The company\u2019s leadership endorses its Business Ethics Code of Conduct, which outlines its anti-bribery and corruption commitment. <\/p>\n
However, the company receives a \u20181\u2019 because its leadership does not explicitly mention bribery and corruption in their statement. <\/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, payments to public officials and commercial bribery. This policy applies to all employees and board members, including those of subsidiaries and controlled entities.<\/p>\n
However, the company receives a score of \u20181\u2019 because its policy makes no specific reference to facilitation payments. It is also unclear whether the company\u2019s policies apply to non-executive and independent directors. <\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is evidence that the company\u2019s Nominating\/Corporate Governance Committee oversees the company's anti-bribery and corruption programme, contained within the company\u2019s ethics and compliance programme. The company states that the committee provides oversight of the programme.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the committee reviews reports from management or the results of internal and external audits relating to the company\u2019s anti-bribery and corruption policies and procedures. There is also no clear evidence that the committee has the authority to require that changes are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
There is no evidence that the company has a specific managerial-level employee who holds ultimate responsibility for implementing and managing the company\u2019s anti-bribery and corruption programme.<\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company has a formal risk assessment procedure which is used to inform its anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
Although there is some evidence that the company reviews its anti-bribery and corruption programme, it does not provide sufficient detail to receive a score of \u20181\u2019, and the company does not specify how frequently it conducts these reviews. It is also unclear if the review findings are presented to the board or used to update the programme. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly commits to investigating incidents, and that it has specific procedures in place to deal with whistleblowing cases, which stipulates documentation and actions to be taken at each step. <\/p>\n
However, the company does not cover the whole investigation process from receipt to final outcome, there is no evidence that investigations are handled by an independent team and\/or report to an independent board member, and there is no evidence that the company commits to providing whistleblowers with updates on the outcome of investigations. Finally, there is no evidence that summary information is reviewed by a central body on an annual basis.<\/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":"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 the 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":"
The company states that all employees are required to undertake a compliance verification process, which includes an understanding of the company\u2019s anti-corruption and anti-bribery policies. However, it is not clearly stated that employees are required to undertake training on the company\u2019s anti-corruption programme. <\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk. Although the company states that managers and select employees are required to verify understanding of all of the company\u2019s business conduct, it is not explicitly clear that this constitutes training. <\/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 commits to support or protect employees who refuse to act unethically, even when it might result in a loss of business.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
The company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, which applies to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners. <\/p>\n
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 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 whistleblowing and advice channels, some of which allow for anonymous and confidential reporting. The company also provides channels and resources for employees to receive advice related to anti-corruption and ethics and there is evidence that the company\u2019s channels are available to all employees in all countries of operation, in all relevant languages. There is also evidence that the company maintains a reporting and advice channel for use by third parties. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is unclear whether the company has an externally operated whistleblowing or advice channel. <\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence that the company has policies covering actual and perceived conflicts of interest, which apply to all employees and directors, including those employed by subsidiaries and the company\u2019s other holdings. The policies cover conflicts of interest concerning the employment of current and former government officials, secondary employment, employee relationships and financial interests. There is also evidence that the company has an internal policy covering conflicts of interest, but this is not publicly accessible. <\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is evidence that the company\u2019s Nominating\/Corporate Governance Committee is responsible for oversight of conflicts of interest within the organisation. However, the company provides insufficient information regarding its procedures for managing conflicts of interest to receive a score of \u20181\u2019.<\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy that addresses the risks associated with the employment of public officials. <\/p>\n
However, the policy does not include any specific controls to assess and regulate the employment of current or former public officials, such as requiring senior approval for the initiation of employment discussions, undertaking a conflict of interest review and imposing restrictions on activities if risks are identified, or stipulating a cooling-off period of 12 months. <\/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":"
The company operates a political action committee and therefore receives a score of \u20180\u2019. <\/p>\n"},{"question":76,"commitment_area":11,"score":"2","comments":"
The company discloses the political candidates that it supports. There is evidence that this information is updated annually. <\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is no clear evidence that the company has a policy and\/or procedure covering both charitable donations and sponsorships. The company also does not publish detailed data on its charitable contributions. <\/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 provides details about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy and\/or procedure on the giving and receipt of gifts and hospitality. The policy covers gifts and hospitality given to and received from government officials. <\/p>\n
However, the company receives a score of \u20181\u2019 because the policy does not specify financial or proportional limits or different approval procedures for different types of promotional expenses. There is also 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":"0","comments":"
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 bribery and corruption-based due diligence on its suppliers. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place, which cover conflicts of interest and gifts and hospitality. The company also states that suppliers must attempt to adhere to the principles outlined in its Business Ethics Code of Conduct.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is unclear whether all suppliers are required to adhere to the company\u2019s anti-bribery and corruption terms and conditions. Moreover, these conditions do not explicitly prohibit facilitation payments, or cover whistleblowing. There is also no evidence to suggest that the company takes steps to ensure that its suppliers have adequate anti-bribery and corruption policies and procedures in place, or whether it does so when there is a significant change in the business relationship.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is some evidence that the company requires its suppliers\u2019 subcontractors to observe anti-bribery and corruption legislation, but there is no evidence that it requires its suppliers to flow down the broader principles of its anti-corruption programme throughout its 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 some evidence that the company undertakes due diligence on its third parties. However, the information provided is insufficiently detailed to receive a score of \u20181\u2019. <\/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 some evidence that the company\u2019s anti-bribery and corruption policy applies to agents and intermediaries acting on the company\u2019s behalf. However, the company does not include clear audit and termination rights in its contracts with these entities. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company acknowledges 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 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 evidence that the company\u2019s anti-bribery and corruption policies or procedures apply to its joint venture partners. However, there is no evidence that it 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, 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 such a procedure.<\/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 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, 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 full list of its fully consolidated subsidiaries and non-fully consolidated holdings, including associates, joint ventures and other related entities. For each entity, the company discloses its percentage ownership, and the country of incorporation. There is evidence that this list is current and updated on at least an annual basis. The list is accompanied by a statement that it is complete at the time of publication to the best of the company\u2019s knowledge.<\/p>\n
However, the company receives a score of \u20181\u2019 because it does not list countries of operation for each subsidiary.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company\u2019s parent is publicly listed on the New York Stock Exchange and it therefore automatically receives a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
The company does not publish the customers of its defence sales. <\/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\/444","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=444"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=444"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}