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 leadership.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company publishes a clear 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 as described in (a) and (b) in the question. <\/p>\n"},{"question":56,"commitment_area":7,"score":"0","comments":"
There is no clear evidence to suggest that a designated board committee or individual board member is responsible for the company\u2019s anti-bribery and corruption programme. There is some evidence to indicate that the Legal Affair & Chief Compliance Officer is responsible for the compliance programme, however it is not clear whether this individual is a senior executive or board member, nor that this individual has ultimate responsibility for overseeing the programme. <\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
There is evidence that the Legal Affairs & Chief Compliance Officer 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 CEO and board of directors, which provides oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this individual and the board twice a year as part of the company\u2019s reporting structure.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that this individual is a senior executive.<\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
There is evidence that the company has a risk assessment procedure that informs the design of its anti-corruption programme. 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
However, the company receives a score of \u20181\u2019 because it is not clear whether the results of risk assessments are reviewed by the board on at least an annual basis. <\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is evidence that the company's anti-bribery and corruption programme is subject to regular audit and that the compliance program is monitored once a year. There is also evidence that the findings are used to improve the procedure. However, the company does not clearly state how frequently audits are conducted and so a score of \u20180\u2019 applies.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company commits to investigating incidents and that there is a specific procedure in place to deal with whistleblowing cases. There is a commitment to providing whistleblowers with updates on the outcome of investigations, and there is evidence that the CEO and Chief Justice review summary information of all incidents. <\/p>\n
However, it is not clear from publicly available information how frequently this occurs and the company does not provide publicly available information to cover the whole investigation process from receipt to final outcome. Although the company mentions record keeping as part of its anti-corruption procedures, it is not clear whether this covers investigations and therefore whether information on each investigation is documented. There is also no clear evidence that all investigations are handled by an independent team or reported to an independent board member.<\/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 investigations, for example by indicating that staff conducting investigations are properly trained, by implementing a policy to handle complaints about the process or by reviewing the investigation process every three years. <\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
There is evidence that the company commits to report material findings from investigations to the board. The company commits to report criminal offences to the relevant authorities, and there is evidence that an appropriate senior has been assigned responsibility for ensuring this occurs when necessary.<\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption investigations or disciplinary actions involving its employees.<\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides a training module that outlines the basic principles of the anti-corruption policy. The company indicates that this training is provided to all employees across all divisions, all countries and regions of operation, and in all relevant languages on an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that the training includes the whistleblowing options available to employees.<\/p>\n"},{"question":65,"commitment_area":9,"score":"2","comments":"
There is evidence that the company tailors its anti-corruption training programme to the different levels of risk facing employees in different roles, with specific reference to all categories of employee referred to in the question. There is evidence that employees working in high risk positions are required to refresh their training in this area on at least an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company reviews its anti-corruption communications and personnel training programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear if the company reviews the effectiveness of the programme on at least an annual basis, or whether the results are used to update specific parts of the company's anti-corruption communications and training programme. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is some evidence in the company\u2019s Code of Ethics that it applies fair measures to evaluate the abilities and performances of its employees and rewards them accordingly. However, the company does not provide further details on its approach to indicate that incentives for employees incorporate ethical principles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is evidence that the company commits to protect and support employees who refuse to act unethically. However, it is not clear from publicly available information that this statement extends to situations where such actions result in a loss to the company and there is no evidence that the company assures itself of 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 promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents that explicitly applies to all employees across the organisation, including those employed by the group as third parties and suppliers. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company assures itself of its employees\u2019 confidence in this commitment through surveys, usage data or other clearly stated means. <\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
There is evidence that the company has whistleblowing and advice channels, and that whistleblowing channels are anonymous and confidential. The channels are explicitly available to all employees in any country of operation and to any employees of third parties, suppliers and joint ventures. <\/p>\n
However, the company receives a score of \u20181\u2019 because it only offers internally operated channels and it is not explicitly state that the channels are available in multiple languages. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy for actual conflicts of interest. The policy covers financial interests, other employment, and employee relationships. The policy applies to all employees.<\/p>\n
However, the company receives a score of \u20181\u2019 because it does not explicitly cover potential or perceived conflicts and it does not mention government relationships. It is also not clear whether the policy applies to board members. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has procedures to identify, declare and manage actual conflicts of interest, and that the Compliance department has oversight and accountability for handling cases. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not state that all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process. Additionally, the policy does not mention examples of criteria for recusals and does not state that disciplinary measures will apply if the policy is breached. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company has a clear policy regulating the employment of current or former public officials.<\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company reports details of the contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"2","comments":"
The company publishes a clear statement that it prohibits any form of political donations on its behalf. There is evidence that this position applies company-wide to all employees and board members. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
The company publishes a clear statement that it does not make political contriubtions, and therefore it is exempt from scoring on this question. <\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is evidence that the company has a policy covering both charitable donations and sponsorships, but there is no evidence that there are procedures which include measures to ensure donations are not used as vehicles for bribery and corruption, for example, by specifying criteria for donations, procedures for senior sign-off, or due diligence on recipients. The company also does not publish sufficient detail of the donations made.<\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
The company publishes a statement that Korean law does not permit lobbying and that it complies with all applicable laws. The company receives a score of \u20181\u2019 because it is not clear from publicly available information whether this approach also applies to any lobbing activities conducted in other jurisdictions. There is no publicly available evidence that the company publishes a clear policy to regulate its lobbying activities in other jurisdictions, nor does it publish a statement to indicate that it does not lobby outside Korea.<\/p>\n"},{"question":79,"commitment_area":11,"score":"N\/A","comments":"
The company publishes a statement that Korean law does not permit lobbying and that it complies with all applicable laws. Since this statement applies to the main jurisdiction in which the company operates, it is exempt from scoring on this question; though it is noted that it is not clear from publicly available information whether the company conducts lobbying in other jurisdictions outside of Korea. <\/p>\n"},{"question":80,"commitment_area":11,"score":"N\/A","comments":"
The company publishes a statement that Korean law does not permit lobbying and that it complies with all applicable laws. Since this statement applies to the main jurisdiction in which the company operates, it is exempt from scoring on this question; though it is noted that it is not clear from publicly available information whether the company conducts lobbying in other jurisdictions outside of Korea. <\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. The company specifies financial limits for when employees receive any kind of economic benefit, which includes gifts and hospitality. The policy also addresses the risks associated with gifts given to public officials. <\/p>\n
However, the company receives a score of \u20181\u2019 because the policy does not specify financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated 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's procurement department is involved in the establishment and oversight of supplier relationships. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that this procurement department is the main body responsible for oversight of all of supplier relationships, nor is there evidence that the company assures itself of the procurement department\u2019s proper involvement in this process at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct due diligence on all of its suppliers. The company indicates that due diligence is conducted before engaging with new suppliers and is repeated when renewing the contracts.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that due diligence includes checks on ultimate beneficial ownership or that highest risk suppliers are subject to enhanced due diligence. There is also no evidence that due diligence is repeated at least every two years or when there is a significant change in the business relationship. Additionally, the company the company does not state that it would 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":"1","comments":"
There is evidence that the company requires its suppliers to have adequate anti-bribery and corruption policies and procedures in place. There is evidence that the company takes active steps to ensure this, by requiring that suppliers follow its Code of Ethics and by including anti-corruption terms in its contracts. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not explicitly state that all suppliers must have, at least, policies that prohibit facilitation payments and policies that cover gifts & hospitality or whistleblowing. It is also unclear whether the company assures itself of its suppliers\u2019 adherence to its policies when onboarding and when there is a significant change in the business relationship.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no publicly available 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 or the associated disciplinary actions relating to its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company has a policy on the use of agents.<\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging with its third parties and agents. The company indicates that due diligence is conducted before engaging with new agents and repeated when renewing contracts. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that agents and highest risk intermediaries are subject to enhanced due diligence, and there is no evidence that 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.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is some evidence that the company\u2019s Code of Ethics extends to sales agents and third parties, and that it includes anti-bribery and corruption clauses in its contracts with agents. The company provides information to indicate that these contractual clauses termination rights. However, there is no clear publicly available evidence that the company includes audit rights in its contracts with such entities to detect, control and prevent breaches. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company highlights and addresses incentive schemes as a possible risk factor in agent behavior. The company provides some information to indicate that it prohibits contractual commissions but it does not indicate specifically that this applies to agents and intermediaries, nor does it provide further information on how compensation for agents is structured to reduce bribery and corruption risk. <\/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 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 prior to entering into and while operating in joint venture partnerships.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that the company\u2019s due diligence explicitly includes checks on the ultimate beneficial ownership of the partner company. There is also no evidence to suggest that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence. The company does not state that due diligence is repeated at least every two years.<\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies in all of its joint ventures and that it includes termination rights in contracts with joint venture partners. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that the company takes steps to detect, control and prevent breaches through the inclusion of audit rights in the contracts.<\/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 contracting, nor is there evidence that a dedicated body, department or team is responsible for managing its offset activities. <\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
There is some evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations. The company indicates that its definition of third parties includes offset partners and that such entities are subject to the same due diligence procedures as other third parties. <\/p>\n
However, there is no publicly available evidence that the company\u2019s due diligence process in the case of offset projects and partners includes checks on beneficial ownership and conflicts of interest. There is also no evidence that the company seeks to assure itself of the legitimacy of the project, nor that the company refreshes the due diligence continuously or when there is a significant change in the business relationship.<\/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.<\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of its offset obligations or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no publicly available evidence that the company acknowledges the corruption risks associated with operating in different markets, nor that it has a risk assessment process in place to account for these specific risks.<\/p>\n"},{"question":108,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes a list of consolidated subsidiaries and non-fully consolidated holdings on its website. <\/p>\n"},{"question":109,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes any information about its beneficial ownership or control structure, nor a statement that no individual owns 25% or more of shares or voting rights. The company states that its beneficial ownership and control structure can be checked on an external electronic disclosure system, but it was not possible to identify relevant information from a search of this system. In addition, although the company indicates that it is publicly listed, it does not have voting shares admitted to a regulated market as specified in the guidance. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes any information about its defence sales by customer on its website. The company indicates that this information can be accessed through an external portal, however it was not possible to identify relevant information from a search of this system.<\/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\/595","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=595"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=595"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}