The company publishes an explicit anti-corruption message which is endorsed by its CEO.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company has an anti-corruption policy which prohibits bribery, commercial bribery, facilitation payments and payments to government officials. Evidence indicates that this policy applies to all employees and directors of the company, as well as all employees and leadership of subsidiaries and other controlled entities. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that the board and the audit committee are ultimately responsible for the oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from management on the programme\u2019s performance, along with the results of internal and external audits, and ensuring that required changes are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is clear evidence that a designated senior executive 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. 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, the company has a formal bribery and corruption risk assessment procedure that informs the design of the anti-bribery and corruption programme. The company also states 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. The results of risk assessments are reviewed by the board on at least an annual basis. <\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
There is evidence that the company\u2019s entire anti-bribery and 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. The company states that it continually monitors and improves its programme, which undergoes an annual review. There is also evidence that high-level audit findings are presented to the board, and that the company\u2019s compliance department holds responsibility for implementing planned updates and improvements to the anti-corruption programme.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
The company publicly commits to investigating incidents promptly, independently and objectively. The company states that corruption investigations are carried out by an external team or by an investigations unit within the legal department. The company states that all allegations and investigative steps are documented, and that the senior management, the relevant divisional leadership and the legal department are informed of the status and outcomes of all investigations. The company commits to informing whistleblowers of the outcome of investigations if they so wish. The company also states that as part of each investigation root causes are examined and remediation plans implemented if appropriate. <\/p>\n
However, although the company states that all investigations are reported to senior management, it is not clear how frequently this occurs.<\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
There is evidence that the company assures itself of the quality of both its internal investigations and whistleblowing investigations. The company indicates that its investigators are properly trained and qualified, or that investigations are carried out by specialist external investigators. The company states that its investigations process is reviewed annually.<\/p>\n
However, there is no information about how complaints about the investigation process are handled. <\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
The company states that either the Chief Compliance Officer, Chief Legal Officer, or CEO will report material findings of corruption to the board of directors. There is evidence that the company\u2019s Chief Compliance Officer and Chief Legal Officer hold joint responsibility for disclosing findings to the relevant external authorities. <\/p>\n"},{"question":63,"commitment_area":8,"score":"1","comments":"
The company publishes a statement that it has not received any corruption-related internal reports or whistleblowing reports in the last 12 months and has not initiated any corruption-related investigations. <\/p>\n
However, the company\u2019s statement is not dated and it is unclear whether it updates this information annually. <\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides a training module that outlines the basic principles of its anti-bribery and corruption policy, including the company\u2019s whistleblowing and reporting options. This training is mandatory for all employees and must be completed annually. The company also states that training is provided in all appropriate languages. <\/p>\n"},{"question":65,"commitment_area":9,"score":"2","comments":"
Evidence suggests 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 referred to in the question. There is evidence that employees working in high risk positions, including those in sales and government relations are required to refresh their training in this area on at least an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
The company states that it regularly reviews and measures the effectiveness of its anti-corruption training and communications programme, in line with any regulatory changes, industry best practice and any identified trends. The company states that it also employs external parties to assess its training programme.<\/p>\n
However, there is no evidence that the company uses KPIs, scenario tests or employee surveys or other clearly stated means to measure the effectiveness of its training. It is also unclear whether reviews are used to modify specific parts of the training programme or how frequently the company reviews its training programme. <\/p>\n"},{"question":67,"commitment_area":9,"score":"2","comments":"
There is evidence that the company\u2019s incentive schemes incorporate ethical and anti-bribery and corruption principles. According to publicly available information, with the exception of certain hourly employees, all employees have Annual Performance Agreements which have a compliance element included as a component of their financial remuneration. This agreement involves an evaluation of whether or not employees\u2019 actions are in line with company values. The company also states that it accounts for incentives as a corruption risk for those in high risk positions such as sales by not including incentives linked directly to sales generated.<\/p>\n"},{"question":68,"commitment_area":9,"score":"2","comments":"
There is evidence that any employee who refuses to act unethically, in keeping with the company\u2019s ethical and anti-bribery and corruption values and policy, will be protected and supported even where such actions result in a loss of business or another disadvantage to the company. The company states that it assures itself of its employees' confidence in this commitment through surveys on the company\u2019s whistleblowing and reporting channels.<\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":"
There is evidence that any employee who refuses to act unethically, in keeping with the company\u2019s ethical and anti-bribery and corruption values and policy, will be protected and supported even where such actions result in a loss of business or another disadvantage to the company. The company states that it assures itself of its employees' confidence in this commitment through surveys on the company\u2019s whistleblowing and reporting channels.<\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
The company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. These channels, which include an externally operated hotline, are sufficiently varied to allow employees to raise concerns across the management chain and to relevant external bodies. These channels allow for confidential and anonymous reporting, and are available in multiple languages. The company states that all its reporting and whistleblowing options are available to all third parties, including suppliers and joint venture partners. <\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
The company has a policy on conflicts of interest which refers to actual, potential and perceived conflicts. This policy is set out in the Code of Ethics and Business Conduct which applies to all employees and directors as well as non-employees who act on the company\u2019s behalf in any capacity. The policy explicitly covers employee relationships, government relationships, financial interests and other employment. <\/p>\n"},{"question":72,"commitment_area":10,"score":"2","comments":"
The company indicates that it has a governance committee that has oversight of conflicts of interest. It also suggests that any violations of the Code of Ethics and Business Conduct, containing its conflicts of interest policy, are subject to disciplinary measures, including potential termination of employment. There is evidence indicating that the company\u2019s Ethics and Business Conduct Office maintains all employee and board member conflicts of interest declarations in a central database. The company additionally 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 that addresses the risks associated with the employment of US public officials. The company states that it will only hire former officials after one to two years of a cooling-off period. The company states that it requires permission from the legal department to initiate recruitment discussions with a background in the public sector. The company states that all potential public sector hires are screened to avoid scenarios which might appear to represent a conflict of interest. The above procedures relate to former US public officials, where the company does the vast majority of its business. The company states that in recruiting former officials of other jurisdictions it will apply measures consistent with anti-corruption policies and local legal and regulatory restrictions. <\/p>\n"},{"question":74,"commitment_area":10,"score":"1","comments":"
The company states that it has a policy to not contract serving US politicians. It also indicates that will only contract foreign serving politicians if there are no actual or perceived conflicts of interest. The company states that it does not currently contract any foreign or domestic serving politicians.<\/p>\n
However, it is not clear that the company updates this information on an annual basis. <\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
The company recognises political activities as a corruption risk and has a policy governing its activities in this area. However, the company permits certain political donations and has a Political Action Committee, and therefore receives a score of \u20180\u2019. <\/p>\n"},{"question":76,"commitment_area":11,"score":"2","comments":"
The company publishes some information about its political donations and therefore receives a score of \u20182\u2019. <\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
The company states that it has a policy regarding charitable donations, as referred to in its Code of Ethics and Business, to ensure that they are free from corruption. The company states that the recipients of its charitable donations undergo anti-corruption risk-based due diligence. The company discloses some information about the recipients of its charitable donations, but does not provide full details. <\/p>\n
However, the company receives a score of \u20180\u2019 because there is no evidence that it has a policy and\/or procedure covering sponsorships.<\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
The company has a policy covering responsible lobbying, and provides an overview of its expected standards of conduct comprising responsible lobbying. The company recognises lobbying as a corruption risk and outlines a number of risk mitigation procedures and oversight mechanisms, including due diligence on external lobbyists, reporting obligations, anti-corruption contractual agreements and tailored anti-corruption training for staff overseeing lobbying activities. The company also clarifies that its policy on lobbying only applies to the US because it is the only jurisdiction where it conducts lobbying activities. The policy applies to all employees and third parties. <\/p>\n
However, the company does not clearly outline the specific corruption risks commonly associated with lobbying, such as conflicts of interest, gifts and hospitality and undue influence. Additionally, the company does not specify that its policy also applies to board members. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
The company states that it does not conduct lobbying activities outside the US. The company states that it files disclosures to the United States Congress, which includes information on the topics and aims of the company\u2019s lobbying campaigns. However, the company does not publish information on its lobbying activities on its website or in its reports. It does not provide direct links to the relevant lobbying information disclosed externally. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
The company states that it does not conduct lobbying activities outside of the US. The company also states that it discloses its federal lobbying activities externally. The company, however, does not directly disclose this information on its website or in its reports.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy and\/or procedure on the giving and receipt of gifts and hospitality to ensure that they are not used for corrupt purposes. This explicitly states that employees should never provide or accept business courtesies from domestic or foreign officials. The company also specifies a clear financial threshold, which stipulates senior sign off. <\/p>\n
However, while the company states that all gifts and hospitality are overseen by the company\u2019s Compliance Office, there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or depository accessible to those with oversight responsibility. <\/p>\n"},{"question":82,"commitment_area":12,"score":"2","comments":"
There is evidence that the company requires the involvement of divisional procurement departments in the establishment of all new suppliers. These departments are ultimately responsible for providing oversight of the company's supplier base. There is evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed annually through internal audits. The company states that its procurement procedures are also subject to periodic external audit.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
The company has formal procedures to conduct risk-based due diligence on its suppliers. The company states that due diligence checks on all suppliers include checks on ultimate beneficial ownership, and there is some evidence indicating that high risk suppliers are subject to enhanced due diligence. The company states that all suppliers undergo renewed due diligence annually. <\/p>\n
However, the company does not commit to not engaging a supplier or terminating a supplier agreement if a red flag identified in due diligence cannot be mitigated.<\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
There is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. It is explicitly stated that all suppliers must have, at a minimum, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, as well as policies and procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. The company encourages suppliers to develop their written policies and provides example policies and procedures on its supplier website. The company states that it carries out an assessment of suppliers\u2019 anti-corruption programmes and procedures, and that this assurance is carried out when there is a significant change in the business relationship.<\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
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. <\/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, or the associated disciplinary actions. <\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has a policy and procedures 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, including contractual provisions, due diligence and oversight of activities. 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. The company states that this policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures. <\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
The company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with all third parties, including agents and intermediaries. The company states that all higher risk agents and intermediaries are subject to enhanced due diligence, and that all agents and intermediaries undergo due diligence every two years or whenever there is a significant change in the business relationship. <\/p>\n
However, the company makes no clear commitment not to engage or to terminate a supplier relationship if a red flag identified in due diligence cannot be mitigated.<\/p>\n"},{"question":90,"commitment_area":13,"score":"1","comments":"
Based on publicly available evidence, the company has formal procedures to establish the beneficial ownership of agents prior to engaging them. The company operates, as a minimum, a risk-based beneficial ownership verification policy, whereby all agent provided information is verified; high-risk agents\u2019 information is independently verified by the company\u2019s Corporate Compliance Manager. The company commits to not engaging or terminating its engagement with agents or intermediaries where ultimate beneficial ownership cannot be established or raises concern. <\/p>\n
However, there is no evidence that the company has procedures to verify the beneficial ownership of agents and intermediaries at least every two years and\/or when there is a significant change in the business relationship.<\/p>\n"},{"question":91,"commitment_area":13,"score":"1","comments":"
There is evidence the company\u2019s anti-bribery and corruption policy applies to all third parties, including agents and intermediaries, and that it includes anti-bribery and corruption clauses in its contracts with such entities. There is evidence indicating that all medium and high-risk representatives are subject to termination rights.<\/p>\n
However, the company indicates that not all representatives are subject to audit rights. <\/p>\n"},{"question":92,"commitment_area":13,"score":"2","comments":"
The company recognises agent payments and incentive structures as a corruption risk and outlines various processes to mitigate these risks. These include staged payments, pre-agreed payments based on clear milestones and a cap on commissions. The company indicates that it will not pay agent fees into an account in a jurisdiction that raises concerns.<\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
The company does not publish any details of the agents currently contracted to act for and\/or on its behalf.<\/p>\n"},{"question":99,"commitment_area":13,"score":"1","comments":"
The company publishes a statement that it has not received any corruption-related reports involving its agents or representatives.<\/p>\n
However, it is unclear whether the company updates this information on an annual basis. <\/p>\n"},{"question":100,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence before entering into joint ventures. The company states that its due diligence process includes establishing the ultimate beneficial ownership of the partner company, with enhanced due diligence for high-risk joint venture partners.<\/p>\n
However, there is no evidence that the company repeats due diligence on joint venture partners at least every two years or whenever there is a significant change in the business relationship.<\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
Based on publicly available evidence, the company commits to working jointly with its joint venture partners to implement an anti-corruption programme to the same standard as the company\u2019s own. The company states that all joint venture agreements include anti-corruption clauses and termination rights. <\/p>\n
However, evidence indicates that not all joint venture agreements include audit rights. Additionally, the company does not clearly specify the anti-corruption standards that all joint venture partners must adhere to, such as a prohibition of bribery, payments to public officials and facilitation payments. <\/p>\n"},{"question":102,"commitment_area":13,"score":"2","comments":"
The company publishes a statement that it commits to take an active role in preventing bribery and corruption in all of its joint ventures. There is clear evidence to support the company's commitment, with the company indicating that it appoints a compliance officer within the joint venture and regularly conducts monitoring and auditing of the joint venture. <\/p>\n"},{"question":103,"commitment_area":14,"score":"1","comments":"
The company states that it has never previously, and does not currently, engage in offset agreements but recognises the corruption risks they present. The company also indicates that should it enter into such an agreement in the future that it has a dedicated procedure requiring the input and coordination of several departments to manage and oversee offset obligations. <\/p>\n
However, the company does not suggest that it would require tailored anti-corruption training for all associated employees. Additionally, the company does not specify that this internal grouping would manage the offset arrangement throughout the project lifecycle. <\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
Based on public information, there is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on offset obligations. There is also evidence that these procedures stipulate assurance of the legitimacy of the investment.<\/p>\n
However, there is no evidence that the company\u2019s procedure stipulates refreshing this due diligence continuously or at least when there is a significant change in the business relationship or nature of the partner. Additionally, there is no evidence that this procedure includes checks on ultimate beneficial ownership of offset brokers or beneficiaries, or that it covers conflicts of interest. <\/p>\n"},{"question":105,"commitment_area":14,"score":"N\/A","comments":"
The company publishes a statement that it does not, and has not historically, entered into any offset agreements, as well as a statement that it does not engage offset agents or brokers. <\/p>\n"},{"question":106,"commitment_area":14,"score":"N\/A","comments":"
The company publishes a statement that it does not, and has not historically, entered into any offset agreements.<\/p>\n"},{"question":107,"commitment_area":15,"score":"2","comments":"
The company acknowledges the corruption risks associated with operating in different markets and there is evidence that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. 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 possible controls. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
In its annual filing to the Securities and Exchange Commission the company provides a list of its subsidiaries. This includes the company\u2019s ownership percentage of the subsidiary and the jurisdiction of incorporation. <\/p>\n
However, there is no evidence that the list is complete or up to date. Additionally, the company does not provide information on the subsidiaries\u2019 countries of operation. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is listed on the New York Stock Exchange and therefore automatically receives a score of \u20182\u2019.<\/p>\n"},{"question":110,"commitment_area":15,"score":"2","comments":"
In its annual report, the company indicates that in each of the last three years its contracts with the US government accounted for over 95% of its revenues both where it is the prime contractor and when it is a subcontractor. The company is only active in the defence sector.<\/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\/576","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=576"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=576"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}