Based on publicly available information, there is evidence that the company makes a general commitment to responsible business that is endorsed by its Chief Executive Officer. <\/p>\n
However, there is no evidence that this commitment makes direct reference to the company\u2019s stance against bribery and corruption within the organisation, and therefore the company receives a score of \u20180\u2019. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that the company publishes an anti-bribery and corruption policy which specifically prohibits bribery, payments to public officials, commercial bribery and facilitation payments. The policy applies to all employees, including staff and leadership of subsidiaries and other controlled entities.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that a designated board committee, the Audit & Risk Committee is ultimately responsible for the oversight of the company's compliance programme. This includes reviewing reports from management and the results of external audits.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that a designated senior executive has ultimate responsibility for managing the company's compliance programme. It is clear that this person has a direct reporting line to the board and the board committee that provides oversight of the compliance programme. There is evidence of reporting and feedback activities between this person and the board as part of the company\u2019s reporting structure.<\/p>\n
The company would do well to clarify the extent to which the CFO is responsible for implementing and managing the anti-bribery and corruption programme, or whether these responsibilities lie with the Group Compliance Officer. <\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a formal bribery and corruption risk assessment procedure that informs the design of its compliance programme. The risk assessments are conducted at board level and reviewed at least annually or when the results of the risk assessments reveal significant findings. 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":"
Based on publicly available information, there is evidence that the company\u2019s compliance programme is subject to regular review. The company states that external audits are conducted annually, the results of which are reviewed by a board-level committee. <\/p>\n
However, the company does not specify that the entire anti-bribery and corruption programme is audited to ensure that it is consistent with high standards of best practice and the business risks facing the company.<\/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 there is a specific procedure in place to deal with whistleblowing cases, which stipulates documentation and actions to be taken at each step. The company\u2019s policy covers the whole investigation process from receipt to final outcome. There is evidence that investigations are handled by an independent team and that the company commits to providing whistleblowers with updates on the outcome of investigations. There is also evidence that information on each investigation is documented and that summary information is reviewed by a central body on at least an annual basis. <\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company assures itself of the quality of its internal investigations. There is evidence that the company assures itself of the quality of both incident investigations and whistleblowing cases. There is also evidence that staff conducting investigations are properly qualified. <\/p>\n
However, there is no evidence on how complaints about the investigation process are handled or who is responsible for handling such complaints. 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
\nof bribery and corruption from investigations to the board. <\/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":"1","comments":"
Based on publicly available information, there is evidence that the company publishes some high-level information on its ethics and compliance related incidents and investigations involving company employees. <\/p>\n
However, it is not clear the information provided applies to employees at all levels in the company, nor is there evidence that the data provided includes the number of reports received, including those through whistleblowing channels, or the number of investigations launched.<\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company provides a training module that
\noutlines the basic principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees. The evidence suggests that the training is systematically provided to all employees across all divisions and all countries regions of operation.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear how frequently all employees receive training. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company states that employees in certain positions receive tailored anti-bribery and corruption training. The company indicates that employees in high risk positions \u2013 including those who deal with agents, customers and suppliers \u2013 receive training bi-annually. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it provides tailored anti-corruption training to its middle management and board members. <\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company measures the efficacy of its compliance programme via an employee engagement survey. However, it is not clear that the company measures or reviews
\nthe efficacy of its anti-bribery and corruption communications or training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence to indicate that the company's incentive schemes incorporate ethical or anti-bribery and corruption principles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is evidence that the company commits to support and protect employees who refuse to act unethically. <\/p>\n
However, the company does not specify that it will support employees even where such actions result in a loss of business to the company. There is also no evidence it assures itself of employee\u2019s confidence in this. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents that explicitly applies to all employees across the organization, including those employed by the group as third parties, suppliers and joint venture partners. <\/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. The channels are confidential, there are both externally and internally operated channels and both whistleblowing and advice channels. The channels are explicitly available to any employees of third parties, suppliers or joint venture partners. <\/p>\n
However, there is no clear evidence that the company\u2019s channels are available in multiple languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy for conflicts of interest. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that this policy differentiates between actual, potential and perceived conflicts, nor does it cover specific types of conflicts of interest, such as employee relationships, government relationships, financial interests or other employment. Furthermore, there is no evidence that the policy applies to board members. <\/p>\n
It is noted that the company has a policy entitled \u2018Personal & Business Integrity\u2019 which may contain more information on conflicts of interest, but this does not appear to be publicly accessible.<\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
Based on publicly available information, there is some evidence that the company has some procedures in place to manage conflicts of interest. The company indicates that it requires management approval in certain cases. <\/p>\n
However, the company receives a score of \u20180\u2019 because it does not provide further publicly available information on its controls and procedures in place to identify, declare or manage conflicts of interest.<\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence to indicate 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 publicly available evidence to indicate 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 indicates that it does not make any types of political contributions to parties, candidates or institutions. There is evidence that this policy applies across the company. In addition, the company states that it does not make any contributions through employee action committees. <\/p>\n
However, there is some evidence to indicate that the company might make political contributions in certain circumstances, with the approval of the Group Compliance Officer. Since itdoes not fully prohibit political contributions, the company receives a score of \u20180\u2019 in line with the scoring criteria.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any details of its political contributions. Although the company states that it does not make political contributions, there is some evidence to indicate that it may make such donations in certain circumstances.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is some evidence that the company has a policy covering donations and sponsorship. The company indicates that its policy on \u2018Personal and Business Integrity\u2019 contains more information on its approach to charitable donations, but this does not appear to be publicly available. In addition, the company publishes on some of the charitable initiatives that it supports, but there is no evidence that it publishes a comprehensive list of all donations, nor does it publish specific details such as the recipient, amount and country of recipient for each donation. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy or procedure on lobbying. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company publishes any information on its lobbying aims, topics or activities. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company provides 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 addresses the risks associated with gifts and hospitality in relation to public officials. <\/p>\n
However, there is no evidence that the company\u2019s policy includes specific controls to address these risks, such as financial or proportional limits or different approval procedures for different types of promotional expenses. There is 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. There is evidence that the company has a policy on \u2018Personal & Business Integrity\u2019 which may contain more information on gifts and hospitality, but this does not appear to be publicly accessible.<\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence to indicate that the company requires the involvement of its procurement department in the establishment or oversight of its supplier base.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has formal procedures to conduct
\ndue diligence on its suppliers. There is also evidence that highest risk suppliers are subject to enhanced due diligence. Furthermore, there is evidence to suggest that the company might be willing to terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated. <\/p>\n
However, the company indicates that due diligence is only conducted on some third parties and that checks on ultimate beneficial ownership are only performed in some instances on high risk third parties. The frequency of the due diligence is also unclear. <\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. It is explicitly stated that all suppliers must comply with policies that prohibit bribery and facilitation payments, as well as policies and procedures that address conflicts of interest, gifts and hospitality, and whistleblowing. <\/p>\n
In addition, there is evidence that the company takes active steps to ensure this, for example by requiring that all suppliers follow its own anti-bribery principles and by including termination rights in its contracts with suppliers in the event of non-compliance. The company assures itself of this when onboarding new suppliers. <\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is 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 there is no further evidence of how the company does this in practice.<\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence to indicate that the company publishes any data on ethical or anti-bribery and corruption investigations or disciplinary actions involving its suppliers. <\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy covering the use of agents. The company\u2019s policy addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. This policy also applies to subsidiaries and joint ventures. In addition, there is evidence that the company commits to establishing that the use of agents is, in each case, necessary to perform a legitimate business function. <\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging with third parties and agents. It is also clear that agents and highest risk intermediaries are subject to enhanced due diligence. The company commits to not engaging or terminating its engagement with agents or intermediaries where the risks identified in the due diligence cannot be mitigated. <\/p>\n
However, there is no evidence that due diligence is repeated at least every two years or when there is a significant change in the business relationship. The company indicates that it has a \u2018Financial Compliance Policy\u2019 which may contain more information concerning its policy on agents, but this does not appear to be publicly accessible.<\/p>\n"},{"question":90,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company asks of agents to disclose their beneficial ownership to the company as part of its enhanced due diligence processes. <\/p>\n
However, there is no evidence that the company commits to establishing beneficial ownership of all agents or to verify this every two years or when there is a change in the relationship.<\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
There is evidence that the company\u2019s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. All agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include clear audit and termination rights to detect, control and prevent breaches. <\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company indicates that it monitors such entities on an ongoing basis, and that the Compliance Department is responsible for reviewing all invoices before payment. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it imposes a threshold on the payment of sales commissions to agents, nor is there evidence that the company requires that remuneration is made in stage payments or into local bank accounts. <\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company publishes any details of the agents currently contracted to act for or on its behalf. <\/p>\n"},{"question":99,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company publishes some high-level data on ethical or bribery and corruption related investigations involving agents. The company states that no confirmed incidents relating to corruption for all business partners took place in the past year. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that this information includes data on the number of investigations launched. <\/p>\n"},{"question":100,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering a joint venture partnership. There is evidence that this due diligence is conducted for every joint venture partnership and it is clear that the company\u2019s due diligence includes checks on the ultimate beneficial ownership of the partner company. <\/p>\n
However, there is no evidence to suggest that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence. In addition, there is no evidence that the due diligence is repeated at least every two years or when there is a significant change in the business relationship.<\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company states that it accounts for anti-bribery and corruption considerations when entering into a joint venture. The company states that its anti-bribery and corruption policy applies to joint venture partners, and it ensures this through the inclusion of termination rights in its contracts with them. The company states that it will only enter into joint ventures if anti-bribery and corruption clauses are included in the contract. <\/p>\n
However, there is no evidence that the company includes audit rights in its contracts with joint venture partners.<\/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":"
Based on publicly available information, there is some evidence that the company addresses the corruption risks with offset contracting. However, there is no evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities, nor is there evidence that employees involved in managing the company\u2019s offset activities receive tailored anti-corruption training on the potential corruption risks associated with offsets.<\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has formal procedures in place to conduct risk based anti-bribery and corruption due diligence on its offset obligations. The company clearly indicates that this process includes checks on beneficial ownership and that takes steps to verify the business rationale of the relationship or transaction.<\/p>\n
However, there is no evidence that the company refreshes due diligence continuously or when there is a significant change in the business relationship or nature of the partner.<\/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 on its offset obligations or contracts. <\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no publicly available evidence that the company acknowledges the corruption risks of operating in different markets, nor that it has a risk assessment procedure in place to identify such risks.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
Based on publicly available information, there is evidence that the company publishes a list of all of its consolidated subsidiaries and non-fully consolidated holdings. For each entity, the company lists a country which is understood to represent the headquarters and country of incorporation. There is evidence that the list is updated on an annual basis. <\/p>\n
However, there is no evidence that the company\u2019s list includes the percentage of ownership or the country of operation for each entity. <\/p>\n"},{"question":109,"commitment_area":15,"score":"0","comments":"
There is no publicly available evidence that the company publishes any information about its beneficial ownership or control structure. There is no evidence that the company publishes a statement that no individual owns 25% or more of its shares or voting rights, nor that its ownership information is available in a freely accessible national or global corporate register. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no publicly available evidence to indicate that the company publishes the customers of its defence sales.<\/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\/505","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=505"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=505"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}