There is evidence that the company has a publicly stated commitment to anti-bribery and corruption, which outlines the company\u2019s stance against all forms of bribery and corruption within the organisation. It is clear that this commitment is endorsed and authorised by the company\u2019s senior leadership. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
The company publishes a clear anti-bribery and corruption policy, which makes specifically 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.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, the company\u2019s Board of Directors and Audit Committee are the bodies that provide oversight of the anti-bribery and corruption programme. There is evidence that their responsibilities include reviewing reports from management on the programme\u2019s performance, along with the results of audits, and there is evidence that it has the authority to require that any necessary changes are made. <\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that the company has an Ethics and Compliance Team which manages its anti-bribery and corruption programme. The Executive Director of this team reports to the Board of Directors and Audit Committee on a quarterly basis regarding the activities of the programme. In addition, there is evidence of reporting and feedback activities between this individual as part of the company\u2019s reporting stricture. <\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company incorporates bribery and corruption risk into its wider Enterprise Risk Management process. <\/p>\n
However, further information on this process is not publicly available. The company does not provide any further detail on the assessment process, such as the frequency at which the assessment is undertaken and reviewed, the types of risk factors which are considered and how the assessment is used to inform the company\u2019s anti-bribery and corruption programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
The company\u2019s Audit Committee is responsible for periodically reviewing its ethics and compliance programme as well as the effectiveness of its compliance function. This includes reviewing the adequacy of policies and practices and the independence, staffing and performance of the Ethics and Compliance Team, and recommending improvements or changes. <\/p>\n
However, the company\u2019s publicly available evidence suggests that internal audits are conducted on the company\u2019s operating functions and it is unclear from public information how frequently audits are undertaken on the company\u2019s ethics and compliance programme. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
The company indicates that it commits to conduct timely investigations, and states that employees are required to cooperate with internal investigations. The company provides some information about the steps in its investigative procedure and there is evidence that the company has a central database where it stores information on whistleblowing reports. There is also evidence that the Executive Ethics Committee reviews quarterly briefings and data on investigations.<\/p>\n
However, the company provides no further publicly available details its investigative process from receipt to final outcome. While the company indicates that employees may follow up on reports, there is no evidence that it clearly commits to provide whistleblowers with information on the outcome of investigations. It is also not clear whether investigations are handled by an independent team and\/or report to an independent board member. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no publicly available information regarding how the company ensures itself of the quality of investigations, for example by indicating that staff conducting investigations are properly trained, by implementing a policy to handle complaints about the process or by reviewing the investigation process every three years. <\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
There is publicly available evidence that the company\u2019s investigative procedure includes provisions to report information about cases to the Board of Directors and Audit Committee on a quarterly basis. The company indicates that the Ethics and Compliance function is responsible for providing updates on this subject. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that 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.<\/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. The company indicates that it collects and evaluates this data on a quarterly basis, however there is no evidence that it publishes this data on its website or in a publicly available report. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is evidence that the company requires its employees to undertake training on anti-bribery and corruption, which it provides in English since it only operates in the United States. The company indicates that employees are required to undertake refresher trainings on a periodic basis. <\/p>\n
However, there is no evidence that employees must undertake and refresh their training on anti-corruption at least every three years. The company also does not clearly indicate that the training includes information on the whistleblowing options available to employees. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides tailored ethics and compliance training for board members and employees in higher risk roles on an annual basis. However, there is no publicly available evidence that the company provides tailored training for employees in middle management positions.<\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
There is evidence that the company has implemented several measures for reviewing the effectiveness of its anti-bribery and corruption communications and training programme. Such measures include a monthly leadership ethics scorecard, a bi-monthly ethics poll and participation in the Defence Industry Benchmark survey on a bi-annual basis. The company\u2019s Executive Ethics Committee reviews trends and employee survey results. The company also gathers data on a quarterly basis from its whistleblowing channel and has developed metrics which allow the company to identify potential risk areas and opportunities for improvement. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no public evidence to suggest that the company\u2019s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
While the company promotes a \u2018speaking up\u2019 culture and has a non-retaliation policy, it does not explicitly state that it will support and protect employees who refuse to act unethically, even when it might result in a loss of business. <\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":"
There is evidence that the company has a clear policy that it will not tolerate retaliation against whistleblowers and employees who report bribery and corruption incidents. The policy applies to all employees and third parties engaged by the company, or anyone on its behalf. There is evidence that the company assures itself of its employees\u2019 trust in this commitment through surveys to assess general awareness of its ethics and compliance programme, as well as through the usage data of its whistleblowing channel. <\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides multiple channels for its employees to report instances of suspected corrupt activity and seek advice on its anti-bribery and corruption programme. The company indicates that these channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an external helpline managed by a third party. These channels allow for confidential and, wherever possible, anonymous reporting. They are available and accessible in English to all employees in the United States, where the company operates, and is also accessible to third parties employed by the group.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence that the company has a clear conflict of interest policy which refers to actual, potential and perceived forms of conflict. The company\u2019s policy covers employee relationships, government relationships, financial interests and other employment and applies to all employees and board members, as well as the company\u2019s subsidiaries and anyone acting on the company\u2019s behalf. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company indicates that employees must provide information on conflicts to the legal and ethics and compliance departments. Although not specific to conflicts of interest alone, the company indicates that any violation of the Code of Conduct may result in disciplinary action, up to and including termination of employment. <\/p>\n
However, it is not clear based on publicly available information whether employees and board members are required to make conflict of interest declarations and whether these are held in a central register or database. The company also does not provide examples of possible criteria for recusals. <\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is evidence that the company highlights the risk around employing current or former government employees or military personnel. The company\u2019s policy stipulates that such individuals must be vetted by legal and human resources before the initiation of any employment discussions. Once hired or retained, the company indicates that those individuals may have their activities restricted which relate to their former employment. <\/p>\n
However, based on publicly available information, it is unclear whether sign-off is required from a senior compliance officer or individual of equivalent seniority. The company also does not state whether it applies a cooling-off period of at least 12 months before individuals can have any form of contact or relationship with their former organisation on the company\u2019s behalf. <\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company publishes details of the contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is evidence that the company has a policy on corporate political donations. The company indicates that political donations, whether made directly or indirectly, are prohibited unless clearly delegated and approved in writing. In cases where donations may be authorised, the company states that they must be approved by its Vice President of Communications. In addition, there is evidence that the company is associated with a Political Action Committee (PAC) in the United States, which is overseen by a committee and board of directors. <\/p>\n
Since the company does not prohibit political contributions and is associated with a PAC, it receives a score of \u20180\u2019 in line with the scoring criteria. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes details of political contributions made on its website.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is evidence that the company has a policy regarding charitable donations to prevent donations being used for undue influence or corrupt intent. However, the company does not have publicly available policy regarding sponsorships; although its foundation states that it does not fund sponsorships, it is not clear whether this is a company-wide policy.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a publicly available policy covering responsible lobbying. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any information on its website regarding its lobbying aims, topics or activities.<\/p>\n"},{"question":80,"commitment_area":11,"score":"1","comments":"
There is evidence that the company provides some details on its lobbying expenditure. The company publishes a high-level figure on its lobbying costs as part of its Annual Report, which appears to indicate that the company did not incur any such costs in the most recently reported financial year. <\/p>\n
However, the company does not publish further information to explain how this figure was calculated and there is no evidence that the company provides a breakdown of these costs by corporate entity, geography, or internal lobbyists versus external lobbyists versus association lobbying. There is also no publicly available evidence to confirm that the company has not engaged in any lobbying activities in the most recently reported financial year, either directly or indirectly, in any jurisdictions. <\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy on gifts and hospitality, which includes financial thresholds and approval processes for different types of gift and promotional expenses. The policy addresses the risks associated with gifts and hospitality given to and\/or received from government personnel, by specifying a different financial threshold and requiring that these be approved in advance by ethics and compliance. The policy also includes several examples of potential red flags around the giving and receipt of gifts and hospitality. <\/p>\n
However, there is no evidence to confirm that gifts and hospitality above a certain threshold are recorded in a dedicated register or central database that is accessible to those responsible for oversight of the process. <\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is evidence that the company\u2019s procurement department is involved in the establishment and oversight of supplier relationships. However, it is not clear from publicly available information that this is the main body responsible for oversight of the company\u2019s entire supply base, nor is there evidence that the company assures itself of the procurement department\u2019s involvement at least every three years. <\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company has procedures in place to conduct anti-bribery and corruption due diligence on its suppliers. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
The company\u2019s Supplier Code of Conduct requires that its suppliers abide by anti-corruption laws and asks them to align their values and ethics to its own. In addition, it prohibits suppliers from making facilitation payments, using gifts and hospitality to gain an unfair competitive advantage, or provide \u2018any improper payments of money or anything of value to government officials, political parties, candidates for public office, or other persons\u2019. <\/p>\n
However, it is not clear from publicly available information whether the company seeks to achieve this by requiring suppliers to develop their own policies or to abide by its Code of Conduct. There is also no public evidence regarding how the company ensures itself of its suppliers\u2019 anti-bribery and anti-corruption policies in practice, or whether it does so when onboarding suppliers and\/or whenever there is a significant change in the relationship. <\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company takes steps to ensure that anti-bribery and corruption standards are cascaded through its 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 or the associated disciplinary actions involving its suppliers. <\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company has a policy on the use of agents or its approach to managing the corruption risks associated with them, such as by establishing and verifying that the use of agents is necessary to perform a legitimate business function. <\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
The company states that it conducts due diligence when selecting or reappointing agents to minimise corruption risk. However, the company does not provide any further publicly available on the company\u2019s due diligence procedure, such as the scope of due diligence, the frequency at which it is undertaken and refreshed, nor whether the company undertakes enhanced due diligence for higher risk agents. <\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company aims to establish the ultimate beneficial ownership of agents and intermediaries. <\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is evidence that the company\u2019s Code of Conduct applies to all agents and intermediaries acting for or on behalf of the company. However, there is no publicly available evidence about whether the company\u2019s contracts with agents and intermediaries include anti-bribery and corruption clauses. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence to suggest that the company recognises incentive structures as a risk factor in agent behaviour, or that its incentive structures have been designed to minimise risks of bribery and corruption.<\/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 or on its behalf.<\/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":"0","comments":"
Based on publicly available information, there is no evidence that the company conducts anti-bribery and corruption due diligence on its joint ventures. <\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company commits to incorporating anti-bribery and corruption policies and procedures in all of its joint venture relationships. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company commits to taking an active role in preventing bribery and corruption in all of its joint venture relationships. <\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no evidence that the corruption risks associated with offset contracting are addressed or that there is a dedicated body, department or team responsible for monitoring the company\u2019s offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company has procedures in place to conduct 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\/or on its behalf.<\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of its offset obligations or contracts. <\/p>\n"},{"question":107,"commitment_area":15,"score":"1","comments":"
There is no evidence that the company acknowledges the corruption risks of operating in different markets, nor that risk assessment procedures are used to inform the company\u2019s operations in any higher risk markets. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a list of fully consolidated subsidiaries and non-consolidated holdings, which includes the countries of incorporation of these entities and the percentage of ownership. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company publishes the country or countries of operation for each entity. In addition, there is evidence to suggest that this list only shows majority owned subsidiaries; it is therefore not clear that this list includes all of the company\u2019s affiliated companies, including all non-fully consolidated holdings. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed on the New York Stock Exchange (NYSE) and therefore it is not required to disclose further information on its beneficial ownership to receive a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"2","comments":"
There is evidence that the company publishes a breakdown of its sales by customer, to indicate that the United States government accounts for 94% of its total sales. The company provides further information on the end users of its products and services, which include two branches of the U.S. military, NASA and other government departments. This information is published on an annual basis as part of the company\u2019s corporate reporting.<\/p>\n
Although the company does not distinguish between defence and commercial sales, there is sufficient evidence to indicate that its sales primarily derive from defence sales and therefore the company receives a score of \u20182\u2019. <\/p>\n"},{"question":111,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":112,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":113,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":114,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":115,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/432","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=432"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=432"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}