There is evidence that 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. There is evidence that this commitment is authorised and endorsed by the company's senior leadership, through a direct statement from the Chief Executive Officer.<\/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 specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. It is clear that this policy applies to all employees and board members, including non-executive directors, as well as to the staff and leadership of subsidiaries and other controlled entities.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that two board level committees provide oversight of the company\u2019s anti-corruption programme: the Business Ethics and Compliance Committee, consisting of senior executives, and the Audit Committee, composed of members of the board. There is also evidence that the Audit Committee engages in formal oversight activities, including reviewing reports from management on the programme\u2019s performance, and that it has the authority to require that any necessary changes to the programme are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that the company\u2019s General Counsel, a senior executive, has ultimate responsibility for implementing and managing its anti-bribery and corruption programme. The company states that the General Counsel has a direct reporting line to the board, and there is evidence of reporting and feedback activities between the General Counsel 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 its anti-corruption and bribery programme. The company indicates that risk assessments are conducted and reviewed by the board-level Audit Committee on an annual basis. In addition, there is evidence that the results of such reviews are used to develop tailored mitigation plans and to update specific parts of the company\u2019s anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
There is evidence that the company\u2019s anti-bribery and corruption programme is subject to regular review, and that the results of audits and reviews are presented at board level. There is further evidence that the Business Ethics & Compliance Committee holds responsibility for implementing suggested improvements to the company\u2019s programme resulting from audits and reviews, with oversight of the company\u2019s board. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that its entire programme is audited or reviewed at least every two years. <\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
There is evidence that the company publicly commits to investigating incidents promptly, independently and objectively. There is evidence that the company takes steps to ensure the independence of the teams carrying out investigations, and the company commits to put in place remediation plans and report investigative findings to senior management and the board. For whistleblowing cases, there is a procedure in place that stipulates documentation and actions to be taken at every step of the case, from receipt to final outcome. There is also evidence that the company commits to ensure whistleblowers are informed of the outcome. <\/p>\n
In addition, the company indicates that a senior committee \u2013 Ethics & Compliance Working Group \u2013 receives and reviews summary information on investigations and regularly reports key findings to senior management. There is also evidence that the Group Executive receives monthly reports on ethics and compliance related issues. <\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
There is evidence that the company takes steps to assure itself of the quality of its internal investigations, including those reported through whistleblowing channels. The company indicates that staff tasked with conducting investigations are properly qualified and trained to perform the function. There is evidence that the company reviews its investigations procedure annually.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it has a procedure in place to handle complaints about the investigation process or to escalate such complaints to senior management for review if necessary. <\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
There is evidence that the company commits to report material findings of bribery and corruption from investigations to the board and to senior management. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its investigative procedure includes a commitment to report material findings from internal investigations to the relevant authorities if necessary, nor is there evidence that a senior individual responsible for ensuring that such disclosures are evaluated and acted upon.<\/p>\n"},{"question":63,"commitment_area":8,"score":"2","comments":"
There is evidence that the company publishes high-level data from ethical incidents and investigations involving company employees at all levels. This includes the number of investigations launched and the number of disciplinary actions taken as a result of investigation findings. The number of investigations launched is understood to reflect the number of reports received. There is evidence that this data is published and updated on an annual basis. <\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides training for its employees that outlines the principles of the anti-bribery and corruption policy and code of conduct, which include whistleblowing options available. The company states that all employees must undertake this anti-corruption training, along with a refresher course on an annual basis. The company states that it offers training in all necessary languages and there is evidence that the company delivers this training online, which is understood to indicate that it is available to all employees across the company\u2019s operations.<\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company provides tailored anti-bribery and corruption training to employees in different positions based on their role and exposure to corruption risk. There is evidence that the company provides tailored training to employees in high risk positions and to board members, who must undertake this training on an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that it provides tailored anti-corruption training to employees in middle management positions. There is also no evidence that those in high risk positions are required to refresh their training on this subject on an annual basis. <\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company measures and reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme. There is evidence that the company does this through monitoring training completion rates on an annual basis.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that the company takes additional steps to measure the effectiveness of its initiatives, for example by conducting staff surveys, audits or undertaking face-to-face conversations. There is also no clear evidence that such reviews are used to update and enhance specific elements of the company\u2019s anti-bribery and corruption training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
There is evidence that the company\u2019s incentive schemes for employees incorporate ethical and anti-bribery and corruption principles. The company indicates that its annual employee performance reviews are designed to recognise employees that demonstrate ethical behaviours by promoting a focus on \u2018how\u2019 they achieved their objectives, in addition to the objectives themselves. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence to indicate that certain restrictions on incentives are applied to employees in high risk roles, such as ensuring that financial rewards are proportionate to the employee\u2019s salary. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is some evidence that the company encourages and supports employees who choose to act ethically or speak out against unethical conduct. <\/p>\n
However, there is no evidence that the company clearly commits to support and protect employees who choose to act ethically, when doing so may result in a loss of business. There is also 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 has a clearly stated policy of non-retaliation against whistleblowers and those who report ethics and corruption-related concerns. There is evidence that this commitment extends to employees of third parties engaged by company, including suppliers and joint venture partners.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it assures itself of its employees\u2019 confidence in its non-retaliation 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 multiple channels for its employees to report instances of suspected corrupt activity and seek advice on its anti-bribery and corruption programme. There is evidence that these channels are sufficiently varied to allow employees to raise concerns across the management chain and to an external party through an independently-operated hotline. The company\u2019s channels also allow for confidential and, wherever possible, anonymous reporting. <\/p>\n
In addition, there is evidence that the company\u2019s reporting channels are available in all relevant languages and are available and accessible to all employees in all jurisdictions where the company operates, including to those employed by the group as third parties, suppliers and joint venture partners.<\/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 there is evidence that it has policies and procedures in place that define conflicts of interest, including those actual, potential and perceived. There is evidence that the company\u2019s policy specifically addresses possible conflicts arising from personal relationships, outside employment and financial investments. The company states that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it addresses possible conflicts of interest relating to government relationships.<\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has procedures in place 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 there is no 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. In addition, there is no evidence that a specific body or individual has oversight and accountability for handling cases, nor that the company provides examples of criteria for recusals or state that disciplinary measures will apply if breached. <\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is 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 its policy includes specific controls to assess and regulate the employment of current or former public officials, beyond a commitment to take legal advice in order to ensure that it is compliant with laws. There is some indication that the company has a policy on Hiring Current and Former USG Employees, but this does not appear to be publicly available.<\/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":"
Based on publicly available information, there is evidence that the company has a policy on corporate political contributions. The company publishes a clear statement that the use of corporate funds or facilities for the benefit of political parties or candidates is prohibited in all jurisdictions. There is evidence that the company is associated with a Political Action Committee (PAC) in the United States.<\/p>\n
Since the company does not prohibit political donations and is associated with a PAC, it receives a score of \u20180\u2019 in line with the scoring criteria. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
The company publishes a clear statement that it does not make corporate political contributions of any kind. However, there is no evidence that the company publishes details of the contributions made by its Political Action Committee (PAC), nor a link to its official disclosures in the United States, and therefore it receives a score of \u20180\u2019.<\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy on charitable donations, which stipulates criteria for donations and requirements for senior sign off on all donations. In addition, the company publishes a total figure of its donations made in the most recently reported financial year. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company publishes full details of all charitable donations made, for example the recipient, amount and country of recipient for each donation. There is evidence that the company has a separate Community Involvement Policy which may contain more information, however this does not appear to be publicly available. <\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company recognises the corruption risks inherent in lobbying activities. The company provides a definition of responsible lobbying and describes certain standards of conduct expected of both internal and external lobbyists. There is evidence that the company has a policy on lobbying with controls and oversight mechanisms for lobbying activities, including due diligence on lobbyists, proportionate payment scales and senior compliance officer sign off on their activities. There is evidence that that this policy applies to contracted third parties and external lobbyists.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it has policies and controls in place for in-house employees and directors that might be involved in lobbying activities; the company\u2019s publicly available information relates specifically to third party lobbyists or intermediaries. In addition, it is not clear whether the company\u2019s procedures apply solely in the United States or to lobbying activities worldwide. <\/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 publishes any information on 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, which stipulates clear procedures designed to ensure that such promotional expenses are not used for bribery. This policy establishes financial limits, along with an approval procedure, for different types of promotional expense that employees may encounter. In addition, there is evidence that the company\u2019s policy addresses the risks associated with gifts and hospitality given to or received from domestic and foreign public officials. The company's policy includes a clear statement that all gifts and hospitality above certain thresholds are recorded in a dedicated central register.<\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is evidence that the company\u2019s procurement department is involved in the establishment and oversight of supplier relationships. It is clear that the procurement team is the main body responsible for oversight of the company\u2019s supplier base. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it assures itself of the procurement department\u2019s appropriate involvement in this process at least every three years. <\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
There is evidence that the company has formal procedures in place to conduct due diligence on its supply chain. The company states that this process is undertaken on an annual basis and regularly throughout the duration of the commercial relationship. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that this due diligence includes checks on ultimate beneficial ownership, nor that highest risk suppliers are subject to enhanced due diligence. There is also no clear evidence that the company might be willing to not engage or to terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.<\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
There is evidence that the company takes steps to ensure that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company states that, in addition to adhering to its Supplier Code of Conduct, suppliers are also contractually required to follow its Anti-Corruption Policy, which prohibits bribery, facilitation payments, payments to government officials, and contains guidance regarding gifts and hospitality. <\/p>\n
In addition, the company indicates that suppliers must have in place policies that reflect standards in its Code of Business Conduct, which contains provisions for conflicts of interest and whistleblowing. There is evidence to suggest that the company assesses suppliers\u2019 policies prior to engaging with them and that it repeats this assurance periodically throughout the business relationship. <\/p>\n"},{"question":85,"commitment_area":12,"score":"1","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. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide any further information on how it ensures this in practice, for example through contractual requirements or the provision of training.<\/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 incidents, investigations or disciplinary actions relating to its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has a clear policy and procedure to control the use of agents, which addresses the corruption risks associated with their use 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. 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 in place to conduct risk-based anti-bribery and corruption due diligence on its third parties and agents. There is some evidence that some agents require senior review and sign off based on an assessment of their risk and any red flags identified, which is understood to include an enhanced due diligence process. In addition, there is evidence that this due diligence is conducted at the start of the agreement and on an ongoing basis throughout the contractual relationship. <\/p>\n"},{"question":90,"commitment_area":13,"score":"1","comments":"
There is clear evidence that the company has procedures in place to verify and conduct checks on the ultimate beneficial ownership of its agents and third parties. The company indicates that such checks are conducted at the start of the agreement and on an ongoing basis throughout the contractual relationship. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that it is willing to terminate an existing agreement or not engage an agent in instances where ultimate beneficial ownership cannot be established. <\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
There is evidence that the company\u2019s Code of Business Conduct applies to all agents and intermediaries acting for or on behalf of the company. The company indicates that all agents are subject to anti-bribery and corruption clauses in their contracts, which include 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 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. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no further evidence that the company commits to paying agents in staged payments over the course of their contract, based on clear milestones, 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 and\/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 disciplinary actions involving agents.<\/p>\n"},{"question":100,"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 on all of its joint venture partnerships, and that this process includes checks on ultimate beneficial ownership. The company also indicates that joint venture partners identified as higher risk are subject to enhanced due diligence and sign-off procedures. In addition, the company indicates that such checks are conducted at the start of the agreement and on an ongoing basis throughout the contractual relationship.<\/p>\n"},{"question":101,"commitment_area":13,"score":"2","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 anti-bribery and corruption programme and by assisting in its implementation with the partner company. The company indicates that it will only enter into joint ventures if anti-bribery and corruption clauses are included in the contract, at minimum prohibiting foreign and domestic bribery and facilitation payments, as well as specifying clear audit and termination rights to detect, control and prevent breaches. <\/p>\n"},{"question":102,"commitment_area":13,"score":"2","comments":"
There is evidence that the company takes an active role in preventing bribery and corruption in all of its joint ventures. There is clear evidence to support the company's commitment, through practical examples of controls that it implements. <\/p>\n"},{"question":103,"commitment_area":14,"score":"1","comments":"
There is evidence that the company recognises the corruption risks associated with offset contracting. There is further evidence that the company has a dedicated team charged with managing its offset obligations, and that this team is responsible for monitoring these activities throughout the lifecycle of each project.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that those responsible for monitoring its offset activities receive tailored anti-corruption training. <\/p>\n"},{"question":104,"commitment_area":14,"score":"2","comments":"
There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset partners, which it conducts at the start of the agreement and repeats on a continuous basis throughout the lifecycle of the project. There is evidence that this process includes checks on beneficial ownership and that the company takes steps to assure itself of the legitimacy of the investment. The also company indicates that its due diligence process includes checks on key personnel; although the company does not explicitly state that this includes checks on conflicts of interest, the company provides sufficient detail on the process to receive a score of \u20182\u2019. <\/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, whether direct or indirect. <\/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 dedicated assessment process in place to assess such risks. In addition, there is evidence that the results of risk assessments have an impact on business decisions or trigger the implementation of additional controls as part of the annual Cobham Ethics & Compliance Programme Plan (CECP).<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a list of its fully consolidated subsidiaries and non-fully consolidated holdings, including associates, joint ventures and all other related entities. For each entity, the company discloses its percentage ownership and the country of incorporation. There is evidence that this list is current and updated on at least an annual basis 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, the company receives a score of \u20181\u2019 because there is no evidence that it publishes the country or countries of operation for each entity. <\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
There is evidence that the company discloses all beneficial owners with an ownership stake or voting rights of 25% or above. The company\u2019s disclosure refers to all individuals and entities by name. There is evidence that this information is available in a freely accessible national corporate register. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its beneficial ownership is available in open data format that is machine readable and structured. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
The company publishes some information on its defence sales by customer, to indicate that the United States accounts for 38% of its defence and security sector revenue in the most recently reported financial year. The company indicates that a further 26% of its revenue is generated from defence and security sales to the United Kingdom and rest of the world. <\/p>\n
The company receives a score of \u20181\u2019 because it does not provide further information on the major customers that account for at least 50% of its defence and security revenue. The company provides some information on its overall revenue by geographic region, but this does not indicate specific countries\/customers nor does it show defence sales specifically. <\/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\/501","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=501"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=501"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}