Based on publicly available information, company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's CEO.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
The company publishes a comprehensive Anti-Corruption Policy and supporting Code of Conduct, both of which specifically define and prohibit bribery, payments to public officials, commercial bribery and facilitation payments. Both policies clearly apply to all employees and board members as described in (a) and (b) above, regardless of their location, responsibilities or seniority.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that the company has a designated board committee \u2013 the Ethics and Compliance Committee \u2013 that is ultimately responsible for oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from management on the programme\u2019s performance and ensuring that required changes are made. <\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior executive \u2013 the Ethics and Compliance Officer \u2013 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 committee that provides oversight of the anti-bribery and corruption programme, and there is evidence that the company\u2019s reporting structure allows the Ethics and Compliance Officer to report and feedback to the board directors (through the General Counsel). <\/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 the anti-bribery and corruption programme. It is clear that the results of these risk assessments are used to develop action plans and update policies and procedures. There is evidence that the board reviews the results of these assessments on at least an annual basis. <\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
Based on publicly available evidence, the company\u2019s internal processes and activities \u2013 including the company\u2019s anti-bribery and corruption programme \u2013 are subject to internal and external audit. The company develops action plans to improve its anti-corruption policies based on the findings and recommendations of these audits and, more recently, has appointed an Independent Compliance Review Panel to advise the CEO and Board on how to improve ethics and compliance processes. There is evidence that these audits are conducted annually. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, the company commits to investigating incidents promptly and has a specific procedure in place to deal with whistleblowing cases. This procedure covers the whole investigation from receipt to outcome and includes provisions to provide employees (including whistleblowers) with updates on the outcome of investigations. Additionally, the company\u2019s investigations procedure ensures independence by outsourcing to an external provider and by stipulating the involvement of different senior individuals depending on the type of report. However, the company does not clearly state that information on each investigation is documented, nor that a central body reviews summary information of all reports and their status on an annual basis<\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
There is some evidence that the company assures itself of the quality of its internal investigations and whistleblowing cases, for example by asking for feedback from those who report cases. There is also evidence that staff conducting investigations are properly qualified. However, the company does not provide sufficient detail on how complaints about the investigation process are handled, nor does it state that its procedures are reviewed regularly or at least every three years in response to any changes in the regulatory environment. More information may be available in the document entitled \u201cAirbus Method for Investigation of Compliance Allegations\u201d, however this is not publicly accessible.<\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
The company makes a clear commitment 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 found necessary.<\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company publishes high-level results from incident investigations or any information related to disciplinary actions against its employees. <\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides both face-to-face and online anti-corruption training to all employees across all divisions and geographies, in four different languages. The company requires its employees to undertake Ethics and Compliance training, including on Anti-Bribery and Corruption, at least once a year. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides tailored anti-bribery and corruption training to employees based on their job role, location and level of risk. There is evidence that this includes employees in high risk employees and board members. However, there is insufficient evidence that the company provides training to employees covered in (b) above, and it is not clear that training for employees in high-risk positions is refreshed on at least an annual basis. <\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, the company\u2019s board of directors receives an update on ethics and compliance training on an annual basis. The Annual Report also contains some high-level information on the anti-bribery and corruption e-training provided to employees, in the form of completion rates. However, there is no evidence to indicate that the company measures or reviews the effectiveness of its anti-bribery and corruption communications or training programme beyond completion rates. According to the Annual Report, the company issued questionnaires to its affiliates in 2018 to check that internal procedures were adequate and to ensure that anti-corruption messaged had been communicated, but this is not sufficient to receive a score of \u20182\u2019. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company\u2019s incentive schemes incorporate ethical or anti-bribery and corruption principles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company commits to supporting employees who refuse to act unethically where such actions may result in a loss of business or other disadvantage to the company.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, the company has a clear policy of non-retaliation against whistleblowers and employees who report suspected bribery and corruption incidents. This commitment provides a clear definition of actions that may constitute retaliation and is repeated in several different documents that are made available to all employees. Additionally, there is evidence that this policy extends to suppliers, affiliates and third parties who may wish to report suspected bribery and corruption. However, there is no evidence that the company assures itself of its employees\u2019 confidence in the commitment of non-retaliation through surveys, usage data or other clearly stated means. <\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
According to publicly available information, the company offers multiple channels for employees, suppliers and third parties to report instances of suspected bribery or corruption or seek advice. Channels are sufficiently varied to allow employees to raise concerns across the management chain and across divisions \u2013 including to an external independent provider \u2013 as well as being accessible to employees in all jurisdictions in which the company operates and in all relevant languages. There is evidence that these channels allow for confidential and, where possible, anonymous reporting of concerns. <\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
Based on publicly available evidence, the company has a policy on conflicts of interest which applies to all employees and board members. This policy covers actual, potential and perceived conflicts of interest and covers employee relationships, other employment, government relations and financial interests as possible categories of conflict. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
Based on publicly available evidence, the company has procedures in place to identify, declare and manage conflicts of interest. This includes declaring the actual or perceived conflict to a line manager or to the Ethics and Compliance team, the latter of which provides oversight of these declarations. However, there is no evidence that all declarations are recorded in a central register. Additionally, there is no information regarding the possible criteria for recusals or potential punitive measures for breaches of the policy. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company has a policy regulating the employment of current or former public officials. Although the company acknowledges the need to comply with all applicable laws and regulations when hiring such individuals, there is no evidence of a policy with specific controls to regulate such interactions. <\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the company reports details of contracted services of serving politicians. <\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
There is publicly available evidence to indicate that the company has a policy on corporate political donations, where by such contributions are permitted subject to prior review and approval.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company discloses details of its political contributions. <\/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. This policy specifies criteria for the type of donations and states that authorisation is required for donations over a certain threshold. Examples of charitable donations and sponsorships are mentioned on the company\u2019s website and in the Annual Report. However, the company does not publish full details of the donations made by the company, such as the recipient, amount, country and corporate entity that made the payment. The relationship between the company\u2019s Sponsorships, Donations and Corporate Memberships Directive and the activities of the Airbus Foundation is also unclear. <\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
There is some publicly available evidence that the company has a policy on lobbying. This policy requires due diligence checks on lobbyists and compliance with all relevant laws, and states that lobbying is overseen jointly by the Ethics and Compliance and Government Relations teams. However, these provisions are not sufficient to constitute a responsible lobbying policy. Although the company mentions an internal Lobbyist & Special Advisors Due Diligence Directive, there is no publicly available evidence of guidelines to establish certain standards of conduct for lobbyists, beyond a broad commitment to integrity. <\/p>\n"},{"question":79,"commitment_area":11,"score":"2","comments":"
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. The company provides specific aims and topics for in the main jurisdictions in which it lobbies. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes details of its global lobbying expenditure. <\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. The policy addresses the risks associated with gifts and hospitality given to and received from domestic or foreign government officials. The policy also indicates that there are specific financial limits and different approval procedures for different types of promotional expenses. However, there is no 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. <\/p>\n"},{"question":82,"commitment_area":12,"score":"2","comments":"
There is evidence that the company requires the involvement of its procurement team in the establishment of new suppliers and that this team is ultimately responsible for providing oversight of the company's supplier base. The company states that the procurement team maintains oversight of all supplier relationships, which implies that the department is constantly involved in the company\u2019s supplier relationships. <\/p>\n"},{"question":83,"commitment_area":12,"score":"2","comments":"
According to publicly available evidence, the company has procedures to conduct due diligence on all of its suppliers both at the start of the business relationship and on an ongoing basis afterwards. There is evidence that the company\u2019s checks include verifying the beneficial ownership of each supplier and that suppliers may be subject to enhanced due diligence based on an internal risk assessment. Additionally, it is clear that supplier relationships will be subject to review and possible termination if the results of due diligence reveal significant concerns. <\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence that the company contractually requires all of its suppliers to comply with the Airbus Supplier Code of Conduct which outlines the best practices in regards to ethics and compliance. This includes requirements for policies that prohibit foreign and domestic bribery, facilitation payments, and address conflict of interest, gifts and hospitality and whistleblowing. The company assures itself of its suppliers\u2019 compliance with its code of conduct when onboarding new suppliers and for the duration of the business relationship.<\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
The company publicly states that its suppliers are expected to cascade the ethics and compliance standards outlined in the Airbus Supplier Code of Conduct throughout their own supply chains. However, it is unclear how the company does this in practice.<\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
Based on publicly available evidence, the company publishes some information about the number of suppliers it has identified through its risk mapping system and the number of quality alerts received. However, it does not publish any high-level results from ethical incident investigations or the related disciplinary actions. <\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
Based on publicly available evidence, the company has a policy on the use of agents which acknowledges the associated corruption risks and provides details of specific controls to mitigate these risks. There is evidence that the company\u2019s approach includes ensuring that third parties conduct work under a valid, approved contract, thereby ensuring that agents are only engaged to perform legitimate business functions. There is evidence that this policy applies across all group companies.<\/p>\n"},{"question":89,"commitment_area":13,"score":"2","comments":"
Based on publicly available evidence, the company has in place formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with third parties. There is evidence that agents and high risk intermediaries are subject to enhance due diligence, and it is clear that these checks are conducted regularly throughout the entire life of the relationship. There is evidence that the company commits to review or terminate its engagement with third party agents and intermediaries where risks identified in the due diligence cannot be mitigated. <\/p>\n"},{"question":90,"commitment_area":13,"score":"2","comments":"
There is publicly available evidence that the company has formal procedures in place to establish and verify the beneficial ownership of third party agents prior to engaging with them and on an ongoing basis throughout the relationship. The company commits 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":"2","comments":"
According to publicly available information, the company requires that all of its third parties comply with its anti-bribery and corruption policies as well as with international anti-corruption laws. The company monitors its third parties in this respect throughout the duration of the relationship and conducts regular audits of these parties. There is evidence that the company\u2019s contracts with third party agents include formal provisions to terminate the relationship if necessary. <\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, incentive structures for agents are highlighted and addressed 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 there is no requirement that remuneration is paid in stage payments or into local bank accounts.<\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes details of the agents currently contracted 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 any associated disciplinary actions involving its third party agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has procedures in place to conduct due diligence when entering into and operating as part of joint ventures. The company states that it has processes to ensure that corruption risks associated with joint ventures are detected, assessed and mitigated. There is some evidence that high-risk intermediaries are subject to enhanced due diligence. The company\u2019s due diligence explicitly includes checks on the ultimate beneficial ownership of the partner company. However, there is no evidence that due diligence checks are conducted at least every two years. <\/p>\n"},{"question":101,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company commits to establishing and implementing anti-bribery and corruption policies and procedures in all of its joint ventures. The company implemented a directive that requires the company to terminate a joint venture following a breach of anti-corruption representations and warranties in its joint venture agreement, and that also specifies the company\u2019s right to conduct periodic audits of these entities. <\/p>\n"},{"question":102,"commitment_area":13,"score":"1","comments":"
There is evidence that the company publicly 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 statements or evidence to support this claim.<\/p>\n"},{"question":103,"commitment_area":14,"score":"1","comments":"
There is evidence that the company recognises the corruption risks associated with offset contracting, and that it has a dedicated team involved in managing offset obligations. However, there is little evidence of policies and processes in place, and it is not clear that this team is responsible for monitoring the company\u2019s offset activities throughout the lifecycle of each project. There is also no evidence that all employees within the team receive tailored anti-bribery and corruption training.<\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
There is publicly available evidence that the company conducts due diligence on its offset activities. There is evidence that the company takes steps to ensure the legitimacy of the investment and that the due diligence checks include beneficial ownership. However, there is no evidence that the due diligence checks include conflict of interest risks. There is also no evidence that the company refreshes its due diligence continuously or when there is a significant change in the business relationship or nature of the partner. <\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
The company does not publish 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":"
The company does not publish any details of its offset obligations or contracts. <\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
Based on publicly available evidence, the company acknowledges the risks associated with operating in different markets and there is evidence that a risk assessment procedure is in place to account for specific risks associated with anti-money laundering\/counter terrorism financing risks. There is evidence that these assessments impact business decisions to some extent. However, there is no evidence to suggest that the company\u2019s risk assessment procedures cover bribery and corruption risks in different markets. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
Based on publicly available evidence, the company discloses its fully consolidated and non-fully consolidating holdings, its percentage of ownership and their country of incorporation. This information is published annually. However, there is evidence that the company has other holdings which are not part of this list; it is therefore not clear that the company has disclosed a full list of its holdings and subsidiaries. Additionally, the company does not publish countries of operation for each of its subsidiaries. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
Based on publicly available evidence, the company is a publicly listed company on the Paris, London and other international stock exchanges. It therefore automatically receives a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
The company publishes some information about its defence customers. The company publishes defence sales by customer and the total number of aircraft ordered, delivered and in operation for its Military Aircraft programme. However, there are three other programme lines falling under Defence and Space for which information is not published. It is therefore not possible to deduce a breakdown of defence sales per customer. <\/p>\n"},{"question":111,"commitment_area":16,"score":"2","comments":"
The company publishes a breakdown of its shareholder voting rights, including where this relates to the French, German and Spanish states that each own minority shares. Evidence suggests that the voting rights for these states are equivalent to the percentage of shares held in the company and that no shareholder may retain more than 15% of the capital or voting rights.<\/p>\n"},{"question":112,"commitment_area":16,"score":"2","comments":"
The commercial and public policy objectives of the company are made publicly available on its website, and are updated on an annual basis. <\/p>\n"},{"question":113,"commitment_area":16,"score":"2","comments":"
Based on publicly available information, there is evidence that the company is open and clear 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. <\/p>\n"},{"question":114,"commitment_area":16,"score":"2","comments":"
According to publicly available evidence, the company\u2019s audit committee is fully composed of independent directors. <\/p>\n"},{"question":115,"commitment_area":16,"score":"1","comments":"
Based on publicly available evidence, the company has a system in place to manage asset transactions. However, there is no evidence that responsibility for managing asset transactions is held at board level or that asset transactions are subject to scrutiny by an audit board. The company does not publish financial information from its asset acquisitions and there is no evidence that all transactions are documented. <\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/434","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=434"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=434"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}