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's Chairman.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has an explicit anti-bribery and corruption policy, which makes 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 as described in (a) and (b) above.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that the board is ultimately responsible for the oversight of the company\u2019s anti-corruption programme. The company has established a Control and Risk Committee which comprises several board members and provides direct reporting on the anti-corruption programme to the board. There is also evidence that the board engages in formal and direct oversight functions, including reviewing reports from management along with the results of internal and external audits.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, the Chairman of the Board has ultimate responsibility for overseeing the implementation of the company's anti-bribery and corruption programme. An anti-corruption unit is responsible for management and implementation, reporting to the Chairman and the Group General Counsel. <\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a formal bribery and corruption risk assessment procedure that informs the design of its anti-bribery and corruption programme. The results of risk assessments are reviewed by the board on an annual basis. There is evidence that the results of such reviews are used to develop tailored mitigation plans and to update specific parts of the company's anti-bribery and corruption programme.<\/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 a regular audit process to ensure the programme is consistent with best practice and the business risks facing the company. The company explicitly includes provisions for continuous improvement, supplemented by internal audits as well as an external audit of its anti-bribery management system accreditation every year. There is evidence that high-level audit findings are presented to the board and acted upon by the anti-corruption unit. <\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company publicly commits to investigating incidents promptly, independently and objectively. There is evidence that the company takes steps to ensure the independence of its investigations. It commits to establishing root causes, putting in place remediation plans and reporting investigative findings to senior management and the board. For whistleblowing cases, there is a procedure in place that stipulates documentation and actions to be taken at every step of the case, from receipt to final outcome, and the company commits to ensure whistleblowers are informed of the outcome. There is evidence that a central body of the company receives and reviews summary information on all incidents on a regular basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company assures itself of the quality of its internal investigations, including those reported through whistleblowing channels. There is evidence that staff tasked with conducting investigations are properly trained and qualified to perform the function. There is evidence that the company\u2019s Surveillance Body oversees complaints about the investigation process. The 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":"
Based on publicly available information, the company makes a clear commitment to report material findings of bribery and corruption from investigations to the board. There is evidence that an appropriate senior individual 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":"2","comments":"
The company publishes high-level data from bribery and corruption-related incidents and investigations involving company employees at all levels. This includes the number of reports received, including the number received through whistleblowing channels, the number of investigations launched, and the number of disciplinary actions as a result of investigation findings. The information covers the last financial year.<\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides training that outlines the principles of its anti-bribery and corruption policy, including the whistleblowing options available to employees. The company provides this training to all employees across all divisions and countries of operation and in all appropriate languages. The company states that employees are required to undertake training on the anti-bribery and corruption programme 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 different anti-bribery and corruption training. The company makes specific reference to all three categories of employees. The company indicates that training frequency is based on a differentiation of risk, and that training is refreshed on either a one-year or three-year basis depending on the risk exposure of the employee. <\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme. There is evidence that the company has a system to do this through an anonymized employee survey conducted annually. It is clear that the results of these reviews are then used to update specific parts of the company's anti-bribery and corruption communications and training programme, with a review of the programme taking place at least every three years.<\/p>\n"},{"question":67,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence indicating that the company\u2019s incentive schemes are designed in such a way that they simultaneously promote ethical behaviour and discourage corrupt practices. The company incentivises ethical conduct through its performance and development management and leadership frameworks. There is evidence that financial rewards included in the company\u2019s incentive schemes must be proportionate to salaries for all employees. There is evidence indicating that the policy applies to employees in sales roles.<\/p>\n"},{"question":68,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, the company clearly states that any employee who refuses to act unethically, in keeping with the company\u2019s ethical and anti-bribery and corruption values and policy, will be protected and supported even where such actions result in a loss of business or another disadvantage to the company. There is evidence that the company assures itself of its employees' confidence in this commitment through annual anonymised surveys.<\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company promotes a policy of non-retaliation against all whistleblowers and employees who report bribery and corruption incidents, including those employed by the group as third parties. The company commits to assure itself of its employees\u2019 confidence in this commitment through annual anonymised surveys. <\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and to a relevant external body. These channels allow for confidential and anonymous reporting. They are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners, and in all relevant languages. <\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
Based on publicly available information, there is evidence that the has a policy that defines conflicts of interest, including actual and potential conflicts. The policy explicitly covers all of the categories of possible conflicts listed in the guidance. The company states that this policy applies to all employees and board members, including those at subsidiaries and other controlled entities. <\/p>\n"},{"question":72,"commitment_area":10,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual and potential conflicts. The Surveillance Body has oversight and accountability for handling cases. The policy mentions that disciplinary measures will apply if the Code of Ethics, in which conflicts of interest is regulated, is breached. The company indicates that all conflict of interest declarations must be submitted to the Surveillance Body.<\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a procedure which includes controls to assess and regulate employment and offers of employment or consultancy engagement to current and recently departed public officials, including politicians. There is evidence indicating the policy requires the involvement of the Senior Compliance Officer in employment discussions with former or current public officials, a review of conflict of interest and restrictions on their activities if such conflicts of interest are identified. <\/p>\n
In accordance with Italian law, the company has a policy to implement a cooling-off period of at least three years before public officials are permitted to have any form of contact or relationship with their former organisation on the company\u2019s behalf. However, there is no clear evidence that this requirement extends to all of the company\u2019s countries of operation.<\/p>\n"},{"question":74,"commitment_area":10,"score":"2","comments":"
The company publishes a clear statement that it does not contract serving politicians in all countries of operation. <\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, the company has a policy prohibiting corporate political contributions. This policy applies to all employees, board members, third parties and other entities controlled by the company. However, the company\u2019s US subsidiary has a Political Action Committee (PAC) and therefore the company receives a score of \u20190\u2019.<\/p>\n"},{"question":76,"commitment_area":11,"score":"2","comments":"
In publicly available evidence the company provides a link to the contributions made by its US subsidiary\u2019s Political Action Committee. The information provided includes details of the recipient, amount, country of recipient and the name of the corporate entity that made the contribution. There is evidence indicating that the data is updated and released on an annual basis.<\/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 to ensure that they are not used as vehicles for bribery and corruption. There is evidence that these procedures include criteria for donations, due diligence on recipients, and that donations are approved by senior management. <\/p>\n
However, while the company publishes some information on its charitable contributions on an annual basis, this is not sufficiently detailed for a score of \u20182\u2019. The company does not publish information on the amount of its donations for each recipient nor does it state which corporate entity made the payment. <\/p>\n"},{"question":78,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy that defines lobbying and sets out the values and behaviours that constitute \u2018responsible\u2019 lobbying. It refers to certain standards of conduct and oversight mechanisms that apply to all lobbyists. There is evidence that this policy applies to all employees, board members and third parties lobbying on the company\u2019s behalf.<\/p>\n"},{"question":79,"commitment_area":11,"score":"2","comments":"
Based on publicly available evidence, the company publishes a list of the topics on which it lobbies and its aims. The company provides specific aims and topics for each of its divisions. The evidence indicates that this information is provided for every jursidiction in which the company lobbies.<\/p>\n"},{"question":80,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides details of its global lobbying expenditure. The data is correct up to the most recently reported financial year. Expenditure data is broken down by corporate entity, geography, internal lobbyists v external lobbyists v association lobbying. The evidence indicates that the figure reported represents the company\u2019s expenditure on all lobbying activities worldwide. The company provides an explanation of how the figures in the data have been calculated.<\/p>\n"},{"question":81,"commitment_area":11,"score":"2","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 with clear procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits for the different types of promotional expense that employees may encounter, and there is evidence of an approval procedure. The policy also explicitly addresses the risks associated with gifts and hospitality given to and received from public officials. The company's policy includes a clear statement that all gifts and hospitality above certain thresholds are recorded in a dedicated register. <\/p>\n"},{"question":82,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence that the company requires the involvement of its procurement department in the establishment of new suppliers. This department is ultimately responsible for providing oversight of the company's supplier base. The company assures itself that proper procedures regarding the onboarding of suppliers are followed through an annual audit. <\/p>\n"},{"question":83,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based due diligence when engaging and re-engaging with any suppliers. The due diligence process explicitly includes establishing the ultimate beneficial ownership of the supplying company. There is evidence indicating that the highest risk suppliers are stated to be subject to enhanced due diligence. This process is conducted at least every two years or when there is a significant change in the business relationship. The company indicates that supplier relationships will be subject to review, and potential termination, if any red flags 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 evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. It is explicitly stated that all suppliers must have policies that prohibit bribery and facilitation payments, as well as those that address conflicts of interest, gifts and hospitality and whistleblowing. There is evidence that the company takes active steps to ensure this by requiring that all suppliers follow the anti-bribery policies and procedures of the company and the Supplier Code of Conduct. The company assures itself of this by contractually requiring this with every purchase order. <\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, 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 about the minimum standards of ethical behaviour expected throughout the supply chain, which the company enforces through its contracts with its own suppliers.<\/p>\n"},{"question":86,"commitment_area":12,"score":"2","comments":"
The company publishes high-level data from all ethical, bribery or corruption-related incidents and investigations involving suppliers. This includes the number of investigations launched and the number of disciplinary actions as a result of investigation findings. This data is published on an annual basis covering cases in the past 12 months. <\/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. The policy addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. The company commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. There is evidence indicating that the policy applies to subsidiaries and joint ventures. <\/p>\n"},{"question":89,"commitment_area":13,"score":"2","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 engaging any agents and intermediaries at least every two years or when there is a modification to the contract. The company also indicates that it will refresh its due diligence prior to making any payments to agents and intermediaries. All 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. <\/p>\n"},{"question":90,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company asks its agents to disclose their beneficial ownership to the company, which it verifies as part of its due diligence processes. The company states that it will not engage with agents or intermediaries if beneficial ownership cannot be established. The company also indicates that if any of the information provided by the agents or intermediaries is found to be inaccurate, it may suspend or terminate the contract. <\/p>\n
However, the company scores \u20181\u2019 as there is no clear evidence of a commitment to independently verify the beneficial ownership information of high risk agents.<\/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. All agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include audit rights and termination rights.<\/p>\n"},{"question":92,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that incentive structures for agents are addressed as a factor in bribery and corruption risk. The company places a clear threshold on sales-based commissions to agents and states that remuneration to agents is paid only in staged payments over the course of their contract, based on milestones. The company also commits to only paying agents into bank accounts where the company has its registered office.<\/p>\n"},{"question":98,"commitment_area":13,"score":"1","comments":"
The company publishes a figure of the number of agents it currently contracts disaggreated by contract type. The list covers the most recent financial year. <\/p>\n
However, the list falls short of the minimum level of detail required in score \u20182\u2019 as the company does not publish the names of agents.<\/p>\n"},{"question":99,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company publishes high-level data from all bribery and corruption-related incidents and investigations involving its agents. This includes the number of incidents and the types of sanctions applied as a result of investigation findings. This data is published on an annual basis.<\/p>\n"},{"question":100,"commitment_area":13,"score":"2","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 joint ventures. There is evidence indicating that the company\u2019s due diligence process includes checks on the owners of the partner company and joint ventures operating in high risk markets are subject to enhanced due diligence. There is evidence that the company conducts anti-bribery and corruption due diligence both prior to entering into a joint venture and when there is a significant change in the business relationship. <\/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 joint ventures. It does so by requiring joint ventures to adopt its own programme. The company includes audit and termination rights in its contracts with joint venture partners. <\/p>\n"},{"question":102,"commitment_area":13,"score":"2","comments":"
In publicly available evidence the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. There is evidence to support the company's commitment. The company indicates that it will work through its board representatives to ensure the adoption of a compliance programme. It also periodically performs assessments and holds staff meetings and workshops on anti-bribery and corruption.<\/p>\n"},{"question":103,"commitment_area":14,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has policies and procedures in place to address the corruption risks associated with offset contracting. The company requires offset partners to adhere to its anti-bribery and corruption standards through appropriate contractual clauses. The company has a dedicated body responsible for the monitoring and oversight of its offset activities throughout the lifecycle of each project. There is evidence that employees within this body receive anti-bribery and corruption training.<\/p>\n"},{"question":104,"commitment_area":14,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on offset partners. This process specifically includes checks on the beneficial ownership of partners and any potential conflicts of interest. As part of this process, the company's policy also commits to establishing and verifying that the offset obligation proposed is founded on a legitimate rationale. The company refreshes this due diligence whenever there is a significant change in the business relationship.<\/p>\n"},{"question":105,"commitment_area":14,"score":"1","comments":"
The company publishes an aggregate figure of the number of offset agents it employs for the most recent financial year. <\/p>\n
However, the list falls short of the minimum level of detail required for a score of \u20182\u2019. The company does not publish the names of its offset agents and brokers.<\/p>\n"},{"question":106,"commitment_area":14,"score":"1","comments":"
The company publishes aggregate information about its indirect offset projects for the most recent financial year.<\/p>\n
However, the list falls short of the minimum level of detail required for a score of \u20182\u2019.<\/p>\n"},{"question":107,"commitment_area":15,"score":"2","comments":"
Based on publicly available evidence, the company acknowledges the corruption risks associated with operating in different markets, and there is evidence that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. The results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. The company provides examples of these controls. <\/p>\n"},{"question":108,"commitment_area":15,"score":"2","comments":"
Based on publicly available information, the company publishes a list of all of its consolidated subsidiaries and non-fully consolidated holdings. The list includes the percentages owned and countries of incorporation for each entity. The list is complete and updated on at least an annual basis. The company also published information in the most recent financial year on the countries of operation of its largest subsidiaries. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is publicly listed on the Milan Stock Exchange and therefore automatically receives a score of \u20182\u2019. The company also discloses some information on its beneficial owners on its website. <\/p>\n"},{"question":110,"commitment_area":15,"score":"1","comments":"
The company publishes some information on its defence sales by market and geographical area. The company mentions specific customers (Italy, the US, the UK) representing 53% of its defence sales. <\/p>\n
The remaining 47% is an aggregate figure of the reminder of its defence clients by geographical area, and therefore is insufficiently detailed for the company to receive a score of \u20182\u2019. <\/p>\n"},{"question":111,"commitment_area":16,"score":"2","comments":"
The company is a publicly listed company with voting shares admitted to trading on a regulated market in the European Economic Area. The company publishes ownership and voting rights for the state entity which has a stake of over 10%. <\/p>\n"},{"question":112,"commitment_area":16,"score":"2","comments":"
The SOE's commercial and public policy objectives are made publicly available on its website and are updated on at least an annual basis or whenever there is a change in objectives.<\/p>\n"},{"question":113,"commitment_area":16,"score":"2","comments":"
The company is open and clear about the nomination process, appointment and composition of its board and provides details of its board members. The company discloses details of its nomination process, including the criteria for nomination and which company representatives are involved in the nomination. For each board member, the company discloses whether that person has any connection to the company, is an independent director, or whether they are a state representative.<\/p>\n"},{"question":114,"commitment_area":16,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s Control and Risks Committee is composed of a majority of independent directors. The company discloses the names and the status of each member. <\/p>\n"},{"question":115,"commitment_area":16,"score":"2","comments":"
Based on publicly available evidence, the SOE has a clear system in place for asset transactions, with responsibility assigned at board level for managing transactions. There is evidence indicating that asset transactions are scrutinised by an audit body. The SOE states that all transactions are documented. Financial results from asset acquisitions or disposals are made publicly available in the SOE\u2019s financial reports. <\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/594","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=594"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=594"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}