The company has a publicly stated commitment to 'integrity' and 'high ethical standards'. However, there is no evidence that this statement is directly authorised or supported by the company leadership and it does not explicitly refer to anti-bribery and corruption. <\/p>\n"},{"question":55,"commitment_area":7,"score":"0","comments":"
The company has a Code of Ethics which applies to directors and employees. However, the code is not available on the company\u2019s website. The company provides a summary of its Code of Ethics and outlines some standards that it establishes, but these summaries do not specifically mention tackling bribery or corruption. <\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is evidence that a designated board committee \u2013 the Social & Ethics Committee \u2013 oversees the company's ethics and anti-bribery and corruption activities. However, the company receives a score of \u20181\u2019 because there is no evidence to suggest that it engages in formal oversight functions, such as reviewing reports from management. The Audit Committee reviews reports from auditors although it is unclear if this specifically includes reviewing reports on the anti-bribery and corruption programme.<\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
There is no evidence that a specific managerial-level employee has ultimate responsibility for implementing and managing the company\u2019s anti-bribery and corruption programme. There is evidence that the company has a Risk and Compliance Manager but it is not explicitly stated that this individual\u2019s remit includes implementing and managing the company\u2019s anti-bribery and corruption activities.<\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
The company has a risk assessment process managed by the Risk and Finance Committee. While this makes reference to fraud risk evaluation, there is no evidence that the company specifically refers to assessment of bribery and corruption risks.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is evidence that the company\u2019s mitigations for fraud and corruption include provisions for continuous review of internal controls by internal audit. However, the company receives a score of \u20180\u2019 because further details are not provided, for example, it is not clear how frequently audits are conducted or whether the findings are used to update the anti-bribery and corruption programme.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company commits to investigating incidents, which are monitored by the Audit Committee and Social Ethics Committee. However, the company receives a score of \u20181\u2019 because it does not provide details on its investigation process from receipt to final outcome. It is also not fully clear which team or individual currently conducts investigations and whether evidence on each investigation is documented. The company does not make a commitment to providing whistleblowers with updates on the outcome of investigations. In addition, it is not clear whether the Audit Committee or Social Ethics Committee review summary information on investigations on a regular, at least quarterly, basis.<\/p>\n
In its 2018 Annual Report, the company describes plans to establish a penal to ensure that cases are independently investigated. However, publicly available information does not contain any further information on what changes were made and whether they were implemented. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company assures itself of the quality of its internal investigations. The company states that ethics matters are monitored by the Audit Committee and Social Ethics Committee, but it is not clear whether the committees review the company\u2019s investigation procedures. Moreover, there is no evidence that staff tasked with conducting investigations are properly trained to perform the function, nor that a procedure is in place to handle complaints about the process. <\/p>\n
In its 2018 Annual Report, the company describes plans to establish a penal to ensure that cases are independently investigated. However, publicly available information does not contain any further information on what changes were made and whether they were implemented. <\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company\u2019s investigative procedure includes a commitment to report material findings to the board or relevant authorities. The company states that ethics issues are monitored and reported to the board-level Audit Committee and Social and Ethics Committee, but it is not clear from this statement whether this specifically applies to material findings, nor how direct this reporting line is to the board itself. Moreover, there is no evidence that an appropriate senior individual within the committees is responsible for ensuring this disclosure, 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-related investigations or disciplinary actions involving its employees. In its 2018 Annual Report, the company makes reference to one corruption allegation involving former senior management at the company, but this is not counted as high-level data from all ethics investigations.<\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company provides its employees with training on anti-bribery and corruption. The company states that prevention of corruption is included as part of its induction programme. However, the company receives a score of \u20181\u2019 because it is unclear whether training is refreshed throughout employment or whether training is systematically provided to all employees across all divisions, all countries regions of operation or in all appropriate languages.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.<\/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. The company mentions some information on its remuneration strategy, but there is no evidence that this includes a consideration of 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.<\/p>\n"},{"question":69,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company has a policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents. <\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides an externally operated whistleblowing channel to allow employees and external stakeholders to report bribery or corruption allegations. However, the company receives a score of \u20181\u2019 because it is not clear that these channels can be used to seek advice on the company\u2019s anti-bribery and corruption activities, nor does it state that reports can be made anonymously and are treated confidentially. It is not explicitly clear that the channel is available to all employees in any country of operation, or in multiple languages, or to any employees of third parties, suppliers or joint venture partners.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a conflict of interest policy for board members and it states that a similar policy applies to all employees of the group. There is evidence that the company addresses risks arising from personal relationships and some indication that it addresses financial interests, though this category is not fully defined. <\/p>\n
The company receives a score of \u20181\u2019 because, based publicly available information, there is no evidence that this policy covers actual, potential and perceived conflicts, nor whether explicitly applies to all employees, including those of subsidiaries and other controlled entities. In addition, there is no evidence that the company\u2019s policy addresses other categories of conflict outlined in the scoring criteria, such as government relationships or other employment. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has procedures to identify and manage conflicts of interest. The company states that director interests are held in a dedicated register which is presented to the company\u2019s shareholder on an annual basis, and there is an indication that a similar process applies to all employees. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is unclear with there is a specific body or individual with oversight and accountability for handling cases. There is also no evidence that the company describes criteria for recusals, nor does it explicitly state that disciplinary measures will apply if the policy is breached.<\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company has a policy regulating the employment of current or former public officials.<\/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 no evidence that the company has a policy on corporate political contributions. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company discloses any details of its political contributions.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy and\/or procedure covering charitable donations and sponsorships.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy and\/or procedure on lobbying.<\/p>\n"},{"question":79,"commitment_area":11,"score":"1","comments":"
The company publishes some information on its engagement with government departments in South Africa, including with its shareholder, the Ministry of Public Enterprises, as well as the Department of Defence. However, it provides limited information on its aims in these engagement activities. The company does not publish information regarding its lobbying activities in other jurisdictions, nor an indication that it does not conduct lobbying elsewhere. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company provides details about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy or procedure on gifts or hospitality.<\/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\/or oversight of its supplier base.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
The company states that it conducts due diligence on potential partners, but does not provide any further details on this process that would be required to score \u20181\u2019. <\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
There is evidence that the company sets expectations for its suppliers through its Code of Ethics. However, based on publicly available information, this code refers to general standards of ethical business conduct and does not specifically refer to any of the anti-bribery and corruption measures mentioned in score \u20181\u2019.<\/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 investigations relating to its suppliers, or the associated disciplinary actions. <\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company has a clear policy covering the use of agents. In its Annual Report (2018), it commits to continuously reviewing and strengthening processes for appointing agents. The company receives a score of \u20180\u2019 because it does not provide further information on these processes not does it specifically address the corruption risks associated with the use of agents.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
The company states that it conducts due diligence on potential partners but does not provide any further information on its procedures. <\/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 does it commit to not engaging or terminate its engagement with agents or intermediaries if beneficial ownership cannot be established.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is some evidence that the company includes provisions related to ethics in its contracts with advisors, but it does not mention anti-bribery and corruption. In addition, there is no publicly available evidence that the company includes audit and termination rights in these contracts. It is also not clear that the company\u2019s has an anti-bribery and corruption policy which applies to agents. As such, the company receives a score of \u20180\u2019.<\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company's incentive structures for agents are designed to minimise risks of bribery and corruption or that incentive structures are recognised as a risk factor in agent behaviour. <\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any details of the agents currently contracted to act for or and 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 to agents. <\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
The company states that it conducts anti-bribery and corruption due diligence on its potential partners but there is no evidence that the company directly refers to joint ventures.<\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. <\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no evidence that the corruption risks associated with offset contracting are addressed. There is no evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities. <\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company has a formal procedure to conduct 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, or that risk assessment procedures are used to inform the company\u2019s operations in high risk markets. There is no reference to high risk markets for corruption in the company\u2019s description of its risk management procedures.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes a list of subsidiaries and non-fully consolidated holdings in its annual report. The list includes the countries of incorporation of the subsidiaries and percentages owned. However, the company receives a score of \u20181\u2019 because the list does not include the countries of operation. The list is not accompanied by a statement that it is complete at the time of publication to the best of the company\u2019s knowledge and it is therefore not clear whether this is a complete list of subsidiaries. <\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
The company discloses its ownership by the South African state on its website. The company does not disclose details in an open data format, nor does it disclose its ownership in a freely available central public register.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes details of its defence sales by customer. The company provides some information on sales by destination \u2013 which includes 45% of sales to South Africa \u2013 but does not provide details of other customers beyond regional percentages. <\/p>\n"},{"question":111,"commitment_area":16,"score":"N\/A","comments":"
The company publishes a statement that it is a state-owned enterprise, with 100% of shares held by the South African Government. Therefore, it can be inferred that the company does not have shareholders and that the South African Government also holds 100% of its voting rights. <\/p>\n"},{"question":112,"commitment_area":16,"score":"2","comments":"
The company provides details of its commercial and public policy objectives on its website, and there is evidence in the Annual Report to indicate that these objectives are updated and reviewed on an annual basis. This includes reporting against an annual performance plan agreed with the shareholder. Although there is no direct evidence that the objectives on the company\u2019s website are updated annually, the inclusion of key objectives in the Annual Report is considered sufficient to receive a score of \u20182\u2019. <\/p>\n"},{"question":113,"commitment_area":16,"score":"1","comments":"
The SOE publishes clear information about the composition of its board, for example whether each board member is an independent director or an executive. It states that independent board members are appointed by the Minister for Public Enterprises, acting on behalf of the company\u2019s sole shareholder, the Ministry for Public Enterprises. However, the company receives a score of \u20181\u2019 because on its website it does not provide any further information on the nomination and appointment process for executive and non-executive directors.<\/p>\n"},{"question":114,"commitment_area":16,"score":"2","comments":"
There is evidence that the company\u2019s executive-level audit committee is composed of a majority of independent directors. The company provides clear information about the independence of directors alongside their committee membership. <\/p>\n"},{"question":115,"commitment_area":16,"score":"0","comments":"
The company does not publish any details about its management of asset transactions.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/507","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=507"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=507"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}