There is some evidence that the company has a publicly stated commitment against corruption as part of its group-wide integrity standards. However, the company receives a score of \u20181\u2019 because it is not clear that the company\u2019s commitment is authorised and endorsed by the company\u2019s leadership. <\/p>\n"},{"question":55,"commitment_area":7,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company has an anti-corruption policy. The company\u2019s website lists integrity and anti-corruption as core values, but there is no indication that the company has and publishes a comprehensive anti-bribery and corruption policy that applies to all employees and board members. <\/p>\n"},{"question":56,"commitment_area":7,"score":"0","comments":"
There is no evidence that the company has an anti-corruption policy or programme, nor that a designated board committee or an individual board member is responsible for the company\u2019s anti-bribery and corruption activities.<\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
There is no evidence that the company publishes an anti-corruption policy, nor that a specific managerial-level employee has ultimate responsibility for implementing and managing the company\u2019s anti-bribery and corruption programme.<\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
There is some evidence that the company has a formal risk assessment procedure in place that informs the design of its anti-bribery and corruption activities on an annual basis. The company indicates that it monitors and assesses the performance of its employees in implementing anti-corruption measures and there is evidence that it recognises the different corruption risks faced by employees in different positions. There is some evidence that the results of these assessments are used to make recommendations for management on how to better counter the corruption risks identified. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company has a group-wide risk assessment procedure, rather than one targeted at specific employees or job roles. There is also no evidence that the company has a group-wide anti-bribery and corruption programme that is designed or adapted based on this procedure. Moreover, the company states that \u2018management\u2019 is responsible for reviewing the results of such assessments, but it is not clear that this includes board-level review. <\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company has an anti-bribery and corruption programme nor that this programme is subject to audit or review. There is some indication that the company reviews the risks facing employees in certain departments and positions, but there is no evidence that it has a group-wide programme which is subject to review on a regular basis.<\/p>\n"},{"question":60,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company has a publicly stated procedure for dealing with bribery and corruption allegations, incidents or whistleblowing reports.<\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company takes steps to assure 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 has an investigative procedure which includes a commitment to report material findings to the board or, if necessary, to 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":"0","comments":"
Based on publicly available information, there is no evidence that the company provides anti-bribery and corruption training to all employees.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk. There is some indication that the company recognises the different corruption risks facing employees in different positions, but it is not clear that it provides training to employees to counter these risks. <\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption communications or training programme. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company\u2019s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles.<\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company commits to support or protect employees who refuse to act unethically. <\/p>\n"},{"question":69,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company has a policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.<\/p>\n"},{"question":70,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company provides whistleblowing or advice channels for employees to report suspected incidents of corruption or seek advice on the company\u2019s anti-bribery and corruption activities.<\/p>\n"},{"question":71,"commitment_area":10,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company has a policy or procedure regulating conflicts of interest.<\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is no evidence the company has procedures to manage conflicts of interest or their oversight. <\/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":"
Based on publicly available information, 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":"
Based on publicly available information, there is no evidence that the company has a policy on corporate political contributions.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company discloses any details of its political contributions.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy on charitable donations or sponsorships, nor that it discloses details of any such donations made. The company provides some information on community projects that it supports, but it is not clear whether these are charitable donations or part of broader agreements.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy or procedure on lobbying.<\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company publishes any information on its lobbying aims, topics or activities.<\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company provides any details about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy or procedure on gifts and hospitality.<\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company requires the involvement of its procurement department in the establishment or oversight of its supplier base.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain.<\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company takes steps to ensure that anti-bribery and corruption procedures and standards are required 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 investigations relating to its suppliers, or the associated disciplinary actions.<\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company has a policy on the use of agents.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company aims to establish the beneficial ownership of its agents, nor that it commits to not engaging 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 no publicly available evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries to detect, control and prevent breaches of its policy. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company considers incentive structures as a risk factor in agent behaviour.<\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any details of the agents currently contracted to act for or on 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":"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":"
There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, nor 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 publicly 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, nor that a dedicated department, body or team is responsible for oversight of the company\u2019s offset programme. <\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company conducts risk-based anti-bribery and corruption due diligence on its offset obligations.<\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf 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 and\/or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no publicly available evidence that the company acknowledges the corruption risks of operating in different markets or that risk assessment procedures are used to inform its operations in high risk markets. Although the company primarily operates in China, there is no clear evidence to suggest that this is the only market in which it operates. There is some indication that the company has risk management procedures in place for employees in certain positions, but there is no evidence that this is based on an assessment of the market risk. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a list of its subsidiaries on its website, which all appear to be based in China. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not publish accompanying details for each entity such as percentage ownership, country of operation or country of incorporation. As a result, it is not clear whether the companies listed are principal or significant subsidiaries, joint ventures or other affiliated entities, and it is not clear that this list represents all of the company\u2019s holdings. In addition, the company\u2019s data includes no information on percentage ownership, incorporation or countries of operation. There is also no clear indication that the data is updated on an annual basis.<\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
There is some evidence that the company is a state-owned enterprise in China. The company receives a score of \u20181\u2019 because it does not provide further information on its beneficial ownership and this information is not disclosed in open data format. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes information about its major defence sales or customers. <\/p>\n"},{"question":111,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company publishes details of its shareholder voting rights. Although the company states that it is a state-owned enterprise, it does not provide clear ownership information and therefore it is not clear whether the Chinese government is the sole owner of shares or voting rights. <\/p>\n"},{"question":112,"commitment_area":16,"score":"0","comments":"
The company publishes some information on its areas of business activity and services. However, the company receives a score of \u20180\u2019 because it does not publish clear details of its commercial or public policy objectives and there is no evidence that this information is updated on an annual basis.<\/p>\n"},{"question":113,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company makes any information about its board members or the nomination and appointment process publicly available.<\/p>\n"},{"question":114,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company has an audit committee that is composed of a majority of independent directors.<\/p>\n"},{"question":115,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company publishes any information about its management of asset transactions.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/500","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=500"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=500"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}