The institute has a publicly stated commitment to 'integrity' and 'high ethical standards' but does not explicitly mention anti-bribery and corruption. There is no direct evidence that this statement is authorised and supported by the institute\u2019s leadership. <\/p>\n"},{"question":55,"commitment_area":7,"score":"0","comments":"
There is no publicly available evidence that the institute has an anti-bribery and corruption policy. The institute appears to have a Code of Business Conduct and Ethics, however this document is not publicly accessible so it is not possible to determine whether this covers anti-bribery and corruption.<\/p>\n"},{"question":56,"commitment_area":7,"score":"0","comments":"
There is no evidence that the institute has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.<\/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 institute\u2019s anti-bribery and corruption programme.<\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
There is no evidence that the institute 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":"
There is no evidence that the institute\u2019s anti-bribery and corruption programme is subject to audit or review.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is some evidence that the institute commits to investigate ethical allegations and incidents and that a specific procedure is in place to deal with those reported through its whistleblowing channel. There is evidence that the institute takes steps to ensure the independence of investigations through the use of an external reporting channel and the establishment of a regular investigative committee formed of multiple individuals. <\/p>\n
However, the institute receives a score of \u20181\u2019 because it does not provide further details of its investigative procedure, from receipt to final outcome, and does not specifically mention allegations or incidents relating to bribery or corruption. There is also no evidence that information on each investigation is documented at each stage.<\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
There is some evidence that the institute takes steps to ensure the quality of its investigations. It states that all staff tasked with conducting investigations are properly trained to perform the function and indicates that the Investigation Oversight Committee is composed of appropriate senior individuals. <\/p>\n
However, the institute receives a score of \u20181\u2019 because there is no evidence of a procedure to handle complaints about the investigation process, nor is there evidence that the institute reviews its investigations procedure at least every three years or in response to any changes in the regulatory environment.<\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
There is no evidence that the institute\u2019s investigative procedure includes a commitment to report material findings to the board and, if necessary, to the relevant authorities.<\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
There is no evidence that the institute 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 institute 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 institute 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 institute measures or reviews the effectiveness of its anti-bribery and corruption communications and training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no evidence that the institute\u2019s incentive schemes incorporate ethical or anti-bribery and corruption principles.<\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is some evidence that the institute aims to promote an ethical culture in the workplace, however it does provide sufficiently clear evidence that it will support and protect employees who refuse to act unethically, even where it might result in a disadvantage or loss of business. There is also no evidence that the company takes steps to assure itself of employees\u2019 belief in this commitment through surveys or other means. <\/p>\n"},{"question":69,"commitment_area":9,"score":"0","comments":"
There is evidence that the institute promotes a policy of non-retaliation against whistleblowers and employees who report compliance incidents. However, the institute receives a score of \u20180\u2019 because it is not clear whether this policy applies to all employees across the organisation, including those employed by the group as third parties, suppliers and\/or joint venture partners. <\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
There is evidence that the institute provides several channels through which to report instances of suspected corrupt activity and seek advice on its Code of Business Conduct and Ethics. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an independent third party, through the provision of an externally-operated hotline. These channels allow for confidential and, wherever possible, anonymous reporting. This platform is available and accessible to employees in any jurisdiction through the online reporting system or international telephone service, and there is evidence that reports can be made in all relevant languages. <\/p>\n"},{"question":71,"commitment_area":10,"score":"0","comments":"
There is evidence that the institute recognises the potential risks posed by conflicts of interest by listing it as a reporting category on the EthicsPoint portal and providing a broad definition. However, the institute receives a score of \u20180\u2019 because there is no evidence that the company has a formal policy on conflicts of interest that covers those actual, potential and perceived, as well as those stemming from certain relationships (e.g. government, financial, etc.). <\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is no evidence that the institute 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 institute 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 institute reports details of the contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"N\/A","comments":"
There is no readily available evidence that the institute is able to make political contributions due to its nature as a non-profit, tax-exempt organisation in the United States of America. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
There is no readily available evidence that the institute is able to make political contributions due to its nature as a non-profit, tax-exempt organisation in the United States of America. <\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is no evidence that the institute has a policy or procedure to address the potential bribery and corruption risks arising from charitable donations and sponsorships. The institute publishes some information about type of organisations that it sponsors and provides an estimate figure of the amount it donates annually, but this information is insufficiently detailed to receive a score of \u20181\u2019. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no evidence that the institute has a policy or procedure on lobbying.<\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the institute 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 institute provides any details about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"0","comments":"
There is some evidence that the institute recognises the potential risks posed by gifts and hospitality by listing it as a reporting category on the EthicsPoint portal and providing a broad definition. However, the institute receives a score of \u20180\u2019 because there is no evidence that the company has a formal policy on the giving and receiving of gifts and hospitality to ensure that such promotional expenses are not used as vehicles for bribery and corruption. <\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no evidence that the institute requires the involvement of its procurement department in the establishment and oversight of its supplier base.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is no evidence that the institute conducts anti-bribery and corruption due diligence on its supply chain.<\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
There is evidence that the institute requires that its suppliers meet a certain standard of ethical business conduct, but the institute does not specifically refer to any of the anti-bribery and corruption measures necessary to score \u20181\u2019.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no evidence that the institute 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 institute 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":"N\/A","comments":"
There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.<\/p>\n"},{"question":89,"commitment_area":13,"score":"N\/A","comments":"
There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.<\/p>\n"},{"question":90,"commitment_area":13,"score":"N\/A","comments":"
There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.<\/p>\n"},{"question":91,"commitment_area":13,"score":"N\/A","comments":"
There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.<\/p>\n"},{"question":92,"commitment_area":13,"score":"N\/A","comments":"
There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.<\/p>\n"},{"question":98,"commitment_area":13,"score":"N\/A","comments":"
There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.<\/p>\n"},{"question":99,"commitment_area":13,"score":"N\/A","comments":"
There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.<\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
There is no evidence that the institute 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 that the institute commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures; it does not require 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 institute commits to take an active role in preventing bribery and corruption in its joint ventures.<\/p>\n"},{"question":103,"commitment_area":14,"score":"N\/A","comments":"
There is no readily available evidence that the institute engages in offset contracting.<\/p>\n"},{"question":104,"commitment_area":14,"score":"N\/A","comments":"
There is no readily available evidence that the institute engages in offset contracting.<\/p>\n"},{"question":105,"commitment_area":14,"score":"N\/A","comments":"
There is no readily available evidence that the institute engages in offset contracting.<\/p>\n"},{"question":106,"commitment_area":14,"score":"N\/A","comments":"
There is no readily available evidence that the institute engages in offset contracting.<\/p>\n"},{"question":107,"commitment_area":15,"score":"N\/A","comments":"
There is no readily available evidence that the institute is engaged in supplying goods or services, nor that it operates in markets or jurisdictions outside of the United States of America.<\/p>\n"},{"question":108,"commitment_area":15,"score":"0","comments":"
There is no evidence that the institute publishes a list of its subsidiaries or affiliated entities. <\/p>\n"},{"question":109,"commitment_area":15,"score":"N\/A","comments":"
The institute is a non-profit organisation and therefore does not have shareholders. <\/p>\n"},{"question":110,"commitment_area":15,"score":"N\/A","comments":"
There is no readily available evidence that the company engages in commercial or industry 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\/446","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=446"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=446"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}