There is evidence that the company\u2019s Code of Conduct, which outlines its stance against bribery and corruption, is authorised and endorsed by the board and the Chief Executive Officer. However, the company receives a score of \u20181\u2019 because there is no evidence that the company\u2019s leadership makes a direct commitment to anti-bribery and corruption. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company has an anti-bribery and corruption policy as part of its Code of Conduct. The company\u2019s policy clearly prohibits bribery, payments to public officials, commercial bribery and facilitation payments. There is evidence that this policy applies to all employees and board members, including non-executive directors, as well as the staff and leadership of subsidiaries and other controlled entities. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated board committee \u2013 the Audit Committee \u2013 is responsible for providing oversight of the company\u2019s anti-corruption programme. There is evidence that the Audit Committee\u2019s oversight responsibilities include reviewing reports from management on the programme\u2019s performance, along with the results of audits, and there is evidence that it has the authority to ensure that any required changes are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that the General Counsel 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 board, as well as to the board-level Audit Committee responsible for oversight of such activities. There is evidence of reporting and feedback activities between the General Counsel 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 in place that informs the design of its anti-bribery and corruption programme. There is evidence that the results of risk assessments are reviewed by the board-level Audit Committee that oversees the programme. There is also evidence that the results of such reviews are used to develop tailored mitigation plans and to update specific parts of the company's anti-bribery and corruption programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
There is evidence that the company\u2019s entire anti-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. There is evidence that the company conducts annual internal audits, supplemented by external audits, on a regular basis. There is evidence that the Audit Committee reviews audit findings on an annual basis, and that that the company\u2019s management are tasked with implementing required changes identified through audits. <\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
There is evidence that the company publicly commits to investigating incidents promptly and objectively, and that it has a specific procedure in place to deal with whistleblowing cases. The company provides information on its investigative procedure with documentation and actions to be taken at each step, from receipt to final outcome. The company commits to informing whistleblowers of the outcome of investigations, if they so wish. <\/p>\n
In addition, there is evidence that all investigations are handled by independent teams. There is evidence that the company\u2019s Corporate Ombudsperson's Office gathers and reviews summary information on investigations and that this body submits reports on investigations to the company\u2019s Audit Committee on a regular basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"2","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 the staff conducting investigations are properly qualified and trained to perform this function. There is some evidence that the company has a procedure for handling complaints about the investigation process; the company states that concerns are raised to an appropriate higher level for review. In addition, there is evidence that investigations are conducted under the Corporate Ombudsman programme, which is subject to an annual review. <\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
There is evidence that the company commits to report significant findings from ethics and corruption investigations to board via the Audit Committee. In addition, there is evidence that company\u2019s General Counsel is responsible for ensuring that the disclosure of criminal offences to relevant authorities is evaluated and acted upon if necessary.<\/p>\n"},{"question":63,"commitment_area":8,"score":"2","comments":"
There is evidence that the company publishes high-level data from bribery and corruption-related incidents and investigations involving company employees at all levels. This includes the number of reports received, information about the number of investigations launched and the number of disciplinary actions as a result of investigation findings. There is evidence that the company publishes and updates this data on an annual basis. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides training for its employees that outlines the basic principles of its anti-bribery and corruption policy, as well as providing details of the whistleblowing options available. There is evidence that the company provides this training to all employees across all divisions and countries of operation, and in all appropriate languages. The company indicates that all employees receive this training during the onboarding process. <\/p>\n
Although the company states that employees receive clear communications on anti-corruption in annual and quarterly meetings, there is no publicly available evidence that employees are required to refresh their training on the company\u2019s anti-bribery and corruption programme and whistleblowing options on a regular basis or every three years.<\/p>\n"},{"question":65,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides tailored training on its anti-bribery and corruption programme to employees based on the different levels of risk facing those in different roles. There is evidence that the company provides tailored training to employees in high risk positions, as well as for middle management and board members. The company indicates that all categories of employees must refresh their training regularly or at least annually, and states that middle management must certify their understanding of the Code of Conduct on an annual basis. <\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
There is evidence that the company measures and reviews the effectiveness of its anti-corruption training programme. There is evidence that the company has a system in place to do this, through an annual employee survey and regular monitoring and assessments of the programme. The company indicates that it undertakes such reviews on at least an annual basis, and there is evidence that the results are used to update specific parts of its anti-bribery and corruption communications and training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company\u2019s incentive schemes for employees incorporate anti-bribery and corruption principles. The company indicates that where employees receive performance-based pay, such incentives are calculated based on performance appraisals which include a qualitative assessment of the employee\u2019s behaviours in line with the company\u2019s Code of Conduct. The company states that per deal incentives are uncommon but that where such incentives are provided they are designed to discourage corrupt practices. <\/p>\n
The company receives a score of \u20181\u2019 because there is no clear evidence that it adjusts its incentive schemes to account for employees in high risk positions and ensures that incentives are proportionate to the employee\u2019s base salary in such cases. <\/p>\n"},{"question":68,"commitment_area":9,"score":"2","comments":"
There is evidence that the company publicly commits to protect and support any employee who refuses to act unethically, in keeping with the company\u2019s anti-corruption commitments, even where such actions may result in a loss of business or another disadvantage to the company. There is evidence that the company assures itself of its employees' confidence in this commitment through anonymised 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, including those engaged by the group as third parties, suppliers and joint venture partners. There is evidence that the company seeks to assure itself of its employees\u2019 confidence in the commitment through monitoring the usage statistics of whistleblowing channels and employee surveys.<\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides both whistleblowing and advice channels for its employees to report concerns and seek advice on its anti-bribery and corruption programme. There is evidence these channels allow for confidential and anonymous reporting. The company indicates that these channels are available to all employees in all locations and in multiple languages, including those engaged as third parties, suppliers and joint venture partners. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it provides an external channel for employees to report concerns or incidents, such as an independently-operated hotline. <\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence that the company formally addresses conflicts of interest as a corruption risk, and that it has a policy that defines conflicts of interest, including actual, potential and perceived conflicts. The company\u2019s policy clearly addresses possible conflicts arising from personal employee relationships, government relationships, financial interests and outside employment. There is evidence that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities. <\/p>\n"},{"question":72,"commitment_area":10,"score":"2","comments":"
There is evidence that the company has procedures in place to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company indicates that employee declarations are reviewed by a \u201cdesignated risk leader\u201d along with relevant managers, Human Resources (HR) and the legal counsel, while the Governance and Public Affairs Committee reviews any potential conflicts involving directors. There is evidence that employee and director declarations are held in a dedicated online register. The company provides some examples of criteria for recusals and there is evidence that disciplinary measures apply if the policy is breached.<\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy which includes controls to assess and regulate employment and offers of employment or consultancy engagement to public officials. This policy prohibits employees from entering into employment discussions with government officials or individuals from the public sector while they can influence decisions relating to the company. In addition, there is evidence that the company has a policy to implement a cooling-off period of one to two years depending on the circumstance, in line with the mandatory requirements in a particular jurisdiction. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that it conducts a review of actual, potential or perceived conflicts of interest when any former government employees join the company, nor is it clear that the company may place restrictions on their activities if such conflicts are identified. It is noted that the company has a \u2018Hiring From the Government Implementing Procedure\u2019 which may contain more information, but this is not publicly available. <\/p>\n"},{"question":74,"commitment_area":10,"score":"2","comments":"
The company publishes a clear statement that it does not currently engage any serving politicians contracted as consultants. There is evidence that this statement accounts for the most recently reported financial year.<\/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 indicates that it may make political contributions in line with its policy and with prior approval from the Corporate Government Affairs department, a company officer or the GE counsel. There is evidence that the company has criteria in place for donations and that a dedicated board-level committee \u2013 the Governance and Public Affairs Committee \u2013 is responsible for overseeing all political spending and any associated activities. 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":"
The company publishes a statement that it has not made any corporate political donations in the most recently reported financial year. In addition, there is evidence that the company publishes full details of the contributions made through its Political Action Committee (PAC) in the United States, by providing a link to its official disclosures. This data includes details of the recipient, amount and the name of the corporate entity that made the contribution. There is evidence that this data is updated and published on at least an annual basis. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has policies on both charitable donations and sponsorships, whether made directly or indirectly through its corporate foundation. There is evidence that any charitable donations and sponsorships must comply with a range of company policies to ensure their integrity. The company publishes details of its charitable contributions over $10,000, including the name of the recipient organisation, amount and corporate entity that made the payment. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes full details of all charitable donations or sponsorships made, including those under $10,000. In addition, the company does not provide further publicly available information on the specific procedures and controls in place to regulate these donations, such as procedures for senior sign-off or due diligence on recipients.<\/p>\n"},{"question":78,"commitment_area":11,"score":"2","comments":"
There is evidence that the company has a policy and procedures on lobbying that specify certain standards of conduct and oversight mechanisms. There is evidence that company\u2019s Vice President of Government Affairs & Policy provides oversight and prior approval of all lobbying activities. In addition, the company indicates that it has specific policies and procedures in place to ensure that lobbying is conducted responsibly, including dedicated training for lobbyists and restrictions on gifts and hospitality. It is clear that this policy applies to both employees engaged in lobbying activities and any third party lobbyists approved by the VP of Government Affairs & Policy. <\/p>\n"},{"question":79,"commitment_area":11,"score":"2","comments":"
The company publishes a list of the topics on which it lobbies, including a description of its core positions, their importance or relevance to the company and stakeholders, and the activities it carries out. There is evidence that this represents lobbying activities conducted by both the company\u2019s employees and any third parties engaged in lobbying on its behalf. In addition, it is clear that these points represent the aims and topics in all jurisdictions where the company conducts lobbying activities.<\/p>\n"},{"question":80,"commitment_area":11,"score":"1","comments":"
There is evidence that the company publishes its lobbying expenditure in the United States, by providing a link to its official disclosures. There is evidence that this information is correct up to the most recent quarter of the financial year. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further details of its lobbying expenditure, to indicate details such as the corporate entity, geography, internal lobbyists\/external lobbyists\/association lobbying and an explanation of how the figures in the data have been calculated. Additionally, the company does not provide a clear statement regarding its lobbying expenditure outside the United States.<\/p>\n"},{"question":81,"commitment_area":11,"score":"2","comments":"
There is evidence that the company has a policy on the giving and receipt of gifts and hospitality with clear procedures to ensure that such expenses are not used as vehicles for bribery or corruption. The company\u2019s policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. There is evidence the policy addresses the risks associated with gifts and hospitality given to and\/or received from domestic and foreign public officials, by specifying a different financial threshold. In addition, there is evidence that gifts and hospitality are recorded in a dedicated register that is accessible to those responsible for oversight of the process. <\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is evidence that the company's procurement department is the main body involved in the establishment and oversight of supplier relationships. However, the company receives a score of \u20181\u2019 because there is no evidence that the company takes steps to assure itself of the proper functioning of this system or that the procurement department is appropriately involved in the process, such as through regular audits. <\/p>\n"},{"question":83,"commitment_area":12,"score":"2","comments":"
There is evidence that the company has formal procedures to conduct anti-bribery and corruption due diligence on all suppliers. There is evidence that the highest risk suppliers are subject to enhanced due diligence and the process includes checks on ultimate beneficial ownership. There is evidence that the company will not onboard a supplier, and will also terminate an existing relationship, if a red flag identified in due diligence cannot be mitigated. In addition, there is evidence that such checks on suppliers are repeated throughout the relationship, with audits conducted every one to three years depending on the level of risk and on-site assessments every one to five years. <\/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 and procedures in place, by stating that all suppliers must adhere to its Integrity Guide for Suppliers Contractors and Consultants. This document prohibits bribery, refers to gifts and hospitality and offers of employment, and provides details of the company\u2019s whistleblowing line. There is evidence that the company conducts ethical evaluations of its suppliers when onboarding them, and thereafter every one to five years, although the company does not refer specifically to assessing the anti-bribery and corruption policies of suppliers.<\/p>\n
The company receives a score of \u20181\u2019 because it is not clear from publicly available evidence that it requires suppliers to have policies in place which prohibit facilitation payments and regulate conflicts of interest.<\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
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. The company states that it expects its suppliers to communicate these standards throughout the supply chain, and indicates that it conducts audits on subcontractors in sub-tiers to ensure compliance. <\/p>\n"},{"question":86,"commitment_area":12,"score":"1","comments":"
The company provides some data on environmental, social and governance audits of its suppliers, which includes incidents related to ethics and corruption. This data includes the number of audits conducted and the total number of findings, and there is evidence that this data is published on an annual basis. <\/p>\n
The company receives a score of \u20181\u2019 because there is no evidence that it clearly publishes information on the number of investigations launched and the number of disciplinary actions as a result of investigation findings for suppliers specifically. <\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has a policy and procedure on the use of agents, which addresses the corruption risks associated with their use. The company states that it seeks to establish and verify that the use of agents is, in each case, necessary to perform a legitimate business function. There is evidence that this policy applies to all divisions within the organisation that might employ agents, including subsidiaries and majority-controlled joint ventures. <\/p>\n"},{"question":89,"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 engaging and re-engaging its third parties and agents and when there is a significant change in the business relationship. The company also states that agents and higher risk intermediaries are subject to enhanced due diligence requirements. There is evidence that the company commits to not engaging or terminating its engagement with agents or intermediaries where the risks identified in the due diligence process cannot be mitigated. <\/p>\n"},{"question":90,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has formal procedures in place to establish the beneficial ownership of agents prior to engaging them and when there is a significant change in the business relationship. There is evidence the company operates a risk-based beneficial ownership verification policy. There is evidence indicating that the company will not engage or will terminate its engagement with agents or intermediaries where ultimate beneficial ownership cannot be established.<\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
There is evidence that the company\u2019s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on its behalf. There is evidence that agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include audit rights and termination rights to detect, control and prevent breaches.<\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company indicates that payments to agents are based on market rates and that payments are made according to clear milestones. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that incentives or commission payments must be proportionate to the net fee or that payments must be made 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 or on its behalf. The company states that it does not publish such information. <\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
There is no clear evidence that the company publishes high-level data from all ethical or bribery and corruption-related incidents and investigations involving its agents. The company publishes data on corruption-related investigations and disciplinary actions involving its entire workforce, but there is no evidence that it disaggregates this information to specifically show any investigations and actions against agents. <\/p>\n"},{"question":100,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to entering into, and while operating as part of, joint ventures. The company indicates that due diligence on joint ventures includes establishing ultimate beneficial ownership of the partner company and that high-risk potential partners are subject to enhanced due diligence. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the company repeats due diligence at least every two years or when there is a significant change in the business relationship.<\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies in all of its joint ventures. The company requires its majority controlled joint ventures to adopt and follow its anti-corruption policies and states that it will encourage non-controlled ventures to do the same. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that includes audit and termination rights in its contracts with joint venture partners to detect, control and prevent breaches.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no clear publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. The company indicates that majority controlled joint ventures must adopt and follow its anti-corruption policies and states that it encourages non-controlled entities to do the same, but does not provide any further information or practical details of how it assures itself of this in practice.<\/p>\n"},{"question":103,"commitment_area":14,"score":"2","comments":"
There is evidence that the company has policies and procedures in place to address the corruption risks associated with offset contracting. The company states that it has a dedicated Offset Team responsible for the monitoring and oversight of the company\u2019s offset activities and any potential risks throughout the lifecycle of the project. In addition, there is also evidence that all employees within this team receive tailored anti-bribery and corruption training to perform this function. <\/p>\n"},{"question":104,"commitment_area":14,"score":"2","comments":"
There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations. As part of this process, the company commits to establishing and verifying the legitimacy of the proposed offset activity or investment and to mitigating any possible conflicts of interest. There is evidence that the company refreshes due diligence when there is a significant change in the business relationship. Although the company does not explicitly mention beneficial ownership, it provides sufficient evidence that it checks the beneficiaries of projects and there is accompanying information on beneficial ownership checks as part of its third party due diligence processes, so the company can receive a score of \u20182\u2019. <\/p>\n"},{"question":105,"commitment_area":14,"score":"N\/A","comments":"
The company publishes a statement that it does not engage brokers or agents as part of its offset activities. The company is therefore exempt from scoring on this question. <\/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. The company states that it may communicate this information on a case by case basis, but there is no evidence that it has made such disclosures. <\/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 an assessment process in place to account for these specific risks, with risk management procedures in place. There is evidence that the results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. The company provides examples of such controls.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a list of its fully consolidated subsidiaries. For each entity, the company publishes information on the percentage ownership and country of incorporation. There is evidence that this information is published and updated on an annual basis.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes the country or countries of operation for each entity. There is also evidence to indicate that this list only shows principal affiliates as opposed to a comprehensive list of all of the company\u2019s fully consolidated and non-fully consolidated holdings. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is a subsidiary of General Electric, which is publicly listed on the New York Stock Exchange. The company is therefore not required to disclose further information on its beneficial ownership to receive a score of \u20182\u2019. In addition, the company publishes details of its two major shareholders with a stake over 5% in its corporate reporting documents.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is evidence that the company publishes some information on its defence sales, to indicate that the United States government accounts for 5% of its total revenue and that defence-related sales account for 5% of its total revenue. There is some indication that the company provides products and services for Airbus and Boeing.<\/p>\n
The company receives a score of \u20180\u2019 because it does not publish clear information about the main recipients of its defence sales, to indicate the customers for approximately 50% of its defence sales.<\/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\/517","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=517"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=517"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}