There is no evidence that the company has a publicly stated anti-bribery and corruption commitment, which is authorised and endorsed by the company\u2019s leadership. The company mentions bribery and corruption as behaviours that will not be tolerated but this is indirect and not supported by a senior leadership figure. <\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company has an anti-corruption policy, which prohibits bribery and applies to all employees and board members. <\/p>\n
However, the policy does not explicitly prohibit payments to public officials or facilitation payments. It is also unclear whether the policy applies to the staff and leadership of subsidiaries and other controlled entities. While the company states that more detail on its ethical commitments can be found in the GKN Aerospace Code and Policies, this document is not publicly accessible. <\/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 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 that 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 evidence that the company\u2019s anti-bribery and corruption programme is subject to regular audit or review. Although the company commits to reviewing and updating its policies as a result of any allegations of corruption, this is insufficient to receive a score of \u20181\u2019.<\/p>\n"},{"question":60,"commitment_area":8,"score":"0","comments":"
Although the company publicly commits to investigating incidents and providing feedback to whistleblowers, there is no clear evidence that of specific procedures in place to deal with complaints, which stipulates documentation and actions to be taken at each step. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no 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 relevant authorities.<\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
The company does not publish 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 evidence that the company provides training on the GKN Aerospace Code and Values to all employees. However, the company receives a score of \u20180\u2019 because it is unclear whether this includes the company\u2019s policies on anti-bribery and corruption and the company does not otherwise explicitly state that it conducts training on anti-bribery and corruption. <\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company provides different or 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 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":"0","comments":"
There is no publicly available evidence that the company has policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents. <\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
There is evidence that the company has an external whistleblowing hotline, which is available to all employees in all relevant languages and allows for anonymous and confidential reporting. <\/p>\n
However, there is no evidence that the company provides other reporting options, including advice channels for employees to ask questions about the company\u2019s anti-bribery and corruption policy or activities. Moreover, there is no clear evidence that the external channel is available to employees of third parties, suppliers or joint venture partners. <\/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. The company publishes a statement about avoiding conflicts of interest, but this is insufficiently detailed. While the company\u2019s Supplier Code of Conduct includes a conflict of interest statement, there is no evidence that this extends to GKN Aerospace employees. <\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company has procedures in place to manage conflicts of interest, which are overseen by a responsible body or individual.<\/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 on corporate political contributions.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company discloses any details of its political contributions.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy or procedure covering both charitable donations and sponsorships. There is evidence to suggest that that the company engages in charitable projects, but it does not provide further details regarding these activities. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
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":"0","comments":"
There is some evidence that the company has a policy on the giving and receipt of gifts and hospitality, but this appears to apply only to the company\u2019s suppliers, rather than its own employees. <\/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 and 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":"
There is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place, which prohibit bribery and facilitation payments, and that have procedures related to conflicts of interest and gifts and hospitality. The company also states that it has the right to audit suppliers and that it assures itself on an annual basis of its suppliers\u2019 adherence to its principles. <\/p>\n
However, it is unclear if it conducts this assurance for all suppliers, or whether the company assures itself of this whenever there is a significant change in the business relationship. Additionally, there is no evidence that the company\u2019s suppliers are required to have a procedure for whistleblowing. <\/p>\n"},{"question":85,"commitment_area":12,"score":"1","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. <\/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. <\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company has a clear policy covering the use of agents.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no publicly available 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":"
Based on publicly available information, 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":"
Although the company has a Supplier Code of Conduct, which requires suppliers to adopt anti-bribery and corruption policies, there is no evidence that this code applies to agents and intermediaries. Additionally, while the company\u2019s standard purchasing contracts include anti-bribery and corruption clauses, it is also not clear that these contracts apply to agents and intermediaries.<\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company's incentive structures for agents are designed to minimise risks of anti-bribery and corruption or that incentive structures are recognised 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 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":"
There is no 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. <\/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 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. There is 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":"
There is no evidence that the company has a procedure in place for conducting due diligence on its offset obligations.<\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company. <\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
The company does not publish any details of its offset obligations and\/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, or that risk assessment procedures are used to inform the company\u2019s operations in high risk markets. <\/p>\n"},{"question":108,"commitment_area":15,"score":"0","comments":"
The company does not publish a list of its subsidiaries. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is a wholly-owned subsidiary of a UK-listed company, Melrose Industries Plc. It therefore automatically receives a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"1","comments":"
The company publishes a percentage breakdown of its sales by customer, accounting for 71% of its sales. The company indicates that 29% of its total sales are defence-related. <\/p>\n
However, it is not clear which customers comprise its defence sales. It is also unclear whether this data is updated on an annual basis. <\/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\/518","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=518"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=518"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}