There is evidence that the company\u2019s Chief Executive Officer makes a statement in support of ethical business conduct, and endorses the company\u2019s Code of Business Ethics and Conduct. This document contains the company\u2019s zero-tolerance stance toward bribery and corruption.<\/p>\n
However, the company receives a score of \u20181\u2019 because the public statement from its leadership does not specifically mention and address bribery and corruption. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company publishes a clear anti-bribery and corruption policy, which prohibits bribery, payments to public officials, commercial bribery and facilitation payments. This policy explicitly applies to all employees and directors, including those of subsidiaries and other controlled entities.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that the board level Audit Committee is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. 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":"
There is evidence that a designated senior executive has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to a board committee that provides oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this person and the board committee.<\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
There is evidence that the company has a formal bribery and corruption risk assessment procedure that informs the design of its anti-bribery and corruption programme, and that the results of risk assessments are reviewed by the board on at least an annual basis or when the results of the risk assessments reveal significant findings. The company states that the results of such reviews are used to develop tailored mitigation plans and to update specific parts of the company's anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
The company states that its anti-bribery and corruption programme is subject to regular audit and review, the results of which are presented to the board. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not specify that the entire programme is audited to ensure that it is consistent with high standards of best practice and the business risks facing the company. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly commits to investigating incidents, and there is a specific procedure in place to deal with whistleblowing cases. There is also evidence that all investigations are documented and that whistleblowers are provided updates on the outcome of investigations, if they so wish. There is evidence that investigations are handled by an independent team. <\/p>\n
However, the company does not provide information covering the whole investigative process, from receipt to final outcome, and there is no evidence that a central body reviews the status of investigations on an annual or regular basis. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company assures itself of the quality of investigations, for example by indicating that staff conducting investigations are properly trained, by implementing a policy to handle complaints about the process or by reviewing the investigation process every three years. <\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
The company commits to report material findings of bribery and corruption to the board. There is evidence that the company\u2019s Chief Legal Officer 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":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption investigations or disciplinary actions. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides training for all employees, which outlines the basic principles of its anti-bribery and corruption programme. <\/p>\n
However, there is no clear publicly available evidence that the company\u2019s training specifically includes the whistleblowing options available to employees. It is also not clear from publicly available information that it provides this training to all employees in all divisions, countries and regions of operation and in all appropriate languages. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides tailored anti-bribery and corruption training for employees in high risk positions based on their exposure to possible corruption risk.<\/p>\n
However, there is no clear public available evidence that the company provides tailored anti-corruption training to those in middle management positions and to board members, nor is there clear evidence that employees in high risk positions specifically must undertake and refresh their tailored training on at least an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
There is evidence that the company reviews its anti-bribery and corruption communications and personnel training programme, the results of which are used to update specific parts of the company's anti-bribery and corruption communications and training programme.<\/p>\n
However, it is unclear whether reviews of the training programme are carried out on at least an annual basis.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company\u2019s incentive schemes incorporate ethical or anti-bribery and corruption principles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"1","comments":"
There is publicly available evidence that the company commits to support employees who raise concerns, make ethical decisions and refuse to act unethically, even when situations are difficult in the conduct of business. <\/p>\n
However, there is no publicly evidence that the company assures itself of its employees\u2019 confidence in this commitment through surveys, usage data, or other clearly stated means.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
The company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, which explicitly applies to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners. <\/p>\n
However, there is no publicly evidence evidence that the company assures itself of its employees\u2019 confidence in this commitment through surveys, usage data, or other clearly stated means.<\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides both whistleblowing and advice channels for its employees to report concerns and seek advice on its anti-corruption programme. The company clearly indicates that these channels allow for both confidential and anonymous reporting. In addition, there is evidence that the company operates both internal reporting mechanisms as well as an external whistleblowing service operated by an independent third party. There is also evidence indicating that these channels are available to all employees in any country of operation, in multiple languages, and to any employees of third parties, suppliers and joint venture partners.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence that the company formally addresses conflicts of interest as a corruption risk and that it covers actual, potential and perceived conflicts. The company\u2019s policy clearly applies to all employees and board members, including those of subsidiaries and other controlled entities. In addition, there is evidence that the company\u2019s policy addresses possible conflicts arising from personal financial interests, personal relationships and outside employment, and that it addresses government relationships.<\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is some evidence that the company has procedures to identify, declare and manage conflicts of interest. The company indicates that employees must disclose any actual, potential or perceived conflicts to managers and to withdraw from activities where possible. The company\u2019s policy also mentions examples of criteria for recusals. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that disciplinary actions will apply if this policy is breached, nor is there 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. <\/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 public officials. There is evidence that the company has a system to implement additional approval and screening requirements when hiring former public officials. The company also states that it complies with all applicable laws and restrictions on post-U.S. government employment restrictions. <\/p>\n
However, there is no publicly available evidence that the company\u2019s policy includes further measures to reduce possible corruption or conflict of interest risks, such as a requirement for senior compliance officer (or equivalent) approval before the initiation of employment discussions, clear cooling off periods or restrictions on certain activities post-employment. It is noted that the company references a separate policy document that may contain further details on this subject, but it does not appear to be publicly available.<\/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":"
There is evidence that the company does not make corporate contributions to support political organisations, and this policy applies company-wide to all employees. There is evidence that the company is associated with a Political Action Committee (PAC) in the United States, which is managed and overseen by a board of directors. <\/p>\n
Since the company is associated with a PAC in the United States, it receives a score of \u20180\u2019 in line with the scoring criteria. <\/p>\n"},{"question":76,"commitment_area":11,"score":"2","comments":"
There is evidence that the company publishes information on the donations made through its Political Action Committee (PAC) in the United States, by providing a direct link to the Federal Election Commission website where full details of such expenditure can be found. There is evidence that the company does not make corporate political contributions through direct expenditures. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is some evidence that the company has policies covering charitable donations and sponsorships, which specifies criteria for donations. There is also evidence that the company discloses some summary information on its total charitable contributions, specifically those made through a related foundation. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that its policy has specific controls in place to reduce the risk of bribery and corruption in its charitable activities, such as procedures for senior sign-off or due diligence on recipients. There is also no publicly available evidence that the company publishes full details of its charitable contributions and sponsorships, such as details of the recipient, amount, country of recipient and which corporate entity made the payment.<\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy and procedure on lobbying, which applies company-wide to all employees, board members and third parties engaged as lobbyists on the company\u2019s behalf. The company's policy includes procedures to identify any conflicts of interest associated with engagements in the political process and this approach is outlined in the company\u2019s Code of Business Ethics and Conduct which describes certain standards of conduct for all employees and third parties. <\/p>\n
However, it is not clear from publicly available information that the company\u2019s approach to lobbying includes further details such as specific guidelines or standards of conduct that apply to all types of lobbyists (internal, external and association) or clear oversight mechanisms to monitor activities. It is noted that the company references a separate policy document which may contain more information on its lobbying practices, but this does not appear to be publicly available. <\/p>\n"},{"question":79,"commitment_area":11,"score":"1","comments":"
There is evidence that the company publishes some information on its lobbying topics and activities in the United States, by making its quarterly federal lobbying reports publicly available via a direct link on its website. <\/p>\n
However, there is no evidence that the company provides further publicly available details about its broader public policy aims or positions. There is also no evidence that the company publishes any information on the activities that it has conducted in other jurisdictions nor does it clearly state that it has not engaged in lobbying elsewhere in the most recently reported financial period. <\/p>\n"},{"question":80,"commitment_area":11,"score":"1","comments":"
There is evidence that the company publishes summary information of its lobbying expenditure in the United States, by making its quarterly federal lobbying reports publicly available via a direct link on its website. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it provides a breakdown of its expenditure data to show costs relating to internal, external or association lobbyists. There is also no evidence that the company publishes information on its lobbying expenditure in other jurisdictions nor does it clearly state that it has not engaged in lobbying elsewhere in the most recently reported financial period.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy and\/or procedure on the giving and receipt of gifts and hospitality with clear procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. There is evidence that this policy has financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy also addresses the risks associated with gifts and hospitality given to and\/or received from domestic and foreign public officials. <\/p>\n
However, there is no evidence indicating that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process. <\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is evidence that the company's procurement department is involved, in some capacity, in the establishment and oversight of supplier relationships and there is evidence indicating that this department is the main body responsible for oversight of the company\u2019s supplier base;<\/p>\n
However, there is no evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means, such as an audit, at least every three years.<\/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 ultimate beneficial ownership. There is also evidence suggesting that the company is willing to review and\/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence process cannot be mitigated. The company indicates that due diligence will be undertaken at the outset and over the course of a business relationship. <\/p>\n
However, it is unclear how frequently due diligence is refreshed, and there is no evidence to suggest that highest risk suppliers are subject to enhanced due diligence.. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place, by requiring all suppliers to adhere to its Supplier Code of Conduct. This policy explicitly states that all suppliers must have policies that prohibit foreign and domestic bribery and facilitation payments, as well as policies that cover conflicts of interest, gifts and hospitality, and whistleblowing.<\/p>\n
However, it is not specified whether this assurance is conducted only when onboarding new suppliers or when there is a significant change in the business relationship.<\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. The company indicates that it expects suppliers to conduct appropriate due diligence on its subcontractors and flow down the principles of its anti-bribery and corruption policies throughout the supply chain.<\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or anti-bribery and corruption reports, investigations or the associated disciplinary actions involving its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has a policy and procedures 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, including due diligence reviews, as well as reporting and invoicing requirements. This policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures.<\/p>\n
However, there is no publicly available evidence that the company specifically commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. <\/p>\n"},{"question":89,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and\/or re-engaging any agents and intermediaries. There is evidence that all agents and highest risk intermediaries are subject to enhanced due diligence. There is additional evidence that the company commits to not engaging or terminating its engagement with agents or intermediaries where the risks identified in the due diligence cannot be mitigated. In addition, the company indicates that it has procedures in place to conduct due diligence reviews on a continuous basis throughout the business relationship. <\/p>\n"},{"question":90,"commitment_area":13,"score":"1","comments":"
There is evidence that the company\u2019s due diligence process specifically includes procedures to establish the ultimate beneficial ownership of agents and intermediaries. The company indicates that it does this through a pre-agreement questionnaire, and there is evidence that the company will not engage or terminate its engagement with agents and intermediaries in situations where beneficial ownership cannot be established. <\/p>\n
However, it is not clear from publicly available information that the company has procedures in place to independently verify beneficial ownership information provided by any agents or intermediaries identified as high risk. In addition, there is no publicly available evidence that the company conducts and reviews this information specifically at least every two years or when there is a significant change in the business relationship.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is evidence that the company\u2019s anti-bribery and corruption policy applies to agents, intermediaries and other entities working on its behalf. However, there is no publicly available evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries, nor that its contracts include clear audit and termination rights to detect, prevent and control breaches.<\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
There is evidence that the company recognises incentive structures as a risk factor in agent behaviour, by stipulating a specific approval procedure for payments to such entities.<\/p>\n
However, there is no further publicly available evidence that incentives for agents are designed to promote ethical behaviour and discourage corrupt practices, for example by imposing a threshold on the payment of sales commissions to agents, or by requiring that remuneration is paid in stages and into local bank accounts.<\/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":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering and while operating in a joint venture, and that this process includes checks on the ultimate beneficial ownership of the partner company. <\/p>\n
However, it is not clear from publicly available information whether joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence. In addition, there is no evidence that the due diligence process is repeated at least every two years.<\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is some evidence that the company commits to establishing anti-bribery and corruption policies and procedures in its joint ventures. However, there is no publicly available evidence that the company requires anti-bribery and corruption clauses in its contracts with joint venture partners nor that such clauses include clear audit and termination rights to detect, control and prevent breaches. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures, for example by providing training to employees of joint ventures or implementing a policy to second senior individuals to the partner company\u2019s management board. <\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for oversight of its offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations. The company provides some information on its approach to due diligence in relation to third parties, but it is not clear from publicly available information that this process applies to offset partners or to other aspects of an offset obligation. <\/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":"0","comments":"
There is no evidence that the company publishes any details of its offset obligations, nor does it publicly indicate that it has not engaged in such activities in the most recently reported financial year.<\/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. The company provides some examples of possible controls.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a list of subsidiaries, which includes details of the jurisdiction or country of incorporation for each entity. This list is published on an annual basis as part of the company\u2019s reporting and is accompanied by a statement that it is complete at the time of publication to the best of the company\u2019s knowledge.<\/p>\n
However, there is no publicly available evidence that the company publishes further details of its percentage ownership in each entity, nor the relevant country or countries of operation. It is therefore not clear from publicly available information that this list represents all of the company\u2019s fully and non-fully consolidated holdings such as associates, joint ventures and other entities.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed on the New York Stock Exchange (NYSE) and therefore it is not required to disclose further information on its beneficial ownership to receive a score of \u20182\u2019.<\/p>\n"},{"question":110,"commitment_area":15,"score":"1","comments":"
There is evidence that the company provides some information about its major customers, to indicate that the United States government and branches of the military account for a substantial portion of its defence sales. The company indicates that revenue from customers in the defence and intelligence sectors accounts for approximately 70% of its overall sales. There is evidence that this information is updated and published on an annual basis as part of the company\u2019s annual corporate reporting. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further publicly available information to indicate the major customers for 80% or more of its 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\/495","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=495"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=495"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}