There is evidence that the company makes a public commitment to anti-corruption through provisions in its Anti-Corruption Policy. There is evidence that this policy as a whole is authorised and endorsed by the company\u2019s Managing Director. In addition, there is also evidence that its parent company \u2013 CSG Holding \u2013 makes a commitment to ethical standards and that this commitment is supported by the CEO. <\/p>\n
The company receives a score of \u20181\u2019 because there is no evidence that the company, or its parent company, publishes a specific or direct commitment to anti-bribery and corruption from its senior leadership, in addition to an endorsement of the anti-corruption policy overall. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has an explicit anti-corruption and bribery policy, which specifically prohibits bribery, facilitation payments and payments to public officials. The policy clearly applies to employees and board members as described in (a) and (b) in the question.<\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
Based on publicly available information, there is evidence that the board of directors of the company\u2019s parent company is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. There is evidence that the board oversees the Compliance Department, which is responsible for the implementation of the programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear publicly available evidence to suggest that the board engages in formal oversight functions, such as reviewing reports from management or the results of audits. <\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
Based on publicly available information, 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. The company indicates that the Group\u2019s Compliance Department as a whole manages the programme but there is no evidence that there is a specific individual with ultimate responsibility for anti-bribery and corruption. <\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is some evidence that the company engages in regular risk assessment procedures in the form of annual internal audits. However, there is no clear evidence that the company\u2019s anti-bribery and corruption programme as a whole is designed and updated as a result of these assessments. There is also no evidence that the results of risk assessments are reviewed at board level. <\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company\u2019s anti-bribery and corruption programme is subject to regular review in the form of annual internal audits. In addition, the company indicates that it conducts random checks, inspections, and questionnaires to determine the efficacy of its anti-corruption programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that audit findings are reviewed by the board. Moreover, there is no evidence that the company provides any information regarding ownership of this process, i.e. which body or senior individual is responsible for using the audit findings to make updates to the company\u2019s programme. There is also no evidence that \u2013 in addition to ensuring the proper functioning of the company\u2019s internal controls \u2013 these audits ensure that the programme is consistent with best practice.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company commits to investigating incidents and that there is a procedure in place to deal with whistleblowing cases. There is evidence that the group\u2019s human resources department receives all complaints, and that it commits to informing whistleblowers of the outcome of investigations. There is some evidence to indicate that information on each investigation is documented. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that investigations are handled by an independent team or that the team leading investigations report to an independent board member. In addition, there is no evidence that a central body reviews summary information on all investigations.<\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company takes steps to ensure the quality of its internal investigations.<\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company commits to reporting criminal offences to the relevant authorities. However, the company receives a score of \u20181\u2019 because there is no evidence that material findings of bribery and corruption are reported to the board, nor that an appropriate senior individual is responsible for ensuring the disclosure of criminal offences.<\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company publishes high-level results from incident investigations and disciplinary actions against its employees.<\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company provides a training module that outlines the basic principles of its anti-bribery and corruption policy. The company indicates that it provides this training to employees when they join the company.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that training is systematically provided to all employees across all divisions, all countries and regions of operation and in all appropriate languages. It is also unclear how frequently employees receive this training, nor is there clear evidence that training includes an outline of the whistleblowing options available to employees. <\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to risk.<\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme. The company indicates that it conducts annual audits to determine the effectiveness of its anti-corruption programme, but there is no evidence that it specifically measures the effectiveness of its training and communications as part of this process. <\/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 incorporate ethical or anti-bribery and corruption principles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is no clear 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":"
Based on publicly available information, there is some evidence that the company has a policy of non-retaliation against whistleblowers and employees who report bribery and corruption incidents. There is evidence that this commitment extends to third parties. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it assures itself of its employees\u2019 confidence in this commitment through surveys, usage data, or other clearly stated means.<\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company provides multiple channels for its employees to report instances of suspected corrupt activity. There is evidence that employees may report concerns anonymously, and the company indicates that these channels are open to third parties.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company provides an external reporting channel operated by an independent third party, nor is it clear that the channels provided could be used to seek advice about the company\u2019s anti-corruption programme. There is also no publicly available evidence that reports are treated confidentially. In addition, there is no clear evidence that these channels are available to all employees in any country of operation, or in multiple languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy defining actual and potential conflicts of interest. This policy defines several categories of possible conflicts including employee relationships and financial interests. There is evidence that the policy applies to all employees and board members.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its policy addresses possible conflicts associated with government relationships and other employment. The policy also does not explicitly refer to perceived conflicts of interest. <\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company has a procedure dedicated to identifying, declaring and managing conflicts of interests. Although the company states that possible conflicts of interest must be declared to the Group\u2019s Compliance Department, the procedures beyond this are sufficiently unclear, based on publicly available information, that they cannot satisfy the requirements of score \u20181\u2019. <\/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 publishes details of the contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
There is publicly available evidence that the company has a policy on corporate political contributions, which states that any such donations must be transparent and adhere to all relevant legal requirements. There is no evidence that the company\u2019s policy includes specific controls or measures to ensure that political donations are not used as vehicles for bribery and corruption. <\/p>\n
The company receives a score of \u20180\u2019 because there is no evidence that it prohibits corporate political contributions. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any details of its political contributions. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has a policy covering both charitable donations and sponsorships. The company publishes a list of the organisations, social events and groups that it supports. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that these policies include specific measures to ensure such donations are not used as vehicles for bribery and corruption, such as criteria for donations, procedures for senior sign-off, or due diligence on recipients. There is also no evidence that the company publishes further details of its donations made, such as details of the recipient or amount, nor is there evidence that the information it does publish is updated annually. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is no evidence the company has a policy or procedure on lobbying.<\/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.<\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any information about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality. The company\u2019s policy acknowledges the risks associated with gifts and hospitality given to and received from public officials. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that all gifts and hospitality above a certain threshold are recorded in a central register accessible to those responsible for oversight of the process. There is also no evidence that the company\u2019s policy specifies financial limits or different approval procedures for different types of promotional expenses. <\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company requires the involvement of its procurement department in the establishment or oversight of its supplier base.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain. The company indicates that it verifies business partners against the standards set out in its Code of Conduct; however, this statement is insufficiently detailed to merit a score of \u20181\u2019. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company ensures that its external partners (which include suppliers) have adequate anti-bribery and corruption policies and procedures in place. There is evidence that the company takes active steps to ensure this, by requiring that all suppliers follow its own anti-bribery policies and procedures. These policies prohibit bribery and facilitation payments and include procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it takes active steps to ensure that its suppliers abide by its policies or that its suppliers have their own adequate anti-bribery and corruption policies and procedures in place. <\/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. 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.<\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company has a policy on the use of agents. There is some evidence that the company\u2019s Code of Ethics applies to intermediaries, but it is not clear that this relates to agents or brokers contracted to act or on behalf of the company. <\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company conducts anti-bribery and corruption due diligence on its agents and intermediaries. The company states that it verifies business partners against the standards set out in its Code of Conduct; however, this statement is insufficiently detailed to receive a score of \u20181\u2019 and it is unclear whether it applies to agents and intermediaries. <\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company commits to establish the beneficial ownership of its agents.<\/p>\n"},{"question":91,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company\u2019s anti-bribery and corruption policy applies to all external subjects working with the company, including consultants and intermediaries. There is some evidence that the company includes anti-bribery and corruption clauses in its contracts with these entities.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it includes audit and termination rights in its contracts with agents and intermediaries. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company considers incentive structures 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 and\/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":"0","comments":"
Based on publicly available information, there is no evidence that the company conducts anti-bribery and corruption due diligence on its joint ventures. The company indicates that it verifies business partners against the standards set out in its Code of Conduct; however, this statement is insufficiently detailed to receive a score of \u20181\u2019 and it is unclear whether it applies to joint venture partners. <\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures. Although the company has such policies relating to external parties, it is not clear whether this includes joint venture partners. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, 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 bribery and corruption risks associated with offset contracting. However, based on publicly available information, there is no clear evidence that the company has policies or procedures in place to address these risks. The company receives a score of \u20180\u2019 because there is no evidence it has a dedicated body, department or team responsible for managing offset obligations. <\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company has formal procedures in place to conduct risk-based 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 its behalf.<\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of its offset obligations or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
Based on publicly available information, there is some evidence that the company acknowledges the corruption risks associated with operating in different markets. The company indicates that its sales representatives take certain risks into account in the conduct of business, such as those related to ownership structures and country of operation. <\/p>\n
However, the company receives a score of \u20180\u2019 because there is no further evidence that risk assessment procedures are used to inform the company\u2019s operations in high risk markets. There is also no evidence that assessments have an impact on business decisions or trigger the 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 consolidated subsidiaries and non-fully consolidated holdings. However, the company receives a score of \u20181\u2019 because there is no evidence that the company discloses the percentage ownership for each entity, nor the countries of incorporation and operation for each entity. There is also no clear evidence that this information is published and updated on an annual basis. <\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
The company discloses the name of its controlling shareholder and parent company, CSG Holding, and provides shareholding information for this entity to indicate that it is privately owned. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further information on its beneficial ownership. There is no evidence that the company publishes a complete breakdown of its ownership structure to confirm whether it might have other shareholders, nor is there evidence that this information is available in a freely accessible public register. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes any information about its defence sales. <\/p>\n"},{"question":111,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":112,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":113,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":114,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":115,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/511","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=511"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=511"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}