The company has a publicly stated anti-corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's leadership.<\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
The company has an anti-corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials and commercial bribery. The policy applies to all company employees and board members.<\/p>\n
However, the company\u2019s anti-corruption policy does not make reference to facilitation payments and it is not explicitly clear that the policy applies to non-executive directors as well as the staff and leadership of subsidiaries and other controlled entities within the policy. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated board committee, the Business Ethics and Compliance Committee, is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from management on the programme\u2019s performance and ensuring that required changes are made. The company\u2019s Audit Committee receives a quarterly briefing on internal and external audits of the company\u2019s ethics and compliance programme.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior executive has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the designated board committee that provides oversight of the anti-bribery and corruption 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"},{"question":58,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company has a formal risk assessment procedure which is used to inform the company\u2019s anti-bribery and corruption programme. While the company refers to internal processes for the evaluation of risk and a risk management process, it does not make any mention of bribery and corruption risk. <\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
There is evidence that the company\u2019s anti-corruption programme is subject to regular review and audit to ensure the entire programme is consistent with best practice and the business risks facing the company. The company explicitly refers to provisions for continuous improvement through regular monitoring by its internal audit department and external audits. In addition, the company undergoes an external audit on an annual basis. A quarterly briefing on this work is provided to the Audit Committee and there is evidence that high-level audit findings are presented to the board, with clear ownership assigned to units for planned updates and improvements to 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, and there is a specific procedure in place to deal with whistleblowing cases, which stipulates documentation and actions to be taken. There is evidence that the Business Ethics and Compliance Committee receives summary information on the status of investigations. <\/p>\n
However, this does not cover the whole investigation process from receipt to final outcome, and it is unclear whether information on each investigation is documented. There is no evidence that investigations are handled by an independent team and\/or report to an independent board member. The company also does not publicly commit to providing whistleblowers with updates on the outcome of investigations. Finally, it is unclear how frequently the Business Ethics and Compliance Committee receives and reviews information on the investigations. <\/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. While government investigations require the involvement of the legal department, it is not clear whether a specific function or appropriately senior individual is responsible for conducting all incident investigations and managing all whistleblowing cases. There is no mention of how complaints about the investigation process are handled. Also there is 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":"
There is evidence that material findings of bribery and corruption are reported to a designated board committee, the Business Ethics and Compliance Committee. <\/p>\n
However, although the company commits to cooperating with government investigations, there is no evidence that it commits to reporting material findings of bribery and corruption to relevant authorities. <\/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 disciplinary actions involving its employees. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides a training module that outlines the basic principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees, which is refreshed on an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear whether this training is provided in all the company\u2019s countries of operation and in all appropriate languages.<\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company provides tailored anti-bribery and corruption training to employees in different roles. For instance, the company states that employees that are more exposed to corruption risk receive additional training on anti-corruption legislation, which is refreshed annually. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it conducts tailored training for middle management and board members.<\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme. However, these measures appear to be too simplistic to receive a score of \u20181\u2019 and are limited to maintaining records of completion. There is also no evidence that the company assures itself of this on at least an annual basis nor that the results are used to update 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 evidence that the company\u2019s incentive schemes incorporate ethical or anti-bribery and corruption principles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company commits to support or protect employees who refuse to act unethically. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
The company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. This applies to all employees across the organisation. <\/p>\n
However, the company does not explicitly refer to employees employed by the group as third parties, suppliers and joint venture partners. There is also no evidence that the company assures itself of its employees\u2019 confidence in this commitment through surveys, usage data, or other clearly stated means.<\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
The company has multiple whistleblowing and advice channels which allow for anonymous and confidential reporting. These channels are sufficiently varied to allow the employee to raise concerns across the management chain and to relevant external bodies. They are available and accessible to all employees in all jurisdictions where the company operates, and in all relevant languages. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not explicitly stated that the whistleblowing and advice channels are also available to those employed by the group as third parties and joint venture partners. <\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence that the company has a conflict of interest policy which explicitly applies to all employees and board members. This covers actual, potential and perceived conflicts. It refers to all of the categories of conflicts listed in the question, namely employee and government relationships, financial interests and other employment. <\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company has procedures in place to manage conflicts of interest or their oversight. <\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy that addresses the risks associated with the employment of public officials. The company requires employees to consult the legal or human resources departments before starting discussions about the potential employment of current or former public officials. <\/p>\n
However, there is limited information on the specific controls in place to assess and regulate the employment of current or former public officials. It is not explicitly stated that sign-off is required from the company\u2019s General Counsel. Additionally, although the company states that the activities of the official may be restricted after joining the company, it does not refer to a specific cooling-off period. <\/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":"
The company operates a political action committee and therefore receives a score of \u20180\u2019. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company discloses details of its political contributions on its website.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy and\/or procedure covering both charitable donations and sponsorships. The company provides some details regarding the charities it supports but it does not publish full details of all charitable contributions made. <\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy on lobbying in its Code of Ethics and Business Conduct, which applies to all employees, board members, agents and contractors. The policy outlines some requirements for employees conducting lobbying activities on the company\u2019s behalf. <\/p>\n
However, it is not explicitly stated that this includes all third parties engaged in lobbying activities on the company\u2019s behalf. Additionally, the company does not provide information on what it considers to constitute responsible lobbying nor does it publish clear guidelines on what behaviours are acceptable, or acknowledge the corruption risks associated with lobbying. While the company refers to a lobbying procedure, this is not publicly accessible.<\/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 on its website. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company provides any details about its global lobbying expenditure on its website. <\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy on the giving and receipt of gifts and hospitality. The policy addresses the risks associated with gifts and hospitality given to\/received from public officials, and refers to proportional limits for different types of promotional expenses. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not specify certain financial thresholds in the policy. 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":"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 simply states that it conducts due diligence on its suppliers before entering into agreements and potentially throughout the business relationship. However, it does not provide any further details on its due diligence procedures so receives a score of \u20180\u2019.<\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company requires its suppliers to comply with the Supplier Code of Ethics and Business Conduct, which prohibits bribery, facilitation payments and covers conflicts of interest, gifts and hospitality, and whistleblowing. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is unclear how the company assures itself that suppliers have such policies in place, such as by conducting assessments of supplier policies during the onboarding process and when there is a significant change in the business relationship.<\/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 does this 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 relating to its suppliers, or the associated disciplinary actions. <\/p>\n"},{"question":87,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company has specific procedures in place to control the use of agents. The company requires the approval of the legal department prior to engagement and will only work with agents who operate to its standards. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not explicitly address the corruption risks associated with the use of agents. It also does not commit to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. <\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
The company states has formal procedures to conduct anti-bribery and corruption due diligence prior to engaging third parties and agents. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that agents and highest risk intermediaries are subject to enhanced due diligence. The company says that due diligence is conducted prior to entering into agreements and at later stages if red flags are identified, but it is unclear whether due diligence is repeated at least every two years or when there is a significant change in the business relationship.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company aims to establish the beneficial ownership of its agents.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is evidence that the company\u2019s anti-bribery and corruption policy applies to agents and intermediaries. Agents must certify that they will comply with the company\u2019s Code of Ethics and Business Conduct, and there is evidence that the Supplier Code of Ethics and Business Conduct also applies to agents and intermediaries. However, although the company states that it includes termination rights in its contracts with agents and intermediaries, there is no evidence that it also includes audit rights.<\/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":"
The company does not publish any details of the agents currently contracted to act for and\/or on behalf of the company.<\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving agents. <\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
The company states that it conducts due diligence on all parties with whom it does business. However, it does not explicitly refer to joint ventures nor is there evidence that its due diligence process is based on an assessment of risk.<\/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 its joint ventures. <\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company addresses the corruption risks associated with offset contracting. <\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company has such a procedure.<\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
The company does not publish 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":"
The company does not publish 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. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company provides a list of its subsidiaries. This list includes the subsidiaries\u2019 countries of incorporation. <\/p>\n
However, the company does not include the percentages of ownership of the subsidiary, nor is the list accompanied by a statement that it is complete at the time of publication to the best of the company\u2019s knowledge. It is consequently not clear whether the list includes all of the company\u2019s holdings. Additionally, the company does not provide information on the subsidiaries\u2019 countries of operation. <\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
The company discloses information on its controlling shareholder on its website. <\/p>\n
However, it does not disclose full details regarding beneficial owners of the company and the information is not disclosed in an open data format or in a freely accessible public register.<\/p>\n"},{"question":110,"commitment_area":15,"score":"2","comments":"
The company discloses that the United States government accounted for 96% of its revenue for the year ended 31 December 2018. There is evidence that this information is published on an annual basis. <\/p>\n"},{"question":111,"commitment_area":16,"score":"N\/A","comments":""},{"question":112,"commitment_area":16,"score":"N\/A","comments":""},{"question":113,"commitment_area":16,"score":"N\/A","comments":""},{"question":114,"commitment_area":16,"score":"N\/A","comments":""},{"question":115,"commitment_area":16,"score":"N\/A","comments":""}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/508","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=508"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=508"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}