The institute has a publicly stated commitment to adhere to relevant legislation concerning anti-bribery and corruption, such as the U.S. Foreign Corrupt Practices Act. However, further details are not publicly available and it is not clear whether this statement is endorsed by a senior figure. The Lincoln Laboratory, the federally funded research and development centre through which MIT undertakes work for the U.S. Department of Defense, likewise does not publish a separate statement regarding anti-bribery and corruption authorised by a senior figure. <\/p>\n"},{"question":55,"commitment_area":7,"score":"0","comments":"
There is evidence that the Lincoln Laboratory has a code of conduct, which applies to all personnel, including board members. However, this code of conduct makes no reference to anti-bribery and corruption; rather it states that employees must contribute to an ethical atmosphere and comply with laws and regulations. <\/p>\n"},{"question":56,"commitment_area":7,"score":"0","comments":"
There is evidence that the Risk and Audit Committee is responsible for the oversight of the institution\u2019s compliance programme. However, this is only evident from simple statements that do not offer details into oversight functions, such as reviewing reports from management or the results of internal and external audits. There is no publicly available information about whether the committee specifically oversees anti-corruption efforts, nor whether it specifically oversees the Lincoln Laboratory.<\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
There is evidence that the institution has assigned responsibility for implementing and managing its compliance programme to several managerial-level employees. However, anti-bribery and corruption is not mentioned explicitly as a part of the compliance programme. Additionally, there is no evidence of reporting and feedback activities between these individuals and the board as part of the institution\u2019s reporting structure, for example through attendance or participation at board-level committee meetings. <\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
There is evidence that the institution has a formal risk assessment procedure that informs the design of its compliance programme, and that the results of these assessments are reviewed at board level. These procedures do not explicitly apply to bribery or corruption; however, it seems clear that the programme would include these issue areas. It is unclear how often risk assessments are conducted. <\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
The institute states that it has an Audit Division which regularly undertakes audits into its various divisions, inclusive of the Lincoln Laboratory. While there is some evidence that the institute\u2019s audits entail the review of compliance concerns, it is not explicitly clear whether this component of the Lincoln Laboratory\u2019s operations is subject to review. <\/p>\n"},{"question":60,"commitment_area":8,"score":"0","comments":"
There is evidence that the institute has a complaint resolution procedure, which details actions and documentation to be taken at each step. However, publicly available evidence suggests that these procedures only relate to employment policy concerns, such as discrimination and harassment; there is no evidence that they extend to bribery, corruption or ethics-related concerns. The Lincoln Laboratory also publishes separate information for reporting violations, but it does not detail any specific procedures for dealing with such reports. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no evidence that the institute assures itself of the quality of its internal investigations relating to anti-bribery and corruption. There is some evidence that the institute commits to investigating misconduct, harassment and other employment policy complaints promptly and objectively; however the institute receives a score of \u20180\u2019 because it is not clear that this extends to reports made about corruption and bribery concerns, and there is insufficient evidence that it assures itself of the quality through training of staff conducting investigations. <\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
The institute commits to informing a relevant senior executive of the results of investigations regarding complaints about employment policy violations. However, there is no evidence that there are any mechanisms in place for reporting corruption or bribery investigations to the board, or for ensuring the disclosure of material findings of such investigations to the relevant authorities. <\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
The institute does not publish any data on ethical or bribery and corruption investigations or disciplinary actions.<\/p>\n"},{"question":64,"commitment_area":9,"score":"0","comments":"
There is evidence that the Lincoln Laboratory provides training on the Code of Conduct to all of its new employees. However, there is no evidence that the Code of Conduct includes anti-bribery and corruption principles. <\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the institute 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 institute 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 institute\u2019s incentive schemes incorporate ethical or anti-bribery and corruption principles.<\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no evidence that the institute commits to support or protect employees who refuse to act unethically.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
The institute promotes a clear policy of non-retaliation against both whistleblowers and employees. However, the institute\u2019s reporting policy \u2013 and therefore also its non-retaliation policy \u2013 does not explicitly mention anti-bribery and corruption incidents, allegations or concerns. There is also no evidence to suggest that the institute takes steps to assure itself of its employees\u2019 confidence in this commitment, through surveys or other clearly stated means. <\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
The institute has multiple channels to report instances of suspected corrupt activity. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and an independent third party, through the provision of an externally-operated hotline. These channels allow for confidential and, wherever possible, anonymous reporting which extends to both employees and non-employees. Lincoln Laboratory is active only in the U.S. and therefore the reporting channels are automatically available in the relevant jurisdiction and language. <\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
The institute formally addresses conflicts of interest as a corruption risk, and has a clear policy and\/or procedure that defines conflicts of interest, including actual, potential and perceived conflicts. The policy explicitly covers multiple categories of possible conflicts listed in the guidance. The institute states that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities.<\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
The institute has clear procedures to identify, declare and manage conflicts of interest \u2013 including those actual, potential and perceived \u2013 relating to financial interests. This includes a statement that all employee and board member declarations of actual and potential conflicts of interest are recorded in a dedicated register that is accessible to and reviewed by those responsible for oversight of the process. The description of this procedure also includes examples of criteria for recusals and a description of the potential punitive measures for breaches of the policy.<\/p>\n
However, the institute receives a score of \u20181\u2019 because it is not clear that such detailed procedures are followed for other forms of conflicts of interest. Although there seem to be informal mechanisms in place for managing other conflicts of interest, there is insufficient evidence for these to be considered formal management channels. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no evidence that the institute has a policy regulating the employment of current or former public officials.<\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company reports details of the contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"N\/A","comments":"
There is no readily available evidence that the institute is able to make political contributions due to its nature as a non-profit, tax-exempt organisation in the United States of America. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
There is no readily available evidence that the institute is able to make political contributions due to its nature as a non-profit, tax-exempt organisation in the United States of America. <\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
The institute has a policy covering charitable donations, but it is not clear whether this also includes sponsorships. Furthermore, there is no evidence that these procedures 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. There is no evidence that the institute discloses its donations on an annual basis.<\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
The institute has a policy that defines lobbying, and sets out the values and behaviours that constitute \u2018responsible\u2019 lobbying. However, the institute receives a score of \u20181\u2019 because there is no evidence that it provides further details of its lobbying controls and guidelines to ensure these standards are upheld.<\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the institute publishes any specific information on its lobbying aims, topics or activities. The institute publishes some information on its relationships with federal, municipal and state government but this does not cover specific aims or topics. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the institute provides any details about its lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is some evidence that the institute has a policy on the acceptance of gifts and hospitality, which addresses possible bribery and corruption risks and generally prohibits the acceptance of personal gifts by MIT employees. <\/p>\n
However, the institute receives a score of \u20181\u2019 because there is no evidence that the policy covers the giving of gifts, nor does it specify financial or proportional limits or different approval procedures for different types of promotional expenses. It also does not address the specific 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 evidence that the institute 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. However, the institute receives a score of \u20181\u2019 because there is no evidence that it takes steps to assure itself that proper supplier onboarding procedures are followed through clearly stated means, such as an audit, at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is no evidence that the institute conducts anti-bribery and corruption due diligence on its supply chain.<\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
There is some evidence that the institute ensures that its suppliers adhere to its terms and conditions, including compliance and purchasing ethics. However, the institute does not explicitly refer to anti-bribery and corruption in its terms and conditions, and does not provide any details relating to specific anti-bribery and corruption measures.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no evidence that the institute 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 institute 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":"N\/A","comments":"
There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.<\/p>\n"},{"question":89,"commitment_area":13,"score":"N\/A","comments":"
There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.<\/p>\n"},{"question":90,"commitment_area":13,"score":"N\/A","comments":"
There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.<\/p>\n"},{"question":91,"commitment_area":13,"score":"N\/A","comments":"
There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.<\/p>\n"},{"question":92,"commitment_area":13,"score":"N\/A","comments":"
There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.<\/p>\n"},{"question":98,"commitment_area":13,"score":"N\/A","comments":"
There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.<\/p>\n"},{"question":99,"commitment_area":13,"score":"N\/A","comments":"
There is no readily available evidence that the institute engages agents in the conduct of business due to its nature as a non-profit organisation.<\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
There is no evidence that the institute conducts anti-bribery and corruption due diligence on its joint ventures.<\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no evidence that the institute commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, nor is there evidence 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 evidence that the institute 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":"N\/A","comments":"
There is no readily available evidence that the company engages in offset contracting.<\/p>\n"},{"question":104,"commitment_area":14,"score":"N\/A","comments":"
There is no readily available evidence that the company engages in offset contracting.<\/p>\n"},{"question":105,"commitment_area":14,"score":"N\/A","comments":"
There is no readily available evidence that the company engages in offset contracting.<\/p>\n"},{"question":106,"commitment_area":14,"score":"N\/A","comments":"
There is no readily available evidence that the company engages in offset contracting.<\/p>\n"},{"question":107,"commitment_area":15,"score":"N\/A","comments":"
There is no readily available evidence that the institute is engaged in supplying goods or services, nor that it operates in markets or jurisdictions outside of the United States of America.<\/p>\n"},{"question":108,"commitment_area":15,"score":"0","comments":"
There is no evidence that the institute publishes a list of its subsidiaries or affiliated entities.<\/p>\n"},{"question":109,"commitment_area":15,"score":"N\/A","comments":"
The institute is a non-profit organisation and therefore does not have shareholders. The organisation is governed by a board of trustees known as the MIT Corporation. <\/p>\n"},{"question":110,"commitment_area":15,"score":"N\/A","comments":"
There is no readily available evidence that the company makes commercial and industry sales in the defence sector. However, the institute does publish a complete breakdown of the federal grants that it receives. <\/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"}]},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/599","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=599"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=599"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}