There is evidence that the company publishes a clear anti-bribery and corruption commitment, which details its stance against any form of bribery and corruption within the organisation. There is evidence that this commitment was directly authorised and endorsed by the company\u2019s senior leadership. <\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company publishes an anti-bribery and corruption policy, which specifically prohibits commercial bribery and directly addresses facilitation payments. This policy applies to all employees and board members as described in (a) and (b) in the question. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that its anti-bribery and corruption policy prohibits payments to public officials.<\/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 includes anti-bribery and corruption. The company indicates that this body is responsible for reviewing reports from management on the performance of the ethics and compliance programme and ensuring that required changes are made. The Audit Committee also reports at least annually to the board on the implementation and effectiveness of programme.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior individual \u2013 the Senior Vice President of the Office of Internal Governance and Administration \u2013 has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. The company indicates that this individual has a direct reporting line to the Audit Committee which provides oversight of the ethics and compliance programme. There is evidence of reporting and feedback activities between this person and the Audit 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 informs the design of the anti-bribery and corruption programme. There is evidence to indicate that risk assessments are reviewed by the board on an annual basis and that the results are used to update specific parts of the company's anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s ethics and compliance programme is subject to annual review, supplemented with periodic audits and external assessments. The company indicates that it conducts continuous monitoring of its compliance programme to maintain its effectiveness, and states that such processes are built into all levels of the business. There is evidence that the company\u2019s board-level Audit Committee reviews the results of these assessments and there is evidence that the company\u2019s Senior Vice President of the Office of Internal Governance and Administration is responsible for making updates and improvements to the programme on this basis. <\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a system in place to track, investigate and respond to bribery and corruption allegations or incidents, which includes those reported through whistleblowing channels. There is evidence that the company takes steps to ensure the independence of its investigations, as well as committing to establish root causes, put in place remediation plans and implement procedures to report investigative findings to senior management and the Audit Committee. <\/p>\n
In addition, the company\u2019s procedure stipulates documentation and actions to be taken at every step of the case, from receipt to final outcome, and it commits to keeping individuals informed of the outcome of investigations if they so wish. There is evidence that the company\u2019s Audit Committee reviews summary information of all allegations and investigations on a bi-monthly basis. <\/p>\n"},{"question":61,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company assures itself of the quality of its internal investigations, including those reported through whistleblowing channels. The company clearly states that staff tasked with conducting investigations are properly qualified and trained to perform the function. There is evidence that any complaints about the handling of concerns and investigations are overseen by an appropriate senior management officer and a procedure is in place to handle the escalation of complaints. The company indicates that its investigations procedure is subject to ongoing evaluation with a management review conducted on an annual basis. <\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company commits to report material findings from investigations to the board. There is evidence that a senior manager in the law department is responsible for ensuring that the disclosure of criminal offences to relevant authorities is evaluated and acted upon if necessary.<\/p>\n"},{"question":63,"commitment_area":8,"score":"2","comments":"
There is evidence that the company publishes high-level data from ethical investigations involving employees at all levels. This data includes the number of reports received (including those reported through whistleblowing channels), the number of investigations launched and the number of disciplinary actions as a result of investigation findings. There is evidence that this data is published on an annual basis covering cases for the last 12 months<\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides training for its employees that outlines the principles of the anti-bribery and corruption policy, including the whistleblowing options available. There is evidence that the company provides this training to all employees in all business divisions and in multiple languages. The company indicates that employees are required to undertake this training on an annual basis. <\/p>\n"},{"question":65,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides tailored training on anti-bribery and corruption to employees in different positions based on their role and exposure to corruption risk. The company indicates that managers receive tailored training on anti-corruption and compliance, and states that employees receive individual training plans based on the type of work they perform. In addition, there is evidence that board members receive annual training on corporate governance and the company\u2019s policies and procedures, which is understood to include ethics and compliance. The company indicates that all employees are required to update their training on an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
There is evidence that the company reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme on an annual basis. The company states that it does this through staff surveys and feedback from subject matter experts. There is evidence indicating 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":"1","comments":"
There is some evidence that the company\u2019s incentive schemes for employees incorporate ethical and anti-corruption principles. The company indicates that integrity considered as a factor in individual performance reviews, and that these reviews inform the company\u2019s annual employee incentive calculations. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no further publicly available description of how the company achieves this in practice. For example, it is not clear whether incentives focus on the achievement of both financial and non-financial targets, nor is there evidence that such rewards must be proportionate to the base salary, especially in the case of high risk employees. <\/p>\n"},{"question":68,"commitment_area":9,"score":"2","comments":"
There is evidence that the company commits to support and protect employees who refuse to act unethically, even when it might result in a loss of business. There is evidence that the company assures itself of employees\u2019 confidence in this statement on a regular basis through confidential surveys. <\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":"
There is evidence that the company promotes a policy of non-retaliation against both employees and third parties who report allegations of bribery and corruption. There is evidence that the company assures itself of employees\u2019 confidence in this commitment on a regular basis through confidential surveys.<\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. There is evidence that these channels are sufficiently varied to allow employees to raise concerns across the management chain and to an external party through an independently-operated hotline. The company states that these channels allow for confidential and, wherever possible, anonymous reporting. <\/p>\n
In addition, the company indicates that its channels are available and accessible to all employees in all jurisdictions where it operates, including those employed by the group as third parties, suppliers and business partners. The company\u2019s Code of Conduct has been translated into multiple languages, and therefore it is understood that the its reporting channels are available in multiple 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 that addresses conflicts of interest and that defines actual, potential and perceived conflicts. There is evidence that this policy covers possible risks arising from employee relationships, government relationships, financial interests and other employment. There is evidence 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 procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. There is evidence 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 a dedicated team within the Ethics and Business Conduct organisation is responsible for implementation of the policy and the handling of individual cases. The company states that breaches of this policy may result in disciplinary action. Although the company only mentions recusals in the context of directors and corporate officers, there is sufficient accompanying evidence for the company to receive a score of \u20182\u2019. <\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy that addresses the risks associated with the employment of current and former public officials. The company states that it will review potential conflicts arising from such appointments and require certain controls to be adopted, such as cooling off periods and lifetime bans from certain projects.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that it requires senior-level approval for the initiation of any employment discussions with former or current public officials. <\/p>\n"},{"question":74,"commitment_area":10,"score":"2","comments":"
The company publishes a clear statement that it does not contract or employ 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 on corporate political contributions. The company\u2019s policy indicates that it may make political contributions when approved by the company\u2019s Executive Vice President, Government Operations and other relevant senior managers from the Government Operations office. In addition, there is evidence that that the company is associated with a Political Action Committee (PAC) in the United States, which is overseen and managed by an advisory committee.<\/p>\n
Since the company does not prohibit political donations and is associated with a PAC, it receives a score of \u20180\u2019 in line with the scoring criteria. <\/p>\n"},{"question":76,"commitment_area":11,"score":"2","comments":"
The company publishes a statement that it has not made any corporate political corporate contributions to state or local candidates since 2010. The company also indicates that it has not contributed to ballot initiatives since 2011, nor to section 527 entities since 2012. In addition, the company provides a direct link to the United States Federal Election Commission website where full details of its Political Action Committee disbursements can be found. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy on charitable donations and sponsorships, which covers both financial and in-kind donations. The company states that all donations must follow ethical guidelines and must be overseen by the Law Department. There is some evidence that the company has procedures in place to conduct due diligence on recipients.. <\/p>\n
Although the company publishes some details of the recipients of its grants, the company receives a score of \u20181\u2019 because there is no evidence that it publish full details of all donations made, such as the country and amount given to each recipient, as well as which corporate entity made the payment, for both financial and in-kind donations. <\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy on lobbying, which includes specific controls and oversight provisions to regulate the activities of lobbyists. The company states that it provides training on responsible lobbying behaviours and indicates that all lobbying activities are conducted in accordance with its high standards of ethical conduct. The company also states that the Government Operations department is responsible for oversight of all lobbying and political activities. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further information on the standards and types of behaviours that constitute \u2018responsible\u2019 lobbying. <\/p>\n"},{"question":79,"commitment_area":11,"score":"1","comments":"
The company publishes some details of the topics on which it lobbies on its website and in more detail in the Lobbying Disclosure Reports which are available to the United States Congress and Senate. These reports are made available via a direct link on the company\u2019s website and they include information on the specific legislation on which the company has lobbied in the United States. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further details of its lobbying activities, such as a description of its core positions and their importance or relevance to the company and stakeholders. In addition, the information provided only relates to lobbying activities in the jurisdiction in which the company is headquartered (the United States); there is no evidence that the company discloses this information for other jurisdictions, nor does it publish a statement that it does not conduct lobbying activities outside of the United States. <\/p>\n"},{"question":80,"commitment_area":11,"score":"1","comments":"
The company publishes some details of its lobbying expenditure in its annual Proxy Statement, as well as in its Lobbying Disclosure Reports for the United States Congress and Senate. These reports are made available via a direct link on the company\u2019s website and include information on total lobbying expenditure relating to activities in the United States. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further details of its lobbying expenditure, such as a breakdown in expenditure between internal, external and association lobbying, and an explanation of how the figures in the data have been calculated. Furthermore, the information provided only relates to lobbying activities in the jurisdiction in which the company is headquartered (the United States); there is no evidence that the company discloses this information for other jurisdictions, nor does it publish a statement that it does not conduct lobbying activities outside of the United States. <\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality, which addresses the risks associated with gifts and hospitality given to public officials. The company states that certain thresholds are in place for specific types of gifts and hospitality, and that it has a procedure in place which stipulates prior approval from the Law Department. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that 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. It is noted that the company has separate policies on accepting and offering promotional expenses which may outline further control measures, but this does not appear to be publicly available. <\/p>\n"},{"question":82,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence that the company requires the involvement of its procurement department in the establishment of new suppliers. The company indicates that this department is ultimately responsible for providing oversight of the company's supplier base. There is evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through an audit of the supplier management process, which is conducted on an annual basis.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has formal procedures to conduct due diligence on all its suppliers prior to entering into the business relationship. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not explicitly state that due diligence checks include establishing the ultimate beneficial ownership of the supplier. There is no evidence that the highest risk suppliers are subject to enhanced due diligence, and the frequency of these checks is unclear. In addition, there is no clear evidence to suggest that the company might be willing to terminate supplier relationships in circumstances where a red flag highlighted in the due diligence process cannot be mitigated. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company contractually requires its suppliers to comply with anti-corruption laws and have an ethics and compliance programme in place. <\/p>\n
However, the company receives a score of \u20191\u2019 because it does not provide further information on the specific standards that are required; for example it does not explicitly state that all suppliers must have or comply with policies that prohibit bribery and facilitation payments, or procedures to cover conflicts of interest, gifts and hospitality and whistleblowing. It is also not clear that the company takes practical steps to ensure that its suppliers have adequate anti-bribery and corruption policies and procedures in place, such as an audit or assessment of the suppliers\u2019 programme. In addition, it is not clear whether such assurance would take place only during onboarding 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 the substance of its anti-corruption and bribery programme and standards are flowed down throughout the supply chain. This evidence is the form of a contractual commitment placed on suppliers and their sub-contractors.<\/p>\n"},{"question":86,"commitment_area":12,"score":"1","comments":"
There is evidence that the company publishes annual data on ethics-related disciplinary actions and investigations within the organisation, which includes data relating to supplier misconduct. However, the company receives a score of \u20181\u2019 because it does not distinguish concerns and cases related to suppliers from those related to employees and other entities in the organisation. <\/p>\n"},{"question":87,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has a policy on the use of agents, which it refers to as international consultants. The company provides details of some controls to mitigate these risks, including due diligence and multiple senior sign-offs of the agent\u2019s scope of work. There is evidence to suggest the policy also applies to subsidiaries and joint ventures.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that the company commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. <\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging with its agents. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that agents and the highest risk intermediaries are subject to enhanced due diligence. Although the company states that it renews due diligence at appropriate intervals, it is not clear that the company repeats due diligence at least every two years or when there is a significant change in the business relationship. There is also no clear evidence that the company commits to not engaging or terminating its engagement with agents or intermediaries where risks identified in the due diligence cannot be mitigated.<\/p>\n"},{"question":90,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company\u2019s due diligence procedures includes checks on the ownership of its agents and international consultants. The company provides information to indicate that such checks are conducted at the outset of the relationship and that this process is overseen by the Law Department. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the company commits to independently verify the beneficial ownership information provided by high risk agents, nor is there evidence that it commits to not engaging or terminating its engagement with agents or intermediaries in cases where beneficial ownership cannot be established.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is some evidence that the company\u2019s anti-bribery and corruption policy applies to agents, and that it includes anti-bribery and corruption clauses in its contracts with such entities. However, while the company indicates that it maintains contractual rights in case of a breach, there is no clear evidence that these include audit and termination rights.<\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company considers incentive structures as a risk factor in agent behaviour, nor is there evidence that the company's incentive structures are designed to minimise risks of anti-bribery and corruption.<\/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 its behalf.<\/p>\n"},{"question":99,"commitment_area":13,"score":"1","comments":"
There is evidence that the company publishes annual data on ethics-related disciplinary actions and investigations within the organisation, which includes data relating to agent misconduct. However, the company receives a score of \u20181\u2019 because it does not distinguish concerns and cases related to agents from those related to employees, suppliers or other entities in the organisation.<\/p>\n"},{"question":100,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has formal procedures to conduct risk based anti-bribery and corruption due diligence prior to entering into all of its joint venture partnerships. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the company\u2019s due diligence includes checks on the ultimate beneficial ownership of the partner company. In addition, there is no evidence to suggest that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence. It is also not clear that due diligence is repeated at least every two years or when there is a significant change in the business relationship. <\/p>\n"},{"question":101,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company ensures that all of its joint ventures adopt equivalent anti-bribery and corruption policies to its own. The company also states that it includes ethics and compliance provisions in its contracts with joint venture partners, which include audit rights. There is some indication that the company\u2019s contracts with such entities include termination rights in the event of a breach. <\/p>\n"},{"question":102,"commitment_area":13,"score":"2","comments":"
There is evidence that the company publicly commits to take an active role in preventing bribery and corruption in its joint ventures. The company indicates that it does this by requiring that its joint venture entities establish a formal anti-corruption policy, as well as by seconding board members and conducting ongoing risk assessments. <\/p>\n"},{"question":103,"commitment_area":14,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy to address the corruption risks associated with offset contracting. The company has a dedicated department involved in managing offset obligations and there is evidence that all its employees receive dedicated anti-bribery and corruption training on the particular risks associated with offset contracting. <\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
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. There is also evidence indicating that the company includes anti-bribery and corruption provisions in its contracts with offset partners.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that this due diligence includes checks on beneficial ownership or conflicts of interest. In addition, it is not clear that the company seeks to assure itself of the legitimacy of the investment, nor is there evidence that due diligence is refreshed continuously throughout the business relationship. <\/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":"1","comments":"
The company publishes some information about its offset projects, in the form of an aggregate figure of the value of its offset obligations that extend until 2030. This information is published in the company\u2019s Annual Report, which indicates that it is correct for the most recently reported financial year. <\/p>\n
The company receives a score of \u20181\u2019 because it does not publish further information on the beneficiaries of its indirect offset projects, such as the name of the company or organisation receiving the investment or the country in which the recipient entity is based. The company does not indicate whether the aggregate figure includes both direct and indirect offset obligations. <\/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, nor is there evidence 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":"
There is evidence that the company publishes a list of its significant subsidiaries as part of its annual corporate reporting documents. This list includes the country of incorporation for each entity. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is evidence to indicate that this list only includes significant holdings as opposed to all of the company\u2019s affiliates or holdings. There is also no evidence that the company publishes information on its percentage ownership or the countries of operation for each subsidiary.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed on a regulated market in the United States, and therefore it is not required to disclose further information on its beneficial ownership in order to receive a score of \u20182\u2019.<\/p>\n"},{"question":110,"commitment_area":15,"score":"1","comments":"
The company publishes some information on its sales per customer, to indicate that the United States government accounted for 31% of its revenue in 2018. In addition, the company publishes information in its Annual Report on its revenues by customer with reference to China and Canada, which combined with the United States figures accounts for 60% of the company\u2019s major customers. <\/p>\n
However, the company receives a score of \u20181\u2019 because the information provided does not distinguish between revenue generated from defence and commercial customers. <\/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\/452","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=452"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=452"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}