There is some evidence that the company publishes a general commitment to anti-corruption and ethical standards, however the company receives a score of \u20181\u2019 because there is no 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 publishes a clear anti-corruption policy that applies to all employees and directors within the organisation. The company states that it operates according to principles of honesty and integrity and publishes an document outlining the disciplinary measures that may result from acts of corruption from the Chinese Communist Party, but there is no evidence that the company itself has a comprehensive anti-corruption policy in place. <\/p>\n"},{"question":56,"commitment_area":7,"score":"0","comments":"
There is no clear evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.<\/p>\n
The company publishes working regulations produced by the Chinese Communist Party which state that the company\u2019s party group is responsible for conducting anti-corruption activities within the company. However, there is no indication that this group has formal oversight functions or that it maintains a reporting line to the company\u2019s board of directors.<\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
There is some evidence that one of the company\u2019s senior executives has a role involving corporate ethics, according to its 2016 Social Responsibility Report, however the company does not provide any further information on the individual\u2019s role or responsibilities in relation to anti-corruption. In addition, the company refers to a different individual on its website with the same title but similarly provides no further information on the individual\u2019s duties. <\/p>\n
Since the information provided is limited and there is no clear evidence that the company has an anti-corruption programme or management system, the company receives a score of \u20180\u2019. There is also no indication that the individuals responsible for corporate ethics have a direct reporting line to the company\u2019s board of directors. <\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, 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.<\/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. The company publishes some information on the number of audit projects conducted but makes no clear statement that these relate to the company\u2019s anti-corruption programme.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is some evidence that the company publicly commits to investigating incidents, and that there is a specific procedure in place to deal with whistleblowing cases. The company provides a description of its whistleblowing procedure from the initial submission of the report to the final outcome of the investigation. There is clear evidence that information on reports is documented and that individuals submitting reports are provided with updates on the outcome of investigations. In addition, the company publishes some information regarding the number of corruption-related reports submitted and handled.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that investigations are handled by an independent team or report to an independent board member or that summary information of investigations is reviewed by a central body on at least an annual basis. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, 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":"
There is some evidence that the company makes a commitment to report suspected instances of corruption and criminality to law enforcement, according to its publicly available investigations procedure. However, the company receives a score of \u20181\u2019 because there is no clear evidence that reports of corruption and criminality are shared with the company\u2019s board of directors, nor is there evidence that a designated senior individual has responsibility for ensuring that the disclosure of such findings 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":"1","comments":"
There is evidence that the company provides a training module on the basic principles of the anti-bribery and corruption policy. However, the company receives a score of \u20181\u2019 because is not clear that anti-corruption training is delivered to employees in all divisions, all countries of operation and in all appropriate languages. There is also no clear evidence to indicate how frequently training is conducted.<\/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. There is some evidence that company representatives give occasional seminars on business ethics, including anti-corruption, to selected managers, however there is no evidence to indicate that these events constitute a training programme for all relevant individuals across the organisation. <\/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":"
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":"
There is no evidence that the company makes a public commitment to support or protect employees who refuse to act unethically. <\/p>\n"},{"question":69,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company has a publicly available policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents. <\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides whistleblowing and advice channels that allow for anonymous reporting. However, the company receives a score of \u20181\u2019 because it only offers internally operated channels. In addition, the company makes no explicit statement that its whistleblowing and advice channels are 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":"0","comments":"
Based on publicly available information, there is no evidence that the company has a policy on conflicts of interest. <\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company has procedures in place to manage conflicts of interest or their oversight. <\/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":"
Based on publicly available information, there is no evidence that the company has a policy or procedure to regulate corporate political contributions.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes details of its political contributions. <\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
The company discloses information on its charitable activities but receives a score of \u20180\u2019 because there is no clear evidence that it has policies and procedures to protect against charitable donations being used as vehicles for bribery or corruption. There is no evidence that the company has procedures in place to stipulate criteria for donations or oversight mechanisms for any charitable expenditures. <\/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 publishes details of its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy or procedure on gifts and hospitality, to ensure that such promotional expenses are not used as vehicles for corruption. The company publishes a document which states that Chinese Communist Party members will face punishment for giving and\/or receiving lavish or inappropriate gifts or cash; however, the company receives a score of \u20180\u2019 because there is no clear evidence that these principles are incorporated into the company\u2019s own anti-corruption policies or apply to all employees across the company.<\/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":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain. <\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
Based on publicly available evidence, there is no clear 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":"
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 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 evidence that the company commits to establishing the beneficial ownership of its agents, nor that it 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":"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 considers incentive structures as a risk factor in agent behaviour, nor that incentive structures for agents are designed to minimise risks of anti-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 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 clear evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, nor that it requires anti-bribery and corruption clauses in its contracts with joint venture partners. The company publicly commits to operate in accordance with the law and in good faith in all of its business partnerships, without making specific reference to corruption, but this does not specifically relate to joint ventures nor does it imply that specific anti-corruption policies will be put in place. <\/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 and 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 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\/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, nor 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, which includes information about the country of incorporation for each entity. However, the company receives a score of \u20181\u2019 because it is not clear whether the companies listed are principal subsidiaries or joint ventures, or if they represent all of the company\u2019s holdings. In addition, the company\u2019s data does not include information on percentage ownership or country of operation. There is also no evidence to indicate whether the data is updated on at least an annual basis. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence to indicate that the company is a state-owned enterprise, with all shares held by Chinese government. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
The company states that it is a major provider to the Chinese armed forces, without providing detail on sales figures or data representing a percentage of its overall sales. The company receives a score of \u20180\u2019 because it does not disclose the countries or customers that represent at least 50% of its defence sales. <\/p>\n"},{"question":111,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company publishes information on shareholder voting rights. <\/p>\n"},{"question":112,"commitment_area":16,"score":"0","comments":"
The company publishes some information on its areas of activity in the national defence industry. However, the company receives a score of \u20180\u2019 because there is no evidence that it publishes clear information on its commercial or public policy objectives.<\/p>\n"},{"question":113,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company publishes any information about its board members or the process for their nomination and appointment.<\/p>\n"},{"question":114,"commitment_area":16,"score":"0","comments":"
There is no evidence that it is composed of a majority of independent directors. The company publishes information to indicate that it has an audit committee, but provides no further information on the composition of the committee. <\/p>\n"},{"question":115,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company publishes any information regarding its management of asset transactions.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/441","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=441"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=441"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}