There is evidence that the company makes a public commitment to ethical business conduct, and there is evidence that this commitment is supported by the Chairman and Managing Director. However, the company receives a score of \u20181\u2019 because this commitment does not explicitly detail the company\u2019s stance against anti-bribery and corruption.<\/p>\n"},{"question":55,"commitment_area":7,"score":"0","comments":"
There is no evidence that the company publishes an anti-bribery and corruption policy. The company\u2019s website describes high-level procedures to ensure integrity and reduce the opportunities for corruption, however there is no evidence that the company publishes a clear anti-corruption policy for all employees that defines and prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. <\/p>\n"},{"question":56,"commitment_area":7,"score":"0","comments":"
There is no evidence that the company has a dedicated board committee or department responsible for oversight of the company\u2019s anti-bribery and corruption programme. The company indicates that it has a Chief Vigilance Officer responsible for ensuring compliance across the organisation, but there is no evidence that this individual is part of a wider risk or ethics committee which can review and implement changes to the company\u2019s programme. <\/p>\n
The company also states that its activities are monitored by the Central Vigilance Commission, a department within the Indian government responsible for ensuring compliance in businesses. <\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
Based on publicly available information, there is evidence that a managerial-level individual \u2013 the Chief Vigilance Officer \u2013 has been assigned ultimate responsibility for managing the company\u2019s anti-corruption activities. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear whether this person is a senior executive and there is no evidence that this person has a direct reporting line to the board.<\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company has a formal risk assessment procedure which is used to inform the company\u2019s anti-corruption programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company\u2019s anti-bribery and corruption programme is subject to audit or review. The company states that its activities are monitored by several external bodies associated with the government, including the Statutory Auditors, the Controller and Auditor General of India and the Central Vigilance Commission; however, it does not provide further details on the frequency of such reviews or whether this includes anti-corruption activities specifically.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company commits to investigating incidents and that it has a specific procedure in place to deal with whistleblowing cases, which stipulates actions to be taken at each step. The company provides publicly available information on this procedure to cover the whole investigation process from receipt to final outcome. There is evidence that investigations are handled by an independent team. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that the company commits to providing whistleblowers with updates on the outcome of investigations or that information on each investigation is documented. There is also no indication that an Audit Committee receives and reviews the status of investigations on at least an annual basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no clear evidence that the company assures itself of the quality of its internal investigations. The company states that its Audit Committee reviews the functioning of the whistleblower mechanism; however there is no evidence that staff tasked with conducting investigations are properly trained to perform the function or that the company has a procedure in place to handle complaints about the process.<\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
There is evidence that the company\u2019s Audit Committee is responsible for reporting any material findings of unethical activity to the Management of the Company, which is understood to be equivalent to board level. However, there is no evidence to indicate that the committee commits to report such findings to the relevant authorities, nor is it clear that a specific senior individual is responsible for ensuring this information is disclosed, if necessary.<\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption investigations or disciplinary actions involving its employees.<\/p>\n"},{"question":64,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is evidence that the company\u2019s Human Resources and Vigilance departments organise training programmes. However, the company receives a score of \u20180\u2019 because there is no clear evidence that this training covers anti-bribery and corruption, nor that it applies to all employees across the organisation.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company provides tailored anti-bribery and corruption training to its employees based on an assessment of their role and exposure to corruption risk.<\/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":"
Based on publicly available information, there is no evidence that the company\u2019s incentive schemes incorporate ethical or anti-bribery and corruption principles. The company provides some information on it annual incentive schemes and remuneration policy for employees and directors, however the information published indicates that such incentives are based on financial and performance-based targets, with no evidence of ethical targets. <\/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. <\/p>\n"},{"question":69,"commitment_area":9,"score":"0","comments":"
There is evidence that the company has a policy of non-retaliation against any permanent employees who report bribery and corruption incidents. However, the company receives a score of \u20180\u2019 because there is no evidence that the policy applies to all employees across the organisation, including those employed by the group as third parties, and suppliers.<\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides a whistleblowing channel for its employees to report allegations or incidents of bribery and corruption, and there is evidence that reports can be confidential. The company states that employees may raise concerns through the channel in multiple relevant languages. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it offers an external channels operated by an independent third party. There is also no evidence that the company\u2019s reporting channels can also be used to seek advice or ask questions about the its anti-bribery and corruption programme, nor is there evidence that its system allows for anonymous reporting. Furthermore, there is no evidence to suggest that the company\u2019s whistleblowing channel is available to employees of third parties or suppliers. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has formal policies to address conflicts of interest, which apply to all employees and board members. The company\u2019s policy covers actual and perceived conflicts of interest and specifically addresses potential conflicts arising from employee relationships, financial interests and other employment. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that its conflict of interest policy addresses potential risks associated with government relationships. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual and perceived conflicts. The company states that disciplinary measures will apply if the policy is breached.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that all employee and board member declarations are held in a dedicated central register that is accessible to those responsible for oversight of the process. In addition, there is no clear evidence that there is a specific body or individual with oversight and accountability for handling all cases. There is also no evidence that the policy includes examples of criteria for recusals. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
Based on publicly available information, there is some evidence that the company has a policy regarding the employment of current public officials. However, the company receives a score of \u20180\u2019 because there is no evidence that this policy addresses conflicts of interest or that it includes specific controls to assess and regulate the employment of such individuals. There is also no evidence that this applies to former or recently departed public officials.<\/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 no evidence that the company has a policy to prohibit or regulate corporate political contributions. The company\u2019s publicly available information indicates that political contributions may be permitted in certain unspecified circumstances, and notes that such donations are not considered a CSR activity.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any details of its political contributions.<\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has policies and procedures covering both charitable donations and sponsorships. This policy specifies criteria for the types of causes that may receive donations and there is evidence that the company has procedures in place to monitor projects. The company also publishes full details of all charitable donations made, including details of the recipient, amount and location. The data is included in the company\u2019s Annual Report, and is therefore updated and released on an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the company addresses and has specific measures in place to ensure that donations are not used as vehicles for bribery and corruption. <\/p>\n"},{"question":78,"commitment_area":11,"score":"=-D287","comments":"
Based on publicly available information, there is no evidence that the company has a policy on responsible lobbying. The company states in its annual report that any businesses involved in influencing public policy must behave responsibly, however the company does not provide further details on the specific controls or oversight mechanisms in place to ensure this. <\/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 any details about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is some evidence that the company addresses gifts and hospitality. The company\u2019s policy indicates that board members and senior individuals must not solicit gifts or hospitality in order to influence business. <\/p>\n
However, the company receives a score of \u20180\u2019 because there is no evidence that the company\u2019s policy addresses the potential bribery and corruption risks associated with gifts and hospitality. There is also no evidence that the company\u2019s policy includes specific controls or measures to mitigate these risks. <\/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 or oversight of its supplier base.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct due diligence on its suppliers, which includes checks on beneficial ownership. There is evidence that the company may blacklist suppliers. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the company will not engage or potentially terminate its engagement where red flags highlighted in the due diligence process cannot be mitigated. There is also no evidence to suggest that high-risk suppliers are subject to enhanced due diligence, and the frequency of due diligence checks is unclear. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is evidence that the company ensures that its suppliers have adequate anti-corruption policies and procedures in place, by including specific terms in its contracts. The company indicates that this assurance is conducted when onboarding new suppliers, and there is evidence that the company takes steps to assure itself of this on an ongoing basis through external independent monitors. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that all suppliers must have, at least, policies that prohibit facilitation payments or policies that cover conflicts of interest, gifts and hospitality or whistleblowing. <\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
There is evidence that the company takes steps to ensure that the substance of its anti-corruption standards is required of sub-contractors throughout the supply chain. However, the company receives a score of \u20181\u2019 because this is in the form of a simple statement and it is not clear how the company ensures this in practice, for example through contractual terms or provision of additional guidelines.<\/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 or the associated disciplinary actions relating to its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company has a policy covering the use of agents.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries. <\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to establish the beneficial ownership of its agents.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company addresses 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 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 associated disciplinary actions involving its agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no indication that the company conducts anti-bribery and corruption due diligence on its joint venture partnerships. <\/p>\n
The company states that it does not currently have any joint ventures or associate companies; however there is no evidence that it may not enter into joint ventures in the future since the company does not state this as a matter of policy. The company therefore receives a score of \u20180\u2019. <\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, nor there is 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 publicly available evidence to indicate that the company engages in offset projects; however, there is no evidence that it addresses the corruption risks associated with offset contracting. There is no evidence that a dedicated body, department or team is responsible for monitoring the company\u2019s offset activities. <\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company has a formal procedure in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations. <\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of 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 or contracts. <\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no publicly available evidence that the company acknowledges the corruption risks of operating in different markets. <\/p>\n"},{"question":108,"commitment_area":15,"score":"2","comments":"
The company publishes a clear statement that it does not have any subsidiaries, joint ventures or associate companies. There is evidence that this statement is complete at the time of publication as it appears in the company\u2019s Annual Report, and therefore it is understood that the statement is updated on an annual basis. <\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
The company publishes details of its beneficial ownership structure, to indicate that it is partially state-owned with the President of India holding 87.75% of shares. The company also discloses the types of entities that hold the remaining shares. <\/p>\n
The company receives a score of \u20191\u2019 because there is no evidence that the company discloses its beneficial ownership information in a freely-accessible central public register. There is evidence that the company has some shares listed on the National Stock Exchange of India, however this is not specified in the list of regulated markets outlined in the scoring criteria. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes any information about its defence sales in the form of a percentage breakdown by customer. The company publishes high level figures of its total sales of products and services, and indicates that the Indian Ministry of Defence is its primary customer; however it does not provide this information in the form of an amount or percentage of the total sales, nor does it provide any information on its other significant customers. <\/p>\n"},{"question":111,"commitment_area":16,"score":"2","comments":"
There is evidence that the company publishes information about its shareholder voting rights, broken down by percentage allocated to each shareholder. The company publishes beneficial ownership and voting rights of all of its shareholders, and it also publishes ownership and voting rights by state entity over 10%. This data is published alongside each other to reflect the relationship between ownership and voting rights. <\/p>\n"},{"question":112,"commitment_area":16,"score":"2","comments":"
There is evidence that the company\u2019s commercial and public policy objectives are made publicly available on its website. The company also makes information on its objectives available in its Annual Report, which therefore indicates that its objectives are updated on at least an annual basis.<\/p>\n"},{"question":113,"commitment_area":16,"score":"1","comments":"
There is evidence that the company publishes clear information about the composition of its board and whether each board member is an executive, a state representative or an independent board member. There is information that the Government of India appoints the Functional Directors, Government Directors and Independent Directors. <\/p>\n
However, the company receives a score of \u20181\u2019 because further information about the nomination process is unclear. <\/p>\n"},{"question":114,"commitment_area":16,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s executive-level Audit Committee is composed of a majority of independent directors. The company discloses the name and status of each member in its Annual Report.<\/p>\n"},{"question":115,"commitment_area":16,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a system in place for managing assets transactions with responsibility assigned at board level. There is evidence that asset valuations are subject to scrutiny by an audit body. <\/p>\n
However, the company receives a score of \u20191\u2019 because there is no evidence that all transactions are documented and there is no evidence that financial results from asset acquisitions are made publicly available in the company\u2019s reports.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/449","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=449"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=449"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}