The company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. This commitment is clearly endorsed by its Chairman and CEO.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
The company publishes an explicit anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members as described in (a) and (b) above. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that the company's Ethics and Compliance Committee is responsible for overseeing the company's anti-corruption, ethics and integrity programme. The committee reviews reports from management on the programme's performance alongside the results of internal audits. There is also evidence that the committee ensures that necessary changes are made to the company's ethics and compliance programme. It reports at least annually to the company\u2019s leadership.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior executive, the General Counsel, has ultimate responsibility for implementing and managing the company's ethics and compliance programme. The General Counsel chairs the Ethics and Compliance Committee, which provides reporting to the company\u2019s leadership on at least an annual basis.<\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
There is evidence that the company has a formal bribery and corruption risk assessment procedure that informs the design of the anti-bribery and corruption programme. The results of risk assessments are reviewed by the Ethics and Compliance Committee on a quarterly basis. There is evidence that the results of such reviews are used to develop tailored mitigation plans and to update specific parts of the company's anti-bribery and corruption programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
There is evidence that the company\u2019s entire anti-bribery and corruption programme is subject to a regular audit process to ensure the programme is consistent with best practice and the business risks facing the company. There is evidence that this includes provisions for continuous improvement, which are supplemented by annual internal audits. There is also evidence that high-level audit findings are presented to the Ethics and Compliance Committee and Leadership Council, which recommends changes, if appropriate, to the company\u2019s ethics and compliance programme.<\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
There is evidence that the company has a system for tracking, investigating and responding to bribery and corruption allegations or incidents, including those reported through whistleblowing channels. There is evidence that the company takes steps to ensure the independence of its investigations and reports investigative findings to the Ethics and Compliance Committee. There is evidence that for whistleblowing cases, the company has a procedure in place that stipulates documentation and actions to be taken at every step of the case, from receipt to final outcome. The company commits to ensure whistleblowers are informed of the outcome, if they so wish. There is evidence that the Ethics and Compliance Committee receives and reviews summary information of all incidents and their status in the organisation and its subsidiaries, on at least a quarterly basis. <\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
There is some evidence that the company assures itself of the quality of its internal investigations. There is evidence that staff conducting investigations are properly trained and qualified. <\/p>\n
However, in publicly available evidence there is no mention of how complaints about the investigation process are handled and it is unclear who would be responsible for handling such complaints. There is no clear evidence that the company reviews its investigations procedure at least every three years or in response to any relevant changes in the regulatory environment. It is also unclear from publicly available evidence if the company assures itself of the quality of both incident investigations and whistleblowing cases.<\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
There is evidence the company commits to reporting material findings of bribery and corruption to members of its Leadership Council. There is evidence that an appropriate senior individual, the General Counsel, is responsible for ensuring that the disclosure of criminal offences to relevant authorities is evaluated and acted upon if necessary. It is noted that the company only makes reference to authorities in the United States. <\/p>\n"},{"question":63,"commitment_area":8,"score":"1","comments":"
The company publishes some high-level data on calls received on its ethics and corruption reporting service. <\/p>\n
However, it does not publish data on ethical and corruption-related investigations or disciplinary actions involving its employees.<\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides training on its Code of Business Conduct, which outlines the principles of the company\u2019s anti-bribery and corruption policy, including the whistleblowing options available to employees. There is evidence that the company provides this training to all employees across all divisions and countries of operation, and in all appropriate languages. There is evidence that employees are required to undertake refresher courses on the anti-bribery and corruption programme on an annual basis.<\/p>\n"},{"question":65,"commitment_area":9,"score":"2","comments":"
There is evidence that the company tailors its anti-bribery and corruption training programme to the different levels of risk facing employees in different roles, with specific reference to senior executives, as well as senior, middle and lower management, and those engaged in international business. There is evidence that all employees are expected to undertake anti-corruption and ethics training annually. There is also evidence that employees working in high risk positions, namely those involved in international business, are required to refresh their training in this area on at least an annual basis. <\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
There is evidence that the company reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme. There is evidence that the company has a system to do this, via annual audits and interviews with randomly selected employees designed to assess employees\u2019 knowledge and memory of the content of training sessions. The company also states that it monitors training completion rates. The Ethics and Compliance Committee reviews the company\u2019s training and communications programme on a quarterly basis and there is evidence to suggest the results are used to specific parts of the company\u2019s anti-bribery and corruption communications training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence to determine whether the company's incentive schemes are designed to discourage corrupt practices. <\/p>\n"},{"question":68,"commitment_area":9,"score":"1","comments":"
There is evidence that the company will protect employees who refuse to act unethically to gain business. <\/p>\n
However, there is no publicly available evidence that the company assures itself of employees\u2019 confidence in this commitment such as through anonymised surveys or clearly stated means. <\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":"
There is evidence the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. This policy explicitly applies to all employees across the organisation, including those engaged by the group as third parties, sub-contractors, suppliers and joint venture partners. There is evidence the company assures itself of its employees\u2019 confidence in this commitment through employee questionnaires. The company additionally monitors the statistics and usage of its whistleblowing telephone and email service. <\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
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 to a supervisor, Ethics Officer, or one of several internal departments, as well as to external bodies through an ethics helpline managed by a third party. There is evidence that the company's reporting channels allow for confidential and, wherever possible, anonymous reporting. It is also clear that the company\u2019s ethics reporting helpline is available to all employees \u2013 including sub-contractors, representatives, agents or other third parties \u2013 in all jurisdictions; while the company\u2019s Code of Ethics and Standards of Business Conduct, which outlines all the company's whistleblowing options, is available in six languages. <\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence the company formally addresses conflict of interest as a corruption risk. The company\u2019s Code of Ethics and Standards Business Conduct defines conflicts of interest, including actual, potential and perceived conflicts. The company\u2019s policy covers conflicts in employee relationships, government relationships, financial interests and in secondary employment positions. There is evidence that the policy applies to all employees and board members, including those of subsidiaries and other controlled entities. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is evidence the company has procedures to identify, declare and manage conflicts of interest, actual, potential and perceived. The company explicitly states that violations of its Code of Ethics and Standards of Business Conduct policy, which contains the company's conflict of interest policy, will lead to disciplinary action and possible termination. There is evidence that the company\u2019s ethics and compliance department collects conflict of interest declarations from every employee and oversees the process of regulating and mitigating conflict of interest cases. <\/p>\n
However, there is no publicly available evidence that all employee conflict of interest disclosures are recorded in a central register. <\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is evidence that the company recognises the corruption risks associated with employing government officials. The company has a policy which includes controls to assess and regulate employment and offers of employment or consultancy engagement to current and recently departed public officials, including politicians. The policy requires the consultation and approval of the human resources and legal departments before initiating any employment discussions with present or past government officials. <\/p>\n
However, the company does not state that it has a policy to implement a cooling-off period of at least 12 months before former public officials are permitted to have any form of contact or relationship with their former organisation on the company\u2019s behalf. There is also no evidence that the company reviews the former state employee's position and past responsibilities to mitigate any potential conflict of interests arising as part of their work with the company.<\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the company reports details of the contracted services of serving politicians nor that the company has a policy not to contract serving politicians. <\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
There is evidence that the company has a policy on political contributions to ensure that these payments are not used as vehicles for bribery and corruption. However, there is evidence that the company may make political donations when approved by the Law Department or the Company\u2019s Vice President of Government Affairs. In addition, there is evidence that the company is associated with a Political Action Committee (PAC) in the United States. <\/p>\n
Since the company does not prohibit political donations and is associated with a PAC, it receives a score of \u20180\u2019 in line with the scoring criteria. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any details of its corporate political contributions or of the donations made through the Political Action Committee (PAC). <\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is evidence that the company has a policy covering charitable donations, requiring the approval of the company\u2019s legal department. The company states that it reviews charitable donations to assess whether they are associated with a foreign government official. <\/p>\n
However, the company receives a score of \u20180\u2019 because there is no publicly available evidence that its policy includes criteria for charitable donations, nor is there evidence that it publishes comprehensive details of the charitable donations made in the most recently reported financial year.<\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy covering lobbying which assigns oversight of the company's lobbying activities to the Vice President of Government Affairs. Any contacts with lobbyists must be coordinated through the company's government affairs department. There is some evidence the policy applies company-wide to all employees and third parties engaged in lobbying activities on the company\u2019s behalf, although the policy does not explicitly refer to members of the company\u2019s board.<\/p>\n
However, the company receives a score of \u20181\u2019 because responsible lobbying is not clearly defined in publicly available evidence. There is also no publicly available evidence that the company has specific standards of conduct or specific oversight mechanisms that apply to all types of lobbyists, nor that specific controls or guidelines are provided. <\/p>\n"},{"question":79,"commitment_area":11,"score":"1","comments":"
The company publishes limited details regarding its regarding its lobbying activities. <\/p>\n
However, it does not publish supporting details of the aims and significant topics of the lobbying activities the company carries out. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any 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 receiving of gifts and hospitality with procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy also addresses the risks associated with gifts and hospitality given to and\/or received from domestic and foreign public officials by specifying a lower financial value of such gratuities. <\/p>\n
However, there is no explicit 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 evidence that the company requires the involvement of its procurement department in the establishment of new supplier relationships. This department is named as the single point of contact for all new vendors, and there is evidence that it communicates with all suppliers on anti-corruption issues on an annual basis, suggesting that they are the main body responsible for oversight of the company\u2019s supplier base. <\/p>\n
However, although procurement integrity is one the topics which may be discussed by the Ethics and Compliance Committee, there is no publicly available evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means, such as an audit, at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company has formal procedures to conduct due diligence on all its suppliers, and 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, there is no evidence to suggest that high risk suppliers are subject to enhanced due diligence. It is also not clear from publicly available evidence whether the company repeats due diligence on its existing suppliers. There is also no evidence that due diligence includes checks on the beneficial ownership of suppliers.<\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
There is evidence that the company ensures that all its suppliers have adequate anti-bribery and corruption policies and procedures in place. There is evidence that suppliers must have policies that prohibit foreign and domestic bribery, facilitation payments, as well as maintaining policies relating to conflicts of interest, gifts & hospitality and whistleblowing. There is evidence that the company\u2019s procurement department is responsible for monitoring suppliers\u2019 compliance with these policies and that the company assures itself of this on at least an annual basis. <\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. <\/p>\n
However, this evidence is in the form of a simple statement and it is unclear how the company ensures itself of subcontractor compliance 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 or disciplinary actions involving its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has a policy to control the use of agents which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. This policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures. It is noted that the company's policy covering agents relates specifically to those employed in positions either dealing with foreign customers or based outside of the United States, as outlined in the International Business Relationships policy document. Evidence suggests that the company does not employ agents in dealing with US clients. <\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging agents and intermediaries. <\/p>\n
However, while the company refers to conducting periodic due diligence, there is no publicly available evidence that due diligence is repeated at least every two years or when there is a significant change in the business relationship. There is also insufficient evidence that all agents and the highest risk intermediaries are subject to enhanced due diligence. <\/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 nor that the company is committed 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":"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. The company also makes it clear that all agents and intermediaries will be subject to disciplinary action and possible termination of contract in the event that they breach the Code of Ethics and Standards of Business Conduct, which includes provisions for clear audit rights to detect, control and prevent corruption. <\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company considers incentive structures as a risk factor in agent behaviour. The company indicates that it monitors agent performance throughout the contract, and states that all invoices submitted are carefully examined. The company also stipulates that all payments must be properly documented<\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further publicly available details on its measures to ensure that incentives for agents do not pose a bribery and corruption risk, for example by imposing a threshold on the payment of sales commissions or requiring stage payments. <\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes 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":"1","comments":"
There is some 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. <\/p>\n
However, there is no publicly available evidence that the company\u2019s due diligence includes checks on the ultimate beneficial ownership of the partner company, nor that enhanced due diligence is required in vetting possible joint venture partners in high risk markets and jurisdictions. While the company refers to conducting periodic due diligence, there is also no evidence that due diligence is repeated at least every two years. It is also noted that the policy only seems to relate to joint ventures outside of the United States. <\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company requires all joint venture partners to adhere to its own anti-corruption standards and procedures and that the company includes audit rights in its contractual agreements.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear, publicly available evidence that all joint venture partners are required to sign anti-corruption clauses with termination rights in contracts with the company. <\/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 some evidence that the company recognises the corruption risks associated with offset contracting. The company requires suppliers to conduct due diligence on offset agreements. <\/p>\n
However, the company receives a score of \u20180\u2019 because there is no evidence that the company itself has specific policies and procedures to address the corruption risks associated with offset contracting. There is also no evidence that the company has a dedicated body, department or team responsible for managing and monitoring the company's offset obligations. The company does not state publicly that it has no offset agreements. <\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
There is some 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 states that it conducts anti-corruption due diligence into its broker partners at the beginning of a proposed business relationship and updates due diligence on a periodic basis. <\/p>\n
However, the company does not specifically mention checks on beneficial ownership and\/or conflicts of interest. There is also no clear evidence that the company seeks to assure itself of the legitimacy of the investment nor that due diligence is refreshed at least every two years.<\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes 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 details of its offset obligations and\/or contracts. <\/p>\n"},{"question":107,"commitment_area":15,"score":"1","comments":"
There is evidence that the company acknowledges the corruption risks associated with operating in different markets and that it has a dedicated assessment process in place to assess such risks. <\/p>\n
However, there is no evidence that the policy includes clear risk management procedures. There is additionally no clear evidence to suggest that the results of the company's high risk market assessments have an impact on business decisions or trigger the implementation of additional controls. <\/p>\n"},{"question":108,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes a consolidated list of its subsidiaries. The company publishes a list of its \u2018locations\u2019 and it mentions its \u2018businesses\u2019, but it is not clear what relationship these entities have with the parent company. <\/p>\n"},{"question":109,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company discloses its beneficial ownership on its own website. Company ownership information cannot be found through a publicly accessible corporate register. The company states that it is family-owned but does not clearly disclose the identities of its shareholders on its website. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes any information about its major 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\/506","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=506"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=506"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}