There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which is reflected in its Code of Conduct. This is endorsed by the company's leadership in the form of an introductory message from the Chairman and Chief Executive Officer. However, the company receives a score of \u20181\u2019 because this message does not explicitly mention anti-corruption or bribery. <\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company publishes an anti-bribery and corruption policy, which makes explicit reference to the prohibition of bribery, payments to public officials and commercial bribery. This policy clearly applies to all employees and board members as described in (a) and (b) in the question. However, the company receives a score of \u20181\u2019 because there policy does not make specific reference to facilitation payments. <\/p>\n"},{"question":56,"commitment_area":7,"score":"0","comments":"
There is no evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme. The company has a Committee on Directors and Governance but there is no publicly available evidence that specifically states that this committee\u2019s responsibilities include oversight of the anti-bribery and corruption programme. <\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
There is no evidence that a specific executive or 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":"0","comments":"
There is evidence that the company has a risk assessment procedure in place that informs its decisions and the design of the company\u2019s programmes. However, there is no publicly available evidence that this risk assessment procedure informs the design of the company\u2019s anti-corruption and bribery programme. Publicly available documents refer to \u2018compliance\u2019 generally and seem to focus on financial risk rather than anti-bribery and corruption risks.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is evidence that the company organises internal audits to ensure full compliance with all relevant laws, regulations and internal policies. The company also states that the Code of Conduct for Directors is reviewed on an annual basis. However, it is not clear from publicly available evidence that the anti-bribery and corruption programme itself is subject to audit or review, or whether 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 allegations and incidents promptly and objectively. There is evidence that the company has specific procedures in place to involve the Legal Department and any other relevant business units in investigations. In addition, there is evidence that the company takes steps to ensure the independence of investigations through the use of an externally-operated hotline; however there is no evidence of how the company ensures this when evaluating reports internally. <\/p>\n
The company receives a score of \u20181\u2019 because it does not provide further details of its investigative procedure \u2013 both for reports received through the whistleblowing hotline and those reported directly \u2013 and does not stipulate documentation of cases beyond recording allegations through the hotline. There is also no evidence that the company commits to ensure whistleblowers are informed of the outcome, if they so wish. Furthermore, there is no evidence that summary information is reviewed by a central body at least on an annual basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is some evidence that the company takes steps to ensure the quality of its internal investigations, including those reported through whistleblowing channels. The company states that representatives from the Legal Department are responsible for receiving internal reports and that EthicsPoint representatives who receive allegations through the third-party hotline are properly trained. <\/p>\n
However, the company receives a score of \u20180\u2019 because there is no evidence that it has procedures in place to receive, handle and escalate, if necessary, complaints about the investigation process. There is also evidence that individuals outside the Legal Department that might be involved in investigations and properly trained, nor is there 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":"0","comments":"
There is no clear evidence that the company commits to report material findings of bribery or corruption from investigations to the Board of Directors and, if necessary, to the relevant authorities. The company states that Directors must report any violations to the Chairman of the board-level Committee on Directors and Governance, however it is not clear that this applies to employees at other levels involved in handling investigations. The company also states that violations may be reported to government authorities, but there is no evidence that a specific senior individual has responsibility for ensuring this disclosure.<\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company publishes data on ethical or bribery and corruption-related investigations or disciplinary actions.<\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides training to its employees on the Code of Conduct, which includes the company\u2019s anti-bribery and corruption policy and the whistleblowing options available to employees. The company states that this training is provided on an annual basis to all employees across the organisation. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that training is provided to all employees across all divisions and regions of operation or in all appropriate languages. Although the company states that the Code of Conduct is available to employees in all divisions and regions, it is not clear from publicly available evidence that this applies to training. <\/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. Although the company provides a dedicated Code of Conduct for board members, this document does not mention a requirement to undergo training on anti-bribery and corruption. <\/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.<\/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 commits to support or protect employees who refuse to act unethically. The company states its intention to create an ethical workplace but does not provide sufficiently clear evidence that it will support and protect those who refuse to act unethically, even where it might result in a disadvantage or loss of business.<\/p>\n"},{"question":69,"commitment_area":9,"score":"0","comments":"
There is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is evidence that this policy applies to employees and representatives associated with the company, which is understood to include third parties and those employed by joint ventures. <\/p>\n
However, the company receives a score of \u20180\u2019 because it is not clear whether this Code applies to those engaged by the group as suppliers, and there is no mention of non-retaliation in the Code of Conduct for Suppliers and Customers. There is also 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 an independent third party, through an externally-operated hotline. These channels allow for confidential and, wherever possible, anonymous reporting. There is evidence that the EthicsPoint hotline is available to all employees in all jurisdictions \u2013 including those employed by the group as third parties, suppliers and joint venture partners \u2013 and in all relevant languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence that the company formally addresses conflict of interest as a corruption risk, and that it has a policy that defines conflicts of interest, including actual, potential and perceived conflicts. The policy explicitly covers all the categories of possible conflicts listed in the question guidance. The company states that this policy applies to all employees and board members, including those of subsidiaries. <\/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. The company\u2019s Code of Conduct describes potential punitive measures for breaches of the Code as a whole, which includes its policy on conflicts of interest. <\/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 and the policy does not provide examples of criteria for recusals.<\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy that addresses and acknowledges the risks associated with the employment of public officials. However, the company receives a score of \u20181\u2019 because this policy does not include specific controls to assess and regulate the potential risks associated with 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 generally prohibits corporate political contributions, however it does state that contributions may be permissible in certain circumstances, such as in support of local initiatives or referendums, providing that proper authorisation is given from individuals with legal expertise in the company. There is publicly available evidence that the company is associated with a Political Action Committee (PAC), however the company does not publish information about the PAC on its website. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company discloses details of any political contributions made, including those made under the exceptional circumstances described in its policy or those made by the Political Action Committee (PAC) with which the company is associated. <\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy that covers charitable donations or sponsorships. Based on publicly available information, the company does support charities and engage in sponsorships, however it is unclear whether there is a policy or procedure in place to ensure that such donations are not used as vehicles for bribery and corruption. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy on lobbying. In its Code of Conduct, the company states that its lobbying activities are governed by federal and state legislation and are overseen by the Office of the General Counsel, however it does not provide any further details of specific values, behaviours and controls that constitute \u2018responsible\u2019 lobbying. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes 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 details about its lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, which outlines and places financial limits on the different types of promotional expense that employees may encounter. The company\u2019s policy specifically recognises the risks associated with gifts and hospitality given to public officials in the U.S. and it is clear that this applies to all employees. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that the company recognises the risks and has specific controls in place to cover promotional expenses given to or received from foreign public officials. There is also no evidence that all gifts and hospitality above a certain threshold are recorded in a central register that is accessible to those responsible for oversight of the process. The company appears to have a dedicated Gifts and Entertainment Policy, but this document is not publicly accessible. <\/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 no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain.<\/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. According to publicly available evidence, the company does this by requiring that its suppliers adopt its Code of Conduct for Suppliers and Customers, which specifically prohibits foreign and domestic bribery, gifts and conflicts of interest. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that suppliers must have policies in place to prohibit facilitation payments or have systems in place to allow for whistleblowing. Furthermore, it is not clear how the company ensures these standards in practice or when this process is conducted throughout 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":"0","comments":"
There is no evidence that the company publishes any data on ethical or anti-bribery and corruption-related investigations involving its suppliers, or the associated disciplinary actions.<\/p>\n"},{"question":87,"commitment_area":13,"score":"1","comments":"
The company has a policy covering the use of agents and addresses some of the corruption risks associated with the use of agents (referred to as \u2018representatives\u2019). There is evidence that this policy applies to all businesses within the organisation which might employ agents, including subsidiaries and joint ventures. However, the company receives a score of \u20181\u2019 because there is no evidence that the company commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. <\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company states that it 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.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is evidence that the company\u2019s Code of Conduct \u2013 which includes its anti-bribery and corruption policy \u2013 applies to agents and intermediaries. However, there is no evidence that agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts which include audit and termination rights to detect, control and prevent breaches.<\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company addresses incentive structures as a risk factor in agent behaviour, nor that incentive structures for agents are designed to minimise risks of anti-bribery and corruption.<\/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":"
There is evidence that the company\u2019s Code of Conduct \u2013 which includes its anti-bribery and corruption policy \u2013 applies to all businesses and representatives, which is understood to include joint venture partnerships. However, there is no publicly available evidence to indicate that the company requires anti-bribery and corruption clauses in its contracts with joint venture partners, including audit and termination rights.<\/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 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.<\/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":"
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 evidence that the company acknowledges the corruption risks of operating in different markets, nor that risk assessment procedures are used to inform the company\u2019s operations in high risk markets.<\/p>\n"},{"question":108,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes a list of subsidiaries or affiliated entities.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is a publicly listed company on the New York Stock Exchange and is therefore not required to disclose information about its beneficial ownership. The company is automatically awarded a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is evidence that the company publishes the total value and percentage breakdown of sales by business segment, with reference to defence sales. The company also publishes that 34% of its net sales were derived from the U.S. Government. However, the company receives a score of \u20180\u2019 because it does not indicate the percentage breakdown of customers for the defence business segment specifically. <\/p>\n"},{"question":111,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":112,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":113,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":114,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":115,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/503","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=503"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=503"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}