The company\u2019s Code of Business Conduct outlines its commitment to anti-bribery and corruption, however, the statement endorsed by the company\u2019s leadership makes only a general commitment to integrity and high ethical standards. <\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company sets out an anti-bribery and corruption policy in its Code of Business Conduct which includes a prohibition on bribery, payments to public officials, commercial bribery and facilitation payments. The Code of Business Conduct applies to all employees. <\/p>\n
However, it is not clear that the policy applies to all board members, including non-executive directors. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated board committee, the Ethics and Corporate Responsibility Committee, is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. Although the Ethics and Corporate Responsibility Committee Charter does not explicitly mention oversight of anti-bribery and corruption, its remit includes reviewing compliance with the company\u2019s Code of Conduct, which sets out its anti-bribery and corruption policy. This committee receives reports from the Chief Ethics and Compliance Officer and\/or General Counsel and makes recommendations to the board regarding the enhancement of the company\u2019s policies and activities. The company\u2019s Audit and Compliance Committee is responsible for reviewing the results of internal and external audits.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior executive has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. They oversee the implementation of the Code of Conduct and measures relating to the anti-corruption programme. There is evidence that they provide regular reporting to the Ethics and Corporate Responsibility Committee on the effectiveness of the company\u2019s anti-corruption programme. <\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company\u2019s anti-bribery and corruption programme is designed and adapted based on an assessment of risk. Although there is evidence that the company has a broader Enterprise Risk Management process, details about this as it relates to the anti-bribery and corruption programme is insufficient to merit a score of \u20181\u2019. <\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company\u2019s anti-bribery and corruption programme is subject to audit or review, and the company does not clearly state how frequently audits are conducted or whether the findings are used to update the 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, which stipulates documentation and actions to be taken at each step. Information on whistleblower reports is held by EthicsPoint, the operator of the company\u2019s external whistleblower channel. Whistleblower reports are made available to the Ethics and Corporate Compliance Group, as well as appropriate members of the company\u2019s management. The company commits to providing whistleblowers with updates on the outcome of investigations where legal. The Chief Ethics and Compliance Officer provides summary information on reports received to the Ethics and Corporate Responsibility Committee. <\/p>\n
However, it is not clear how frequently the committee reviews this summary information or whether it is on a regular basis. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company assures itself of the quality of its investigations. Although the company indicates that individuals receiving reports receive some training regarding the confidentiality of the investigations, there is nothing to suggest that they are otherwise trained or qualified. Furthermore, there is no evidence that the company has a system in place for handling complaints about investigations themselves, or whether an appropriate senior individual would be responsible for oversight of such a process. Finally, there is no evidence that the company reviews its investigations procedure at least every three years, or in response to any changes in the regulatory environment. <\/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 level Ethics and Corporate Responsibility Committee and the Audit and Compliance Committee. <\/p>\n
However, 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":"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 it is unclear how frequently training is conducted and whether training is provided in all appropriate languages. <\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
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. The Code of Business Conduct indicates that employees interacting with customers receive training on the company\u2019s ethical standards. However, it is not clear that this is tailored to employees in high risk positions, nor how frequently this is conducted. There is also no evidence of tailored training for middle management or board members. <\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme. The company does not provide information on any data it collects on its communications and personnel training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company\u2019s incentive schemes 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 makes an explicit commitment to protect employees who refuse to act unethically, even when it might result in a loss of business. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is evidence that the company, in its Code of Conduct, promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. The Code of Conduct 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 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, and in all relevant languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a clear policy that defines conflicts of interest, including actual, potential and perceived conflicts. The policy explicitly covers employee relationships, government relationships, financial interests and other employment. The policy applies to all employees of the company. <\/p>\n
However, it is not clear whether this policy applies to board members. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is evidence that the company requires employees to disclose potential conflicts of interest to their manager, Human Resources, Corporate Compliance or the Law Department. There is also some evidence that employees may make disclosures on the company website. Any violation of the Code of Business Conduct can result in various forms of disciplinary action for employees. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no reference to a specific body or individual with oversight and accountability for handling cases and it is not stated whether declarations are held in a dedicated register or central depository which is accessible to those responsible for oversight of the process. The company also 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, or that the company addresses the corruption risks associated with the employment of 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 to follow all relevant local laws regarding political contributions in different jurisdictions. In addition, there is evidence that the company has a political action committee, and therefore receives a score of \u20180\u2019.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company discloses details of its political contributions on its website.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is no publicly available information about the company\u2019s policies and procedures for charitable contributions and sponsorships. For instance, the company does not indicate that it has policies and procedures in place which specify criteria for donations, procedures for senior sign-off, or due diligence on recipients. Nor does the company publish full details of all charitable donations made, including details of the recipient, amount, country of recipient and which corporate entity made the payment; this includes donations made, financial or in-kind, to corporate foundations. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy and\/or procedure on lobbying. The company says that it will conduct lobbying in accordance with the law but does not provide further information on its procedures, such as the standards of conduct or specific oversight mechanisms that apply to all types of lobbyists. It also does not provide a definition of lobbying and\/or responsible lobbying.<\/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":"1","comments":"
There is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. This addresses the risks associated with gifts and hospitality given to\/received from domestic or foreign public officials, for which employees must first consult with the company\u2019s legal department. <\/p>\n
However, the policy does not specify financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.<\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company requires the involvement of a centralised procurement department in the establishment and\/or 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 third parties, however the company does not explicitly mention suppliers and does not provide any further details on its due diligence processes. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company states that suppliers which do not already have an existing robust code of conduct must follow theirs, which prohibits bribery and facilitation payments, and covers conflicts of interests and gifts and hospitality. The company\u2019s whistleblowing channel is also open to suppliers. The company assures itself of its suppliers\u2019 compliance with these principles by requiring them to grant the company or an independent auditor access to documentation demonstrating this. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not stated that the company assures itself of this when onboarding new suppliers and\/or when there is a significant change in 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. Suppliers are instructed to advise their contractors to observe the standards outlined in the Code of Conduct for Third Parties. <\/p>\n
However, the company receives a score of \u20181\u2019 because this is a simple 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":"1","comments":"
There is evidence that the company has a policy on the use of agents. It commits to establishing that the use of agents is necessary to perform a legitimate business function. <\/p>\n
However, the company provides little detail on the corruption risks associated with agents and there is no evidence of specific controls to mitigate these risks. It is also not clear whether the Code of Business Conduct applies to agents engaged by joint ventures and subsidiaries. <\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
There is evidence that the company conducts anti-bribery and corruption due diligence on third parties (including consultants, technical advisors and business representatives). <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear whether agents and highest risk intermediaries are subject to enhanced due diligence. It is also not clear if due diligence is repeated at least every two years and\/or whenever there is a significant change in the business relationship. <\/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. The company does not commit 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":"
The company\u2019s Code of Conduct for Third Parties applies in general to all third parties, including agents and the company\u2019s representatives. This code prohibits bribery, facilitation payments, covers conflicts of interests and gifts and hospitality, and states that the company\u2019s whistleblowing channel is also open to third parties. However, the company receives a score of \u20180\u2019 because there is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company's incentive structures for agents are designed to minimise risks of bribery and corruption or that incentive structures are recognised 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 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 prospective joint venture partners based on an assessment of corruption risk.<\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company includes 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. 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 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":"
The company does not publish any details of its offset obligations and\/or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company\u2019s operations in high risk markets. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company, in its annual filing to the Securities and Exchange Commission, provides a list of its subsidiaries. This includes the company\u2019s ownership percentage of the subsidiary and the country of incorporation. <\/p>\n
However, the list is not accompanied by a statement that it is complete at the time of publication to the best of the company\u2019s knowledge; it is consequently not clear whether the list includes all of the company\u2019s holdings. Additionally, the company does not provide information on the subsidiaries\u2019 countries of operation. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is a publicly listed company listed on the New York Stock Exchange (\u2018NYSE\u2019) and therefore automatically receives a score of \u20182\u2019.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes details of its defence sales by customer. The company indicates that for its Cubic Global Defence segment, sales to international customers constituted 52% of its sales. However, the company provides no specific details with regard to these customers, and its assumed domestic sales do not meet the 50% threshold for the company to receive a score of \u20181\u2019. <\/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\/502","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=502"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=502"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}