There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which details the company\u2019s stance against any form of bribery or corruption within the organisation. It is clear that this commitment is authorised and endorsed by the company\u2019s President and CEO. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that the company publishes an Anti-Corruption Guide and a Code of Ethics and Business Conduct, both of which specifically prohibit bribery, payments to public officials, commercial bribery and facilitation payments. These policies apply to all employees and board members.<\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is some evidence that the Board of Directors provides oversight of the company\u2019s anti-corruption and compliance programme, including for example by adopting the Code of Ethics and Business Conduct. The company has an Ethics Committee appointed by the Board, which is responsible for promoting high ethical standards. <\/p>\n
However, although there is some evidence that the board reviews the results of internal audits, it is not sufficiently clear that the scope of these audits include the company\u2019s anti-bribery and corruption programme. There is also no clear evidence that the board or a board committee receives reports from management on the programme\u2019s performance and ensures 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\u2019s anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the board committee that provides oversight of the anti-bribery and corruption programme. There is evidence of 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 that informs the design of its anti-corruption and bribery programme. The company indicates that its risk assessments incorporate a range of sector-specific risks, including industry, country, business area and the use of third parties. There is evidence that the board reviews risk management and internal control procedures, as well as the group\u2019s governance documents, on an annual basis. Since this is process is interpreted to include risks relating to the company\u2019s anti-bribery and corruption approach, the company receives a score of \u20182\u2019. <\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s anti-bribery and corruption programme is subject to periodic evaluation and a regular internal audit process. Evidence in the company\u2019s Annual Report indicates that the company plans to carry out internal audits of its internal controls and compliance processes on an annual basis, supplemented by an external audit of the anti-corruption programme every third year. In addition, it is clear that the findings of these audits are presented to the Board and used to develop follow-up risk management plans. Although it is not explicitly clear where ownership for this process lies, it is assumed to sit with the Board\u2019s Audit Committee. <\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
There is evidence that the company publicly commits to investigating bribery and corruption allegations or incidents, which includes a statement that all allegations must be investigated promptly and by personnel who have no connection with the case. In addition, there is a specific procedure in place to deal with whistleblowing cases which stipulates documentation and actions to be taken at each step, covering the whole investigation process from receipt to final outcome. The company commits to providing those who raise concerns \u2013 including whistleblowers \u2013 with updates on the outcome of investigations. Although the company does not explicitly state that a senior central body receives and reviews summary information of all incidents on a regular basis, the involvement of the CCO and legal department in the investigation process is assumed to cover this role. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company assures itself of the quality of investigations. Although the company provides information about its investigation process, it does not provide any publicly available evidence of how it ensures the quality of these procedures, for example by stating that staff tasked with conducting investigations are properly trained and qualified. There is also no mention of how complaints about the process are handled, nor does the company state that an appropriate senior individual is responsible for oversight of this process. Additionally, there is no evidence that the company reviews its investigations procedure at least every three years or in response to any changes in the regulatory environment.<\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
There is evidence that the company\u2019s investigative procedure includes provisions to report material findings to the board and potential criminal conduct to the relevant authorities where appropriate. There is evidence that there are procedures in place which determine the relevant senior manager responsible for reporting findings to authorities. <\/p>\n"},{"question":63,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publishes data on the number of ethics and compliance-related investigations involving its employees for the most recently reported financial year. <\/p>\n
However, this data is insufficiently detailed: it does not include the number of reports received, including through whistleblowing channels, nor the number of disciplinary actions taken as a result of investigation findings.<\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, the company provides a training module that outlines the principles of its anti-bribery and corruption policy that includes the whistleblowing options available to employees. There is evidence that employees receive basic online training on the Code of Ethics, as well as classroom training for all new employees and new line managers. There is evidence that training is provided to all employees in all divisions and geographies, and in all appropriate languages. There is evidence that employees are required to refresh their training at least every three years. <\/p>\n"},{"question":65,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that employees in certain positions receive specialised or tailored anti-bribery and corruption training. The company states that risk-exposed personnel, managers and market representatives, and board members receive specific training. In addition, the company states that the annual training plan is risk- based, and updated to include new laws and requirements. There is evidence that high-risk positions are required to undertake refresher training on an annual basis. <\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
There is publicly available evidence that the company takes steps to assure itself of the effectiveness of its anti-bribery and corruption communications and training programme. Information suggests that the company assures itself of this annually, and that the results of its reviews are used to update specific parts of the company\u2019s anti-bribery and corruption communications and training programme. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence to indicate that the company\u2019s incentive schemes incorporate ethical or anti-corruption principles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"1","comments":"
There is evidence that the company commits to support or protect employees who refuse to act unethically. <\/p>\n
However, there is no evidence that the company assures itself of its employees\u2019 confidence in this statement through anonymised surveys or other clearly stated means.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is evidence that the company has a clear policy of non-retaliation against both whistleblowers and employees who report concerns. <\/p>\n
However, the company receives a score of \u20181\u2019 as it does not explicitly commit to assure itself of its employees\u2019 confidence in this commitment through surveys or other clearly stated means.<\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
There is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company\u2019s anti-bribery and corruption programme, including through a dedicated whistleblowing channel. These channels allow for anonymous and confidential reporting, and are sufficiently varied to allow employees to raise concerns across the management team. There is also evidence that the channels are available and accessible to employees in multiple jurisdictions, in all relevant languages (Norwegian and English), including those employed by the group as suppliers or other external parties. <\/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 that covers actual, potential and perceived conflicts. This policy applies to both employees and board members. It defines and describes financial interests and other employment as categories of potential conflict of interest risk. <\/p>\n
However, the company receives a score of \u20181\u2019 because its conflict of interest policy does not clearly define all types of relationship listed in the question guidance, such as employee and government relationships. It is also not clear whether this policy applies to those not directly employed by the company, such as those of subsidiaries and other controlled entities. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is some publicly available evidence that the company has procedures in place to manage conflicts of interest; for example, its conflict of interest policy states that any actual or potential conflicts must be disclosed to a manager and receive approval.<\/p>\n
However, there is no evidence that actual and potential conflict of interest declarations are held in a central register, nor that such declarations are reviewed and overseen by a designated body or individual with ultimate accountability for the management of the process. Moreover, the company does not provide any further detail on its criteria for recusals or the potential disciplinary measures for breaches of the policy. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence to indicate 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 to indicate that the company reports details of the contracted services of serving politicians. <\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
Although the company indicates that it generally prohibits political contributions, there is evidence that they are permitted in certain circumstances. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company discloses details of its political contributions.<\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy and procedure covering both charitable donations and sponsorships. These policies include specific measures to ensure that such donations are not used as vehicles for bribery and corruption, for example by specifying criteria for donations, provisions for senior sign-off and due diligence on recipients. The company also publishes some information on the recipients of its donations, but it is not clear whether this description represents a full list of all recipients. <\/p>\n
However, the company does not publish sufficient details on its charitable donations and sponsorships, such as the amount, country of recipient and which corporate entity made the payment. <\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has a policy on lobbying that applies to all employees and associated lobbying firms. The company states that any lobbying activities must comply with all relevant laws and regulations, and that lobbying on behalf of the company must never be used to gain an improper advantage. <\/p>\n
However, the company\u2019s approach does not define and control the standards of conduct required to ensure responsible lobbying. There is some evidence that the company may provide this information in an internal document, but this is not publicly available. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence to indicate 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 to indicate that the company publishes 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 and procedure on the giving and receipt of gifts and hospitality. The policy specifies financial or proportional limits for different types of promotional expenses. It also addresses the risks associated with gifts and hospitality given to\/received from public officials. <\/p>\n
Although the company indicates that gifts and hospitality must be recorded in financial records, there is no evidence the company has a dedicated register or central depository 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 responsible for establishing all new supplier relationships and for oversight of its supplier base. <\/p>\n
However, 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":"1","comments":"
Based on publicly available information, there is some evidence that the company undertakes risk-based anti-corruption due diligence on its supply chain. <\/p>\n
However, there is no evidence that the due diligence is repeated at least every two years, or that the company might be willing to review or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated. <\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. In its Supplier Conduct Principles, the company addresses the bribery, conflicts of interests, gifts and hospitality and whistleblowing procedures that suppliers should have in place. There is also evidence that the company takes active steps to ensure that its suppliers follow the principles, and that it assures itself of this for all new suppliers and on an ongoing basis throughout the duration of the relationship. <\/p>\n"},{"question":85,"commitment_area":12,"score":"2","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 is applied by sub-contractors throughout the supply chain. The company states that it ensures this by requiring audit rights and access to data for contractors throughout its supply chain. <\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions. <\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy covering the use of agents. This policy addresses the corruption risks associated with the use of agents and applies this to subsidiaries and joint ventures. The company states that the use of agents must be justified with a business rationale. <\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has formal procedures for conducting risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging its third parties and agents. There is evidence that agents and highest-risk intermediaries are subject to enhanced due diligence. The company also commits to not engaging with intermediaries where risks identified in the due diligence cannot be mitigated.<\/p>\n
However, there is no evidence that this due diligence is repeated at least every two years or when there is a significant change in the business relationship. <\/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, or that it commits to not engaging or terminate its engagement with agents or intermediaries if beneficial ownership cannot be established. <\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries. The company includes audit and termination rights in its contracts with these parties to detect, control and prevent breaches. <\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
There is some evidence that incentive structures for agents are highlighted and addressed as a risk factor in bribery and corruption risk. The company states that fees and bonuses must be justifiable and reasonable, and that payments to agents must be pro rata in accordance with the project. <\/p>\n
However, there is no evidence that the company imposes a specific threshold on the payment of sales commissions to agents so that they do not exceed a proportion of the net fee to the agent, or that the company requires that remuneration be paid in stages into local bank accounts. <\/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":"1","comments":"
Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering a joint venture. There is evidence that this due diligence is conducted for every joint venture partnership. <\/p>\n
However, it is not clear that the company\u2019s due diligence explicitly includes checks on the ultimate beneficial ownership of the partner company or that due diligence is repeated at least every two years. <\/p>\n"},{"question":101,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company commits to establishing and implementing anti-bribery and corruption policies in all of its joints ventures. The company indicates that it monitors its joint ventures\u2019 compliance with these agreements and that it includes termination rights in its contracts to prevent breaches. <\/p>\n"},{"question":102,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. <\/p>\n
However, the company does not provide any further statements or evidence to support this claim. <\/p>\n"},{"question":103,"commitment_area":14,"score":"1","comments":"
There is evidence that the company recognises the corruption risks associated with offset contracting. The company has a dedicated team involved in managing offset obligations, particularly in the establishment of offset suppliers. <\/p>\n
However, there is little evidence of policies and process to address the risks associated with offset contracting. It is also not clear that the offset team is responsible for monitoring the company\u2019s offset activities throughout the lifecycle of each project, and there is no evidence that all employees within the team receive tailored anti-bribery and corruption training. <\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
There is 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
However, the company does not specifically mention checks on beneficial ownership or conflict of interest, there is no evidence that the company seeks to assure itself of the legitimacy of the investment, and there is no evidence that the company refreshes this due diligence continuously or when there is a significant change in the business relationship or nature of the partner. <\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence to indicate that the company publishes 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":"
There is no publicly available evidence to indicate that the company publishes any details of its offset obligations or contracts. <\/p>\n"},{"question":107,"commitment_area":15,"score":"2","comments":"
Based on publicly available information, there is evidence that the company acknowledges the corruption risks associated with operating in different markets and that it has an assessment process in place to assess such risks. This includes clear risk management procedures and there is evidence that the results of these assessments have an impact on business decisions and trigger the implementation of additional controls. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
Based on publicly available information, there is evidence that the company publishes a list of its consolidated subsidiaries and some of its non-fully consolidated holdings. The lists include percentage of holdings, countries of incorporation and are updated on at least an annual basis. <\/p>\n
However, it is not clear that the company has included all of its joint ventures and associated companies, or the countries of operation for each entity. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
Based on publicly available information, the company is listed on the Oslo Stock Exchange, along with several other stock exchanges in the European Economic Area. It therefore automatically receives a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no publicly available evidence to indicate that the company publishes a percentage breakdown of its defence sales by customer. <\/p>\n"},{"question":111,"commitment_area":16,"score":"2","comments":"
The SOE publishes information about its shareholder voting rights, indicating that its voting rights are proportionate to the shares held and are not differentiated. The company is also publicly listed and therefore receives \u20182\u2019 because it publishes the required voting rights. <\/p>\n"},{"question":112,"commitment_area":16,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s commercial and public policy objectives are made publicly available on its website and are updated on at least an annual basis. <\/p>\n"},{"question":113,"commitment_area":16,"score":"2","comments":"
The SOE is open and clear about its nomination process, appointment and composition of its board and provides details of its board members. The SOE discloses details of its nomination process, including the criteria for nomination, which company representatives are involved in the nomination, and who makes the final appointment decision. For each board member, the SOE discloses whether that person has any connection to the company or the state or is an independent director.<\/p>\n"},{"question":114,"commitment_area":16,"score":"1","comments":"
Based on publicly available information, the company does not explicitly state that the majority of its audit committee members are independent directors, although information provided elsewhere suggests that they are. <\/p>\n
To score \u20182\u2019 the company would need to state that the Audit Committee comprises a majority of independent and non-state affiliated directors by design at all times. <\/p>\n"},{"question":115,"commitment_area":16,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a system to manage asset transactions. The company indicates that responsibility for auditing and approving the company\u2019s financial statements is held by the board of directors. <\/p>\n
However, there is no evidence that the responsibility for managing asset transactions is held at board level. It is unclear and not specified whether asset transactions are subject to scrutiny by an audit body. Furthermore, there is no evidence that all transactions are documented or that the financial results from asset acquisitions are made publicly available in the company\u2019s reports. <\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/589","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=589"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=589"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}