There is evidence that the company has a publicly stated anti-bribery and corruption statement that is endorsed by its leadership. There is evidence that this statement is published in the company\u2019s Code of Business Conduct, which contains its anti-bribery and corruption policy.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that its senior leadership directly addresses and supports the company\u2019s stance against corruption.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company publishes an anti-bribery and corruption policy, which makes specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that this policy clearly applies to all employees and board members as described in (a) and (b) above. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that a board committee is 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 has the authority to ensure 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 or board committee that provides oversight of the anti-bribery and corruption programme. 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":"
There is evidence that the company has a formal bribery and corruption risk assessment procedure in place. The company indicates that such risk assessments are undertaken periodically and that the results inform the design of its anti-corruption and bribery programme. In addition, there is some evidence that the company\u2019s board-level Audit Committee is responsible for reviewing the compliance programme, including significant updates from risk assessments, on a quarterly basis with input from the Chief Compliance Officer and General Counsel. <\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
There is evidence that the company\u2019s 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. This process includes provisions for continuous improvement, supplemented by regular internal or external audit. There is also evidence that high-level audit findings are presented to the board, with clear ownership assigned to units and\/or individuals for planned updates and improvements to the anti-bribery and corruption programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that the compliance and anti-corruption programme is subject to audit at least every two years.<\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company commits to investigating incidents promptly and objectively. There is evidence that the company reports investigative findings to the Audit Committee through the General Counsel and Director of Business Conduct. The company provides publicly available details on its investigation process from receipt to outcome, for both reports received through whistleblowing and internal channels. <\/p>\n
In addition, there is evidence that the company ensures the independence of its internal investigations by involving individuals from different departments or external counsel. There is evidence that the General Counsel reviews all significant investigations and findings on a monthly basis and that the board-level Audit Committee reviews summary information on all cases on a quarterly basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
There is evidence that the company takes steps to assure itself of the quality of its internal investigations, including those reported through whistleblowing channels. The company provides clear information to indicate that staff tasked with conducting investigations are properly qualified and trained to perform the function, and indicates that in cases where specific expertise is required staff may engage external assistance. There is evidence that the company has a system in place to handle complaints about the investigation process and that this process is ultimately overseen by the Chief Compliance Officer, General Counsel and board of directors. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that its investigations procedure is subject to review at least every three years, or in response to any relevant changes in the regulatory environment. <\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
There is evidence that the company clearly commits to report material findings of bribery and corruption from investigations to the board. There is evidence that an appropriate senior individual \u2013 the General Counsel, along with the Audit Committee \u2013 is ultimately responsible for ensuring that the disclosure of criminal offences to relevant authorities is evaluated and acted upon if found necessary.<\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
The company does not publish any data on ethical or bribery and corruption investigations or disciplinary actions involving its employees.<\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides training on its Code of Business Conduct, which includes the anti-bribery and corruption programme. The company states that this training is provided in all relevant languages and locations. There is evidence that all employees are required to undertake this training on an annual basis. <\/p>\n"},{"question":65,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides specific anti-bribery and corruption training to certain employees based on their roles and exposure to corruption risk. The company indicates that board members must complete annual ethics training and states that employees in critical or high risk or with significant authority must certify their ethics and compliance understanding on an annual basis. As part of its definition of high risk roles, there is evidence that the company identifies employees in government relations, accounting, finance and internal audit, business development, sales and those dealing with high-risk intermediaries.<\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
There is some evidence that the company measures and reviews the effectiveness of its anti-bribery and corruption communications and training programme. There is evidence that the Director of Business Conduct is responsible for this process, which includes reviewing survey questions and responses. The company indicates that the results of such reviews are used to update specific parts of its anti-bribery and corruption programme. There is evidence that such reviews are conducted on an continuous basis with a full assessment questionnaire on an annual basis. <\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
There is evidence that the company\u2019s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles. The company publishes a statement to indicate that it considers ethical conduct and compliance with the Code of Business Conduct as factors in annual performance reviews, which determine employee incentive compensation. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further publicly available information on the way in which it structures its incentives, for example by indicating that financial rewards must be proportionate to the employee\u2019s salary for those in high risk departments or roles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company commits to support and protect employees who refuse to act unethically, even where such actions may result in a loss of business or other disadvantage. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that the company assures itself of its employees' confidence in this commitment through anonymised surveys or other clearly stated means on a regular basis.<\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":"
There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. The company indicates that its policy applies to all employees across the organisation, including those employed by the group as third parties. In addition, there is evidence that the Director of Business Conduct conducts periodic reviews of the company\u2019s systems to ensure employees understand and have confidence in its non-retaliation commitment.<\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides multiple channels for its employees to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. The company indicates that these channels are sufficiently varied to allow employees to raise concerns across the management chain and externally through a reporting channel operated by an independent third party. The company states that the channels allow for confidential and, wherever possible, anonymous reporting. <\/p>\n
In addition, there is evidence that these channels are accessible to all employees in all jurisdictions where the company operates and are available in multiple languages. Since it is possible for anyone to make a report via the Ethics Point website, it is understood that the channels are available to third parties, suppliers and joint venture partners.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence that the company formally addresses conflict of interest as a corruption risk, and has a clear policy to define actual, potential and perceived conflicts. The company indicates that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities. In addition, there is evidence that the company\u2019s policy clearly addresses possible conflicts arising from employee relationships, financial interests and outside employment and government relationships. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has procedures in place to identify, declare and manage conflicts of interest. The company indicates that the Director of Business Conduct is ultimately responsible for reviewing and handling conflicts of interest when reported by employees, and states that senior executives must report specific conflicts as part of an annual compliance certification process. In addition, there is evidence that the Chief Executive Officer and Audit Committee review certain conflicts related to senior executives. The company also indicates that its policy includes examples of possible criteria for recusals and indicates that disciplinary actions may apply if this policy is breached. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that all employee and board member conflict of interest declarations are held in a central register that is accessible to those with oversight of the process.<\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a procedure in place with controls to assess and regulate employment and offers of employment to current and recently departed public officials, including politicians. There is evidence that this policy requires approval from a HR representative or the Anti-Corruption Compliance team for the initiation of any employment discussions with former or current public officials, and a review of actual, potential or perceived conflict of interest. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it provides further publicly available information on this procedure. There is no evidence that the company implements restrictions on the activities of the hired people if conflicts of interest are identified, nor is it clear that the company may require a cooling-off period of at least 12 months before such public officials are permitted to have any form of contact or relationship with their former organisation on the company\u2019s behalf.<\/p>\n"},{"question":74,"commitment_area":10,"score":"2","comments":"
There is evidence that the company publishes a clear statement that it does not contract serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
There is evidence that the company has a policy on corporate political contributions, which generally prohibits such payments but states that they are permissible in certain circumstances and in accordance with all applicable laws. There is evidence that the Government Relations department is responsible for reviewing and approving any proposed contributions. This policy applies company-wide to all employees, including those of subsidiaries. There is also evidence that the company is associated with a Political Action Committee (PAC) in the United States. <\/p>\n
The company receives a score of \u20180\u2019 since it does not prohibit political contributions and is associated with a PAC in the United States, as outlined in the scoring criteria.<\/p>\n"},{"question":76,"commitment_area":11,"score":"2","comments":"
The company publishes a statement that it did not make any political contributions in the last 12 months. The company publishes some data on its political contributions on an annual basis.<\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has a policy on charitable donations and sponsorships. There is evidence that the company specifies criteria for donations and that some donations are subject to an anti-corruption review and approval process. In addition, the company provides some high-level figures of its charitable donations and community sponsorships. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it publishes full details of its charitable contributions, such as details of the recipient, amount, country of recipient and which corporate entity made the payment. It is also not clear that the company has further procedures in place to reduce the risk of corruption, such as due diligence on recipients.<\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
There is some evidence that the company has a procedure on lobbying to ensure compliance with all applicable laws and regulations. The company indicates that any lobbyists outside of the United States are subject to the same due diligence, approval and standards of conduct that apply to commercial intermediaries. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further publicly available information on its procedures to ensure responsible lobbying, such as standards of conduct for lobbyists in the United States or specific oversight mechanisms for both domestic and foreign lobbying activities. There is also no clear evidence that the company\u2019s policy addresses and applies to all internal, 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 information on its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"2","comments":"
There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with procedures designed to ensure that such promotional expenses do not pose a bribery and corruption risk. There is evidence that this policy establishes an approval procedure for the different types of promotional expense that employees may encounter, and it addresses the risks associated with gifts and hospitality given to and received from public officials. There is some evidence that the policy includes financial or proportional limits and 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 requires the involvement of its procurement department in the establishment of new suppliers. The company indicates that this department is ultimately responsible for providing oversight of the company's supplier base. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it assures itself of this department\u2019s proper involvement in the procurement process, for example through audits of the system, on a regular basis or at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
There is evidence that the company has formal procedures in place to conduct due diligence on its suppliers. The company indicates that all new suppliers are screened to ensure compliance with ethical practices and all suppliers are monitored on an ongoing basis through various surveys and assessments. There is evidence that highest risk suppliers are subject to enhanced review. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that these due diligence reviews include checks on the ultimate beneficial ownership of suppliers. Although the company indicates that suppliers are monitored on an ongoing basis, it is not clear how frequently these checks are conducted during the supplier relationship. In addition, there is no clear publicly available evidence that the company might be willing to review or terminate supplier relationships if a red flag highlighted in the 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. The company indicates that all suppliers must have, at minimum, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, as well as policies and procedures relating to gifts and hospitality. There is evidence that the company takes active steps to ensure this, for example by requiring that suppliers abide by the Code of Conduct, which includes procedures related to conflict of interest and whistleblowing. The company ensures that suppliers have adequate bribery and corruption policies when onboarding suppliers and throughout the course of the business relationship. <\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
There is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place and that the substance of its anti-corruption and bribery programme and standards are included in subcontracts throughout the supply chain. This evidence is in the form of a clear statement, and a set of supplier principles that sets the minimum standards of ethical behaviour expected throughout the supply chain. <\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company publishes data on ethical or corruption-related reports investigations or disciplinary actions involving its suppliers. <\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has a clear policy and\/or procedure to control the use of agents which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. 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":"2","comments":"
There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging any agents and intermediaries. The company indicates that agents and highest risk intermediaries are subject to enhanced due diligence. The company commits to not engaging or terminating its engagement with agents or intermediaries where the risks identified in the due diligence cannot be mitigated. In addition, there is evidence that the company reviews this due diligence periodically or at least every three to five years throughout the relationship.<\/p>\n"},{"question":90,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has formal procedures to establish the beneficial ownership of agents prior to engaging them and whenever there is a significant change in the business relationship. The company indicates that high-risk agents and intermediaries are subject to enhanced due diligence and that it may engage an external legal counsel to review such information depending on the risk and circumstances. There is evidence that the company commits to not engaging or terminating its engagement with agents or intermediaries where ultimate beneficial ownership cannot be established. <\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
There is evidence that the company\u2019s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. The company indicates that all agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include clear audit rights and termination rights to detect, control and prevent breaches.<\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company indicates that part of its anti-corruption due diligence includes ensuring that any proposed compensation is reasonable and that payments are reviewed periodically. <\/p>\n
However, there is no publicly available evidence that the company imposes a threshold on the payment of sales commissions to agents, nor that it remuneration must be paid in stage payments or into local bank accounts.<\/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 or 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, incidents or the associated disciplinary actions involving its agents.<\/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 on all of its joint venture partnerships. The company conducts enhanced due diligence for joint ventures operating in high risk countries or with high risk partners. There is evidence that the company conducts anti-bribery and corruption due diligence both prior to entering into a joint venture and on both the entity and its activities once established. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence to indicate that the company establishes the beneficial ownership of its joint venture partners as part of due diligence, nor is there evidence that such checks are repeated at least every two years throughout the relationship.<\/p>\n"},{"question":101,"commitment_area":13,"score":"2","comments":"
There is evidence that the company clearly commits to establishing and implementing anti-bribery and corruption policies and procedures in all of its joint ventures, by requiring the adoption of its own Code of Conduct, inclusive of its anti-bribery and corruption programme. There is evidence that the company requires anti-bribery and corruption clauses in its contracts with joint venture partners. There is also evidence that the company specifies clear audit and termination rights to detect, control and prevent breaches.<\/p>\n"},{"question":102,"commitment_area":13,"score":"2","comments":"
There is evidence that the company 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, through practical examples and a statement of possible controls that it may implement, dependent on the context. <\/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 oversight of its offset activities. There is no evidence that the company publishes a statement to indicate that it does not engage in offset contracting.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company has formal procedures 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 evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme, nor does it indicate that it does not employ or engage such entities.<\/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, nor does it publish a statement that it does not engage in offset contracting.<\/p>\n"},{"question":107,"commitment_area":15,"score":"1","comments":"
There is evidence that the company acknowledges the corruption risks associated with operating in different markets and there is evidence that it has a dedicated assessment process in place to assess such risks. The company suggests that the results of such assessments may impact business decisions. <\/p>\n
However, there is no publicly available evidence that the company publishes details of its clear risk management procedures nor is it clear that the results of risk assessments trigger the implementation of additional controls.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes details of its fully consolidated subsidiaries and non-fully consolidated holdings. There is evidence that this list includes all of the company\u2019s material subsidiaries and significant joint ventures, along with its percentage ownership for some entities and the country or jurisdiction of incorporation for all entities. It is clear that this information is published annually as part of the company\u2019s annual corporate reporting. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that this list represents all of the company\u2019s holdings and associates, including entities in which the company has non-significant ownership or control. There is also no publicly available evidence that the list includes the percentage ownership and country or countries of operation for each associated entity.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed on the New York Stock Exchange (NYSE) and therefore it is not required to disclose further information on its beneficial ownership to receive a score of \u20182\u2019. The company also discloses all beneficial owners with ownership or voting rights of 5% or above on its website.<\/p>\n"},{"question":110,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a breakdown of its sales per customer, to indicate that the United States and United Kingdom governments accounted for 65% of its total sales in the most recently reported financial year. There is evidence that this data is correct up to the most recently reported financial year. <\/p>\n
However, he company receives a score of \u20181\u2019 because there is no evidence that it publishes information on its defence sales specifically nor is it clear that it publishes details of its customers for more than 80% of its sales. <\/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\/586","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=586"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=586"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}