There is evidence that the company publishes a Standards of Ethics and Business Conduct which outlines its stance against bribery and corruption. It is clear that this document was authorised and endorsed by the company's leadership, though an introductory message from the company\u2019s President and CEO and executive team. <\/p>\n
However, the company receives a score of \u20181\u2019 because the statement from the company\u2019s leadership does not directly address or mention the organisation\u2019s stance against bribery and corruption.<\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company publishes an anti-bribery and corruption policy which specifically prohibits bribery, payments to public officials and commercial bribery. There is evidence that this policy applies to all employees and board members of the company as listed in (a) and (b) in the question.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence it prohibits facilitation payments. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated board committee \u2013 the Audit Committee \u2013 oversees the company's ethics and compliance programme. The company indicates that this includes reviewing reports from management on the programme\u2019s performance. In addition, there is evidence that Audit Committee has the authority to require that updates and changes to the programme are made when necessary. <\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
There is evidence that the General Counsel and Chief Compliance Officer have been assigned responsibility managing the company\u2019s ethics and compliance programme. There is evidence that these individuals have a direct reporting line to the board-level Audit Committee, which is responsible for providing oversight of the programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence of reporting and feedback activities between these individuals and the board as part of its reporting structure.<\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company has a formal risk assessment procedure in place, which is used to inform the company\u2019s anti-bribery and corruption programme. There is evidence that the company has a risk management programme, but there is no publicly available indication that this includes an assessment of ethics and compliance-related risks. <\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is evidence that the company\u2019s Audit Committee conducts periodic reviews of the company\u2019s Standards of Ethics and Business Conduct document, which includes its policy on anti-bribery and corruption. However, there is no clear publicly available evidence that the company conducts internal or external audits of its anti-bribery and corruption programme. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company commits to investigating incidents and that it has a procedure for documenting and handling whistleblower reports. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes information on the whole investigation process from receipt to final outcome. There is no clear evidence that all investigations are handled by an independent team, nor that the company commits to providing whistleblowers with updates on the outcome of investigations. In addition, although the Audit Committee reviews whistleblower complaints related to the integrity of the company\u2019s financial statements, it is not clear that it receives summary information of all investigations relating to bribery and corruption incidents. <\/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":"1","comments":"
There is some evidence that the company commits to report material findings of bribery and corruption from internal investigations to the board, through the Audit Committee. However, the company receives a score of \u20181\u2019 because there is no evidence 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 any data on ethical or bribery and corruption incidents, investigations or disciplinary actions involving its employees. <\/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 its employees.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company provides anti-bribery and corruption training to its employees, nor that it tailors its anti-bribery and corruption training to certain 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 publicly available evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption communications or training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company\u2019s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles. The company provides some information on its executive compensation programme, but there is no evidence that it provides information on its incentive structures for employees. <\/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.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is evidence the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. The company\u2019s policy explicitly applies to all employees across the organisation. There is also evidence that the company\u2019s whistleblowing line is open to third parties, including those employed by 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":"2","comments":"
There is evidence that the company provides multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. The company indicates that these channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an external party through an independently-operated channel. These channels allow for confidential and anonymous reporting and are accessible to all employees in all jurisdictions where the company operates. In addition, there is also evidence to indicate that the company\u2019s whistleblowing line is open to third parties including suppliers and available in relevant languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence the company has a policy that defines conflicts of interest, including actual and potential conflicts. The company\u2019s policy clearly covers possible conflicts arising from employee and government relationships, financial interests and other employment. There is evidence this policy applies to all employees and board members. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that this policy includes perceived conflicts, nor is it clear that it applies to the company\u2019s subsidiaries and other controlled entities. It is noted that the company has an additional policy on conflicts of interest - ManTech policy CG 306 \u2013 Personal Conflict \u2013 but this does not appear to be publicly available.<\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is evidence the company has procedures in place to identify, declare and manage conflicts of interest, including actual and potential conflicts. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that all employee and board member declarations are held in a dedicated central register or database that is accessible to those responsible for oversight of the process. There is also no clear evidence that disciplinary measures will apply if the company\u2019s policy on conflicts of interest is breached. It is noted that the company has an additional policy on conflicts of interest \u2013 ManTech policy CG 306 \u2013 Personal Conflict \u2013 but this does not appear to be publicly available.<\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy that addresses the risks associated with the employment of public officials. The company\u2019s policy states that employees are required to obtain permission from the company\u2019s Human Resources Department before engaging in employment discussions with current or former government employees. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it 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. In addition, although the company states that it will comply with legally-required employment restrictions, it is not clear that the company may impose its own restrictions to prevent conflicts of interest with former government officials. <\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no publicly available 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 has a policy on corporate political contributions. The company\u2019s policy indicates that it may make political contributions when approved by the company\u2019s Corporate Legal Department and providing that such donations are not used to obtain an improper advantage. In addition, there is evidence that that the company is associated with a Political Action Committee (PAC) in the United States.<\/p>\n
Since the company does not prohibit political donations and is associated with a PAC, it receives a score of \u20180\u2019 in line with the scoring criteria. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company discloses any details of its corporate political contributions or the donations made through its Political Action Committee (PAC). <\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy or procedure on charitable donations and sponsorships. The company publishes some information on the charitable organisations that it supports, but there is no evidence that it publishes a clear policy with controls to ensure donations are not used as vehicles for bribery and corruption, nor that it publishes full details of the donations made to these organisations. <\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
There is some evidence that the company has a policy on lobbying, in line with its policy on political contributions. The company indicates that employees must obtain prior approval from the Corporate Legal Department before engaging in lobbying. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it defines responsible lobbying, nor that its policy outlines certain standards of conduct or specific oversight mechanisms that apply to all types of lobbyists. There is also no clear publicly available evidence that the policy applies to third parties and other entities controlled by the company.<\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any information on its lobbying aims, topics or activities.<\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any details about its global lobbying expenditure. <\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a procedure on the giving and receipt of gifts and hospitality, which stipulates procedures to ensure that such promotional expenses are not used for bribery. The company\u2019s policy addresses the risks associated with gifts and hospitality given to and received from domestic and foreign public officials. There is also some evidence that the company has different approval procedures for different types of promotional expenses.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register or database that is accessible to those responsible for oversight of the process. It is noted that the company has a gifts and entertainment policy but this does not appear to be publicly available.<\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base. The company indicates that it has a Procurement Manual which may include more information on this subject, but this does not appear to be publicly available. <\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company conducts risk-based anti-bribery and corruption due diligence on its supply chain. The company states that it conducts due diligence on its vendors and indicates that this includes compliance; however there is no evidence that such checks are risk-based, nor that they specifically include an anti-bribery and corruption component. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is evidence that the company requires that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company indicates that suppliers must comply with its Supplier Code of Conduct, which requires suppliers adopt policies that prohibit bribery and facilitation payments, as well as procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that it assures itself of this when onboarding new suppliers and when there is a significant change in the business relationship. <\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. However, this evidence is in the form of a simple statement and it is unclear how the company does this in practice.<\/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 incidents, investigations or 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":"0","comments":"
There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its agents and 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 no publicly available evidence that the company\u2019s anti-corruption policy applies to agents, nor that it includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.<\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company considers incentive structures as a risk factor in agent behaviour. <\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any details of the agents currently contracted to act for or on its behalf.<\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving its agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"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, nor 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 taking 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 evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that it has a dedicated body, department or team is responsible for monitoring of 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":"
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 some evidence that the company acknowledges the corruption risks of operating in different markets. However, there is no evidence that risk assessment procedures are used to inform the company\u2019s operations in high risk markets, nor is it clear that the results of such assessments have an impact on business decisions.<\/p>\n"},{"question":108,"commitment_area":15,"score":"0","comments":"
There is evidence that the company publishes a list of its significant subsidiaries as part of its annual reporting documents. However, the list does not include the percentages owned, country of incorporation and countries of operation for each entity. Since it is not clear whether this list includes both fully consolidated subsidiaries and any non-fully consolidated holdings, there is no evidence that this list is represents all of the company\u2019s affiliates and therefore it receives a score of \u20180\u2019. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed, trading on regulated markets in the United States and European Economic Area. The company is therefore not required to disclose further information on its beneficial ownership and receives a score of \u20182\u2019. The company also publishes some information regarding its beneficial ownership on its own website as part of its annual corporate reporting documents.<\/p>\n"},{"question":110,"commitment_area":15,"score":"1","comments":"
The company publishes information on its defence sales to indicate that the United States government accounts for 98% of its total revenue, 73% of which stems from defence sales. There is evidence that this information accounts for the most recently reported financial year. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not publish information on its customers that account for more than 80% 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\/597","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=597"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=597"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}