The 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\u2019s leadership. <\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
The company publishes an explicit anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery and commercial bribery. This policy clearly applies to all employees, including staff and leadership of subsidiaries and other controlled entities as well as all board members, including non-executive directors. <\/p>\n
However, the policy does not specify that it includes a prohibition of facilitation payments. <\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is evidence that a designated board committee oversees the company's anti-bribery and corruption programme. <\/p>\n
However, there is no evidence to suggest that it engages in formal oversight functions, such as reviewing reports from management or the results of internal and external audits.<\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
There is no evidence that a specific managerial-level employee has ultimate responsibility for implementing and managing the company\u2019s anti-bribery and corruption programme. <\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
There is evidence that the company has a formal bribery and corruption risk assessment procedure that informs the design of the anti-corruption and bribery programme. <\/p>\n
However, there is no evidence that the results of this risk analysis are reviewed at board level on at least an annual basis.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company\u2019s anti-bribery and corruption programme is subject to audit or review. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly 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. There is evidence that the procedure covers the whole investigation process from receipt to final outcome. There is also evidence that reports shall be reviewed by the Board of Directors within thirty days from its entry. <\/p>\n
However, it is unclear whether investigations are handled by an independent team. There is also no evidence of a commitment to provide whistleblowers with updates on the outcome of investigations or that the information on each investigation is documented. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company assures itself of the quality of its internal investigations.<\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
The company commits to report material findings of bribery and corruption from investigations to the board. <\/p>\n
However, the company receives a score of \u20181\u2019 because 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.<\/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":"0","comments":"
There is no evidence that the company provides anti-bribery and corruption training to all employees.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company provides anti-bribery and corruption training to all employees, nor that it 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":"0","comments":"
There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
The company\u2019s approach to incentives is unclear to the extent that it cannot satisfy the requirements of score \u20181\u2019.<\/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":"0","comments":"
There is some evidence to suggest that the company has a policy of non-retaliation against individuals who report bribery and corruption incidents, however, the policy does not explicitly refer to both whistleblowers and employees who report bribery and corruption incidents, and does not apply company-wide.<\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
There is evidence that the company has a whistleblowing channel. <\/p>\n
However, there is no evidence that the company has an advice channel, there are no explicitly anonymous or confidential channels, the company only offers internally operated channels, and 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.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
The company has a policy for conflicts of interest that applies to all employees, and third parties. <\/p>\n
However, there is no evidence that the policy covers all of the categories listed in the question, and it does not clearly define the types of relationships or conflicts covered under its policy. <\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
While there is some evidence to suggest that the company has a policy to identify conflict of interest (whistleblowing channel) with clearly assigned responsibility over handling the reported cases, there is no evidence that there are further procedures to declare and manage conflicts of interest. 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, and the policy does not mention examples of criteria for recusals and does not state that disciplinary measures will apply if breached. Therefore, there is no evidence that the company has sufficiently clear procedures in order to receive a score of \u20181\u2019. <\/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.<\/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":"
There is no evidence that the company has a policy on corporate political contributions.<\/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":"0","comments":"
There is no evidence that the company has a policy or procedure covering charitable donations and sponsorships.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy 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 publishes any details about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy or procedure on gifts or hospitality.<\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company requires the involvement of its procurement department in the establishment or oversight of its supplier base.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company states that it conducts due diligence on its supply chain.<\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
Although there is evidence that the Company Policy for Prevention applies to the company\u2019s subcontractors, there is no evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard. <\/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":"0","comments":"
There is no evidence that the company has a policy covering the use of agents. <\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company states that it conducts anti-bribery and corruption due diligence on its agents or intermediaries.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company aims to establish the beneficial ownership of its agents.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.<\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company mentions incentive structures as a risk factor in agent behaviour.<\/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 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":"0","comments":"
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":"
There is no evidence to suggest that the company requires anti-bribery and corruption clauses in its contracts with joint venture partners. <\/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.<\/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. <\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no 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.<\/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 or contracts. <\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company\u2019s operations in high risk markets.<\/p>\n"},{"question":108,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes a list of its subsidiaries and non-fully consolidated holdings.<\/p>\n"},{"question":109,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company discloses any information about its beneficial ownership or control structure, nor a statement that no individual owns 25% or more of shares or voting rights.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company provides a percentage breakdown of its defence sales by customer. <\/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":""}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/437","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=437"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=437"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}