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 bribery or corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company\u2019s CEO.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
The company publishes an explicit anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members.<\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
Based on publicly available information, there is some evidence that the board of directors is responsible for the company\u2019s anti-bribery and corruption programme.<\/p>\n
However, there is no evidence to suggest that it engages in formal oversight functions, such as reviewing reports from management or the results of internal and external audits.<\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
While the company refers to a local compliance officer in its Ethics Charter, there is no further public information concerning the role, responsibilities or seniority of this individual. There is insufficient evidence that a specific managerial-level employee has ultimate responsibility for implementing and managing the company\u2019s anti-bribery and corruption programme.<\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company has a formal risk assessment procedure which is used to inform the company\u2019s anti-bribery and corruption programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company\u2019s anti-bribery and corruption programme is subject to audit or review. <\/p>\n"},{"question":60,"commitment_area":8,"score":"0","comments":"
There is some evidence that the company commits to investigating incidents. However, the company does not provide any details about specific procedures in place to deal with whistleblowing cases, which stipulate documentation and actions to be taken at each step. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company assures itself of the quality of its internal investigations. <\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company\u2019s investigative procedure includes a commitment to report material findings of bribery and corruption to the board, or 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":"0","comments":"
There is no evidence that the company publishes high-level results from incident investigations and disciplinary actions.<\/p>\n"},{"question":64,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company provides anti-bribery and corruption training to all of its employees. <\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk. <\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company\u2019s incentive schemes incorporate ethical or anti-bribery and corruption principles.<\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company commits to support or protect employees who refuse to act unethically, even when this might result in a loss of business. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is evidence the company has a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, which applies to all employees across the organisation. There is also evidence the company\u2019s whistleblowing channels are open to third parties engaged by the group.<\/p>\n
However, the company scores \u20181\u2019 as 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":"
There is evidence that the company has multiple whistleblowing and advice channels, which are open to all employees. There is also evidence the company\u2019s whistleblowing channels are open to third parties. There is some evidence that whistleblowing complaints may be handled confidentially. <\/p>\n
However, the company scores \u20181\u2019 as the evidence suggests the company only offers internally operated channels and does not explicitly offer anonymous channels. There is also no publicly available evidence that the channels are available in all relevant languages. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is some evidence that the company has a policy for conflicts of interest that applies company-wide. <\/p>\n
However, the policy does not explicitly cover all of the categories of possible conflicts listed in the question. The company also does not clearly define the types of relationships or conflicts covered under its policy. <\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
While the company states that employees must inform their manager of conflicts of interest, there is no further publicly available evidence concerning the company\u2019s procedures for managing conflicts of interest and their oversight.<\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is some evidence that the company has a policy that addresses the risks associated with the employment of public officials. The company states that human resources and compliance departments must review the hiring process for former government employees or their family members. <\/p>\n
However, the company scores \u20181\u2019 as publicly available evidence does not provide further details of specific controls to assess and regulate the employment of current or former public officials. There is no evidence that the company has a policy to implement 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":"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 company permits political contributions. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
The company does not disclose details of its political contributions. <\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is some evidence that the company has procedures covering both charitable donations and sponsorships to ensure that such donations are not used as vehicles for bribery and corruption. However, the company does not publish further details regarding these procedures, for example, by specifying criteria for donations, requirements for senior sign-off, or due diligence on recipients. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no evidence the company has a policy or procedure on lobbying.<\/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 information on its lobbying aims, topics or activities.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that that the company has a procedure on the giving and receipt of gifts and hospitality. The company indicates that any expenses associated with gifts and hospitality must be entered into its financial accounts. <\/p>\n
However, the company scores \u20181\u2019 as there is no evidence the company\u2019s policies or procedures specify financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no evidence the company addresses the risks associated with gifts and hospitality given to\/received from domestic or foreign public officials. 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. <\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company\u2019s procurement department is involved, in some capacity, in the establishment and oversight of supplier relationships. <\/p>\n
However, there is no evidence that the involvement of the procurement department is required for establishing any new suppliers over a certain threshold. It is not clear from publicly available evidence that the procurement department is the main body responsible for oversight of the company\u2019s supplier base. There is also no evidence that the company assures itself of the procurement department\u2019s involvement at least every three years. <\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company conducts risk-based anti-bribery and corruption due diligence on its supply chain. <\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
While there is evidence that the company requires suppliers to comply with applicable anti-corruption laws, there is nothing to suggest that it ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no 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":"
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":"0","comments":"
While the company states that the use of sales partners, which can be understood to include agents, is governed by internal procedures, the company does not publish any further information on these procedures. <\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no 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 evidence that the company aims to establish the beneficial ownership of its agents.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is evidence that the company\u2019s Ethics Charter applies to sales partners, which can be understood to include agents and intermediaries. However, there is no publicly available evidence that the company includes audit and termination rights in its contracts with these entities. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company's incentive structures for agents are designed to minimise risks of bribery and corruption.<\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
The company does not publish any details of the agents currently contracted to act for or on behalf of the company.<\/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 agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its joint ventures. <\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, or that it requires anti-bribery and corruption clauses in its contracts with joint venture partners. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.<\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company addresses the corruption risks associated with offset contracts. There is also no evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.<\/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":"
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 about the beneficiaries of its indirect offset obligations.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no publicly available evidence that the company acknowledges the corruption risks of operating in different markets, 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 publishes some information regarding its subsidiaries on its website but the information published is insufficiently detailed to satisfy the requirements to receive a score of \u20181\u2019.<\/p>\n"},{"question":109,"commitment_area":15,"score":"0","comments":"
The company does not disclose information about its beneficial ownership or control structure, nor a statement that no individual owns 25% or more of shares or voting rights.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
The company does not publish a percentage breakdown of its defence 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\/591","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=591"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=591"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}