There is evidence that 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 a clear 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 the board-level Compliance Committee provides oversight of the company\u2019s anti-bribery and corruption programme. There is evidence that the committee reviews reports from management and the results of internal and external audits, and that it has the authority to require that any necessary changes to the programme 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 \u2013 the Compliance Officer \u2013 has ultimate responsibility for implementing the company\u2019s anti-corruption program. This person has a direct reporting line to the board and the Compliance Committee. There is evidence of reporting and feedback activities between this person and the board as part of the company\u2019s reporting structure.<\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a formal corruption risk assessment procedure that informs the design of its anti-corruption programme. There is evidence that the results of the risk assessments are reviewed annually by the Compliance Committee. In addition, there is evidence to indicate taht the results of such asessments are used to update specific parts of the company\u2019s anti-bribery and corruption programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s entire anti-corruption programme is subject to regular audit. The company indicates that this includes provisions for continuous improvement, supplemented by an internal audit every year. In addition, there is evidence that audit findings are presented to the board, with ownership assigned to the Compliance Committee for amendments to the anti-corruption programme. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly commits to investigating incidents and that it has a specific procedure in place to deal with whistleblowing cases. There is evidence that this procedure covers the whole investigation process from receipt to final outcome, and that it includes a commitment to providing whistleblowers with updates on the outcome of investigations. The company commits to put in place remediation plans and report investigative findings to senior management and the board upon the completion of every investigation. There is evidence to indicate that investigations are only undertaken by a qualified, independent team. <\/p>\n
However, the company receives a score of \u20191\u2019 because there is no clear evidence that a central body reviews the status of all investigations on an annual basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company assures itself of the quality of its internal investigations, both for incident investigations and whistleblowing cases. There is evidence that staff conducting investigations are properly trained and qualified, and the company provides an explanation of how complaints about the investigation process are handled and who is responsible for handling such complaints. <\/p>\n
However, there is no evidence that the company reviews its investigations procedure at least every three years or in response to any changes in the regulatory environment. <\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the Compliance Team commits to report material findings of bribery and corruption from investigations to the board and to the relevant authorities. The company indicates that the Compliance Team 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":"1","comments":"
Based on publicly available information, there is evidence that the company publishes some high-level information on its ethics and compliance-related incidents and investigations involving company employees. The data is updated on at least an annual basis. <\/p>\n
However, the company receives a score of \u20191\u2019 because there is no evidence that the company publishes disaggregated information to indicate the number of reports received, including those received through whistleblowing channels, and the number of disciplinary actions as a result of investigation findings.<\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides training to its employees that outlines the principles of the anti-bribery and corruption policy, including 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 states that employees are required to undertake refresher courses or modules on the anti-bribery and corruption programme at least every three years.<\/p>\n"},{"question":65,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company tailors its anti-bribery and corruption training programme to the different levels of risk facing employees in different roles, with specific reference to the categories of employee listed in the question. There is evidence that employees working in high risk positions, such as those in sales and government relations, are required to refresh their training in this area on an annual basis. <\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme. There is evidence that the company has a system in place for doing this, in the form of staff surveys and employee tests. The company assures itself of this on an annual basis and there is evidence indicating that the results are used to update specific parts of the company's anti-bribery and corruption communications and training program. <\/p>\n"},{"question":67,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s incentive schemes incorporate ethical and anti-bribery and corruption principles. There is evidence to suggest that incentives are designed to reward behaviour in line with the company\u2019s ethical values. There is evidence that the policy applies to high-risk employees, such as sales roles.<\/p>\n"},{"question":68,"commitment_area":9,"score":"1","comments":"
There is evidence that the company commits to protecting and supporting employees who refuse to act unethically, even where such actions result in a loss of business or another disadvantage to the company. There is evidence that the company conducts surveys to understand employee perceptions and confidence in its Compliance Program generally. However, based on publicly available information, there is no clear evidence that the company assures itself of its employee\u2019s confidence in this commitment specifically. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","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 bribery and corruption incidents. The company\u2019s policy clearly applies to all employees across the company, including those engaged by the group as third parties, suppliers and joint venture partners.<\/p>\n
However, although there is evidence that the company measures its employees\u2019 confidence in its company\u2019s compliance programme generally, there is no clear evidence that the company specifically assures itself of its employees\u2019 confidence in this commitment through surveys, usage data or other clearly stated means. <\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has multiple channels 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 to external parties through an independently-operated hotline. These channels allow for confidential and, wherever possible, anonymous reporting. There is evidence that these 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 multiple 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 that defines conflicts of interest, including actual and potential conflicts. The policy applies to all employees and board members, including those of subsidiaries and other controlled entities. The policy explicitly covers employee and government relationships, financial interests and other employment. <\/p>\n
However, the company receives a score of \u20191\u2019 because there is no clear publicly available evidence that its policy covers perceived conflicts of interest. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has procedures to declare and manage conflicts of interest, including actual and potential conflicts. The company indicates that the Compliance Team and the Audit Team are responsible for managing conflict of interest cases. The company states that disciplinary measures will apply if the policy is breached. <\/p>\n
However, there is no evidence that all employee and board member declarations are held in a dedicated central register or database that is accessible to those responsible for oversight of the process. There is also no evidence that the company provides examples of criteria for recusals. <\/p>\n"},{"question":73,"commitment_area":10,"score":"2","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 current and recently departed public officials, including politicians. The company requires senior compliance office approval for the initiation of any employment discussions with former or current public officials. There is evidence that the company has a policy to implement a cooling-off period of at least 36 months before such public officials are permitted to have any form of contact or relationship with their former organisation on the company\u2019s behalf.<\/p>\n"},{"question":74,"commitment_area":10,"score":"2","comments":"
The company publishes a clear statement that it does not hire or engage the services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"2","comments":"
There is evidence that the company has a policy on corporate political contriubtions, which clearly states that such donations are prohibited. There is evidence that this policy applies to all types of contributions, whether made by the company itself or by any other entity or individual acting on the company\u2019s behalf. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
The company publishes a clear statement that it does not make any political contributions, and is therefore exempt from scoring on this question. <\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is evidence that the company has a policy and procedure covering charitable donations to ensure that such donations are not used as vehicles for corruption. The company\u2019s policy includes clear criteria for donations and procedures for prior approval of any donations. The company publishes some details of its charitable donations, including the name and targets of each donation made for the most recently reported financial year. <\/p>\n
However, the company receives a score of \u20191\u2019 because there is no evidence that the company publishes the amount or value of each donation made in the most recently reported financial year. <\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
The company publishes a clear statement that it does not conduct lobbying activities. The company receives a score of \u20181\u2019 because it is not clear from publicly available information whether this approach also applies to any lobbing activities conducted in other jurisdictions. There is no publicly available evidence that the company publishes a clear policy to regulate its lobbying activities in other jurisdictions, nor does it publish a statement to indicate that it does not lobby outside Korea.<\/p>\n"},{"question":79,"commitment_area":11,"score":"N\/A","comments":"
The company publishes a clear statement that it does not conduct lobbying activities, and therefore it is exempt from scoring on this question.<\/p>\n"},{"question":80,"commitment_area":11,"score":"N\/A","comments":"
The company publishes a clear statement that it does not conduct lobbying activities, and therefore it is exempt from scoring on this question.<\/p>\n"},{"question":81,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. The company\u2019s policy addresses the risks associated with gifts and hospitality given to public officials and that it specifies financial limits and different approval procedures for different types of promotional expenses. In addition, there is evidence that all gifts and hospitality are recorded in a dedicated central register, which is accessible to those responsible for oversight of the process.<\/p>\n"},{"question":82,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u00b4s procurement department is involved in the establishment and oversight of supplier relationships. The company indicates that its Procurement Team is the main body responsible for oversight of the company\u2019s supplier base. There is evidence that the company assures itself of the procurement department\u2019s involvement on an annual basis. <\/p>\n"},{"question":83,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has formal procedures to conduct due diligence on all of its suppliers. Due diligence is conducted when engaging with new suppliers. There is evidence indicating that due diligence includes checks on the supplier\u2019s ownership and that the company would be willing to terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated. There is some evidence indicating that the highest risk suppliers are subject to enhanced due diligence. In addition, the company\u2019s information indicates that such checks are repeated regularly throughout the supplier relationship. <\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence that the company ensures that all of its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company states that suppliers must adopt a code of conduct equivalent to its own, which covers conflicts of interest, gifts and hospitality and whistleblowing, and prohibits bribery. <\/p>\n
In addition, the company states that the Policy for Compliance with Anti-Corruption Acts, which prohibits facilitation payment, applies to suppliers. There is evidence that the company ensures this in practice through contractual terms and assures itself of this when onboarding new suppliers and through monitoring rights in its contracts with third parties.<\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is 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 indicates that its suppliers ensure that their own subcontractors adhere to its anti-bribery and corruption policy through contractual requirements. <\/p>\n"},{"question":86,"commitment_area":12,"score":"1","comments":"
The company provides some information on its ethical investigations relating to suppliers. There is evidence that the company undertook one investigation into a supplier in 2015 which led to corrective measures, and indicates that it has not conducted further investigtaions. <\/p>\n
The company receives a score of \u20181\u2019 because there is no evidence that it provides further data on its investigations, nor is it clear that the information provided represents all supplier incidents and allegations. <\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a clear policy and procedure to control the use of agents which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. There is evidence that this policy also applies to subsidiaries and joint ventures. <\/p>\n"},{"question":89,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, 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 with its third parties and agents. There is evidence that due diligence is repeated when there is a significant change in the business relationship. There is some evidence to indicate that agents and the highest risk intermediaries are subject to enhanced due diligence.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is evidence that the company asks agents to disclose their ownership to the company.<\/p>\n
However, there is no clear evidence the company commits to independently verify the beneficial ownership information of high risk agents. While the company states that it can terminate contracts in circumstances where the ownership of the agent raises a compliance issue, there is no clear evidence that the company commits to not enganging or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established. <\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. The company indicates that agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include audit and termination rights to detect, control and prevent breaches. <\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company states that it will use only local bank accounts for payments to agents. The company imposes a threshold on sales commissions to agents.<\/p>\n
However, there is no evidence that the company commits to pay the agent in stage payments over the course of their contract, based on clear milestones. The company also indicates the commission is based on a proportion of the net value of the total sale rather than the net fee to the agent.<\/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. The company publishes a statement that it does not disclose such information. <\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
There is no evidence that the publishes any data on ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving agents. The company publishes a statement that it does not disclose such information.<\/p>\n"},{"question":100,"commitment_area":13,"score":"N\/A","comments":"
The company publishes a clear statement that it does not operate as part of joint ventures, and therefore it is exempt from scoring on this question. <\/p>\n"},{"question":101,"commitment_area":13,"score":"N\/A","comments":"
The company publishes a clear statement that it does not operate as part of joint ventures, and therefore it is exempt from scoring on this question. <\/p>\n"},{"question":102,"commitment_area":13,"score":"N\/A","comments":"
The company publishes a clear statement that it does not operate as part of joint ventures, and therefore it is exempt from scoring on this question. <\/p>\n"},{"question":103,"commitment_area":14,"score":"N\/A","comments":"
The company indicates that it does not currently, and has not in the past, entered into any kind of offset contract with purchasing government. The company is therefore exempt from scoring on this question. <\/p>\n"},{"question":104,"commitment_area":14,"score":"N\/A","comments":"
The company indicates that it does not currently, and has not in the past, entered into any kind of offset contract with purchasing government. The company is therefore exempt from scoring on this question. <\/p>\n"},{"question":105,"commitment_area":14,"score":"N\/A","comments":"
The company indicates that it does not currently, and has not in the past, engaged the services of offset agents or brokers. The company is therefore exempt from scoring on this question. <\/p>\n"},{"question":106,"commitment_area":14,"score":"N\/A","comments":"
The company indicates that it does not currently, and has not in the past, entered into any kind of offset contract with purchasing government. The company is therefore exempt from scoring on this question. <\/p>\n"},{"question":107,"commitment_area":15,"score":"2","comments":"
Based on publicly available information, there is evidence that the company acknowledges the corruption risks associated with operating in different markets. There is evidence that it has a designated risk assessment process to account for these specific risks, with clear risk management procedures in place. The results of risk assessments inform the development and implementation of additional controls and there is evidence the company provides examples of such possible controls.<\/p>\n"},{"question":108,"commitment_area":15,"score":"2","comments":"
Based on publicly available information, there is evidence that the company publishes a list of its fully consolidated subsidiaries and non-fully consolidated subsidiaries. For each entity, the company discloses its percentage ownership and the country of incorporation and operation. There is evidence that this list is current and updated on at least an annual basis. <\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
There is evidence that the company discloses all entities with an ownership in the company of 5% or above. In addition, there is evidence to indicate that the company is publicly traded on the Korea Exchange (KEX). <\/p>\n
However, the company receives a score of \u20191\u2019 because there is no evidence that this information is available in open data format or in a freely accessible public register. Although the company is publicly traded, there is no evidence that it trades on one of the regulated markets with beneficial ownership requirements as listed in the scoring criteria. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is evidence that the company publishes some information on its major customers. The company lists its major customers for each significant business division (aviation and defence) and provides information on the total revenue generated from each division as part of its finanical statements. <\/p>\n
However, the company receives a score of \u20190\u2019 because it does not publish clear information to show the percentage breakdown of its defence sales or revenue per major 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\/571","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=571"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=571"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}