There is evidence that 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. It is clear that this commitment is authorised and endorsed by the company\u2019s President and Chief Executive Officer.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company publishes an anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that this policy applies to all employees and board members as described in (a) and (b) in the question. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that the board and the Audit Committee are ultimately responsible for providing oversight of the company\u2019s anti-bribery and corruption programme. There is evidence to suggest that these bodies engage in formal oversight functions, such as reviewing reports from management, and that they have the authority to require that any necessary changes to the programme are made. <\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that a senior executive, the Chief Compliance Officer, has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. The company indicates that this individual has a direct reporting line to the board and periodically reports findings on the effectiveness of the company\u2019s anti-bribery and corruption programme to both the board and Audit Committee. <\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, 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. There is some indication that the company is aware of the potential bribery and corruption risks that it faces, but there is no evidence that it has an assessment process to determine these risks or to adapt and update its anti-corruption programme on this basis.<\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company\u2019s anti-bribery and corruption programme is subject to periodic review. The company indicates that it reviewed its ethics and anti-corruption procedures in 2018 and there is evidence that its policies and procedures were updated and improved based on opportunities identified. There is also evidence that the board and Audit Committee review high-level findings. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear publicly available evidence that it has procedures in place to conduct formal audits of its programme, with an internal or external audit taking place at least every two years.<\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
There is evidence that the company publicly commits to investigating incidents and there is evidence that it takes steps to ensure the independence of its investigations. It commits to reporting investigative findings to senior management and the Audit Committee, including root cause analysis and remedial or mitigation recommendations. <\/p>\n
There is evidence that there is a procedure in place for whistleblowing cases that stipulates documentation and actions to be taken at every step of the case, from receipt to final outcome, and the company indicates that it has a mechanism to keep whistleblowers informed of the outcome. In addition, the company indicates that the CCO and the Audit Committee receive and review summary information of all incidents and their status in the organisation upon the completion of every investigation. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company assures itself of the quality of its internal investigations. The company provides some evidence to indicate senior functions are involved in investigations and that the ethics procedures as a whole are reviewed periodically, but it is not clear from publicly available evidence that the company has specific measures in place to ensure the quality of its investigative procedure specifically, for example by indicating that staff conducting investigations are properly trained, by implementing a policy to handle complaints about the process or by reviewing the investigation process every three years.<\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
There is evidence that the company makes a public commitment to report material findings of bribery and corruption from investigations to the board and to the relevant authorities. The company indicates that its Chief Compliance Officer, along with the Chief Legal Officer, is ultimately 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":"
There is evidence that the company publishes some information on its corruption-related incidents and investigations involving company employees. The company provides information to indicate that it did not have any confirmed incidents of corruption in the most recently reported financial year. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it publishes further data on its incidents and investigations, such as the number of reports received, including the number received through whistleblowing channels, and the number of investigations launched to determine whether an incident had occurred. <\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides training on a periodic basis that outlines the principles of its anti-bribery and corruption policy, including the whistleblowing options available to employees. The company indicates that it provides this training to all employees, across all divisions and countries of operation. In addition, there is evidence that the company provided training on anti-corruption and ethics in the most recently reported financial year and that it aims to provide training all employees every two years. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company provides different or tailored anti-bribery and corruption training to employees based on their roles. The company indicates that employees in certain professional functions receive dedicated anti-bribery and corruption training on a periodic basis. <\/p>\n
However, it is not clear from publicly available information that the company provides tailored anti-bribery and corruption training to middle management and board members, to account for the specific risks that they might face. It is also not clear from publicly available information whether employees in professional functions include all employees in high risk positions nor is it clear that such individuals must refresh their specific training on at least an annual basis. <\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company measures the effectiveness of its anti-bribery training and communications programme. The company provides data on the percentage of employees trained on anti-corruption in the most recently reported financial year, and there is also some evidence that the company may hold in-person sessions to reinforce understanding of its policies. <\/p>\n
However, there is no publicly available evidence that the company has further procedures in place to measure and review the effectiveness of its anti-corruption training and communications programme specifically, for example by conducting staff surveys or targeted audits of these aspects of its programme at least every three years. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company\u2019s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles.<\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company commits to support or protect employees who refuse to act unethically. The company indicates that employees who report incidents are protected and that it will not proceed with a third party transaction where concerns are identified, however it is not clear from publicly available information that the company commits to support employees to make ethical decisions in their responsibilities, even when this might result in a loss of business.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is publicly available evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, which clearly applies to all employees across the organisation. There is evidence that the company makes this commitment in its Anti-Bribery and Corruption Compliance Policy, which also applies to third parties acting on the company\u2019s behalf. <\/p>\n
However, the company receives a score of \u20181\u2019 because 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. Although there is evidence that the company conducts employee engagement surveys, it is not clear from publicly available information that this survey addresses employees\u2019 understanding and belief in the company\u2019s non-retaliation policy.<\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence the company provides multiple channels for employees to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. There is evidence that these channels are sufficiently varied to allow the employee to raise concerns across the management chain. The company indicates that these channels allow for confidential and, wherever possible, anonymous reporting. In addition, there is evidence that whistleblowing channels are available and accessible to all employees, in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that it offers an external reporting channel for employees to report incidents outside the management chain, for example through a channel operated by an independent third party.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company addresses conflicts of interest as a corruption risk, and has a policy that defines conflicts of interest, including actual, potential and perceived conflicts. There is evidence that the company\u2019s policy addresses possible conflicts arising from employee relationships, financial interests and outside employment. In addition, the company\u2019s policy makes reference to the possible conflict of interest risks arising from relationships with government officials.<\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has procedures in place to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company indicates that its Compliance and Legal Departments are responsible for managing conflict of interest cases. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that all employee and board member declarations are held in a dedicated central register that is accessible to those responsible for oversight of the process. There is also no evidence that the policy provides examples of possible criteria for recusals, nor does it indicate that disciplinary measures will apply if the policy is breached. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
Based on publicly available information, 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 publicly 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 which prohibits corporate political contributions, whether by the company itself or by any other entity or individual acting on its behalf. However, there is evidence that the company has a Political Action Committee (PAC) in the United States, so the company therefore receives a score of \u20180\u2019 as per the scoring criteria. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
The company publishes a statement that it does not make corporate political contributions. <\/p>\n
However, the company receives a score of \u20180\u2019 because there is evidence that it has a Political Action Committee (PAC) in the United States and there is no evidence that it publishes any information in relation to the PAC\u2019s disbursements on its website or that it provides a direct link to its official disclosures. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
Based on publicly available evidence, there is some evidence that the company has a policy on charitable donations. The company indicates that this policy includes conducting due diligence to ensure that recipients are legitimate and to avoid any risk of a donation being used to exert undue influence. In addition, there is some evidence that the company publishes high-level details of its total charitable contributions made and initiatives supported in the most recently reported financial year. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it publishes further details of its charitable donations, such as details of the recipient, amount, country of recipient and which corporate entity made the payment.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy 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 evidence that the company publishes any details about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"2","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 with procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy indicates that the company has established financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. There is also evidence that the company\u2019s policy clearly addresses the risks associated with gifts and hospitality given to from public officials. The company's policy includes a clear statement that all gifts and hospitality are recorded.<\/p>\n
In addition, there is evidence that further detail relating to the company\u2019s approval procedures and financial thresholds is available in an Approval Annex; however, this does not appear to be publicly accessible. <\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no clear publicly available evidence the company requires the involvement of its procurement department in the establishment of new supplier relationships and the oversight of its supplier base.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct risk-based due diligence when engaging with suppliers. The company indicates that the highest risk suppliers are subject to enhanced due diligence. There is also evidence that the company is willing to review and terminate supplier relationships in instances where red flags highlighted during the due diligence process cannot be mitigated. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information how frequently it conducts these checks. There is also no clear evidence that the company includes checks on the ultimate beneficial ownership of suppliers as part of its due diligence procedure.<\/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. The company indicates that all suppliers must have, at minimum, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, as well as policies and procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. <\/p>\n
There is evidence that the company takes active steps to ensure this by requiring that all suppliers follow its Supplier Code of Conduct. In addition, there is evidence that the company assures itself of this when onboarding new suppliers and periodically thereafter through the inclusion of auditing rights in its contracts with suppliers.<\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, 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, the company receives a score of \u20181\u2019 because the company does not provide further publicly available information on how it ensures this in practice, for example by adding a clause on subcontractors in contracts with suppliers or by providing training to subcontractors. <\/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 the associated disciplinary actions involving its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence the company has a policy on the use of agents, which also applies to agents employed by subsidiaries and joint ventures. There is evidence to indicate that the company assures itself that there is a legitimate need and business rationale prior to contracting an agent. The company states that it conducts due diligence as one method for mitigating the corruption risks associated with using agents<\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with its third parties and agents. There is evidence indicating that the company conducts enhanced due diligence on the higher risk intermediaries. The company indicates that in instances where red flags identified during the due diligence process cannot be mitigated, third parties may be disqualified from engaging with the company. <\/p>\n
However, 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.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is some evidence that the company aims to establish the identity and background of its agents as part of the due diligence process. <\/p>\n
However, it is not clear publicly available information that this includes formally establishing the ultimate beneficial ownership of agents, nor is there evidence that the company commits to not engage or terminate its engagement with agents or intermediaries in situations where beneficial ownership cannot be established. <\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, 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 indicates that all agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts. There is evidence indicating that the company includes audit and termination rights in its contracts with these entities. <\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
There is publicly available evidence that the company highlights incentive structures for third parties as a factor in bribery and corruption risk. The company outlines a number of these risks, including cash payments and unusual payment methods, as well as excessive fees. <\/p>\n
However, it is not clear from publicly available information that the company\u2019s incentive structures for agents include further controls to reduce bribery and corruption risk, such as a threshold on the payment of sales commissions to agents or a requirement remuneration be made in stage payments or into local bank accounts.<\/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 on its behalf.<\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption-related investigations, incidents or the associated disciplinary actions involving its agents.<\/p>\n"},{"question":100,"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 on all of its joint venture partnerships. The company indicates that it conducts enhanced due diligence on joint ventures operating in high risk countries. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that such due diligence is repeated at least every two years. There is also no clear evidence that the company\u2019s due diligence procedure includes checks on the ultimate beneficial ownership of the partner company.<\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies and procedures in all of its joint ventures, by requiring the adoption of its own anti-bribery and corruption programme for all controlling joint ventures and by requiring a similar policy for other joint venture partnerships. These policies prohibit bribery and facilitation payments. There is evidence to indicate that the company requires anti-bribery and corruption clauses in its contracts with joint venture partners.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that its contracts with joint venture partners include clear audit and termination rights to detect, control and prevent breaches.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures, for example by providing training to employees of joint ventures or implementing a policy to second senior individuals to the partner company\u2019s management board. <\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company addresses the specific corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of 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":"
The company publishes some high-level information on its offset projects to indicate the total value of its outstanding offset obligations. However, it is not clear from publicly available information that the company publishes any further information on the beneficiaries of these projects nor is it clear whether this figure includes both direct and indirect obligations for all jurisdictions in which the company operates. <\/p>\n"},{"question":107,"commitment_area":15,"score":"1","comments":"
Based on publicly available information, there is evidence that the company acknowledges the corruption risks associated with operating in different markets. There is some evidence that the company has mechanisms to assist in identifying such risks and that it has a management system in place which involves reporting red flags to the Legal Department or CCO. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that the results of risk assessments have a direct impact on business decisions and are used to inform the development and implementation of additional controls.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a list of its major subsidiaries on an annual basis. However, the company receives a score of \u20181\u2019 because this list does not include public details of the percentage ownership, country of incorporation and country or countries of operation for each entity. It is also not clear that this list includes all of the company\u2019s fully and non-fully consolidated holdings including all associates, joint ventures and other related entities. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly traded on the Tel Aviv Stock Exchange. Based on the scoring criteria, the company is not required to provide further details of its beneficial ownership to receive a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is evidence that the company publishes some information about its defence sales by customer. The company indicates that, for its most recently reported financial year, Israel accounted for 20.1% of its sales and it provides further information on the rest of its sales in the form of percentages per geographic region. <\/p>\n
However, the company receives a score of \u20180\u2019 because it does not publish information about its customers for at least 50% of its defence sales. The company also does not indicate whether this data represents defence or non-defence sales, or both.<\/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\/509","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=509"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=509"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}