Based on publicly available information, there is evidence that the company has a publicly stated commitment to anti-bribery and corruption as part of its Standards of Business Ethics and Conduct, which is endoresd by the chairman and CEO. <\/p>\n
However, the company receives a score of \u20181\u2019 because the statement from the company\u2019s leadership does not explicitly mention and stand against bribery or corruption. <\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company publishes an anti-bribery and corruption policy, which applies to all employees and executives within the organisation. <\/p>\n
However, the company receives a score of \u20181\u2018 because there is no clear evidence that this policy prohibits facilitation payments and it is not clear that the policy applies to non-executive directors. <\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is evidence that the company\u2019s board-level Audit Committee provides oversight of the anti-bribery and corruption programme as part of its oversight of the company\u2019s Business Ethics and Conduct Program. There is evidence that this Committee engages in formal oversight functions such as monitoring the programme\u2019s implementation and meeting with auditors. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the Committee reviews reports on anti-bribery and corruption performance specifically, nor is there clear evidence that it has the authority to require that changes to the programme are made when necessary. <\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
There is some evidence that the company has an ethics officer responsible for managing reviewing, investigating and addressing issues related to the company\u2019s Standards of Business Ethics and Conduct, which includes anti-bribery and corruption. There is evidence that this individual has a direct reporting line to the Audit Committee, which in turn presents its findings to the board. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that this individual holds a senior or managerial level position within the organisation. <\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company has a formal risk assessment procedure in place that informs its anti-bribery and corruption programme. Although there is evidence that the company has a risk management strategy, it is not clear that such a procedure includes anti-corruption considerations or that the results of these assessments are used to inform the design of its anti-bribery and corruption programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
There is evidence that the company\u2019s anti-bribery and corruption programme, as part of its Standards of Ethics and Business Conduct, is subject to annual review by the Audit Committee. The company\u2019s publicly available documents indicate that the Audit Committee has a direct line to report findings to the board. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that it conducts internal and\/or external audits of its anti-bribery and corruption programme at least every two years, to ensure that the programme is consistent with high standards of best practice and the business risks facing the company. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly commits to investigating incidents promptly and that it has a specific procedure in place to deal with whistleblowing cases, which stipulates documentation and actions to be taken at each step. The company indicates that investigations are handled by an independent team and it provides information on the process from receipt to final outcome. The company states that whistleblowers will receive updates on the outcome of investigations. There is evidence that information on each investigation is documented and that summary information on all reports is held in a central database. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the process includes reporting findings to an independent board member. There is also no evidence that summary information on investigations is reviewed by a central body on at least a quarterly basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
There is some evidence that the company assures itself of the quality of its internal investigations, for example by indicating that its staff responsible for conducting internal investigations are professionally qualified. <\/p>\n
However, the company receives a score of \u20181\u2018 because there is no evidence that it reviews its investigations procedure at least every three years or in response to any changes in the regulatory environment. It is also not clear how complaints about the investigation process are handled, nor who might be responsible for handling such complaints. <\/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 to the relevant authorities, if necessary. <\/p>\n
However, the company receives a score of \u20181\u2018 because 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. In addition, there is no clear evidence that material findings are reported to the board. <\/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 incidents, investigations or disciplinary actions involving its employees.<\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides an ethical training module for its employees, which outlines the basic principles of its anti-bribery and corruption policy, including the whistleblowing options available. There is some evidence that such training is mandatory for all employees and that it is provided every two years. <\/p>\n
However, the company receives a score of \u20181\u2018 because there is no clear evidence that this training is provided to employees across all divisions, in all countries or regions of operation and in all appropriate languages. Moreover, it is not clear whether the requirement to complete the training every two years is targeted or whether it applies to all employees across the company.<\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company provides tailored ethics training to its directors at the start of their employment. There is evidence to indicate that this ethics training includes anti-bribery and corruption. <\/p>\n
However, the company receives a score of \u20181\u2018 because there is no evidence that it provides tailored anti-bribery and corruption training to middle management or employees in high risk positions. <\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company measures or reviews the effectiveness 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 commits to support or protect employees who refuse to act unethically.<\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report ethical incidents of any kind. This policy applies to all employees across the organisation, including those engaged by the group as third parties, suppliers and joint venture partners. There is evidence that the company assures itself of its employees\u2019 confidence in this commitment by monitoring the usage statistics. <\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides multiple channels for its employees to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. The company indicates that these channels are sufficiently varied to allow the employee to raise concerns across the management chain and externally through an independently-operated hotline. These channels allow for confidential and, wherever possible, anonymous reporting. There is evidence that the company\u2019s whistleblowing 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":"1","comments":"
There is evidence that the company has a policy that formally addresses conflicts of interest as a potential corruption risk and defines such conflicts, including those actual, potential and perceived. The company indicates that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities. The policy makes reference to financial interest, employee relationships and other employment situations. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its policy covers possible conflicts arising from government relationships. Although the company has a procedure in place for hiring government officials in certain countries, this relates to legal restrictions rather than conflict interest risks. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has some procedures in place to identify, declare and manage conflicts of interest, including actual and perceived conflicts. The company indicates that employees and directors must disclose conflicts of interest to ethics officers within their relevant business unit. The company also provides some criteria for recusals and states that disciliplinary measures will apply if employees fail to disclose conflicts of interest. <\/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. In addition, there is no evidence that a specific body or individual is responsible for oversight and has accountability for the handling of conflict of interest cases.<\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is some evidence that the company has a policy that addresses the risks associated with the employment of public officials. The company\u2019s policy notes that in some countries this practice may be prohibited, and indicates that employees must seek legal advice before recruiting, interviewing or hiring former government officials. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the policy provides any further controls to assess and regulate the eployment of current or former public officials, such as stipulating a cooling-off period. <\/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":"
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 corporate political contriubtions when approved by the Senior Vice President, Planning and Development and when such donations are in the company\u2019s business interests. There is also evidence that the company is associated with a Political Action Committee (PAC) in the United States, which is overseen by a committee of senior management employees. <\/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 details of its political contributions. The company publishes a total figure of all contributions made to state and local candidates for the most recently reported financial year, though it is noted that this figure is not broken down by recipient, amount and country of recipient per donation. In addition, the company provides a direct link to the United States Federal Election Commission website, where information about the donations made through its PAC may be accessed.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy on charitable donations or sponsorships. The company addresses donations to charities that are affiliated with a politician as part of its political contriubtions policy, but there is no evidence that it has a specific policy on charitable donations to address the potential bribery and corruption risks. <\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
There is some evidence that the company has a corporate procedure on lobbying practices. The company indicates that this policy is designed to ensure compliance with all relevant laws and regulations involving government officials, as well as outlining the relevant disclosure requirements. <\/p>\n
However, the company receives a score of \u20191\u2019 because the policy does not clearly define lobbying, nor does it outline certain standards of conduct for lobbyists. It is also not clear whether this policy applies company-wide to all employees and all third parties engaged in lobbying activities on the company\u2019s behalf. <\/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":"1","comments":"
There is evidence that the company publishes its annual lobbying expenditure, in the form of a total amount. <\/p>\n
The company receives a score of \u20191\u2019 because this expenditure information is not broken down by corporate entity, geography, and there is no explanation of how the data has been calculated. In addition, there is no clear indication that the expenditure figure represents the United States only or all jurisdictions in which the company has conducted lobbying activities.<\/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. The company indicates that employees should not offer a gift that may appear to be improper, and states that only gifts that are modest in value should be accepted. Where substantial gifts are accepted, the company indicates that they must be reported to the relevant business unit\u2019s ethics officer. <\/p>\n
However, the company receives a score of \u20181\u2019 because its policy does not provide further details of controls to reduce the risks arising from gifts and hospitality, such as financial or proportional limits or different approval procedures for different types of promotional expenses. In addition, the policy does not address the risks associated with gifts and hospitality given to or received from domestic or foreign public officials. There is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process. <\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base. It is not clear which entity or department is primarily responsible for supply chain management at the company. <\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is some evidence that the company has a procedure to screen and conduct checks on suppliers prior to entering into a business relationship, but it is not clear what these checks include, how frequently they are conducted or whether they amount to full due diligence.<\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies in place. The company indicates that it expects suppliers to demonstrate high ethical standards as part of its pre-selection requirements, and states in its Standards of Busines Ethics and Conduct that it expects suppliers to develop ethics programmes in line with its own values. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear whether the company takes active steps to ensure this in practice. <\/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 incidents, investigations or 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 covering 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 and intermediaries.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is no evidence to suggest 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, nor is there evidence that the company's incentive structures for agents are designed to minimise risks of anti-bribery and corruption. <\/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 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 its 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 clear evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, or that it requires anti-bribery and corruption clauses in its contracts with such entities. The company indicates that it expects joint venture partners to develop ethics programmes consistent with its values, but does not provide further details on how it assures this in practice. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no publicly available 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 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 clear evidence that the company acknowledges the corruption risks of operating in different markets, nor is there evidence that it has a risk assessment procedure in place to identify such risks. The company acknowledges the financial and legal risks from operating internationally, but there is no evidence that this recognition goes beyond compliance with regulations or that it specifically includes corruption risks. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes details of its fully consolidated subsidiaries. For each entity, the company discloses its percentage voting power \u2013 which is understood to also reflect the percentage ownership \u2013 and the country or place of incorporation. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company publishes the country of operation for each entity. It is also not clear whether this list includes all of the company\u2019s holdings, since it does not appear to include non-fully consolidated entities such as joint ventures or associates. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed on the New York Stock Exchange and is therefore not required to further disclose information on its beneficial ownership. Based on the scoring criteria, the company receives a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"1","comments":"
The company publishes information on its sales by customer to indicate that the U.S. Government accounted for 66% of its sales in the most recently reported financial year. There is evidence that this information is published annually, as part of the company\u2019s Annual Report. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not clearly provide figures to distinguish between defence and commercial sales and does not indicate its main defence customers for 80% of its sales. Although the company identifies the U.S. Deoartment of Defense as its primary customer, it is not clear whether the remaining U.S. government sales are defence or commercial. In addition, the company provides information on its revenue by geographic region, but this appears to include total sales across divisions. <\/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\/516","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=516"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=516"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}