The company publishes a clear statement on its anti-bribery and corruption commitment, which details the company\u2019s stance against any form of bribery or corruption within the organisation. There is evidence that this commitment was authorised and endorsed by the company\u2019s leadership. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
The company publishes an anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly 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":"
Based on publicly available information, there is evidence that a designated board committee, the Risk Management and Compliance Committee, is ultimately responsible for oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from management on the programme\u2019s performance. There is evidence that the committee has the authority to require that changes are made. <\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that a designated senior executive, the Chief Risk Management & Compliance Officer, has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the Risk Management and Compliance Committee which provides oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this person and the committee as part of the company\u2019s reporting structure.<\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a formal risk assessment procedure that informs the design of its anti-bribery and corruption programme. There is evidence the assessments are reviewed by the Risk Management and Compliance Committee, a designated board committee, and that the results are used to update the company\u2019s anti-bribery and corruption programme. <\/p>\n
However, while the company states that risk assessment are conducted regularly, it is unclear whether they are conducted and reviewed on at least an annual 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 regular review. This includes provisions for continuous improvement, supplemented by internal and external audits, to ensure that the programme is consistent with the business risks facing the company. There is evidence that the results of audits are reported to the Risk and Compliance Committee, a designated-board committee. <\/p>\n
However, based on publicly available information, the frequency of audits is unclear and there is no clear evidence that audits of the entire anti-bribery and corruption programme are conducted 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 promptly, independently and objectively, and that there is a specific procedure in place to deal with whistleblowing cases. The company\u2019s compliance department is responsible for conducting investigations, and has procedures in place that stipulate documentation and actions to be taken at every step, from receipt to final outcome. The company commits to put in place remediation plans and to report investigative findings to senior management and the Risk Management and Compliance Committee, which receives information concerning all investigations on a regular basis. There is also evidence indicating that information on each investigation is documented and that the company informs whistleblowers of the outcome of investigations.<\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company assures itself of the quality of its investigations. The company indicates that managers supervising investigations must be properly qualified and that it reviews its investigation procedure on an annual basis.<\/p>\n
However, in publicly available information, there is no mention of how complaints about the investigation process are handled.<\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company reports material findings of bribery and compliance to the board. The compliance team is responsible for ensuring that the disclosure of criminal offences to relevant authorities is evaluated and acted upon if found necessary.<\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
The company publishes limited information on ethical or bribery and corruption investigations or the disciplinary actions involving its employees. The company provides details concerning one case in its 2019 Sustainability Data Book. However, there is no evidence that it publishes high-level information on all ethical, bribery or corruption incidents and investigations involving employees. <\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides a training module that outlines the basic principles of its anti-bribery and corruption policy, including the whistleblowing options available to employees. There is evidence that training is provided to all employees across all divisions, all countries\/regions of operation and in all appropriate languages. There is evidence that the training is held annually. <\/p>\n"},{"question":65,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides tailored anti-bribery and corruption training to employees in different roles, including managers, employees in high-risk positions such as public sector business and sales, and executives. There is evidence to suggest that the training is held on at least an annual basis. <\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
The company states publicly that it reviews its anti-bribery and corruption communications and personnel training programme on an annual basis. The company tracks training completion rates.<\/p>\n
However, it is unclear how the company reviews the programme in practice. It is also unclear whether 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":"0","comments":"
Based on publicly available information, there is no clear 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 evidence that the company commits to support or protect employees who refuse to act unethically, even when it might result in a loss of business.<\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, the company promotes a policy of non-retaliation against both whistle-blowers and employees who report bribery and corruption incidents, which explicitly applies to all employees across the organisation. There is evidence indicating that the company\u2019s whistleblowing line is open to third parties and that its policy on non-retaliation extends to these parties. There is evidence that the company assures itself of its employees\u2019 confidence in this commitment by tracking usage data from its whistleblowing line.<\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and to relevant external bodies. These channels allow for confidential and, wherever possible, anonymous reporting. They are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, and in all relevant 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 which addresses conflicts of interest, including actual, potential and perceived conflicts. The policy covers conflicts of interest associated with employee relationships, financial interests and other employment. There is evidence the policy applies to all employees and executives across the group.<\/p>\n
However, while the company has a policy on government relationships, there is no specific mention of the risks associated with conflicts of interest in these relationships. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is some evidence the company has procedures to manage conflicts of interest. Employees must report potential conflicts to their manager while the board of directors exercises oversight of potential conflicts of interest involving directors.<\/p>\n
However, there is no evidence that all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process. The company\u2019s policies also do not mention examples of criteria for recusals nor do they state that disciplinary measures will apply if 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 the company has a policy on political contributions. However, while donations are generally prohibited, these are stated to be permissible in certain circumstances, providing that proper authorisation is given by a senior manager. Based on the scoring criteria, the company therefore receives a score of \u20180\u2019. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes details of its political contributions.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is some evidence that the company has a policy on charitable donations. However, there is no evidence that the company has a policy on sponsorships, and the available information relating to its approach to charitable donations is insufficiently detailed. The company also publishes only high-level information concerning its charitable contributions. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is no evidence that 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 details 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, with procedures to ensure that such promotional expenses are bona fide and not used for bribery. The company explicitly addresses the risks associated with gifts and hospitality given to and received from public officials. <\/p>\n
However, the policy does not specify financial or proportional limits or different approval procedures for different types of promotional expenses. There is also 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":"0","comments":"
Based on publicly available information, there is no clear evidence that the company has a procurement department that is involved in and responsible for the establishment and\/or oversight of its supplier base<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
The company simply states publicly that it conducts due diligence on third parties without providing any specific details regarding its due diligence process. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company requires suppliers to comply with its Global Business Standards. These standards prohibit bribery and facilitation payments and include procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. The company requires new suppliers to sign an agreement stating that they will comply with the company\u2019s anti-bribery and corruption policies. <\/p>\n
However, it is unclear how the company assures itself that suppliers have adequate anti-bribery and corruption procedures in place in practice. The company also does not specify that it conducts assurance when there is a significant change in the business relationship. <\/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, this evidence is in the form of a simple statement and it is unclear how the company does this in practice.<\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.<\/p>\n"},{"question":87,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence the company has a policy covering the use of agents, which addresses the corruption risks associated with the use of agents. The policy includes details of controls to mitigate these risks, including financial controls, contractual agreements and due diligence. There is evidence the policy applies across the group. <\/p>\n
However, the company does not explicitly commit to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
The company simply states publicly that it conducts due diligence on third parties without providing any specific details regarding its due diligence process. <\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company aims to establish the ultimate beneficial ownership of its agents.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is evidence the company\u2019s anti-bribery and corruption policy applies to agents and intermediaries, and that it includes anti-bribery and corruption clauses in its contracts with such entities. However, there is no evidence that the company includes audit and termination rights in its contracts with these entities.<\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. <\/p>\n
However, there is no evidence that the company imposes a threshold on the payment of sales commissions to agents, and there is no requirement that remuneration is paid 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 and\/or on behalf of the company.<\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
The company simply states publicly that it conducts due diligence on third parties without providing any specific details regarding its due diligence process. There is no clear evidence that due diligence includes and is based on an assessment of potential bribery and corruption risk.<\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company requires all business partners to comply with its Global Business Standards and it requires anti-bribery and corruption clauses in its contracts with all partners. <\/p>\n
However, it is unclear how the company ensures that joint venture partners abide by these standards in practice. The company does not specify that it takes steps to detect, control and prevent breaches through the inclusion of audit and termination rights in the contract. <\/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":"
Based on publicly available information, there is no evidence that the company addresses the corruption risks associated with offset contracting. There is also no 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":"
Based on publicly available information, there is no evidence that the company has a procedure 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 the company\u2019s 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 contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"2","comments":"
In publicly available information the company acknowledges the corruption risks associated with operating in different markets, and there is evidence that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures. The results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes a list of its major subsidiaries and associated companies on an annual basis. The company lists its percentage voting rights in each entity.<\/p>\n
However, the evidence suggests this is not a full list of all the company\u2019s holdings. While the company lists the country of each entity, it is unclear whether this relates to the country of incorporation or operation.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is a publicly listed on the Tokyo and Nagoya stock exchanges and therefore automatically receives a score of \u20182\u2019. The company also publishes a list of its major shareholders on its website. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes a breakdown of its defence sales by customer. <\/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\/514","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=514"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=514"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}