There is no evidence that the organisation has a publicly stated commitment to anti-bribery and corruption that is authorised by its leadership. The organisation makes a publicly stated commitment to high standards of ethical conduct but there is no specific mention of anti-bribery and corruption, nor is there evidence that this commitment is supported by a senior figure. <\/p>\n"},{"question":55,"commitment_area":7,"score":"0","comments":"
There is no publicly available evidence that the organisation has an anti-bribery and corruption policy. The organisation makes a general commitment to upholding ethical values but there is no specific mention of policies or procedures to prevent bribery and corruption.<\/p>\n"},{"question":56,"commitment_area":7,"score":"0","comments":"
There is no evidence that the organisation has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.<\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
There is no evidence that a specific managerial-level employee has ultimate responsibility for implementing and managing the organisation\u2019s anti-bribery and corruption programme.<\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
There is no evidence that the organisation has a formal risk assessment procedure that is used to inform its anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is no evidence that the organisation\u2019s anti-bribery and corruption programme is subject to audit or review.<\/p>\n"},{"question":60,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the organisation has a procedure for dealing with bribery and corruption allegations, incidents or whistleblowing reports. There is evidence that it operates a whistleblowing channel, however the organisation does not provide any further information on how allegations and investigations are handled. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no evidence that the organisation assures itself of the quality of its internal investigations.<\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
There is no evidence that the organisation\u2019s investigative procedure includes a commitment to report material findings to the board and, if appropriate, to relevant authorities.<\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
The organisation does not publish any data on ethical or bribery and corruption investigations or disciplinary actions involving its employees. <\/p>\n"},{"question":64,"commitment_area":9,"score":"0","comments":"
There is no evidence that the organisation provides anti-bribery and corruption training to all employees. <\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the organisation provides tailored anti-bribery and corruption training to its employees depending on their exposure to potential risks.<\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is no evidence that the organisation 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 evidence that the organisation\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 organisation commits to support or protect employees who refuse to act unethically.<\/p>\n"},{"question":69,"commitment_area":9,"score":"0","comments":"
The organisation does not have a publicly available policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents. <\/p>\n"},{"question":70,"commitment_area":9,"score":"0","comments":"
There is evidence that the organisation provides whistleblowing and advice channels for use by its employees. The organisation states that these channels allow for anonymous reporting and that concerns may be raised in confidence. <\/p>\n
However, the organisation receives a score of \u20180\u2019 because the information provided about these channels is insufficiently clear and there is no publicly available evidence of how employees may access these channels. It is also not clear whether the organisation provides both internally- and externally-operated channels, nor is it clear whether these channels are available to employees of third parties, suppliers and joint venture partners. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the organisation has a policy that formally requires employees to avoid any actual or perceived conflicts of interest. The organisation states that this includes both personal and business relationships, and there is evidence that this applies to all employees and third parties. <\/p>\n
However, the organisation receives a score of \u20181\u2019 because it does not provide any further information on potential categories of conflicts \u2013 e.g. government relationships, financial interests, etc. \u2013 and it does not explicitly state that this policy applies to all board members. <\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the organisation has procedures to manage conflicts of interest or their oversight. The organisation requires all employees to avoid actual or perceived conflicts but does not provide further information on specific procedures to identify, declare or manage conflicts of interest. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no evidence that the organisation 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 organisation 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 organisation 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 organisation 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":"
There is no evidence that the organisation has a policy and\/or procedure covering both charitable donations and sponsorships. The organisation publishes some information about its charitable activities in its Corporate Social Responsibility Report; however, this does not include full details of all charitable donations made, including details of the recipient, amount, country of recipient and which entity made the payment. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no evidence that the organisation has a policy and\/or procedure on lobbying.<\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the organisation 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 organisation provides any details about its global lobbying expenditure. <\/p>\n"},{"question":81,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the organisation has a policy or procedure on gifts or hospitality.<\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no evidence that the organisation requires the involvement of its procurement department in the establishment and oversight of its supplier base.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is no evidence that the organisation conducts anti-bribery and corruption due diligence on its supply chain.<\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the organisation requires its suppliers to have their own anti-bribery and corruption policies and procedures in place. The organisation\u2019s Code of Ethics and Conduct applies to contractors; however, this refers to general standards of ethical business conduct and, with the exception of conflicts of interest, does not provide the level of detail of anti-bribery and corruption controls necessary to receive a score of \u20181\u2019.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no evidence that the organisation 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 organisation publishes any data on ethical or anti-bribery and corruption-related 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 organisation 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 organisation 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 organisation 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 organisation 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 organisation 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 organisation 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 organisation 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 organisation 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 organisation commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no evidence that the organisation 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 organisation engages in offset contracting.<\/p>\n"},{"question":104,"commitment_area":14,"score":"N\/A","comments":"
There is no readily available evidence that the organisation engages in offset contracting.<\/p>\n"},{"question":105,"commitment_area":14,"score":"N\/A","comments":"
There is no readily available evidence that the organisation engages in offset contracting.<\/p>\n"},{"question":106,"commitment_area":14,"score":"N\/A","comments":"
There is no readily available evidence that the organisation engages in offset contracting.<\/p>\n"},{"question":107,"commitment_area":15,"score":"N\/A","comments":"
There is no readily available evidence that the organisation 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 organisation publishes a list of subsidiaries or affiliated entities. The organisation operates Federally Funded Research and Development Centers and publishes details of these entities, but these are considered to be different from subsidiaries. <\/p>\n"},{"question":109,"commitment_area":15,"score":"N\/A","comments":"
The organisation is a non-profit organisation and therefore does not have shareholders. <\/p>\n"},{"question":110,"commitment_area":15,"score":"N\/A","comments":"
There is no readily available evidence that the company engages in commercial or industry sales in the defence sector. <\/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\/600","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=600"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=600"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}