There is evidence that the company has a publicly stated commitment to 'integrity' and 'high ethical standards', but it does not explicitly mention anti-bribery and corruption. There is no clear evidence that this statement is endorsed or authorised by the company\u2019s leadership and it only appears in its supplier code of conduct. <\/p>\n"},{"question":55,"commitment_area":7,"score":"0","comments":"
There is no publicly available company has or publishes an anti-bribery and corruption policy for its employees. <\/p>\n"},{"question":56,"commitment_area":7,"score":"0","comments":"
There is no evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.<\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
There is no evidence that a specific senior individual or managerial-level employee has ultimate responsibility for implementing and managing the company\u2019s anti-bribery and corruption programme.<\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company has a formal risk assessment procedure which is used to inform the company\u2019s anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company\u2019s anti-bribery and corruption programme is subject to audit or review.<\/p>\n"},{"question":60,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company has a publicly stated procedure for dealing with bribery and corruption allegations, incidents or whistleblowing reports.<\/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":"0","comments":"
There is no evidence that the company has an investigative procedure which includes a commitment to report material findings to the board of directors or the relevant authorities.<\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption investigations or disciplinary actions involving its employees.<\/p>\n"},{"question":64,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company provides anti-bribery and corruption training to its employees.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company provides tailored anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.<\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company\u2019s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company publicly commits to support or protect employees who refuse to act unethically.<\/p>\n"},{"question":69,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company has a publicly available policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.<\/p>\n"},{"question":70,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company provides either whistleblowing or advice channels for its employees.<\/p>\n"},{"question":71,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the company has a conflict of interest policy.<\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the company has procedures in place to manage conflict of interest or their oversight.<\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
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 reports details of the contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy to regulate corporate political contributions. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company publishes any details of its political contributions.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy or procedure covering charitable donations or sponsorships.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available 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":"0","comments":"
There is no publicly available evidence that the company has a policy on gifts or hospitality.<\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
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":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain. <\/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 suppliers have adequate anti-bribery and corruption policies and procedures in place. This includes policies prohibiting bribery, and those that manage conflicts of interest, and gifts and hospitality. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear what steps the company takes to ensure this in practice. In addition, it is not clear that the company assures itself of this for all suppliers and there is no evidence that this assurance is conducted when onboarding new suppliers and\/or when there is a significant change in the business relationship. There is also no evidence that the company requires that its suppliers must have a policy on whistleblowing. <\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.<\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations or the associated disciplinary actions relating to its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company has a policy on the use of agents.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company aims to establish the beneficial ownership of its agents.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.<\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company recognises 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 agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its joint ventures.<\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, nor that it requires anti-bribery and corruption clauses in its contracts with joint venture partners.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
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 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 or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company acknowledges the corruption risks of operating in different markets, nor that risk assessment procedures are used to inform the company\u2019s operations in high risk markets.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes a list of affiliated companies, which appears to include consolidated subsidiaries and non-fully consolidated holdings. <\/p>\n
However, the company receives a score of \u20181\u2019 because this list does not include the percentage ownership, country of incorporation and\/or countries of operation for each entity. There is also no evidence that the list is updated on an annual basis, nor is it accompanied by a statement that it is complete at the time of publication to the best of the company\u2019s knowledge. <\/p>\n"},{"question":109,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes any information about its beneficial ownership or control structure, nor a statement that no individual owns 25% or more of shares or voting rights.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes any information about its defence sales in the form of a percentage breakdown by customer. <\/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\/515","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=515"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=515"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}