There is evidence that the company has a publicly stated anti-corruption commitment which details the company's stance against corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's CEO.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company publishes an Anti-Corruption Policy and a Code of Conduct. The Anti-Corruption Policy makes specific reference to prohibition of bribery, payments to public officials, commercial bribery and facilitation payments and applies to all employees as specified in (a) and (b) above. The Code of Conduct applies to all groups as specified in (a) and (b), and makes specific reference to prohibition of bribery and payments to public officials. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that the board and the Sustainability Committee are ultimately responsible for the oversight of the company's anti-bribery and corruption programme. There is evidence to suggest that they engage in formal oversight functions, such as reviewing reports from management on the programme\u2019s performance, and ensuring that required changes are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
Based on publicly available information, there is evidence the company has established an Anti-Corruption Function, which manages and implements the company\u2019s anti-corruption policy and has a direct reporting line to the Board of Directors. However, there is no clear publicly available evidence that a specific senior employee or executive has ultimate responsibility for implementing and managing the company\u2019s anti-bribery and corruption programme.<\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a formal bribery and corruption risk assessment procedure that informs the design of the anti-bribery and corruption programme. The results of risk assessments are reviewed by the board on at least an annual basis. There is evidence indicating that the results of such reviews are used to develop tailored mitigation plans and to update specific parts of the company's anti-bribery and corruption programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s anti-bribery and corruption programme is subject to regular review. This includes provisions for continuous improvement, supplemented by an internal audit on an annual basis. There is evidence high-level audit findings are presented to the board, with clear ownership assigned to units\/individuals 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 publicly commits to investigating incidents promptly, independently and objectively. There is evidence that the company takes steps to ensure the independence of its investigations. It commits to establishing root causes, putting in place remediation plans and reporting investigative findings to senior management and the board. For whistleblowing cases, there is a procedure in place that stipulates documentation and actions to be taken at every step of the case, from receipt to final outcome, and the company commits to ensure whistleblowers are informed of the outcome. There is evidence that summary information of all investigations is reviewed by a central body. However, it is not clear that this information is reviewed on at least a quarterly basis. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company assures itself of the quality of its internal investigations.<\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
There is evidence that the company commits to report material findings of bribery and corruption from investigations to the board and to relevant authorities. However, based on publicly available information, the ownership process for reporting to relevant authorities is unclear. There is no evidence that an appropriate senior individual is 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":"
The company states that no cases of corruption concerning companies in the Group were found in the previous two years. However, the information published is insufficiently detailed. The company does not publish information on the number of reports received, the number of investigations launched or disciplinary actions involving its employees.<\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, 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. There is evidence that the training is conducted annually and is provided systematically to all employees across all divisions and in all countries and regions of operation. There is evidence to suggest that training is provided in all appropriate languages. However, while the company states it conducts periodic refresher training, there is no clear evidence that employees are required to undertake refresher courses at least every three years. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
The company states that employees in certain positions receive different anti-bribery and corruption training and makes specific reference to employees in high risk positions and middle management. However, there is no evidence that board members receive tailored training on the company\u2019s anti-bribery and corruption programme. There is also no clear evidence that training for employees in high risk positions is refreshed on at least an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company reviews its anti-bribery and corruption communications and personnel training programme through staff questionnaires. The company also publishes information on the number of personnel trained on an annual basis. The board receives an annual report regarding the company\u2019s training activities. There is evidence indicating that the results are used to update specific parts of the company's anti-bribery and corruption communications and training programme. <\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company\u2019s incentive schemes incorporate ethical and anti-bribery and corruption principles. An employee\u2019s commitment to the company\u2019s objectives on anti-corruption is one of the elements considered when awarding variable renumeration. However, there is no evidence that in the case of high risk employees, such as sales roles, financial rewards must be proportionate to the employee\u2019s salary. <\/p>\n"},{"question":68,"commitment_area":9,"score":"1","comments":"
The company clearly states that any employee who refuses to act unethically, in keeping with the company\u2019s anti-corruption commitments, will be protected and supported even where such actions result in disadvantages to the company. Although the company indicates that it carries out surveys of its employees, it is unclear whether these include a question relating to employees\u2019 trust in this commitment. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company promotes a policy of non-retaliation against both whistleblowers and company employees who report bribery and corruption incidents. There is evidence this commitment extends to third parties, although the company does not refer to those engaged by the company as suppliers and joint venture partners specifically. 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.<\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has external and internal whistleblowing and advice channels that are confidential and allow for anonymous reporting. The channels are explicitly available to all employees in any country of operation and to third parties. There is evidence that the channels are provided in multiple languages. <\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
The company formally addresses conflicts of interest as a corruption risk, and has a policy that defines conflicts of interest, including actual, potential and perceived conflicts. The policy explicitly covers all of the categories of possible conflicts listed in the guidance. There is evidence that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities.<\/p>\n"},{"question":72,"commitment_area":10,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. All employee and board member declarations are held in a dedicated register that is accessible to those responsible for oversight of the process. The description of this procedure also includes examples of criteria for recusals and potential punitive measures for breaches of the policy. There is evidence that potential or actual conflict of interest declarations are reviewed and overseen by the Oversight Board. <\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy which includes controls to assess and regulate consultancy engagements to current and recently departed public officials, including politicians. There is evidence indicating that the company undertakes a review of conflicts of interest and appointments require the approval of the company\u2019s CEO. The company has a policy to implement a cooling-off period of 36 months before such public officials are permitted to have any form of contact or relationship with their former organisation on the company\u2019s behalf. However, there is no clear publicly available evidence that the company has similar rules concerning the employment of current or former public officials.<\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
The company does not publish details of the contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
There is evidence that the company permits political contributions through its political action committee and therefore receives a score of \u20180\u2019. <\/p>\n"},{"question":76,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, the company discloses the amount of money that it provided to its PAC. It is not clear whether this covers all corporate political contributions and the company does not disclose information about its PAC disbursements. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy and procedure covering both charitable donations and sponsorships. The company publishes some information on its sponsorships and donations, including details of the recipient and the country of the recipient; the data is updated annually. There is also evidence that these policies and procedures include measures to ensure that donations are not used as vehicles for bribery and corruption, by specifying criteria for donations and procedures for senior sign-off. However, the company does not publish full details of all charitable donations made, such as the amount of donation or which corporate entity made the payment; it is also unclear whether the information provided includes donations made, whether financial or in-kind, to corporate foundations. <\/p>\n"},{"question":78,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy and procedure on lobbying (described as Relations with Public Administration) which sets out the values and behaviours that constitute \u2018responsible\u2019 lobbying. It provides clear guidelines on what behaviours are acceptable and unacceptable and the corruption risks associated with lobbying (e.g. gifts and hospitality, undue influence, conflicts of interest, etc.). This policy applies to all employees, board members and third parties lobbying on the company\u2019s behalf. <\/p>\n"},{"question":79,"commitment_area":11,"score":"1","comments":"
The company publishes some details regarding its lobbying activities. However, there are no supporting details of the aims and significant topics or the activities that were carried out. On its website the company provides links to lobbying registers maintained by public bodies but not to its own reports specifically. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
The company does not publish details about its global lobbying expenditure. On its website the company provides links to lobbying registers maintained by public bodies but not to its own reports specifically.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy and procedures on the giving and receipt of gifts and hospitality. The policy specifies different approval procedures for different types of promotional expenses and addresses the risks associated with gifts and hospitality given to\/received from public officials. There is evidence that expenses in relation to gifts and hospitality have to be documented. However, based on publicly available information, there is no clear evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.<\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company's procurement department is involved in the establishment of supplier relationships and that this department is ultimately responsible for providing oversight of the company\u2019s supplier base. Although there is evidence that the company conducts ongoing monitoring of its suppliers, there is no public evidence that the company assures itself of the procurement department\u2019s involvement in the onboarding process itself at least every three years. <\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is some evidence indicating that the company has formal procedures to conduct due diligence on its suppliers. The company indicates that its suppliers are monitored and that annual audits are conducted on 99% of its suppliers. The company indicates that it might be willing to terminate supplier relationships in circumstances where a red flag highlighted in the due diligence process cannot be mitigated. However, it is unclear whether due diligence is also conducted whenever there is a change in the business relationship. In addition, there is no evidence that due diligence includes checks on ultimate beneficial ownership or that the highest risk suppliers are subject to enhanced due diligence. <\/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, and the company assures itself of this when onboarding suppliers. It is explicitly stated that all suppliers must have policies that prohibit bribery and facilitation payments as well as policies and procedures that address conflicts of interest, gifts and hospitality and whistleblowing. There is evidence that the company takes active steps to ensure this through contractual terms and by requiring suppliers to follow its Code of Conduct and Anti-Corruption Policy. <\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
There is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place and that the substance of its anti-corruption and bribery programme and standards are included in subcontracts throughout the supply chain. This evidence is in the form of a clear statement and contractual commitments. <\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
The company does not publish any data on ethical or anti-bribery and corruption investigations or the associated disciplinary actions relating to its suppliers. <\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy and procedure to control the use of agents. This addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. The company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. This policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures.<\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging with its third parties and agents. There is some evidence that agents and highest risk intermediaries might be subject to enhanced due diligence. The company states that it verifies the integrity of agents at least annually, but it is not clear whether it repeats its due diligence process at least every two years or when there is a significant change in the business relationship. In publicly available evidence, the company does not explicitly commit to not engaging or terminating its engagement with agents or intermediaries where the risks identified in the due diligence cannot be mitigated.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is evidence that the company asks agents to disclose their beneficial ownership to the company, and it verifies this information, as part of its due diligence processes. However, there is no clear evidence of a commitment to independently verify the beneficial ownership information of high risk agents. The company also does not publicly commit to reviewing or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.<\/p>\n"},{"question":91,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company includes anti-bribery and corruption clauses as well as termination rights in its contracts with agents and intermediaries. However, the company does not explicitly include audit rights in its contracts with these entities.<\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that incentive structures for agents are highlighted and addressed as a factor in bribery and corruption risk, with some examples of controls to mitigate these risks. The company commits to only paying agents into local bank accounts. However, there is no evidence that the company imposes a threshold on the payment of sales commissions to agents. <\/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":"
The company does not publish any data on ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering into all of its joint ventures. However, there is no evidence that the company\u2019s due diligence explicitly includes checks on the ultimate beneficial ownership of the partner company, or that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence. In addition, there is no evidence that due diligence is repeated at least every two years.<\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company accounts for anti-bribery and corruption considerations when entering into a joint venture and requires compliance with its anti-bribery and corruption programme, which prohibits foreign and domestic bribery and facilitation payments. Contracts with joint venture partners include ethical provisions and termination rights. However, there is no publicly available evidence that the company includes audit rights in its contracts with joint venture partners. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence to indicate 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":"1","comments":"
Based on publicly available information, there is evidence that the company recognises the corruption risks associated with offset contracting. The company has a dedicated body, the Offset Committee, which is involved in managing its offset obligations. There is evidence that this body is responsible for monitoring the company\u2019s offset activities throughout the lifecycle of each project. However, there is no evidence that committee members receive tailored anti-bribery and corruption training.<\/p>\n"},{"question":104,"commitment_area":14,"score":"2","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 its offset obligations. There is evidence that the company refreshes this due diligence on an annual basis. The process mentions checks on beneficial ownership and conflict of interest and there is evidence indicating that the company seeks to assure itself of the legitimacy of the investment.<\/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 or contracts.<\/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 and there is evidence that it has a process in place to assess such risks. However, it is not clear whether the results of these assessments have an impact on business decisions or trigger the implementation of additional controls. <\/p>\n"},{"question":108,"commitment_area":15,"score":"2","comments":"
The company publishes a list of all of its consolidated subsidiaries and non-fully consolidated holdings. The list includes the percentages owned and countries of incorporation and operation for each entity. It is updated on at least an annual basis. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is a publicly listed company with voting shares admitted to trading on a regulated market in the European Economic Area. Based on the scoring criteria, the company therefore automatically receives a score of \u20182\u2019.<\/p>\n
In addition, it is noted that the company provides a breakdown of its shareholding structure on its website. There is evidence that a company by the name of CDP Industria S.p.A. holds 71.32% of its share capital, and that this entity is majority owned by Italy\u2019s Ministry of Economy and Finance. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is evidence that the company publicly discloses some of its major customers. However, the company does not publish any data or percentages in relation to its defence sales. <\/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\/512","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=512"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=512"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}