There is evidence that the company makes a general commitment to ethical standards. However, there is no evidence that the company directly addresses anti-bribery and corruption in this commitment, nor is there evidence that this statement is authorised or supported by a senior figure within the organisation.<\/p>\n"},{"question":55,"commitment_area":7,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company has a comprehensive anti-bribery and corruption policy that applies to all employees. The company indicates that it has a Code of Conduct as well as specific anti-corruption and whistleblowing policies, however these policies do not appear to be available in the public domain.<\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is some evidence that the company\u2019s board and a board-level committee \u2013 the Audit and Risk Management Committee \u2013 oversee the company\u2019s compliance programme. There is evidence to suggest that the bodies engage in formal oversight functions, such as reviewing reports from management.<\/p>\n
However, the company scores \u20181\u2019 because there is no publicly available evidence to indicate that this includes oversight of its anti-bribery and corruption activities specifically. There is also no evidence that either the board or the Audit and Risk Management Committee reviews the results of internal and external audits of the anti-bribery and corruption programme. <\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
There is no evidence that a specific senior individual or 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 risk assessment procedure, which is used to inform the its compliance programme. The company indicates that its board of directors reviews the effectiveness of the company\u2019s risk management and compliance procedures on an annual basis. <\/p>\n
The company scores \u20181\u2019 because there is no clear evidence that it assesses bribery and corruption risks as part of its risk management procedures. It is also not clear from publicly available evidence whether the findings of compliance reviews are used to develop tailored mitigation plans and to update specific parts of the company\u2019s anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
There is some evidence that the company\u2019s compliance programme is subject to audit to ensure that its procedures are in line with relevant regulatory requirements and good practice standards. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that such reviews cover the whole anti-corruption or compliance programme, nor does the company provide clear information on the frequency of such reviews.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company has a system for tracking, investigating and responding to bribery and corruption allegations or incidents, including those reported through whistleblowing channels. The company\u2019s Whistleblower Protection Policy outlines the whole investigation process from receipt to final outcome and there is a commitment to providing whistleblowers with updates on the outcome of investigations. There is also evidence indicating that information on each investigation is appropriately documented. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that a central body reviews summary information on investigations on a regular basis. It is also not clear that 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 clear evidence that the company assures itself of the quality of its internal investigations. The company indicates that its investigators receive training on the Whistleblower Protection Policy, but there is no evidence that staff conducting investigators receive other training related to internal investigations, nor is there evidence that the company has a procedure in place to handle complaints about the process or to review the procedure regularly. <\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company\u2019s investigative procedure includes a commitment to report material findings of bribery and corruption to the board or to 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":"0","comments":"
Based on publicly available information, there is no evidence that the company provides anti-bribery and corruption training to its employees. <\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company provides tailored anti-bribery and corruption training to its employees based on an assessment of their role and exposure to corruption risk.<\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption communications or training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company\u2019s renumeration structures incorporate ethical principles. The company states that it emphasises ethics when recognising employee performance and indicates that individual employees may also lose rewards in cases of misconduct.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that it has a specific approach for employees in high risk positions, such as those in sales roles. There is also no evidence that financial rewards must be proportionate to the employee\u2019s salary in the case of high risk employees.<\/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":"
There is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is evidence that this applies to all employees across the organisation, including those employed by the group as third parties, such as suppliers and contractors. <\/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":"1","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. The company indicates that these channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an independent body through a third party-operated channel. The company\u2019s channels allow for confidential and anonymous reporting, and there is evidence that these channels are open to all employees as well as third parties, including suppliers.<\/p>\n
The company receives a score of \u20181\u2019 because there is no evidence these channels are available in multiple languages, nor that the channels are may be accessed by employees and third parties in any country of operation.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is publicly available evidence that the company has a policy on conflicts of interest, which makes specific reference to actual, perceived and potential conflicts of interest. There is evidence that the company\u2019s policy covers employee relationships, financial interests and other employment.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that this policy covers conflicts associated with government relationships. In addition, there is evidence to indicate that the policies apply primarily to directors and managers; it is not clear that the same conflict of interest policies apply to all employees. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is some evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that all employee and board member declarations are held in a dedicated central register that is accessible to those responsible for oversight of the process. Based on publicly available evidence, it is not clear that a specific body or individual provides oversight and has accountability for handling cases. There is also no indication that the company provides examples of criteria for recusals, nor that disciplinary measures will apply 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.<\/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":"
Based on publicly available information, there is no evidence that the company has a policy to regulate corporate political contributions. The company indicates that employees engaged in political activities must receive approval from the company\u2019s leadership, but there is no evidence that the company has a formal policy in place at corporate level. <\/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, The company publishes some information on its charitable activities but does not publish any details of specific procedures for such activities to ensure that such donations are not used as vehicles for bribery or corruption. Although the company provides some information on the charitable causes it supports on its website, there is no evidence that it publishes full details of its donations \u2013 including details of the recipient, amount, country of recipient and which corporate entity made the payment \u2013 on at least an annual basis. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, 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":"1","comments":"
There is some evidence that the company has a policy on the giving and receipt of gifts and hospitality, which specifies senior manager approval for certain proportionate gifts. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the policy specifies financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no evidence that the policy addresses the risks associated with gifts and hospitality given to or received from domestic or foreign public officials. There is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.<\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company\u2019s purchasing departments are involved, in some capacity, in the establishment and oversight of its supplier relationships. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that the procurement department is the main body responsible for oversight of the company\u2019s supplier base. There is also no 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":"1","comments":"
There is some evidence that the company has formal procedures to conduct due diligence on its suppliers. There is evidence that the highest risk suppliers are subject to enhanced due diligence procedures. <\/p>\n
However, the company receives a score of \u20181\u2019 because its publicly available information indicates that only certain types of suppliers are subject to due diligence. There is no evidence that the due diligence process includes checks on ultimate beneficial ownership, nor that due diligence is repeated at least every two years or whenever there is a change in the business relationship. There is also no evidence to suggest that the company might be willing to review supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.<\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company requires its suppliers to comply with certain anti-bribery and corruption standards through the inclusion of contractual clauses in its purchase order terms and conditions. There is evidence that these standards prohibit bribery and facilitation payments. <\/p>\n
The company receives a score of \u20181\u2019 because there is no evidence that it requires suppliers to have policies and\/or procedures that cover conflicts of interest, gifts and hospitality and whistleblowing. The company indicates that its due diligence includes checks on the supplier\u2019s human resources policies and procedures, but it is not clear that this includes anti-bribery and corruption policies.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption standards are required throughout the supply chain. There is some evidence in the company\u2019s purchase order terms and conditions that suppliers are responsible for their subcontractors, but there is no evidence that this extends to a commitment on anti-bribery and corruption standards.<\/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 relating to its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company has a policy on the use of agents.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company 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 publicly available 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 publicly available 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 publicly available evidence that the company recognises 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 and\/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 its agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
There is no publicly available 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 publicly available evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no publicly available 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, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.<\/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 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 its 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 contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no publicly available 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":"1","comments":"
The company publishes a list of its subsidiaries and joint ventures as part of its annual reporting documents. For each entity, the company discloses the country of incorporation and the percentage ownership that it holds. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear whether the list includes non-fully consolidated holdings or any other related entities. There is also no evidence that the company publishes the country of operation for each entity.<\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
There is evidence that the company discloses all of its beneficial owners with an ownership in the company of 25% or above. These entities and\/or individuals are referred to in the company\u2019s Annual Report by name, along with their percentage of issued share capital. There is also evidence that ownership information is available on the Australian Securities & Investment Commission site and that the company is publicly listed on the Australian Securities Exchange. <\/p>\n
However, the company receives a score of \u20181\u2019 because the company\u2019s beneficial ownership information is not published in open data or machine readable format. Although information is available through the Australian Securities & Investment Commission site, this information requires payment and is therefore not publicly available. In addition, although the company is listed on the Australian Securities Exchange, this is not one of the specific regulated markets listed in the scoring guidance.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes information about its defence sales in the form of a percentage breakdown by customer. The company mentions some of its main customers in its Annual Report and on its website, but it is not clear whether these represent commercial or defence customers (or both), nor does it provide further information to indicate the percentage sales per 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\/440","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=440"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=440"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}