The company\u2019s Code of Business Conduct details the company's stance against bribery and corruption. It is clear that the Code of Business Conduct was authorised and endorsed by the company's leadership in the form of an introductory message from the President and Chief Executive Officer. <\/p>\n
However, this message does not specifically mention anti-bribery and corruption and therefore a score of \u20181\u2019 applies.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
The company publishes a clear anti-bribery and corruption policy, which specifically defines and prohibits 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":"1","comments":"
There is evidence that a board level committee - the company\u2019s Governance Committee - provides oversight of the company's anti-bribery and corruption programme. There is evidence that this committee\u2019s responsibilities include reviewing reports from management on the programme\u2019s performance and reviewing policies. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available evidence whether the Governance Committee reviews the results of internal and external audits of the anti-bribery and corruption programme, or that it has the authority to require that changes are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior executive - the General Counsel, Chief Compliance Officer and Corporate Secretary - 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 the Governance Committee which provides oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this person and the board as part of the company\u2019s reporting structure<\/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 the anti-corruption and bribery programme. The Annual Information Form provides evidence that the board conducts quarterly and annual reviews of risks, including corruption. 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 anti-bribery and corruption programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is evidence that the company\u2019s Ethics and Compliance programme has recently been subject to a diagnostic to ensure that it is consistent with best practice, and that the company conducts periodic audits of areas of risk. There is evidence of clear ownership assigned to the Global Ethics and Compliance Office for planned updates and improvements based on audit findings. <\/p>\n
However, the company scores \u20180\u2019 as it does not clearly state how frequently audits are conducted. Also, while there is evidence that the results of the recent diagnostic was presented to the board-level Governance Committee, there is no further evidence that audit findings in relation to the anti-bribery and corruption programme are presented to the board. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company has a system for tracking, investigating and responding to bribery and corruption allegations or incidents, including those reported through whistleblowing channels. There is evidence that the company takes steps to ensure the independence of its investigations and reports investigative findings to senior management and the board. <\/p>\n
There is also evidence that the company has specific procedures in place for whistleblowing cases, stipulating documentation and actions to be taken at every step of the case, from receipt to final outcome, and that the company\u2019s Governance Committee receives and reviews summary information of all incidents and investigations and their status on a quarterly basis.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence of a commitment to inform whistleblowers of the outcome of investigations, if they so wish. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is insufficient publicly available evidence that the company takes measures to assure itself of the quality of its internal investigations.<\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
There is clear evidence that the company commits to report material findings of bribery and corruption from investigations to the board. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that an appropriate senior individual 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":"1","comments":"
In its 2019 Corporate Social Responsibility Report the company published a summary of the number of reports submitted to its whistleblowing line, which included ethics and compliance-related data. <\/p>\n
However, the company receives a score of \u20181\u2019 because the data does not include details concerning the number of investigations or disciplinary actions. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides a training module to all employees that outlines the basic principles of its anti-bribery and corruption programme, including the whistleblowing options available to employees. There is also evidence indicating that the company provides this training in all company locations worldwide.<\/p>\n
The company receives a score of \u20181\u2019 because although the company states that employees must undertake refresher anti-corruption training periodically, there is no evidence that employees must do this at least every three years. There is also no evidence that training is delivered in all appropriate languages.<\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
The company states that employees in certain high-risk positions receive different or tailored anti-bribery and corruption training. <\/p>\n
However, there is no evidence that this includes middle management or board members. There is also no evidence that the company updates its training for those in high-risk positions at least annually. <\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because the measures are limited to completion rates, and there is no evidence that the results of reviews are used to update specific parts of the company\u2019s anti-bribery and corruption communications training programme. There is also no evidence that the company assures itself of the quality of its anti-corruption training on at least an annual basis.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
While there is evidence that the company\u2019s incentive schemes are designed to discourage excessive risk-taking, 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 evidence to suggest that any employee who refuses to act unethically, in keeping with the company\u2019s anti-corruption commitments, will be protected and supported, even where such actions result in a loss of business or another disadvantage to the company. <\/p>\n
However, there is no evidence that the company assures itself of its employees\u2019 confidence in this statement through anonymised surveys or other clearly stated means.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents that applies to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no 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 has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. The evidence indicates that the channels are sufficiently varied to allow employees to raise concerns across the management chain, as well as through an external channel operated by an independent third party. There is evidence that these channels allow for confidential and, wherever possible, 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 several languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence the company formally addresses conflict of interest as a corruption risk, and has a policy that defines conflicts of interest, including actual, potential and perceived conflicts. There is evidence that the policy explicitly covers all of the categories of possible conflicts listed in the guidance, and that it applies to all employees and board members, including those of subsidiaries and other controlled entities.<\/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, including actual, potential and perceived conflicts. <\/p>\n
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 register or repository accessible to those responsible for handling cases. In publicly available evidence, the company also does not name a designated body or individual with specific responsibility for handling cases, nor does the company mention examples of criteria for recusals or state that disciplinary measures will apply if its conflicts of interest policy is breached. <\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is some evidence that the company has a policy that addresses the risks associated with the employment of public officials. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company\u2019s policy includes specific controls to assess and regulate the employment of current or former public officials. <\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company reports details of the contracted services of serving politicians.<\/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. However, the company receives a score of \u20180\u2019 because there is evidence that political donations are permissible in certain circumstances.<\/p>\n"},{"question":76,"commitment_area":11,"score":"2","comments":"
The company publishes details of its political contributions, and there is evidence that this data is updated and published on at least an annual basis. The company discloses that it made no political donations during the last two reporting years.<\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a 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 includes measures to ensure this, for example, by specifying criteria for donations and procedures for senior sign-off. The company also provides limited details of specific causes that it has supported, as well as high level summary of its total charitable donations, published on an annual basis.<\/p>\n
However, the company receives a score of \u20181\u2019 because it does not publish a detailed breakdown of all charitable donations made, including details of the recipient, amount, country of recipient and which corporate entity made the payment.<\/p>\n"},{"question":78,"commitment_area":11,"score":"2","comments":"
There is evidence that the company has a policy that defines lobbying, broad enough to cover the spirit of the term as described in the guidance, and sets out the values and behaviours that constitute \u2018responsible\u2019 lobbying. There is evidence that lobbyists are required to comply with the company\u2019s Code of Business Conduct and Anti-Corruption Policy, which set out what behaviours are acceptable in risk areas such as gifts and hospitality, undue influence and conflicts of interest. There is evidence of oversight mechanisms, including due diligence on lobbyists and provisions for senior sign off on lobbying activities. This policy applies to all employees, board members and third parties lobbying on the company\u2019s behalf. <\/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":"2","comments":"
There is evidence the company has a policy on the giving and receipt of gifts and hospitality with procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. There is evidence that this policy specifies financial limits and different approval procedures for different types of promotional expenses, and that it also explicitly addresses the risks associated with gifts and hospitality given to and\/or received from domestic and foreign public officials. There is evidence that all gifts and hospitality worth over a certain threshold are logged in a dedicated register 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, referred to as its Global Strategic Sourcing Department, is involved, in some capacity, in the establishment and oversight of supplier relationships. <\/p>\n
However, the company does not state that the involvement of the department is required for establishing any new suppliers over a certain threshold. It is also not expressly clear that this department is the main body responsible for oversight of the company\u2019s supplier base, nor that that the company assures itself of this department\u2019s involvement at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
The company states that it conducts risk-based anti-corruption due diligence on third parties, which includes suppliers, and there is evidence that highest risk third parties are subject to enhanced due diligence. There is also evidence to suggest that the company might be willing to review and\/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated. <\/p>\n
The company receives a score of \u20181\u2019 because it is not clear from the publicly available evidence whether all suppliers are subject to due diligence. In addition, there is no evidence to indicate that due diligence procedures include checks on ultimate beneficial ownership. The frequency with which due diligence is refreshed is also unclear. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company ensures that suppliers have adequate anti-bribery and corruption policies and procedures in place, by requiring suppliers to affirm that their own ethics and anti-corruption procedures are equivalent to the company\u2019s. There is also evidence that the company requires its suppliers in Europe and the US to agree to comply with the company\u2019s own Code of Business Conduct. This code contains regulations covering foreign and domestic bribery, facilitation payments, and policies that cover conflicts of interest, gifts & hospitality, and whistleblowing.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is unclear if the company ensures these standards for all of its suppliers. It is also not clear from the evidence whether this assurance is conducted when onboarding all new suppliers and\/or when there is a significant change in the business relationship.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.<\/p>\n"},{"question":86,"commitment_area":12,"score":"1","comments":"
The company states that during the last fiscal year it had no reported incidents on supplier practices. However, it is not clear from the evidence that this information would include details of ethical, bribery or corruption related incidents, investigations or disciplinary actions. <\/p>\n
It is noted that there is evidence that the company published a summary of the number of reports submitted to its whistleblowing line, also in the last fiscal year, which included ethics and compliance-related data. However the company does not state whether this data includes reports in relation to the company\u2019s suppliers, and the data does not include details concerning the number of investigations or disciplinary actions.<\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has a 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. 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 to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures. <\/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 re-engaging agents and intermediaries. The company states that it reviews due diligence on an annual basis. There is evidence that all agents and highest risk intermediaries are subject to enhanced due diligence. There is also 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 evidence that the company has formal procedures in place to establish the beneficial ownership of agents prior to engaging them, which includes requiring agents to disclose this information as part of the due diligence process. The company also states that it reviews due diligence on an annual basis.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company commits to independently verify the beneficial ownership information provided by high risk agents. The company also does not specifically commit to reviewing or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.<\/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 and intermediaries. The evidence also suggests that the company includes anti-bribery and corruption clauses in its contracts with these entities. <\/p>\n
However the company receives a score of \u20180\u2019 because it is not explicitly clear that that contracts include audit and termination rights. It is noted that the evidence includes a hyperlink to a model agreement, however this information is not publicly accessible.<\/p>\n"},{"question":92,"commitment_area":13,"score":"2","comments":"
There is evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. There is evidence that the company places a threshold on sales-based commissions to agents so that payments do not exceed a proportion of the net fee to the agent. There is also evidence that the company has a chain of approval and monitors agent payments, and commits to only paying agents 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 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, bribery or corruption-related investigations or the associated disciplinary actions involving its agents.<\/p>\n
It is noted that there is evidence that the company published a summary of the number of reports submitted to its whistleblowing line in the last fiscal year, which included ethics and compliance-related data. However the company does not state whether this data includes reports in relation to the company\u2019s agents, and the data does not include details concerning the number of investigations or disciplinary actions.<\/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 into all joint venture agreements. <\/p>\n
However, there is no evidence that the company\u2019s due diligence explicitly includes checks on the ultimate beneficial ownership of the partner company. There is also 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. Additionally, the company\u2019s public statements only make reference to due diligence prior to entering into joint venture agreements and there is no evidence that due diligence is repeated every two years and\/or when there is a significant change in the business relationship.<\/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 and procedures in all of its joint ventures by requiring the adoption of its own, or equivalent, anti-bribery and corruption policy. The company also states that it must include anti-corruption provisions in its joint venture agreements.<\/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 through the inclusion of audit and termination rights in contracts with joint venture partners.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is insufficient publicly available evidence to show 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 no evidence that the company addresses the corruption risks associated with offset contracting, or that it has a dedicated body, department or team responsible for monitoring of the company's offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company conducts 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 and\/or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"1","comments":"
There is evidence that the company acknowledges the risks associated with operating in different markets, including some corruption risks. There is evidence that the company has a risk assessment process in place to account for these risks, with clear risk management procedures in place. <\/p>\n
However, there is no clear evidence that risk assessment procedures which account for corruption risks are used to inform the company\u2019s operations in high risk markets.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings. For each entity, the company discloses its percentage ownership and the country of incorporation. This list includes all the company\u2019s subsidiaries and non-wholly owned holdings, and is updated annually. The list is accompanied by an indication that it is complete at the time of publication.<\/p>\n
However, the company receives a score of \u20181\u2019 because the published information does not disclose the countries of operation of each entity.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is publicly listed on the New York Stock Exchange and is automatically awarded a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
The company publishes information regarding its overall sales, however there is no evidence that it publishes a percentage breakdown of its defence sales by customer. <\/p>\n"},{"question":111,"commitment_area":16,"score":"N\/A","comments":""},{"question":112,"commitment_area":16,"score":"N\/A","comments":""},{"question":113,"commitment_area":16,"score":"N\/A","comments":""},{"question":114,"commitment_area":16,"score":"N\/A","comments":""},{"question":115,"commitment_area":16,"score":"N\/A","comments":""}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/496","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=496"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=496"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}