There is evidence that the company has a publicly stated commitment to ethics. However, the company receives a score of \u20180\u2019 because there is no evidence that this commitment is not authorised or supported by a senior figure. The company\u2019s statement also does not make specific reference to anti-bribery and corruption. <\/p>\n"},{"question":55,"commitment_area":7,"score":"0","comments":"
There is evidence that the company has ethical guidelines for its employees that includes a compliance manual on fair trade, which refers to some of the risk areas related to bribery and corruption. However, the company receives a score of \u20180\u2019 because this document does not make explicit reference to anti-bribery and corruption, and there is no evidence that any of the company\u2019s other publicly available information outlines anti-bribery and corruption policies for its employees or board members. <\/p>\n"},{"question":56,"commitment_area":7,"score":"0","comments":"
There is evidence that a designated board committee \u2013 the Ethics Committee \u2013 oversees the company's compliance programme. However, there is no evidence to suggest that the compliance programme includes a focus on bribery and corruption. In addition, there is no clear evidence that the committee engages in formal oversight functions such as reviewing reports from management or the results of internal and external audits of an anti-bribery and corruption programme.<\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
Based on publicly available information, there is no evidence that a senior individual is ultimately responsible for implementing and managing the company\u2019s anti-bribery and corruption programme. Although there is evidence that the company has a Compliance Officer, there is no publicly available evidence to suggest that their responsibilities include oversight of anti-bribery and corruption. <\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company has a formal risk assessment procedure which is used to inform the company\u00b4s anti-corruption or compliance programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company\u2019s ethics, compliance or anti-bribery and corruption programme is subject to audit or review.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company commits to investigating incidents, and there is a specific procedure in place to deal with whistleblowing cases. The company stipulates actions to be taken at each step and indicates that whistleblowers can check on the outcome of the investigation. <\/p>\n
However, the company scores \u20181\u2019 as this does not cover the whole investigation process from receipt to final outcome. There is no evidence that investigations are handled by an independent team or reported to an independent board member. There is also no evidence that the information on each investigation is documented with summary information on investigations reviewed by a central body on a quarterly basis. In addition, it is noted that the company\u2019s investigative procedure as outlined in publicly available information relates only to reports received through whistleblowing channels. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no publicly available 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 publicly available evidence that the company\u2019s investigative procedure includes a commitment to report material findings to the board or the relevant authorities.<\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company publishes 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 no publicly available evidence that the company provides ethics, compliance or anti-bribery and corruption training to its employees.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company tailors its 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 publicly available evidence to indicate 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 publicly available 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 publicly available evidence to indicate that the company commits to support or protect employees who refuse to act unethically, even when it might result in a loss of business.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company promotes a policy of non-retaliation against whistleblowers who report bribery and corruption incidents through its whistleblowing channel. There is evidence that the company\u2019s whistleblowing channel is open to third parties including business partners, and the company indicates that its non-retaliation policy extends to these entities. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it 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":"1","comments":"
There is evidence that the company provides a whistleblowing line, which its employees can access as a confidential reporting channel. The company indicates that this channel is available to all employees and business partners, although the company does not specifically refer to suppliers or joint venture partners.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company provides an externally operated reporting channel, in addition to its internally operated whistleblowing line. There is also no evidence that the company provides channels through which employees can seek advice about its anti-corruption policies and activities. Moreover, there is also no evidence that the channels are available in all relevant languages or that individuals can report incidents anonymously, wherever possible. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is some evidence that the company has a policy for conflicts of interest, which covers employee relationships. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence its policy covers potential or perceived conflicts of interest. There is also no evidence that the company\u2019s policy makes reference to government relationships, financial interests and other employment. Based on publicly available information, it is not clear that the policy applies to all employees and board members.<\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company has procedures to manage conflicts of interest or ensure their oversight. Where conflicts involve employee relationships, the company states that employees should consult with their supervisor or human resources team; but it is not clear that this applies to all conflicts of interest as part of a broader set of procedures. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no publicly available 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 publicly available 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 publicly available evidence that the company discloses full 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 and procedure covering charitable donations and sponsorships. The company publishes some information on its sponsorships and donations but it does not provide comprehensive details to indicate that this covers all sponsorships, nor is there evidence that the company has an accompanying policy or procedure in place.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy or procedure on lobbying.<\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no publicly available 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 publicly available evidence that the company provides any details about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts. The company\u2019s policy specifies financial limits for the receipt of gifts. There is evidence that gifts received are recorded in a depository that is accessible to those responsible for oversight of the process. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence it addresses the risks associated with gifts and hospitality given to\/received from public officials. There is also no evidence that the company records or specifies financial limits for the giving of gifts, nor the giving and receipt of hospitality. <\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company's procurement department is involved, in some capacity, in the establishment of supplier relationships. <\/p>\n
However, the company receives a score of \u20181\u2019 as it is not clear that the procurement department is the main body responsible for oversight of the company\u2019s supplier base. In addition, there is no evidence that the company assures itself of the procurement department\u2019s involvement at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence when engaging or re-engaging with its suppliers. <\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard. <\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption standards are required throughout the supply chain.<\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company publishes any data on ethical or anti-bribery and corruption investigations or the associated disciplinary actions relating to its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company has a policy on 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":"
There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.<\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company addresses incentive structures as a risk factor in agent behaviour.<\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no publicly available 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 publicly available 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 publicly available evidence that the company conducts anti-bribery and corruption due diligence on its joint venture partners or entities.<\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, nor that it requires anti-corruption clauses in its contracts with joint venture partners.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence to indicate that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.<\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring its offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company has a procedure in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations. <\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the its offset programme.<\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company publishes any details of its indirect offset obligations or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no publicly available evidence that the company acknowledges the corruption risks of operating in different markets, nor 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 publishes some information on its affiliates, ordered by industry. However, the company receives a score of \u20180\u2019 because it does not provide further details of these entities, such as the percentage ownership, country of incorporation and country\/countries of operation. There is also no evidence to clearly indicate how frequently this information is updated. <\/p>\n"},{"question":109,"commitment_area":15,"score":"0","comments":"
The company publishes some information about its beneficial ownership, which identifies major shareholders with a stake of 25% or higher; however, there is evidence to indicate that this information dates from 2016 and 2017, so therefore it is not clear that this ownership structure is up-to-date. The company has not published more recent beneficial ownership information on its website, and there is no indication that the company discloses its ownership in a freely available central public register. <\/p>\n
It is noted that the company is publicly listed, however it does not have voting shares admitted to trading on one of the regulated markets listed in the scoring criteria so is not eligible for a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes any information on its defence sales by 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\/578","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=578"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=578"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}