There is evidence that the company\u2019s CEO makes a public statement in support of the company\u2019s ethics programme and promotes a commitment to \u2018transparent business practice\u2019 and \u2018high ethical standards\u2019. <\/p>\n
However, the company receives a score of \u20181\u2019 because the CEO\u2019s public statement does not explicitly address or promote the company\u2019s stance against bribery and corruption. There is evidence that in 2015 the company\u2019s leadership explicitly endorsed its commitment to anti-bribery and corruption, however there is no evidence of a more recent statement to reaffirm this position. <\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company publishes an anti-bribery and corruption policy, and that this policy applies to all employees and board members as described in (a) and (b) above. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its publicly available policy extends beyond a general commitment to comply with anti-bribery laws. There is no evidence that the company specifically addresses and prohibits payments to public officials, commercial bribery or facilitation payments. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s Audit Committee is ultimately responsible for the oversight of its anti-corruption programme. There is evidence that this includes reviewing reports from management on investigations and the performance of the company\u2019s ethics programme.<\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
Based on publicly available information, there is evidence that a managerial-level individual, the Head of Corporate Auditing & Consulting Division, has ultimate responsibility for managing the company's anti-corruption programme. There is evidence that this individual has a direct reporting line to the Audit Committee and there is evidence of feedback activities between this person and the Audit Committee as part of the company\u2019s reporting structure.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the individual heading the Corporate Auditing & Consulting Division is a senior executive. It is also noted that, based on publicly available information, there is evidence that the development of ethics training and policies appears to fall under the remit of a different department: Compliance & Legal Support.<\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has a formal risk assessment procedure that informs the design of its ethics programme.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is limited publicly available information concerning this procedure. There is also no clear evidence that risk assessments are reviewed on at least an annual basis at board level.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is some evidence indicating that the company\u2019s ethics programme is subject to continuous review by the internal audit department. However, there is evidence that this department is also responsible for implementing the programme and it is unclear based on publicly available evidence whether there is a separate, independent review of the programme. There is also no clear evidence that the findings of audits are used to update the company\u2019s anti-bribery and corruption programme.<\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company publicly commits to investigating incidents and that there is a specific procedure in place to deal with whistleblowing cases which stipulates actions to be taken and documented at each step. There is evidence that investigations are carried out by an independent team and reported to the Audit Committee. The company\u2019s stated procedure covers the whole investigation process from receipt to final outcome. There is further evidence that the company informs whistleblowers of the outcome of investigations.<\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company assures itself of the quality of its internal investigations. The company states that its internal audit department, which carries out investigations, takes steps to ensure that investigators are sufficiently trained and qualified to perform investigations. <\/p>\n
However, there is no clear evidence that the company assures itself of the quality of both incident investigations and whistleblowing cases. In publicly available information, there is no evidence of how complaints about the investigation process are handled. There is also 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":"
Based on publicly available information, there is evidence that the company commits to report material findings of bribery and corruption investigations to the board and external authorities. However, there is no evidence that the company has an appropriate senior individual who is responsible for ensuring the disclosure of criminal offences to the 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 the disciplinary actions involving its employees.<\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company systematically provides training to its employees, outlining its anti-corruption policy and the whistleblowing options available to them. The training is provided to all employees. The company states that employees at different levels receive some version of ethics training on a monthly and quarterly basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence to indicate that all employees are required to undertake and refresh their training on anti-bribery and corruption at least every three years. The company indicates that some employees may be required to refresh their training on ethics, but it is not clear which employees this includes nor which the topics that might be covered. There is also no clear evidence that the company provides training in all appropriate languages for employees of subsidiaries or offices in other countries. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is some evidence that certain employees in certain positions receive different or tailored anti-bribery and corruption training. The company makes reference to employees in high risk positions and management employees. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that board members receive tailored training. The company also does not specify whether training for employees in high risk positions is refreshed on at least an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company reviews its anti-bribery and corruption communications and training programme. Although the company states that it hosts an ethics conference to obtain employee feedback, it is not clear whether this includes a review of its anti-bribery and corruption communications and training activities. <\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
Based on publicly available evidence, there is some evidence that the company\u2019s incentive schemes for employees incorporate ethical and anti-bribery and corruption principles. There is evidence indicating that performance evaluations take account of compliance with the company\u2019s ethics policies. <\/p>\n
However, the company provides limited public information on how it incentivises ethical conduct. There is also no evidence that financial incentives must be proportionate to the employee\u2019s base salary in the case of high-risk roles, such as sales. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, 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":"
Based on publicly available information, there is evidence that the company has a policy of non-retaliation against whistleblowers who report bribery and corruption incidents. There is evidence indicating that this policy applies to both employees of the company and those outside of the company. <\/p>\n
However, 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":"1","comments":"
Based on publicly available information, there is evidence that the company has whistleblowing and advice channels that allow anonymous reporting and are accessible to all employees. There is also evidence that the whistleblowing channel is accessible to external parties and is available in multiple languages. <\/p>\n
However, the evidence indicates that the company only offers internally operated whistleblowing channels and does not provide any external channels operated by an independent third party. There is also no clear evidence to indicate that the available channels allow for confidential reporting, nor that they are available to the employees of suppliers and joint venture partners. <\/p>\n"},{"question":71,"commitment_area":10,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company has a policy to define and address conflicts of interest. There is some evidence that the company acknowledges some risks related to employee relationships and outside employment; however, this information is not sufficiently detailed to satisfy the requirements of score \u20181\u2019.<\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that 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 publicly available 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":"0","comments":"
Based on publicly available information, there is no evidence that the company has a policy covering corporate political contributions. The company states that employees may engage in the political process privately but does not provide further information on its approach to corporate political contributions.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes details of its political contributions.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
The company publishes some details of its charitable donations and sponsorships. However, based on publicly available information, there is no evidence it has clear policies or procedures in place to ensure donations are not used as vehicles for bribery and corruption, for example, by specifying criteria for donations, procedures for senior sign-off, or due diligence on recipients.<\/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 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 details about its global lobbying expenditure. <\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. The policy specifies financial limits for different types of promotional expenses.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that the company acknowledges the risks associated with giving or receiving gifts from public officials. 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":"1","comments":"
There is publicly available evidence that the company's procurement department is involved, in some capacity, in the establishment of supplier relationships. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the procurement department is the main body responsible for oversight of the company\u2019s supplier base. There is also no evidence that the company assures itself of the procurement department\u2019s involvement at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company conducts due diligence on its suppliers, which includes a review of corruption risks. There is also some evidence indicating that the company might be willing to review and\/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.<\/p>\n
However, there is no evidence that the due diligence process includes checks on ultimate beneficial ownership, nor that the highest risk suppliers are subject to enhanced due diligence. There is also no clear evidence that due diligence is repeated at least every two years or whenever there is a change in the business relationship.<\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company requires its suppliers to abide by anti-bribery and corruption contractual terms. The company states that its suppliers are prohibited from engaging in bribery and making facilitation payments, as well as referring to conflicts of interest, gifts and hospitality and whistleblowing provisions in its commitments to suppliers.<\/p>\n
However, there is no 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, either when onboarding new suppliers or when there is a significant change in the business relationship. While it refers to ethical practice evaluations, it is not clear from publicly available materials what this process entails. <\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
Based on publicly available information, there is no clear 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, bribery or corruption-related investigations or associated disciplinary actions relating to its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has a policy covering the use of agents, which stipulates certain measures and controls to mitigate the corruption risks associated with their use. <\/p>\n
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. The company furthermore does not specify that this policy also applies to subsidiaries and joint ventures. <\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has procedures to conduct due diligence prior to engaging with its business partners, the definition of which includes agents. There is some evidence indicating the company would not engage with an agent when the risks identified in due diligence can not be mitigated.<\/p>\n
However, there is no evidence that agents and the highest risk intermediaries are subject to enhanced due diligence, nor that the company repeats due diligence at least every two years and\/or when there is a significant change in the business relationship. <\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is some evidence that that all third party and agents are subject to the company\u2019s ethics policies. The company indicates that these standards are ensured through anti-corruption clauses in contractual agreements, which include termination rights. However, there is no evidence that the company explicitly includes audit rights in its contracts with these entities and therefore the company receives a score of \u20180\u2019.<\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company addresses 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 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 associated disciplinary actions involving agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering and while operating in joint ventures. The company does not refer to joint ventures in its definition of business partners of the company.<\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures. The company does not refer to joint ventures in its definition of business partners of the company.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence to indicate 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 publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no publicly available 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 contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no publicly available evidence to indicate that the company acknowledges the corruption risks of operating in different markets.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes some information about its subsidiaries and joint ventures. There is evidence that this information is updated on an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that this list includes all of the company\u2019s holdings. The company\u2019s publicy available information also does not indicate the percentages owned, country of incorporation or countries of operation for each entity.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company publishes information about its beneficial ownership in corporate reporting documents and in a freely accessible public register. In each case, identifiable information about the company\u2019s significant shareholders is made publicly available. <\/p>\n
The company is also publicly traded on the Korea Stock Exchange, though it is noted that this is not on the list of regulated markets mentioned in the scoring criteria. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
The company publishes a percentage breakdown of its sales by product type and also discloses a number of its clients in the defence sector. However, the company does not provide a percentage breakdown to indicate at least 50% of its defence sales by customer.<\/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\/504","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=504"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=504"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}