There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which details the company\u2019s stance against any form of bribery or corruption and is endorsed by the President and Chief Operating Officer. Although the statement does not specifically mention bribery and corruption, its position appears as part of the Anti-Corruption Compliance Guidelines and so is sufficient to receive a score of \u20182\u2019.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company publishes an anti-bribery and corruption policy which makes specific reference to the prohibition of 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 Audit Committee \u2013 is ultimately responsible for oversight of the company's ethics and compliance programme, which is understood to incorporate anti-bribery and corruption. There is evidence that this includes reviewing reports from management on the programme\u2019s performance, along with the results of internal and external audits. <\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that a designated senior executive \u2013 the Chief Ethics and Compliance Officer \u2013 has ultimate responsibility for implementing and managing the company's ethics and compliance programme, which is understood to incorporate anti-bribery and corruption. It is clear that this person has a direct reporting line to the Audit Committee, which provides oversight of the ethics and compliance programme. There is evidence of reporting activities between this person and the Audit Committee.<\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a formal risk assessment procedure that informs the design of the ethics and compliance programme, which is understood to address anti-bribery and corruption. There is evidence that the results of risk assessments are reviewed by the board on at least an annual basis. 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 compliance programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
There is evidence that the company\u2019s ethics and compliance programme is subject to a regular audit process to ensure the entire programme is consistent with best practice and the business risks facing the company, including corruption risk specifically. There is evidence that this includes provisions for continuous improvement, supplemented by an internal audit at least every two years. There is also evidence that high-level audit findings are presented to the board, with clear ownership assigned to units and individuals for planned updates and improvements to the ethics and compliance programme.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company commits to investigating incidents and there is a specific procedure in place to deal with whistleblowing cases. There is evidence that the company takes steps to ensure the independence of its investigations and that the company commits to ensure whistleblowers are informed of the outcome, if they so wish.<\/p>\n
There is also evidence that the company\u2019s Chief Ethics and Compliance Investigator receives and reviews all investigation reports, and that the board-level Audit Committee receives periodic reports on violations of the company\u2019s Code of Conduct. However, it is not clear from the evidence how frequently these reviews take place. Furthermore, the information provided does not cover the whole investigation process from receipt to final outcome, including documentation and actions to be taken at every step. <\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
There is evidence that the company assures itself of the quality of its internal investigations, including those reported through whistleblowing channels. The evidence indicates that staff tasked with conducting investigations are properly qualified to perform the function. There is evidence that complaints about the handling of concerns and investigations are overseen by an appropriate senior management officer. <\/p>\n
However, there is no evidence that the company 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":"2","comments":"
There is evidence that the company commits to provide reports regarding significant violations of its Code of Conduct to the board-level Audit Committee, as well as statistics from its Ethics Helpline. The company also states that it may be required to report material findings to the relevant authorities, and although it is not explicitly stated, there is sufficient evidence to indicate that the Chief Ethics and Compliance Officer is responsible for ensuring this disclosure.<\/p>\n"},{"question":63,"commitment_area":8,"score":"2","comments":"
There is evidence that the company publishes high-level data from ethical-related incidents and investigations involving company employees. This includes the number of reports received in total, including from whistleblowing channels, as well as the number of investigations launched, and the number of disciplinary actions as a result of investigation findings. This data is published at least on an annual basis covering cases from the past 12 months.<\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides training on anti-bribery and corruption. There is evidence that the company provides this training to all employees across all divisions and countries of operation and in all appropriate languages. The company states that employees are required to undertake refresher courses every two years.<\/p>\n"},{"question":65,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that employees in certain positions receive different and tailored training on anti-bribery and corruption. The company makes specific reference to all three categories of employee referred to in the question \u2013 employees in high risk positions, middle management and board members \u2013 and indicates that training requirements are defined according to the level of risk of their specific job assignment. There is evidence that employees in high-risk positions receive tailored training on an annual basis. <\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
There is evidence that the company measures and reviews the effectiveness of its ethics and compliance communications and personnel training programme. There is evidence that the company has a system to do this, for example through staff surveys. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not from the evidence that the company specifically measures the effectiveness of its anti-bribery and corruption training, or whether the results are used to update specific parts of the company's anti-bribery and corruption communications and training programme. There is also no clear evidence that the company conducts a full review of its anti-bribery and corruption communications and training programme at least every three years.<\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company incorporates integrity and accountability as measures in its annual employee performance reviews. The company indicates that such reviews are based on its \u2018Vision, Values and Covenants\u2019, which makes specific reference to ethics and integrity, and are designed to promote ethical behaviour while discouraging corrupt practices. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further information on how such assessments impact on the company\u2019s bonus or reward schemes. There is also no clear evidence to indicate that, where financial rewards are part of incentive schemes, there are procedures in place to ensure that they are proportionate to the base salary in the case of high risk employees. <\/p>\n"},{"question":68,"commitment_area":9,"score":"2","comments":"
There is publicly available evidence that the company commits to support and protect any employee who refuses to act unethically, in keeping with the company\u2019s anti-corruption commitments, even where such actions result in a loss of business or another disadvantage to the company. There is evidence that the company assures itself of its employees' confidence in this commitment through anonymised surveys.<\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is evidence that this policy applies to all employees across the organisation, including those engaged by the group as third parties and suppliers. The company commits to assure itself of its employees\u2019 confidence in this commitment through surveys and other measures. <\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
There is evidence that the company has multiple channels for employees to report instances of suspected corrupt activity and seek advice on the company's ethics and compliance programme. There is evidence that these channels are sufficiently varied to allow employees to raise concerns across the management chain, as well as through an external service provider. There is evidence that these channels allow for confidential and anonymous reporting and that they 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 clear policy and procedure that defines conflicts of interest, including actual, potential and perceived conflicts. There is evidence that the policy explicitly covers employee relationships, government relationships, financial interests and other employment. The company states that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities.<\/p>\n"},{"question":72,"commitment_area":10,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has clear procedures to identify, declare and manage conflicts of interest, actual, potential and perceived. This includes a statement that all employee and board member declarations of actual and potential conflicts of interest are recorded in a dedicated register that is accessible to those responsible for oversight of the process. <\/p>\n
There is evidence that potential and actual conflict of interest declarations are reviewed and overseen by Ethics and Compliance Officers, and\/or the Chief Ethics and Compliance Officer, who has ultimate accountability for implementation of the policy and handling of individual cases. The description of this procedure also includes examples of criteria for recusals and a description of the potential punitive measures for breaches of the policy.<\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy which includes controls to assess and regulate employment and offers of employment or consultancy engagement to current and recently departed public officials. There is evidence that the policy requires senior compliance officer approval for the initiation of any employment discussions with former or current public officials, a review of conflict of interests, and restrictions on their activities if such conflicts of interest are identified. <\/p>\n
However, there is no evidence that the company has a policy to implement a cooling-off period of at least 12 months before such public officials are 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":"2","comments":"
The company publishes a clear statement that it does not contract serving politicians, so therefore receives a score of \u20182\u2019. <\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
There is evidence that the company has a policy on political contributions, which states that such donations are generally prohibited but permissible in certain circumstances with appropriate authorisation and sign-off. There is also evidence that the company is associated with a Political Action Committee (PAC) in the United States. <\/p>\n"},{"question":76,"commitment_area":11,"score":"2","comments":"
There is evidence that the company publishes details of its political contributions in the United States by including direct links on its website to official reporting documents and to the Open Secrets website. There is evidence that this data is updated and published on at least an annual basis. These details include the recipient and amount, and whether the contribution was made by an individual or a Political Action Committee (PAC).<\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a clear policy covering both charitable donations and sponsorships, whether made directly or through corporate foundations, to ensure that such donations are not used as vehicles for bribery and corruption. There is evidence that this policy include measures to ensure this, such as specifying criteria for donations, procedures for senior sign-off, and due diligence on recipients.<\/p>\n
However, while the company publishes some details of the company\u2019s charitable activities, there is insufficient evidence that it publishes details of all donations as described in score \u20182\u2019. There is also no evidence that the company updates this information on at least an annual basis. <\/p>\n
It is noted that the company has an internal policy \u2013 Bechtel Policy 404, Corporate Contributions and Memberships \u2013 but it does not appear to be publicly accessible. <\/p>\n"},{"question":78,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy on lobbying. There is evidence that the policy applies company-wide to all employees, board members and third parties engaged in lobbying activities on the company\u2019s behalf. There is evidence of specific controls and oversight mechanisms that apply to all types of lobbyists, which are ensured through clear terms in all contractual agreements. The company provides guidelines on the types of behaviours that are acceptable by requiring that lobbyists abide by its Code of Conduct, Vision, Values and Covenants document, as well as all appropriate regulations. <\/p>\n"},{"question":79,"commitment_area":11,"score":"1","comments":"
The company publishes some information on its lobbying topics and activities in the United States by providing a direct link to its quarterly federal lobbying reports on its website. These disclosures provide high-level information on the topics on which the comany conducts lobbying activities. <\/p>\n
However, the company receives a score of \u20191\u2019 because it does not provide details about its broader public policy aims or positions. The company also does not publish any information about its lobbying activities outside of the United States.<\/p>\n"},{"question":80,"commitment_area":11,"score":"1","comments":"
There is evidence that the company publishes some details of its lobbying expenditure, by providing direct links on its website to details of all of its lobbying expenditure, up to the most recently reported financial year. This expenditure data is broken down by corporate entity, geography, and internal, external and association lobbying. <\/p>\n
However, the company receives a score of \u20181\u2019 because the data provided only accounts for company\u2019s lobbying activities in the United States and therefore it is not clear that this covers all of the company\u2019s lobbying activities in all applicable jurisdictions.<\/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 and corruption. There is evidence that the policy specifies financial and proportional limits for different types of promotional expenses and addresses the risks associated with gifts and hospitality given to public officials. There is 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 evidence that the company's procurement department is involved in the establishment and management of supplier relationships, and there is some evidence that this department is responsible for oversight of the company\u2019s supplier base. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is 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":"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 any suppliers. The company indicates that this due diligence process includes establishing the beneficial ownership of the supplying company and there is evidence that high risk suppliers are stated to be subject to enhanced due diligence. <\/p>\n
There is evidence that this process is conducted at least every two years or when any red flags arise over the course of the supplier relationship. The evidence indicates that the company will not enter into a relationship with a supplier if red flags highlighted in the due diligence cannot be mitigated.<\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
There is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies in place. The company states that it expects its suppliers to follow its Code of Conduct and Anti-Corruption Guidelines, which prohibit bribery and facilitation payments and address conflicts of interest, gifts and hospitality and whistleblowing. There is evidence which indicates that the company assures itself of this when onboarding new suppliers.<\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
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-corruption and bribery programme is required of sub-contractors throughout the supply chain. This evidence appears in the form of a clear statement and 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":"1","comments":"
There is evidence that the company publishes high-level data from ethical incidents and investigations, and that this includes reports from and about suppliers and contractors. The data includes the number of allegations made and the number of disciplinary actions as a result of investigation findings. This data is published at regular intervals, on at least an annual basis covering cases in the past 12 months. <\/p>\n
However, the company receives a score of \u20181\u2019 because the data is not disaggregated to show supplier data as separate from other types of individuals, such as company employees.<\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has a clear policy to control the use of agents which addresses the corruption risks associated with the use of agents 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 agent is, in each case, necessary to perform a legitimate business function. There is evidence that this policy applies company-wide to all divisions within the organisation which might employ agents, including any subsidiaries and joint ventures. <\/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 and re-engaging any agents and intermediaries, at least every two years. The company states that agents and highest risk intermediaries are subject to enhanced due diligence. The evidence suggests that the company will not engage or terminate its engagement with agents where the risks identified in the due diligence cannot be mitigated. <\/p>\n"},{"question":90,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has formal procedures to establish the beneficial ownership of agents, as part of its due diligence process, prior to engaging them, and at least every two years. There is evidence that the company operates, as a minimum, a risk based beneficial ownership verification policy, whereby all agent provided information is verified and high risk agent\u2019s information is independently verified. In addition, the company indicates that it conducts media searches and may use a third party research company if this information is not readily available.<\/p>\n
There is also evidence company will not engage or terminate its engagement with agents where red flags identified in the due diligence cannot be mitigated. Although the company does not explicitly state that this includes rd flags on beneficial ownership, there is sufficient evidence that beneficial ownership checks are embedded throughout the process to satisfy this part of the scoring criteria for \u20182\u2019.<\/p>\n"},{"question":91,"commitment_area":13,"score":"1","comments":"
There is evidence that the company\u2019s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. There is clear evidence that agents must confirm their commitment to the Code of Conduct prior to undertaking work for the company, and that all agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts. <\/p>\n
However, the company receives a score of \u20181\u2019 because the company does not specifically clarify that these anti-corruption clauses include audit and termination rights. <\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company indicates that it places a reasonable threshold on sales-based commissions and there is evidence that the company is alert to requests for unusually large payments or to pay individuals into non-local bank accounts. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company requires that remuneration is paid in stage payments over the course of their contract. <\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company publishes any details of the agents currently contracted to act for or on its behalf. <\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
There is some publicly available evidence that the company publishes high-level data from ethical incidents and investigations, which includes reports from and about suppliers and contractors. However, it is not sufficiently clear that this evidence includes data about incidents and investigations involving agents or intermediaries, and therefore the company receives a score of \u20180\u2019. <\/p>\n"},{"question":100,"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 on all of its joint venture partnerships. This includes establishing the ultimate beneficial ownership of the partner company, with enhanced due diligence for joint ventures operating in high risk countries. There is evidence that the company conducts anti-bribery and corruption due diligence prior to entering into a joint venture and once activities have been established, at least every two years.<\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies in all of its joint ventures, by requiring adherence to its Code of Conduct. There is evidence that the company states that it includes anti-bribery and corruption clauses in its joint venture contracts. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not specify that it takes steps to detect, control and prevent breaches of this policy through mechanisms such as audit and termination rights. <\/p>\n"},{"question":102,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. There is clear evidence to support the company's commitment, such as a requirement that the company has oversight of the joint venture\u2019s financial activities, including access to books and records.<\/p>\n"},{"question":103,"commitment_area":14,"score":"2","comments":"
The company publishes a clear statement to indicate that it does not enter into contracts that require an offset obligation, as a matter of policy. <\/p>\n"},{"question":104,"commitment_area":14,"score":"N\/A","comments":"
The company publishes a clear statement that it does not enter into offset contracts, and is therefore exempt from scoring on this question.<\/p>\n"},{"question":105,"commitment_area":14,"score":"N\/A","comments":"
The company publishes a clear statement that it does not enter into offset contracts, and is therefore exempt from scoring on this question.<\/p>\n"},{"question":106,"commitment_area":14,"score":"N\/A","comments":"
The company publishes a clear statement that it does not enter into offset contracts, and is therefore exempt from scoring on this question.<\/p>\n"},{"question":107,"commitment_area":15,"score":"2","comments":"
There is evidence that the company acknowledges the corruption risks associated with operating in different markets, and 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. 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":"0","comments":"
There is no evidence that the company discloses details of its fully consolidated subsidiaries or non-fully consolidated holdings. <\/p>\n
Based on publicly available information, there is some evidence to suggest that the company may have subsidiaries or joint venture partners; however the company does not provide a list with percentages owned or further details necessary to satisfy the requirements of score \u20181\u2019.<\/p>\n"},{"question":109,"commitment_area":15,"score":"0","comments":"
There is evidence that the company is privately owned; however, there is no publicly available evidence that the company discloses any information about its beneficial ownership or control structure. As such, it is not clear whether any individual owns 25% or more of its shares or voting rights. There is also no evidence that information about its shareholders is accessible in a publicly available and freely accessible companies register or in a global beneficial ownership register such as Open Ownership.<\/p>\n"},{"question":110,"commitment_area":15,"score":"2","comments":"
The company publishes information about its defence sales by customer, to indicate that over 90% of its defence contracts for the previous year were with the United States. There is evidence that this data is correct up to the most recently reported financial year. The company includes some additional information about its major projects in its Annual Report, however there is evidence to indicate that this includes all contracts and not just defence sales. <\/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\/447","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=447"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=447"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}