to ensure the company\u2019s continued compliance with anti-corruption laws. In 2018 the Audit Committee conducted a review of the Company\u2019s ethics and compliance programme. However, it is unclear how frequently audits are conducted and whether the findings are used to update the anti-bribery and corruption programme. <\/p>\n"},{"question":60,"commitment_area":8,"score":"0","comments":"
While there is evidence that the company publicly commits to investigating incidents and that it has a whistleblowing channel, it does not provide information about its specific procedures in place, which stipulate documentation and actions to be taken at each step. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
The company does not provide evidence in its public materials regarding how it assures itself of the quality of internal investigations. <\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
While the company states that it may, if necessary, report certain investigations to appropriate authorities, there is no evidence that the company makes a firm commitment to report material findings of bribery and corruption to its board and the relevant authorities.<\/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":"
There is evidence that the company provides training for its employees which outlines the basic principles of the anti-bribery and corruption policy, including the whistleblowing options available. The training is available in 15 languages. There is evidence that all employees are required to complete anti-corruption training on an annual basis. <\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.<\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme. <\/p>\n
However, these measures appear to be simplistic and are limited to completion rates and annual certifications of employees\u2019 adherence to the Code of Conduct. There is also no evidence that results are used to update specific parts of the company\u2019s anti-bribery and corruption communications training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company\u2019s incentive schemes incorporate ethical and anti-bribery and corruption principles. Supervisors are advised to consider an employee\u2019s commitment to ethical conduct during the performance evaluation process, although the company does not provide further details on how this is assessed. <\/p>\n
The company receives a score of \u20181\u2019 because there is no evidence that the company\u2019s executive compensation practices also factor in ethical behaviour.<\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company commits to support or protect employees who refuse to act unethically.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
In its Code of Conduct and Anti-Corruption Policy, the company promotes a clear 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 employed by the group as third parties and joint venture partners. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company assures itself of its employees\u2019 confidence in this commitment through surveys, usage data, or other clearly stated means.<\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
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. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and to relevant external bodies. 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. There is evidence that the company\u2019s whistleblowing lines are available in all languages. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy on conflicts of interest, which applies to all employees and board members. This refers to actual and potential conflicts, and covers employee relationships, financial interests and other employment. <\/p>\n
However, the company does not refer to government relationships.<\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
The company provides some information on its conflicts of interest procedures. Employees and directors are required to disclose potential conflicts to management, human resources or in-house counsel, and the company outlines certain approval processes. The company indicates that disciplinary measures apply for breaches of the company\u2019s conflicts policy.<\/p>\n
However, 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. The policy also does not mention criteria for recusals from conflicts.<\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy that addresses the risks associated with the employment of current or former public officials. <\/p>\n
However, while the company refers to following its standard hiring processes when considering employing current of former public officials, its policy does not include any specific controls to assess and regulate the employment of current or former public officials. <\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company reports details of the contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
The company allows political contributions, and therefore receives a score of \u20180\u2019. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
The company does not disclose details of its political contributions on its website.<\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy covering both charitable donations and sponsorships. It states that it conducts due diligence on recipients and refers to a group approvals process. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not explicitly stated that there is a requirement for senior sign-off. Also, the company does not specify criteria for donations or publish full details of its donations. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy and\/or procedure on lobbying.<\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any information on its lobbying aims, topics or activities. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company provides any details about its global lobbying expenditure on its website. <\/p>\n"},{"question":81,"commitment_area":11,"score":"2","comments":"
There is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. This addresses the risks associated with gifts and hospitality to public officials. There is also evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process. There is also evidence that the company\u2019s policy includes monetary limits and approval procedures. <\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company requires the involvement of its procurement department in the establishment and\/or oversight of its supplier base.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
The company simply states that it conducts due diligence on its business partners but does not provide any further information on its due diligence procedures.<\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
The company states that suppliers are expected to follow similar principles to those outlined in its Code of Conduct, which includes anti-bribery and corruption measures. However, the company receives a score of \u20180\u2019 because it is not explicitly stated that suppliers are required to do so, nor is there 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. It is not specified that assurance is conducted when onboarding new suppliers and\/or when there is a significant change in the business relationship.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
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. <\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions. <\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has a policy which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. There is evidence that the company commits to establishing that the use of agents is necessary to perform a legitimate business function. This policy applies to all divisions within the organisations, including subsidiaries and joint ventures.<\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
The company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging with its third parties and agents. There is also evidence that the company undertakes enhanced due diligence for high-risk agents. The company commits to not engaging or terminating its engagement with agents or intermediaries where the risks identified in the due diligence cannot be mitigated. The company states that it typically repeats due diligence every three years or when there is a significant change in the business relationship. <\/p>\n
The company receives a score of \u20181\u2019 because it does not refresh its due diligence at least every two years. <\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
Although the company indicates that it seeks to identify whether there have been changes to the ownership of third parties when refreshing its due diligence, it does not explicitly commit to establishing the beneficial ownership of its agents at the outset of the business relationship. Moreover, the company does not commit to not engaging or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is evidence the company\u2019s anti-corruption policy applies to agents and intermediaries, and that it includes anti-bribery and corruption clauses in its contracts with such entities. The company indicates that it includes audit rights in its contracts with third parties in some cases but it does not explicitly state that it also includes termination rights in its contracts with these entities.<\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
There is evidence that the company highlights 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. <\/p>\n
However, the company does not explicitly state that remuneration to agents is paid only in staged payments over the course of their contract, based on clear milestones, into local bank accounts. <\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any details of the agents currently contracted to act for and\/or on behalf of the company.<\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving agents. <\/p>\n"},{"question":100,"commitment_area":13,"score":"1","comments":"
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. The company states that partners in certain markets may be subject to more in-depth due diligence, and that it typically repeats due diligence every three years or when there is a significant change in the business relationship. <\/p>\n
However, it is not clear that the company\u2019s due diligence explicitly includes checks on the ultimate beneficial ownership of the partner company, or that it conducts due diligence every two years. <\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
The company states that its Code of Conduct is applicable to joint ventures where it holds the majority interest. The company includes anti-corruption clauses in all third party contracts and audit rights in some high-risk joint ventures. <\/p>\n
However, it is unclear whether the company establishes anti-bribery and corruption policies in joint ventures where it does not hold a controlling interest. Additionally, the company does not specify that it takes steps to detect, control and prevent breaches through the inclusion of audit and termination rights in all of its joint ventures. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. Although the company includes anti-corruption contractual clauses in its contracts with all third parties, it does not provide any further public information on active steps it might take to prevent bribery and corruption in all of its joint ventures.<\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company addresses the corruption risks associated with offset contracting. There is no evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company has a procedure in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.<\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company\u2019s offset programme. <\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of its offset obligations and\/or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"1","comments":"
There is evidence that the company acknowledges the corruption risks associated with operating in different markets and there is evidence that it has a dedicated assessment process in place to assess such risks. There is some evidence that these assessments trigger the implementation of additional controls. <\/p>\n
However, this does not include clear risk management procedures and there is no evidence to suggest that the results of these assessments have an impact on business decisions. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company provides a list of its subsidiaries. This includes the countries of incorporation. <\/p>\n
However, company does not include the percentages owned or the subsidiaries\u2019 countries of operation. Additionally, the list is not accompanied by a statement that it is complete at the time of publication to the best of the company\u2019s knowledge and it is not clear whether the list includes all the company\u2019s holdings. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is publicly listed on the New York Stock Exchange (\u2018NYSE\u2019) and therefore automatically receives a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
The company publishes the customers of less than 50% of its defence sales. <\/p>\n"},{"question":111,"commitment_area":16,"score":"N\/A","comments":""},{"question":112,"commitment_area":16,"score":"N\/A","comments":""},{"question":113,"commitment_area":16,"score":"N\/A","comments":""},{"question":114,"commitment_area":16,"score":"N\/A","comments":""},{"question":115,"commitment_area":16,"score":"N\/A","comments":""}]},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/431","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=431"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=431"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}