There is evidence that the company has a publicly stated anti-bribery and corruption commitment. There is clear evidence that this commitment was authorised and endorsed by the company's President and Chief Executive Officer.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is clear evidence that the company has an anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence this policy applies to all employees and board members. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that the company\u2019s Corporate CSR Committee is responsible for overseeing the company\u2019s Code of Conduct and therefore the company\u2019s anti-bribery and corruption policy. There is evidence that this committee is chaired by the President, who is a member of the board of directors. The company indicates that this committee is responsible for monitoring the achievement levels and status of the company\u2019s compliance programme.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that the President of the company, who is also the chair of the Corporate CSR Committee, has ultimate responsibility for overseeing all aspects of the company\u2019s compliance structure, which includes its anti-bribery and corruption programme. Although the company does not explicitly state that the President is responsible for implementing and managing the its compliance activities, the company\u2019s annual report indicates that the Corporate CSR committee is tasked with monitoring and implementation, so this is deemed sufficient for a score of \u20182\u2019. <\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
There is some publicly available evidence that the company has a risk assessment procedure, however there is no clear evidence that the results of risk assessments are used to inform or update the company\u2019s anti-bribery and corruption programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company\u2019s anti-bribery and corruption programme is subject to audit or review. The company provides some indication that it has a process to conduct audits, but it is not clear that such reviews cover the compliance or anti-corruption programme specifically. <\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company investigates compliance incidents and violations of the Code of Conduct, which includes the company\u2019s anti-bribery and corruption policy. There is evidence that the company has a procedure in place to deal with whistleblowing cases, which outlines actions to be taken at each step. The company commits to notifying the whistleblower of the outcome of investigations. <\/p>\n
In addition, the company\u2019s procedure indicates that whistleblowing reports received through the CRC System are investigated by outside lawyers. There is also evidence that internal inquiries are conducted by an independent team and that the CSR Committee receives reports on all investigations.<\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company has a process in place to assure itself of the quality of its investigations, for example by ensuring that staff conducting investigations are properly trained or by stipulating a procedure for handling complaints about the process. <\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company commits to report material findings of bribery and corruption to the CSR Committee. The committee\u2019s members include the company\u2019s President who is a member of the board of directors.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that an appropriate senior individual 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":"
There is evidence that the company publishes some high-level information on compliance-related incidents involving its employees on an annual basis. This information includes the number of investigations launched and resulting disciplinary actions. <\/p>\n
However, the company receives a score of \u20181\u2019 because this information refers to compliance matters such as \u201cabuse of authority\u201d and \u201cfinancial fraud\u201d, without clearly indicating whether the data includes investigations into ethics or bribery and corruption related incidents, investigations or disciplinary actions.<\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company provides training to its employees that outlines the principles of its anti-bribery and corruption policy. The company indicates that this training applies to any employees involved in overseas business, and states that the training is provided in Japan on an annual basis. <\/p>\n
The company receives a score of \u20181\u2019 because it is not clear that anti-bribery and corruption training is provided to all employees across all divisions, countries and regions of operation or in all appropriate languages. The company indicates that one of its divisions in the United States provided training for all its employees, however there is no evidence that this applies group-wide to all employees in all divisions.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is some evidence that the company provides anti-bribery and corruption training specifically for employees involved in overseas business. However, the company receives a score of \u20180\u2019 because it is not clear whether this training is based on an assessment of their role or exposure to corruption risk, nor is it clear that other employees in middle management or on the board receive tailored anti-bribery and corruption training.<\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company measures and reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme. The company indicates that it conducts awareness surveys to measure understanding of compliance initiatives among both its employees and its executives. There is also evidence that the results of these surveys are used to update specific parts of the company\u2019s initiatives. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is evidence to indicate that such surveys are conducted every 3-4 years instead of on an annual basis. There is no evidence that, in addition to regular survey-related updates to the programme, the company also conducts a full review of its initiatives every three years. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company\u2019s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles. The company provides some information on its compensation system for directors and supervisory board members, but there is no evidence that this includes measures to promote ethical behaviour and discourage corrupt practices. <\/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. The company indicates that all reports will be taken seriously and acted upon, but does not encourage employees to speak up even when such actions might result in a loss of business or other advantage.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is evidence that the company promotes a policy of non-retaliation against whistleblowers, which applies to all employees across the organisation, including those employed by the company as third parties. <\/p>\n
However, the company receives a score of \u20181\u2019 because 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 information, there is evidence that the company provides whistleblowing and advice channels for its employees to raise concerns. The company indicates that employees can report concerns confidentially, and there is some indication that its whistleblowing channels are open to third parties and temporary staff. There is also some evidence that the company provides an external reporting system in the form of an independent lawyer, to whom employees may anonymously report violations of the compliance programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that these channels are available to all employees in all countries of operation and in all relevant languages. The company also does not clearly indicate that its channels allow for anonymous reporting, nor is it clear that the channels are available to suppliers or joint venture partners.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy on conflicts of interest which covers actual, potential and perceived conflicts. There is evidence that the company\u2019s policy refers specifically to conflicts related to employee relationships, financial interests and other employment. The company also indicates that its policy applies to all employees and board members. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its policy covers possible conflicts arising from government relationships.<\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a procedure in place to identify, declare and manage conflicts of interest \u2013 including actual, potential and perceived conflicts. The company indicates that disciplinary measures apply if the company\u2019s policy is breached.<\/p>\n
However, the company receives a score of \u20191\u2019 because there is no evidence that all employee and board member declarations are held in a dedicated register, which is overseen by a central body responsible for oversight of the process. There is also no indication that the company provides examples of criteria for recusal.<\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company has a policy regulating the employment of current or former public officials<\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company reports details of the contracted services of serving politicians. <\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
There is evidence that the the company has a policy on corporate political contributions, to ensure that such payments are not used as vehicles of bribery and corruption. There is evidence that this policy applies to all employees, officers, third parties and subsidiaries.<\/p>\n
However, the company receives a score of \u20180\u2019 because its policy does not prohibit corporate political contributions. It is also not clear whether the company has a Political Action Committee (PAC); there is evidence that the company had a PAC in 2017-18 but there is evidence to indicate that the PAC no longer exists.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
The company publishes a high-level figure of all its political contributions made on an annual basis as part of its ESG reporting. However, the company receives a score of \u20180\u2019 because it does not provide any further information of the donations made, such as details of the recipient, amount, country of recipient and the name of the corporate entity that made the contribution. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy on charitable donations and sponsorships, to ensure that such payments are not used as vehicles for bribery and corruption. The company\u2019s policy includes establishing the legitimacy of the donation and oversight from the Compliance Department. In addition, there is evidence that the company publishes high-level figures on its charitable donations made on an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not publish full details of its charitable donations, such as details of the recipient, amount, country of recipient and which corporate entity made the payment.<\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy on lobbying that applies company-wide to all employees, officers and third parties acting on the company\u2019s behalf. The company\u2019s policy provides a definition of lobbying and indicates that employees must act ethically when engaged in lobbying activities. <\/p>\n
However, the company receives a score of \u20181\u2019 because its policy does not provide clear standards of conduct, guidelines or oversight mechanisms that apply to in-house, external and association lobbyists. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any information on its lobbying aims, topics or activities. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any details about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy on the giving and receipt of gifts and hospitality. There is evidence that this policy addresses the risks associated with gifts and hospitality given to and received from public officials, and it indicates that all gifts and entertainment received and given must be recorded. <\/p>\n
However, the company receives a score of \u20181\u2019 because its publicly available policy does not provide financial or proportional limits nor different approval procedures for different types of promotional expenses. There is also no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.<\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is evidence that the company\u2019s procurement department is involved, in some capacity, in the establishment of new suppliers and that it is the main body responsible for oversight of supplier relationships.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company assures itself of the procurement department\u2019s appropriate involvement in this process at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its suppliers.<\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is evidence that the company requires suppliers to have anti-bribery and corruption policies that prohibit foreign and domestic bribery, facilitation payments, as well as policies that address gifts, hospitality and whistleblowing. There is evidence that the company requires that its suppliers follow its own Code of Conduct, which includes its anti-bribery and corruption policy. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that the company has provisions in place to ensure that suppliers adhere to these policies, nor that the company conducts assurance of its suppliers\u2019 policies. <\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. <\/p>\n
However, the company receives a score of \u20181\u2019 because 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 and 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 and intermediaries. <\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is some evidence that the company\u2019s anti-bribery and corruption policy applies to agents. However, the company receives a score of \u20180\u2019 because there is no publicly available evidence that such provisions are included as contractual clauses with these entities, nor that contractual agreements include audit and termination rights.<\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company considers incentive structures as a risk factor in agent behaviour. <\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any details of the agents currently contracted to act for and on its behalf. <\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption-related investigations, or the associated disciplinary actions, involving its 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 when entering into joint ventures.<\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publicly commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to take an active role in preventing bribery and corruption in its joint ventures.<\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company\u2019s offset activities. <\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company has a procedure 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 evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and\/or on its behalf. <\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of its offset obligations or contracts. <\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no clear 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. The company publishes some information on its risk management procedures, but there is no evidence that these procedures address market risk. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a list of its major subsidiaries and associated companies, which is updated on an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because the it does not provide full details of its subsidiaries and associates, such as the percentage ownership, country of incorporation or country of operation for each entity. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed on the Tokyo Stock Exchange and Nagoya Stock Exchange, so therefore it is not required to further disclose its beneficial ownership information and automatically scores \u20182\u2019 as per the scoring criteria. The company also publishes information about its major shareholders in its Annual Report.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
The company publishes some information about its sales, to indicate that Japan and the United States are its two major customers. The company also indicates that the Japanese Ministry of Defense is its major customer. However, the company receives a score of \u20180\u2019 because it is not clear whether the geographic information provided relates to defence sales specifically or total company sales for defence and non-defence products and services. <\/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\/585","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=585"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=585"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}