There is evidence that the company publishes a clear anti-bribery and corruption commitment, which details its stance against any form of bribery or corruption within the organisation. There is evidence that this commitment was directly authorised and endorsed by the company\u2019s Chief Executive Officer. <\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company has an anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials and commercial bribery. There is evidence that this policy applies to all employees and board members as described in (a) and (b) in the question. The company publishes two Codes of Conduct which cover ethical risks, anti-bribery and corruption \u2013 one for employees and one for members of the board.<\/p>\n
Although the company states that facilitation payments are prohibited, there is evidence that these are permissible in some circumstances, providing that they follow certain procedures and are allowed under applicable laws. Since these exceptions appear to encompass more than an imminent threat to physical security, the company receives a score of \u20181\u2019.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that the company\u2019s board-level Audit Committee is responsible for providing oversight of its compliance and ethics programme, which is understood to include anti-bribery and corruption initiatives. The company indicates that the committee\u2019s responsibilities include reviewing reports from management on the programme\u2019s performance, along with the results of internal and external audits, and there is evidence that the committee has the authority to require that any necessary changes to the programme are made. <\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a senior individual \u2013 the Chief Compliance Officer \u2013 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 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":"2","comments":"
There is evidence that the company has a formal bribery and corruption risk assessment procedure that informs the design of its anti-bribery and corruption programme. There is evidence that the results of such reviews are used to develop tailored mitigation plans and update the programme. The company indicates that three board-level committees \u2013 the Audit Committee, the Commercial Strategies and Operational Risk Committee and the Compliance and Ethics Committee \u2013 review the risk assessment procedures in the company and there is evidence that the company\u2019s anti-corruption policies and procedures are reviewed on an annual basis.<\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
There is evidence that the company\u2019s anti-bribery and corruption programme is subject to a regular audit process to ensure the programme is consistent with best practice and the business risks facing the company. The company indicates that its Compliance and Ethics Committee is responsible for auditing the company\u2019s compliance and ethics programme and there is evidence that it reports on a quarterly basis to the board-level Audit Committee. In addition, there is evidence that the Chief Compliance Officer is responsible for implementing planned updates and making improvements to the company\u2019s anti-bribery and corruption programme based on audit findings.<\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
There is evidence the company has a system for tracking, investigating and responding to bribery and corruption allegations or incidents, including those reported through whistleblowing channels. There is evidence that the Corporate Investigations team handles all ethics and compliance investigations with oversight from the Chief Compliance Officer. The company states that the Compliance and Ethics Committee receives and reviews summary information about investigations on an ongoing basis. There is evidence that the company commits to putting in place remediation plans and indicates that information on each investigation is documented. <\/p>\n
In addition, there is evidence that the company commits to ensure that whistleblowers are informed of the outcome if they so wish. The Compliance and Ethics Committee provides information on cases and updates the Audit Committee on a quarterly basis. <\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
There is evidence that the company assures itself of the quality of its internal investigations, including those reported through whistleblowing channels. The company indicates that staff conducting the investigations are properly trained. There is evidence that the company\u2019s Corporate Compliance Department reviews and updates the reporting and investigation guidelines at least every three years or in response to any changes required by law.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence to indicate how complaints about the investigation process are handled and who is responsible for handling such complaints. <\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
There is evidence that the company commits to reporting material findings of bribery and corruption from internal investigations to the board-level Audit Committee. There is also evidence that the company commits to implement a procedure to ensure the disclosure of any ethics and compliance violations to relevant government officials or authorities. The company indicates that the Vice President, Corporate Compliance is the chair of the Compliance and Ethics Committee, and therefore this individual is understood to be responsible for ensuring that such disclosures are evaluated and acted upon if necessary.<\/p>\n"},{"question":63,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publishes some high-level information on its compliance and ethics investigations, including the total number of investigations launched and the percentage of cases that related to bribery or conflicts of interest. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes any information on the number of disciplinary actions taken as a result of investigation findings. It is also not clear whether the information provided includes all investigations involving at all levels, including board members.<\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides training on anti-bribery and corruption to all of its employees, which outlines the principles of its policy and the whistleblowing options available to employees. The company indicates that it provides training for all its employees worldwide, which is understood to include providing training to all divisions and in all appropriate languages. In addition to periodic training on ethics and compliance, there is evidence that employees must review and certify their understanding of the company\u2019s Code of Business Conduct and Ethics, and the anti-corruption principles therein, on an annual basis. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides tailored anti-bribery and corruption training to employees in different roles based on their role and exposure to corruption risk. The company indicates that it provides fact-to-face training for certain employees and all directors, and indicates that middle management receive targeted training on handling and escalating employee concerns and incidents. In addition, the company states that in 2018 it provided an update to its board of directors about the international compliance risks, including anti-corruption risks, facing the company. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence to indicate that employees in high risk positions must refresh their training 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 the effectiveness of its anti-bribery and corruption communications and training programme. The company indicates that it undertakes such reviews on an annual basis using incident reporting data and employee surveys, as well as by making adjustments based on business needs. There is evidence that the company uses these reviews to update specific elements of its anti-corruption training and communications programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company\u2019s incentive schemes are designed to promote its compliance programme and adherence with all relevant regulations and policies. The company indicates that the Compliance and Ethics Committee is responsible for designing and implementing such systems. In addition, there is evidence that the Organisation and Compensation Committee is responsible for ensuring that executive compensation aligns with the company\u2019s values.<\/p>\n
However, the company receives a score of \u20181\u2019 because further details on how the company\u2019s incentive schemes are designed to promote ethical behaviour and discourage corrupt practices are not made publicly available. It is not clear that the incorporation of ethical values into incentives applies to all employees in addition to executives, nor is it clear whether such incentives include both financial and non-financial components. <\/p>\n"},{"question":68,"commitment_area":9,"score":"2","comments":"
There is evidence that the company commits to support and protect any employee who refuses to give or receive bribes, even where such actions may result in a loss of business. There is evidence that the company assures itself of its employees\u2019 confidence in this commitment through employee surveys.<\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":"
There is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. The company clearly indicates that this policy applies to all employees across the organisation, including those employed by the group as third parties, suppliers and other partners. There is evidence that the company assures itself of its employees\u2019 confidence in this commitment through employee surveys.<\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
There is evidence that the company has multiple channels 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 and to an external body through an independently-operated hotline. The company indicates that these channels allow for confidential and, wherever possible, anonymous reporting. There is evidence that 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, and in all relevant languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence that the company formally addresses conflict of interest as a corruption risk, and that it has a policy to clearly define conflicts of interest, including those actual, potential and perceived. There is evidence that this policy covers possible conflicts arising from employee relationships, financial interests, government relationships and other employment. The company indicates that the policy applies to all employees and board members, including those of subsidiaries and other controlled entities. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is some evidence that the company has procedures to identify, declare and manage conflicts of interest, including those actual, potential and perceived. The company indicates that Human Resources, Corporate Compliance and the Law Department are jointly responsible for managing conflict of interest cases within the organisation, with the Chief Compliance Officer ultimately responsible for the system\u2019s operation. There is evidence that employees are required to disclose potential conflicts when joining the company and as part of an annual compliance certification. The company states that disciplinary measures apply for breaches of this code. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that 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 indication that the company provides examples of criteria for recusals. <\/p>\n"},{"question":73,"commitment_area":10,"score":"2","comments":"
There is evidence that the company has a policy that addresses the risks associated with the employment of public officials and specifies controls to assess and regulate such risks. The company\u2019s policy states that employees must seek advice from both the Human Resources Department and the Law Department before initiating employment conversations with a government employee. There is also evidence that government employees must disclose any actual or potential conflicts upon joining the company and indicates that it may be appropriate to impose restrictions on the type of work individuals can perform, as a result of such disclosures. <\/p>\n
Although the company does not explicitly state that it may implement a cooling-off period, there is evidence that the company commits to comply with national restrictions that may be imposed for a period of time after a senior government or contracting official leaves their position, and this is deemed sufficient to receive a score of \u20182\u2019. <\/p>\n"},{"question":74,"commitment_area":10,"score":"2","comments":"
The company publishes a clear statement that it does not hire any current or serving government officials as consultants, directors or employees. <\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is evidence that the company has a policy on corporate political contributions. The company\u2019s policy indicates that it may make political contributions when approved by the company\u2019s Senior Vice President of Government Relations and other relevant senior management and legal professionals. The company states that the board reviews its Political Activities Policy and all donations made on an annual basis. In addition, there is evidence that that the company is associated with a Political Action Committee (PAC) in the United States, which is overseen by a committee of employees from different business divisions.<\/p>\n
Since the company does not prohibit political donations and is associated with a PAC, it receives a score of \u20180\u2019 in line with the scoring criteria. <\/p>\n"},{"question":76,"commitment_area":11,"score":"2","comments":"
There is evidence that the company publishes full details of its political contributions made by the company. The company publishes a list of all corporate contributions and Political Action Committee (PAC) disbursements made in the most recently reported financial year, including details of the recipient, amount and state for each donation. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is some evidence that the company has a policy covering charitable donations and sponsorships. The company indicates that employees must seek advice from the Government Affairs and Community Relations groups before making any contributions, and states that any donations must be properly documented. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes any details of its charitable donations and sponsorships made in the most recently reported financial year. In addition, the company does not provide any further information of the controls or procedures to ensure that such donations are not used as vehicles for bribery and corruption. <\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy on lobbying. The company indicates that all political activities, including lobbying, must be reviewed and approved by the Senior Vice President of Government Relations, along with relevant senior management and legal professionals. There is evidence that the company may employ external consultants to lobby on its behalf, and that it commits to engaging in the political process responsibly. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it clearly defines responsible lobbying, nor is there evidence that its procedure includes standards of conduct for all individuals engaged in lobbying on the company\u2019s behalf. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes details of the aims and topics of its lobbying activities on its website. The company states that its lobbying reports in the United States are available on relevant federal, state and local websites, however it does not provide direct links to these sources on its own site. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any details of its lobbying expenditure on its website. The company states that its lobbying reports in the United States are available on relevant federal, state and local websites, however it does not provide direct links to these sources on its own site. The company does not publish any information about its lobbying activities in other jurisdictions, nor a statement that it does not lobby outside of the United States. <\/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, which stipulates procedures designed to ensure that such promotional expenses are not used for bribery. The company indicates that any gifts offered must be proportionate and states that the Law Department must be notified if a government entity or official is involved. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its policy specifies financial or proportional limits, nor different approval procedures, for different types of promotional expenses. In addition, there is no evidence that gifts and hospitality above a certain threshold are recorded in a dedicated central register or database that is accessible to those responsible for oversight of the process.<\/p>\n"},{"question":82,"commitment_area":12,"score":"2","comments":"
There is evidence that the company requires the involvement of its procurement department in the establishment of new suppliers. The company indicates that this department is ultimately responsible for providing oversight of its supplier base, and there is additional evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through the use of an annual audit process. <\/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 and re-engaging with suppliers. There is evidence that this due diligence includes checks on ultimate beneficial ownership. <\/p>\n
However, although the company states that suppliers undergo continuous monitoring, it is not clear from publicly available evidence that due diligence is repeated at least every two years or whenever there is a change in the business relationship. There is also no publicly available evidence that the highest risk suppliers are subject to enhanced due diligence. In addition, there is no evidence that the company might be willing to review and\/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company takes active steps to ensure this by requiring that all suppliers follow its Business Conduct And Ethics Expectations For Suppliers And Contractors policy which includes provisions that prohibit bribery as well as policies related to conflicts of interest, gifts and hospitality and reporting procedures. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that its standards for suppliers include prohibiting facilitation payments or establishing a whistleblowing mechanism. In addition, although the company indicates that it conducts assurance when onboarding suppliers, there is no publicly available evidence that it repeats these checks when there is a significant change in the business relationship. <\/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 sub-contracts throughout the supply chain. The company publishes a clear statement on this subject, and states that it has the right to verify that its contractors and suppliers meet these expectations. <\/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 incidents, investigations or disciplinary actions relating to its suppliers. <\/p>\n"},{"question":87,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has a policy on the use of agents, which specifically addresses the corruption risks associated with their use and provides details of specific controls to mitigate these risks. This policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function.<\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with agents. However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that agents and highest risk intermediaries are subject to enhanced due diligence. It is also not clear that the company repeats this due diligence at least every two years and\/or when there is a significant change in the business relationship.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company aims to establish the beneficial ownership of agents as part of its due diligence process.<\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
There is evidence that the company publishes a Business Conduct and Ethics Expectations for Suppliers and Contractors policy that applies to agents and intermediaries. There is also evidence that the company includes clauses in its contracts with such entities that stipulate its right to terminate the relationship if any violations of its policies or values are identified. Although the company does not explicitly state that it includes audit rights in its contracts, there is evidence that the company reserves the right to verify that a third party\u2019s operations meet its business conduct and ethics expectations, and this is deemed sufficient to receive a score of \u20182\u2019. <\/p>\n"},{"question":92,"commitment_area":13,"score":"2","comments":"
There is evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company states that it does not operate on a commission based sales structure and notes that other red flags in relation to agent incentives include cash payments and requests for payment in another currency or into a foreign bank account. Although the company does not explicitly state that remuneration must be paid in stage payments, the company provides sufficient information on its other controls to receive a score of \u20182\u2019. <\/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 disciplinary actions involving its agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering into all joint ventures. There is some evidence that due diligence on joint venture partners includes checks on ultimate beneficial ownership. The company indicates that joint ventures operating in high risk markets or with high risk partners, such as government affiliated entities, are subject to enhanced due diligence. In addition, there is evidence that the company monitors its joint venture partners on a continuous basis. <\/p>\n"},{"question":101,"commitment_area":13,"score":"2","comments":"
There is evidence that the company publishes a Business Conduct and Ethics Expectations for Suppliers and Contractors policy that applies to joint ventures. There is also evidence that the company includes clauses in its contracts with such entities that stipulate its right to terminate the relationship if any violations of its policies or values are identified. Although the company does not explicitly state that it includes audit rights in its contracts, there is evidence that the company reserves the right to verify that a third party\u2019s operations meet its business conduct and ethics expectations, and this is deemed sufficient to receive a score of \u20182\u2019. <\/p>\n"},{"question":102,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company has a procedure in place to develop tailored corruption risk mitigation plans for all of its high risk projects or \u2018teaming arrangements\u2019, which is understood to include joint ventures. The company indicates that this plan forms the basis for implementing additional processes or procedures with the partner in relation to ethics and compliance, and states that such plans are reviewed throughout the lifecycle of the partnership. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide any further information or practical examples of how it may identify and implement such plans in practice or in specific relation to 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, 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 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 its offset programme. <\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of its offset obligations and\/or contracts. <\/p>\n"},{"question":107,"commitment_area":15,"score":"2","comments":"
There is evidence that the company acknowledges the corruption risks associated with operating in different markets and there is evidence that it has a dedicated assessment process in place to assess such risks. The company indicates that the results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls, which are reviewed and updated as needed throughout the duration of the project or business relationship. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a list of its fully consolidated subsidiaries and non-fully consolidated holdings, including any associates, joint ventures and other related entities. For each entity, the company discloses its percentage ownership and the country of incorporation. There is evidence that this list is current and updated on at least an annual basis, since it is published as part of the company\u2019s annual reporting documents. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it clearly publishes the country or countries of operation for each entity. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed, trading on regulated markets in the United States, United Kingdom and elsewhere, and is therefore not required to disclose further information on its beneficial ownership. In addition, the company publishes information on its significant shareholders as part of its annual reporting documents. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes any information on its defence sales by customer. The company publishes some information to indicate the main geographic regions in which it generated revenue in the most recently reported financial year, which suggests that the United States is the company\u2019s biggest customer. However, the company identifies the customers for less than 50% of this revenue and the information does not distinguish between defence and commercial projects, so the company receives a score of \u20180\u2019. <\/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\/513","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=513"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=513"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}