The company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. This commitment is included in the company\u2019s Code of Conduct, which is in turn authorised and endorsed by the company's leadership.<\/p>\n
However, the company\u2019s leadership does not explicitly mention anti-bribery and corruption in its statement and the company can therefore not receive a score of \u20182\u2019. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company publishes an explicit anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members, regardless of their seniority, and across all subsidiaries and controlled entities.<\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is evidence that a designated board committee is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence to suggest that it engages in formal oversight functions, such as reviewing reports from management or the results of internal and external audits.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is some evidence to suggest that a designated senior executive has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. There is evidence that this person has a direct reporting line to the board committee that provides oversight of the anti-bribery and corruption programme. There is some evidence of reporting and feedback activities between this person and the board. <\/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-bribery and corruption programme. 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. 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":"2","comments":"
There is evidence that the company\u2019s anti-bribery and corruption programme is subject to a regular audit process to ensure the programme is consistent with best practice and the business risks facing the company. This includes provisions for continuous improvement, supplemented by an internal or external audit annually. There is also evidence that high-level audit findings are presented to the board, with clear ownership assigned to units for planned updates and improvements to the anti-bribery and corruption programme.<\/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. <\/p>\n
However, the company receives a score of \u20181\u2019 because the procedure does not stipulate documentation and actions to be taken at each step nor does it cover the whole investigation process from receipt to final outcome. Furthermore, it is unclear whether the investigations are handled by an independent team and\/or report to an independent board member. Also, there is no commitment to providing whistleblowers with updates on the outcome of investigations. Additionally, there is no evidence that the information on each investigation is documented or that summary information is reviewed by a central body. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company assures itself of the quality of its internal investigations. <\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company\u2019s investigative procedure includes a commitment to report material findings to the board of directors or the relevant authorities.<\/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":"1","comments":"
There is evidence that the company provides a training module that outlines the basic principles of its anti-bribery and corruption policy, including the whistleblowing options available to employees. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the training is systematically provided to all employees across all divisions, all countries and regions of operation or in all appropriate languages. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is evidence that the company tailors its anti-bribery and corruption training to employees in certain positions based on an assessment of their role and exposure to corruption risk. The company states that managers, and employees working in certain positions, including sales and procurement, receive anti-bribery and corruption training tailored to their role. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not mention board members nor does it specify that employees in high-risk positions are required to undertake refresher trainings on at least an annual basis. <\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
There is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme. The company suggests that reviews are used to improve specific parts of its training programme. There is evidence that the company reviews its training on a half-yearly basis as part of its operational assurance process. <\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
There is evidence that the company\u2019s incentive schemes incorporate ethical and anti-bribery and corruption principles. There is evidence to suggest that incentives are designed to minimise compliance risks arising from target-based incentives, and that objectives include compliance principles. <\/p>\n
However, the company receives a score of \u20181\u2019 because this is insufficiently detailed and where financial rewards are part of the company\u2019s incentive schemes, it is not clear that these must be proportionate to the employee\u2019s salary in the case of high risk employees, such as sales roles.<\/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":"1","comments":"
There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents that 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, 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. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and to relevant external bodies. These channels allow for confidential and, wherever possible, anonymous reporting. 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. There is evidence that reporting can be done in all languages relevant to the jurisdictions in which it operates. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company formally addresses conflicts of interest as a corruption risk, and has a clear policy that defines conflicts of interest, including actual, potential and perceived conflicts. The company states that this policy applies to employees and board members, including those of subsidiaries and other controlled entities. The policy covers employee relationships, financial interest and other employment. <\/p>\n
However, the company receives a score of \u20181\u2019 because the policy does not cover 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, potential and perceived conflicts. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not state that all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process. There is also no reference to a specific body or individual with oversight and accountability for handling cases and the policy does not mention examples of criteria for recusals. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company has a policy regulating 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":"2","comments":"
The company states in its code of conduct that it does not make political contributions. This is also reflected in the company\u2019s annual report.<\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
The company publishes a clear statement that it does not make any political contributions, and is therefore exempt from scoring on this question. <\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is some evidence that the company has a policy covering charitable donations; however, there is no evidence that the company has a policy or procedure covering also sponsorships.<\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy covering responsible lobbying. It includes some standards of conduct and provides some guidelines on what behaviours are considered acceptable. This policy applies to all employees, board members and third parties lobbying on the company\u2019s behalf.<\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide guidelines on the corruption risks associated with lobbying and it does not mention specific oversight mechanisms that apply to all types of lobbyists. <\/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 that the company has a policy on the giving and receipt of gifts and hospitality with clear procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes some limits, along with an approval procedure. The company's policy includes a statement that all gifts and hospitality are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process. There is some evidence that the company addresses the risks associated with gifts and hospitality given to and received from domestic or foreign public officials.<\/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 and oversight of its supplier base.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is evidence that the company conducts due diligence on its suppliers. However, the company simply states that it conducts due diligence on its suppliers, without providing any further details and therefore cannot receive a score of \u20181\u2019. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. It is explicitly stated that all suppliers must have, at minimum, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, as well as policies and procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. There is evidence to suggest that the company takes active steps to ensure that its suppliers have adequate anti-bribery and corruption policies and procedures in place.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is unclear whether the company assures itself of this when onboarding new suppliers or when there is a significant change in the business relationship. <\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
There is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place and that the substance of its anti-corruption and bribery programme and standards are included in subcontracts throughout the supply chain. <\/p>\n
However, this evidence is in the form of a clear statement and it is unclear how the company does this in practice. <\/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 relating to its suppliers, or the associated 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. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. 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 with its third parties and agents. The company states that it conducts due diligence on third parties and agents, with more thorough due diligence being undertaken for higher risk agents and third parties. The company states that due diligence is repeated at least annually. The company states that it will not engage with agents or intermediaries where risks identified in the due diligence cannot be mitigated and suggests that it would apply this same approach with existing relationships when refreshing its due diligence on an annual basis. <\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company aims to establish the beneficial ownership of its agents.<\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
There is evidence that the company\u2019s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. All agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include clear audit rights and termination rights to detect, control and prevent breaches. <\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
There is evidence that incentive structures for agents are highlighted and addressed as a factor in bribery and corruption risk. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it imposes a threshold on the payment of sales commissions to agents, and there is no requirement that remuneration is paid in stage payments or 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 or bribery and corruption related investigations, incidents or the associated disciplinary actions involving agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its joint ventures.<\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
Although there is some evidence that the company commits to establishing and implementing anti-bribery and corruption policies in its subsidiaries and with any third parties with whom it engages, there is no evidence that the company states 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 no evidence that the company addresses the corruption risks associated with offset contracting, and there is no evidence that a dedicated body, department or team is 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 has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of 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 contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"2","comments":"
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 examples of such possible controls.<\/p>\n"},{"question":108,"commitment_area":15,"score":"2","comments":"
There is evidence that the company publishes a full list of its fully consolidated subsidiaries and non-fully consolidated holdings. For each entity, the company discloses its percentage ownership, the country of incorporation and countries of operation. There is evidence that this list is current and updated on at least an annual basis. The list is accompanied by a statement that it is complete at the time of publication to the best of the company\u2019s knowledge.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is publicly listed on the London Stock Exchange and therefore automatically receives a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"2","comments":"
The company publishes a breakdown of its defence sales by customer, in the form of the percentage of its total defence sales by customer per year. The company publishes the customers of more than 80% of its defence sales. <\/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\/498","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=498"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=498"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}