There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's leadership.<\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company publishes an anti-bribery and corruption policy, which makes specific reference to bribery and payments to foreign public officials. This policy clearly applies to all employees and board members as described in (a) and (b) above. <\/p>\n
However, the company does not explicitly prohibit facilitation payments or commercial bribery. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that the board is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from the company\u2019s Compliance Officer on the programme\u2019s performance and ensuring that required changes are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior executive, the Compliance Officer, has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that the Compliance Officer has a direct reporting line to the board. There is evidence of reporting and feedback activities between the Compliance Officer and the board as part of the company\u2019s reporting structure.<\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
There is evidence indicating that the company has a formal risk assessment procedure that incorporates reviews of governance and compliance issues. The results of risk assessments are reviewed by the board on an annual basis. <\/p>\n
However, in publicly available information, the company does not explicitly refer to reviews of bribery and corruption risks.<\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
There is some evidence suggesting that the company conducts an annual internal audit of its anti-bribery and corruption programme, and that the results of these audits are reviewed at board level. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear ownership assigned to units and\/or individuals for planned updates and improvements to the anti-bribery and corruption programme. The company additionally does not specify that its entire programme is audited to ensure that it is consistent with best practice and the business risks facing the company.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly commits to investigating incidents, which are handled by the Compliance Officer. There is evidence that information on each investigation is documented. The company commits to put in place remediation plans and to report investigative findings to senior management and the board. A senior central body of the holding or parent company receives and reviews summary information of all incidents and their status in the organisation and its subsidiaries, on an annual basis.<\/p>\n
However, the company does not describe the whole investigation process from receipt to final outcome, nor does it commit to providing whistleblowers with updates on the outcome of investigations. There is also no evidence that the company takes steps to ensure the independence of its investigations, by stipulating that investigations are handled by an independent team and\/or report to an independent board member<\/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":"2","comments":"
Based on publicly available information, the Compliance Officer reports material findings of bribery and corruption from investigations to the board. There is also evidence that the company commits to cooperating with government investigations and will inform authorities of corruption incidents when appropriate. <\/p>\n"},{"question":63,"commitment_area":8,"score":"1","comments":"
The company publishes some high-level information on the number of cases reported through its whistleblowing line on an annual basis.<\/p>\n
However, publicly available information indicates that the company does not release data on the number of investigations launched and the number of disciplinary actions as a result of investigation findings. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides a training module that outlines the basic principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees. The company provides this training to all employees across all divisions of operation. All employees are required to refresh the training every two years. <\/p>\n
However, the company does not state that it provides training in all appropriate languages or in all countries of operation.<\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides tailored anti-bribery and corruption training to employees in different roles based on their exposure to corruption risk, including employees in middle management and high risk positions. These employees are required to refresh their training on an annual basis.<\/p>\n
However, the company does not make reference to tailored training for board members.<\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme. <\/p>\n
However, the measures appear to be limited to tracking the number of personnel trained and completion rates on an annual basis. Based on publicly available information, there is no evidence that the results are used to update specific parts of the company\u2019s anti-bribery and corruption communications training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, 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":"
Based on publicly available information, there is no clear evidence 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":"
The company promotes a policy of non-retaliation against whistleblowers and employees who report bribery and corruption incidents. The company operates a public complaints line, which it can be inferred is open to individuals employed by the groups as third parties, suppliers and joint venture partners.<\/p>\n
However, based on publicly available information, there is no evidence that the company 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":"
Based on publicly available evidence, the company has some whistleblowing and advice channels for employees to report instances of suspected corrupt activity and obtain advice on compliance matters. The company also operates a public complaints line, which it can be inferred is open to individuals employed by the groups as third parties, suppliers and joint venture partners. The company also states that, as a state owned body, reports can be submitted in various languages to a state-level agency with the remit to investigate corruption at state owned enterprises. The company states that whistleblowing reports may be submitted anonymously. <\/p>\n
However, the company does not explicitly refer to confidential channels and the company only offers internally operated channels. There is also no evidence that company\u2019s reporting channels are available in all relevant languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy for actual and potential conflicts of interest, which refers to financial interests, employee relationships, and applies to all employees and board members. <\/p>\n
However, in publicly available evidence, the company does not refer to perceived conflicts. It also does not refer to conflicts associated with government relationships or other employment.<\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
Based on publicly available evidence, directors are required to make conflicts of interest declarations. The company also states that it has policies through which it manages and avoids conflicts of interest throughout the organisation. However, the company does not provide further clarifying information and its wider procedures for managing conflicts are therefore sufficiently unclear that they cannot satisfy the requirements of a score of '1'. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
Based on publicly available information, 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 publicly reports details of the contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"2","comments":"
There is evidence that the company prohibits all financial contributions and donations. On the basis of other policies published by the company, which prohibit political activities on the company premises, it is understood that this includes a prohibition of political contributions. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
The company publishes a clear statement that it prohibits corporate political contributions, so therefore it is exempt from scoring on this question. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
The company publishes a statement that it does not make donations for any purpose with the exception of providing services that do not have material value. <\/p>\n
The company does not meet the criteria for a score of \u20182\u2019 as it does not provide further information on how it defines the value of services. It refers to a policy on this subject but this is not publicly available.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
While the company indicates that its anti-corruption policy applies to lobbyists, in publicly available information it provides no further evidence concerning its procedures and policies on lobbying itself. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
The company does not publish any information on its lobbying aims, topics or activities.<\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
The company does not publish any details about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy on the giving and receipt of gifts and hospitality. This policy addresses the risks associated with gifts and hospitality given to public officials. The company\u2019s management are required to sign an annual certification that they have not provided gifts in contravention of the company\u2019s compliance programme.<\/p>\n
However, based on publicly available information, there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process. The policy also does not specify financial or proportional limits or different approval procedures for different types of promotional expense. It is noted that the company has a separate policy on gifts but this does not appear to be publicly accessible.<\/p>\n"},{"question":82,"commitment_area":12,"score":"2","comments":"
There is evidence that dedicated procurement organisations in each of the company\u2019s business units, as well as a group-level procurement organisation, are involved in the establishment of new suppliers and also hold responsibility for overseeing and managing the company\u2019s supplier base. The company states that it has a corporate-level supplier selection committee, used in reviewing and approving key supplier agreements. There is also evidence that the company maintains proper standards and procedures in procurement activities by way of the corporate procurement organisation providing oversight of and assurance processes for all procurement activities.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company subjects suppliers to risk-based anti-bribery and corruption due diligence.<\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company requires its suppliers to have anti-bribery and corruption policies in place. The company includes contractual clauses on bribery and corruption in its agreements with suppliers and states that suppliers should uphold the values outlined in its own Code of Ethics.<\/p>\n
However, in publicly available information, the company does not explicitly state that all suppliers must have, at a minimum, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, and policies that cover conflicts of interest, gifts & hospitality, and whistleblowing. There is also no evidence that the company takes active steps to ensure that its suppliers have adequate anti-bribery and corruption policies and procedures in place. <\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.<\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
The company does not publish any data on ethical or anti-bribery and corruption investigations relating to its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has policies and procedures to control the use of agents and intermediaries (referred to as marketing consultants or the procurement of expert services) which addresses the corruption risks associated with the use of agents and intermediaries. The company 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 or intermediary is, in each case, necessary to perform a legitimate business function. There is evidence indicating that the policy applies to all divisions within the organisation which might employ agents and intermediaries, including subsidiaries and joint ventures.<\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct anti-bribery and corruption due diligence prior to engaging and re-engaging with agents and intermediaries. There is also evidence that due diligence is repeated at least every two years.<\/p>\n
However, based on publicly available information, there is no clear evidence that agents and the highest risk intermediaries are subject to enhanced due diligence. <\/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 ultimate beneficial ownership of its agents or intermediaries as part of its due diligence procedures.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries, which include termination rights. However, there is no evidence that the company includes audit rights in its contracts with these entities.<\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
In publicly available information the company highlights incentive structures for agents and intermediaries as a factor in bribery and corruption risk. The company publishes details of its financial control procedures for agent and intermediary payments and requires that remuneration is paid in stage payments.<\/p>\n
However, based on publicly available information, there is no evidence that the company imposes a threshold on the payment of sales commissions to agents and intermediaries, nor that it requires payments into local bank accounts.<\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
The company does not publish any details of the agents or intermediaries currently contracted to act for and\/or on behalf of the company.<\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
The company does not publish any data on ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving agents and intermediaries.<\/p>\n"},{"question":100,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has procedures to conduct due diligence on all its joint venture partnerships. <\/p>\n
However, based on publicly available information, there is no evidence that due diligence includes checks on the ultimate beneficial ownership of the partner company nor that due diligence is repeated at least every two years. There is also no evidence to suggest that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence<\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
There is evidence that the company\u2019s anti-corruption policies and procedures apply in joint ventures in which the company has a controlling interest. The company includes anti-corruption clauses in its contracts with all joint ventures. <\/p>\n
However, there is no evidence that the company takes steps to detect, control and prevent breaches through the inclusion of audit and termination rights in these contracts. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence 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 some evidence that the company recognises the corruption risks associated with offset brokers. However, there is no evidence that the company addresses the broader risks associated with offset contracting itself. There is also no evidence that the company has a dedicated body, department or team responsible for monitoring its offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct due diligence on offset brokers. This includes checks on conflicts of interest and measures to evaluate the need for a broker. The company refreshes due diligence on its brokers every two years.<\/p>\n
However, the company does not specifically mention checks on the beneficial ownership of brokers. There is also no evidence that the company conducts due diligence on offset beneficiaries.<\/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\u2019s offset programme.<\/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":"
Based on publicly available information, 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 subsidiaries.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company discloses that it is wholly-owned by the State of Israel. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
The company publishes the customers of less than 50% of its sales. <\/p>\n"},{"question":111,"commitment_area":16,"score":"2","comments":"
In publicly available evidence, the SOE states that it is wholly-owned by the State of Israel. As the company has a single shareholder, there is no requirement to publish information about its shareholder voting rights.<\/p>\n"},{"question":112,"commitment_area":16,"score":"1","comments":"
The SOE publishes some information about its objectives. <\/p>\n
However, the information provided is not detailed and there is no publicly available evidence that the SOE updates its objectives on at least an annual basis.<\/p>\n"},{"question":113,"commitment_area":16,"score":"1","comments":"
The SOE publishes some details about the nomination process to the board and the composition of its current board, and also publishes the names of all board members. <\/p>\n
However, based on publicly available evidence, it is not clear which company directors are independent directors or state representatives. The company also does not provide specific information on its criteria for director appointees other than stating that they must be professionally qualified. <\/p>\n"},{"question":114,"commitment_area":16,"score":"1","comments":"
The company states that, in accordance with Israeli law, its audit committee is composed of a majority of independent directors. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no further evidence to support this statement as the company does not disclose which directors sit on its audit committee. <\/p>\n"},{"question":115,"commitment_area":16,"score":"0","comments":"
The SOE does not publish any details about its management of asset transactions.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/583","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=583"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=583"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}