There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of corruption within the organisation. There is clear evidence that this commitment was authorised and endorsed by the company's CEO.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company publishes a clear anti-bribery and corruption policy, which 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, there is evidence that a designated board committee \u2013 the Corporate Responsibility Committee \u2013 is ultimately responsible for oversight of the company's anti-bribery and corruption programme. There is evidence that this includes reviewing reports from management on the programme\u2019s performance, along with the results of audits, and it is clear that the committee has the authority to ensure that required changes are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that a designated senior executive has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. There is evidence that this person has a direct reporting line to the board committee that provides oversight of the anti-bribery and corruption programme. There is also evidence of reporting and feedback activities between this person and the board committee as part of the company\u2019s reporting structure.<\/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 is used to inform the design of the anti-corruption and bribery programme. The company indicates that the results of the assessments are reviewed at board level twice a year. There is evidence that the results of such reviews are used to develop tailored mitigation plans and to update specific parts of the company's anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
There is evidence that the company\u2019s entire anti-bribery and corruption programme is subject to a regular audit process to ensure the programme is consistent with best practice and the business risks facing the company. The company indicates that this includes provisions for continuous improvement, supplemented by internal and external audits; the last external audit was conducted by Deloitte in 2018. There is also evidence that high-level audit findings are presented to the board, with clear ownership assigned to units for planned updates and improvements to the anti-bribery and corruption programme.<\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
There is evidence that the company publicly commits to investigating incidents promptly, independently and objectively. There is evidence that the company takes steps to ensure the independence of its investigations. The company commits to putting in place remediation plans and reporting investigative findings to senior management and the board. For whistleblowing cases, there is evidence that the company has a procedure in place that stipulates documentation and actions to be taken at every step of the case, from receipt to final outcome, and it commits to ensure whistleblowers are informed of the outcome if they so wish. <\/p>\n
In addition, there is evidence that a senior central body receives and reviews summary information of all incidents and their status in the organisation and its subsidiaries. There is evidence that the data is reviewed on a quarterly basis. <\/p>\n"},{"question":61,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company takes steps to assure itself of the quality of its internal investigations, including those reported through whistleblowing channels. The company clearly indicates that staff tasked with conducting investigations are properly trained to perform the function. There is evidence that complaints about the handling of concerns or investigations can be made to the company\u2019s human resources department. In addition, there is evidence that the company reviews its investigations procedure at least every three years. <\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, the company has an escalation procedure to report material findings of bribery and corruption from investigations to the board. There is also a commitment to ensuring that the disclosure of criminal offences to relevant authorities is evaluated and acted upon if found necessary. Although the company does not explicitly reference a senior individual responsible for ensuring such disclosures, there is sufficient evidence in the company\u2019s publicly available information that this role would be filled by the Group General Counsel (who also has a direct reporting line to the CEO). <\/p>\n"},{"question":63,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publishes high-level data from ethical-related incidents and investigations involving company employees at all levels. This data includes the number of reports received, including the number received anonymously, and the number of disciplinary actions as a result of investigation findings. The data is published annually. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes information on the number of investigations launched as a result of the reports or enquiries received.<\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides training to its employees on the basic principles of its Code of Conduct, which includes scenario-based anti-bribery and corruption issues and covers the whistleblowing options available to employees. There is evidence that training is provided to all employees across all divisions and regions of operation, and in all appropriate languages. The company indicates that employees must refresh their training on the anti-bribery and corruption programme annually.<\/p>\n"},{"question":65,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides tailored training on its anti-bribery and corruption programme for employees in certain positions, with specific reference to all three categories of individuals referred to in the question. There is evidence that all employees, including those in high risk roles such as import and export, receive annual ethics training.<\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company reviews and measures the effectiveness of its anti-bribery and corruption communications and training programme. There is evidence that the company has a system for doing this through employee surveys, face-to-face interviews and by monitoring the number of compliance enquiries. The company commits to conducting and reviewing these measures on an ongoing basis. There is evidence that the results of such reviews are used to update specific parts of the company's anti-bribery and corruption communications and training programme. <\/p>\n"},{"question":67,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s incentive schemes incorporate ethical and anti-bribery and corruption principles. The company states that it incentivises employees based on \u2018how\u2019 they achieve these goals, which is assessed as part of performance reviews throughout the year. There is evidence that the company\u2019s incentive schemes are based on the achievement of 75% financial and 25% non-financial targets, with a focus on integrity. The company also indicates that employees in its defence businesses are excluded from any sales-based incentives. <\/p>\n"},{"question":68,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company commits to support and protect employees to act ethically and \u2018do the right thing\u2019 when conducting business. However, the company receives a score of \u20181\u2019 because there is no evidence that it assures itself of its employees\u2019 confidence in this statement through anonymised surveys or other clearly stated means.<\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company promotes a policy of non-retaliation against anyone who reports apparent misconduct, which includes whistleblowers and employees who report bribery and corruption incidents across the organisation. There is also evidence that this applies to those employed by the group as third parties, suppliers and joint venture partners. There is some evidence that the company assures itself of its employees\u2019 confidence in this commitment by monitoring usage data for its whistleblowing channels.<\/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 in the organisation and to seek advice on the company's anti-bribery and corruption programme. The company indicates that these channels can be confidential and anonymous, and are sufficiently varied to allow the employee to raise concerns across the management chain or to an external ethics hotline provider if necessary. There is evidence that the company\u2019s channels are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners, and in all relevant languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy defining conflicts of interest, including actual, potential and perceived conflicts. There is evidence that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities. The company\u2019s policy makes specific reference to conflicts arising from employee relationships, financial interests, other employment and government relationships.<\/p>\n"},{"question":72,"commitment_area":10,"score":"2","comments":"
There is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. There is evidence that the Business Chief Counsel is responsible for handling conflicts and that the company records conflicts in a dedicated register that is accessible to those responsible for oversight of the process. The company\u2019s Code of Conduct, which covers conflicts of interest, indicates that disciplinary action could apply if breached and provides examples of conflicts and recommended actions. <\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is some evidence that the company addresses the risks associated with the employment of public officials. The company indicates that responsibility for compliance in this area sits with the Human Resources Director for each business.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes details of other controls in place to mitigate these risks. For example, there is no evidence that the company requires senior compliance officer (or equivalent) approval for the initiation of any employment discussions with former or current public officials, a review of actual, potential or perceived conflict of interest and restrictions on their activities if such conflicts of interest are identified.<\/p>\n
In addition, although the company states that it follows government rules on appointments including cooling-off periods, there is no evidence that the company has a policy to implement a cooling-off period of at least 12 months before any public official is permitted to 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 which prohibits corporate political contributions, whether by the company itself or by any other entity or individual acting on its behalf. However, there is evidence that the company has a Political Action Committee (PAC) in the United States, so the company therefore receives a score of \u20180\u2019 as per the scoring criteria. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is evidence to indicate that the company did not make any political contributions in 2018. Since this evidence is included in the company\u2019s Annual Report, it is under that the data is updated on an annual basis. <\/p>\n
However, the company receives a score of \u20180\u2019 because it has a Political Action Committee (PAC) in the United States and there is no evidence that it publishes any information in relation to the PAC\u2019s disbursements on its website or that it provides a direct link to its official disclosures.<\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy covering both charitable donations and sponsorships to ensure that such donations are not used as vehicles for bribery and corruption. There is evidence that company\u2019s policies stipulate measures to ensure this, including sign-off procedures and a requirement to record the donation. <\/p>\n
However, although the company publishes the total amount of contributions to charities and not-for-profit organisations made by the company in 2018, it does not publish full details of all the charitable donations made, such as details of the recipients, amounts, country of recipients and which corporate entity made the payments. <\/p>\n"},{"question":78,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy that defines lobbying and that clearly outlines the values and behaviours that constitute \u2018responsible\u2019 lobbying. There is evidence that the company acknowledges the corruption risks associated with lobbying and it provides clear guidelines on the behaviours that are acceptable and unacceptable for individuals engaged in lobbying activities. The company\u2019s policy applies to all employees, board members and third parties engaged in lobbying on the company\u2019s behalf.<\/p>\n"},{"question":79,"commitment_area":11,"score":"2","comments":"
There is evidence that the company publishes a description of the topics on which it lobbies and the type of activities that it conducts to advance these aims. The company provides details of its core positions and their relevance to its business development plan, and there is evidence to indicate that these aims apply to the company\u2019s lobbying activities in multiple jurisdictions around the world. The extent of the evidence provided is deemed sufficient for a score of \u20182\u2019, though it is noted that the company appears to produce an annual report with further details on its lobbying activities which is not available in the public domain. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes details about its global lobbying expenditure on its website, either directly or via a link to official filing reports. <\/p>\n"},{"question":81,"commitment_area":11,"score":"2","comments":"
There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with clear procedures designed to ensure that such promotional expenses are not used as vehicles for bribery or corruption. There is evidence that the company\u2019s policy establishes financial limits, along with an approval procedure, for promotional expenses. The company\u2019s policy also explicitly addresses the risks associated with gifts and hospitality given to and received from domestic and foreign public officials, by indicating that specific rules and regulations may apply. The company's policy includes a statement that all gifts and hospitality above certain thresholds are recorded in a dedicated register.<\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is evidence that the company's procurement department is involved, in some capacity, in the establishment and oversight of supplier relationships. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear publicly available evidence to indicate that the procurement department is the main body responsible for oversight of the company\u2019s supplier 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":"2","comments":"
Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based due diligence when engaging and re-engaging with suppliers. The company indicates that it conducts this process annually or when there is a significant change in the business relationship, and states that the process includes establishing the beneficial ownership of the supplying company. There is some evidence indicating that the highest risk suppliers are subject to enhanced due diligence. There is evidence that the company might be willing to review and\/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.<\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company clearly states that all suppliers must have, at minimum, policies in place that prohibit foreign and domestic bribery, prohibit facilitation payments, as well as policies and procedures to address conflicts of interest, gifts and hospitality and whistleblowing. There is evidence that the company takes active steps to ensure this, for example by including checks on suppliers\u2019 policies as part of the due diligence and by conducting ongoing risk assessments. The company assures itself of this when onboarding new suppliers or when there is a significant change in the business relationship.<\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place and that the substance of its anti-bribery and corruption programme and standards are included in sub-contracts throughout the supply chain. This evidence is in the form of a set of supplier principles that sets the minimum standards of ethical behaviour expected throughout the supply chain. <\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
The company publishes some high-level information about its ethics enquiries and disciplinary actions involving employees and third parties, however it is not clear whether this includes suppliers. The company receives a score of \u20180\u2019 because the data published does not provide any information on ethics enquiries, investigations launched or disciplinary actions taken as they relate to suppliers, nor does it publish a statement that it has no supplier incidents or investigations to report. <\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has a policy to regulate the use of agents, or \u2018advisers\u2019, which addresses the corruption risks associated with their use and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an adviser is, in each case, necessary to perform a legitimate business function. There is evidence that this policy applies to all divisions within the organisation that might employ advisers, including subsidiaries. <\/p>\n"},{"question":89,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with third parties and agents. The company indicates that this due diligence is conducted before engaging agents and is repeated at least every two years or when there is a significant change in the business relationship. There is evidence that all agents are subject to enhanced due diligence. <\/p>\n"},{"question":90,"commitment_area":13,"score":"2","comments":"
There is evidence that the company aims to establish the beneficial ownership of third parties, including agents, at the outset of the business relationship and every two years. There is evidence that the company commits to independently verify the beneficial ownership information of agents, and the company indicates that it will not engage or terminate its engagement with agents if beneficial ownership cannot be established. <\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
There is evidence to indicate that the company\u2019s anti-bribery and corruption policy applies to agents acting for or on behalf of the company. The company indicates that all agents are subject to anti-bribery and corruption clauses in their contracts, which include audit and termination rights.<\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company highlights incentive structures for agents as a factor in bribery and corruption risk. The company indicates that there must be a compelling justification for the renumeration proposed and states payment terms are reviewed by its Business Development Adviser Compliance Panel.<\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further details on how incentive structures for agents are designed to minimise risks of anti-bribery and corruption. For example, there is no evidence that the company imposes a threshold on the payment of sales commissions to agents, nor that it commits to paying remuneration into local bank accounts or in stage payments based on clear milestones.<\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any details of the agents or \u2018advisers\u2019 currently contracted to act for or and on its behalf. <\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
The company publishes some high-level information about its ethics enquiries and disciplinary actions involving employees and third parties, however it is not clear whether this includes agents or \u2018advisers\u2019. The company receives a score of \u20180\u2019 because the data published does not provide any information on ethics enquiries, investigations launched or disciplinary actions taken as they relate to agents, nor does it publish a statement that it has no agent incidents or investigations to report. <\/p>\n"},{"question":100,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering a joint venture partnership, which includes checks on the beneficial ownership of the partner company. There is evidence that the company conducts enhanced due diligence where required, but it is not clear whether this would include joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises.<\/p>\n
The company receives a score of \u20181\u2019 because there is no clear evidence to indicate that it repeats due diligence on its joint ventures 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 establishes and implements anti-bribery and corruption policies in its controlled joint ventures, by ensuring that they follow its Operational Framework (OF) and anti-corruption programme. In addition, it takes active steps to encourage the joint ventures which are not fully controlled by BAE Systems to adopt substantially equivalent standards in relation to anti-bribery and corruption. The company indicates that its joint venture contracts include anti-corruption provisions and can include audit and termination rights.<\/p>\n"},{"question":102,"commitment_area":13,"score":"2","comments":"
There is evidence that the company commits to take an active role in preventing bribery and corruption its joint ventures. The company indicates that it may do this in practice by providing training to employees in controlled joint ventures and by appointing employees to board positions \u2013 or comparable bodies in non-controlled joint ventures \u2013 to encourage equivalent standards of governance. <\/p>\n"},{"question":103,"commitment_area":14,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has policies and procedures in place to address corruption risks associated with offset contracting. The company indicates that a dedicated team is responsible for the monitoring and oversight of the company\u2019s offset activities throughout the lifecycle of each project. There is evidence that all relevant employees receive tailored anti-bribery and corruption training based on the potential corruption risks associated with offsets. In addition, the company indicates that it ensures that its offset partners adhere to its anti-bribery and corruption standards through appropriate contractual clauses. <\/p>\n"},{"question":104,"commitment_area":14,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations with evidence that the company assures itself of the legitimacy of the investment. There is evidence that the company conducts checks on the beneficial ownership of offset brokers and indicates that it may conduct similar checks on the beneficiaries of offset projects, and there is evidence that it repeats due diligence on brokers every two years. <\/p>\n
Although the company does not specifically state that it conducts conflict of interest checks on its offset brokers, the company indicates that it seeks to identify any areas of concern or unethical behaviour through extensive due diligence, and this is deemed sufficient for a score of \u20182\u2019. <\/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":"2","comments":"
Based on publicly available information, there is evidence that the company acknowledges the corruption risks associated with operating in different markets. There is evidence that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. There is some indication that the results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a list of its fully consolidated subsidiaries and non-fully consolidated holdings, including any associates, joint ventures and other related entities. For each entity, the company discloses its percentage ownership and for most entities the company provides the country of incorporation by publishing its registered address. There is evidence that this list is current and updated on at least an annual basis.<\/p>\n
However, the company receives a score of \u20181\u2019 because it does not publish the country of operation for each entity. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed on the London Stock Exchange. Therefore, it is not required to disclose further information on its beneficial ownership structure and automatically receives a score of \u20182\u2019, as per the scoring criteria. <\/p>\n"},{"question":110,"commitment_area":15,"score":"2","comments":"
There is evidence that the company publishes information about its defence sales in the form of a percentage breakdown per customer. The company provides a percentage breakdown of its major customers that account for 80 percent of its sales in its Annual Report. Although the company does not explicitly state that these percentages account for defence sales, it is sufficiently clear from the accompanying information that the figures provided primarily represent sales in the defence sector.<\/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\/443","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=443"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=443"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}