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 an anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. It is clear from publicly available information that this policy applies to all employees and board members.<\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is some evidence that the company has a designated board committee that oversees all compliance activities, which is understood to include the anti-bribery and corruption programme. The company\u2019s publicly available evidence indicates that the board discusses the results of activities in the previous fiscal year and responds to legal amendments. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence to suggest that it engages in formal oversight functions, such as reviewing the results of internal and external audits.<\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
There is evidence that a managerial-level individual has been assigned ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme, which is understood to be a part of its compliance activities. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence to indicate that the individual is a senior executive. In addition, there is no evidence that this individual has an explicit direct reporting line to the board committee that provides oversight of the anti-bribery and corruption programme.<\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":""},{"question":59,"commitment_area":8,"score":"1","comments":"
There is some evidence that the company\u2019s anti-bribery and corruption programme, as part of its compliance framework, is subject to regular review. There is also evidence that high-level audit findings are presented to the board, with clear ownership assigned to units for planned updates and improvements to the anti-bribery and corruption programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not does not clearly specify that the entire programme is audited to ensure that it is consistent with high standards of best practice and the business risks facing the company.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly commits to investigating incidents, and the company has a specific procedure in place to deal with whistleblowing cases, which stipulates documentation and actions to be taken at each step. The process covers the investigation from receipt to outcome and is held by an independent team. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it commits to provide whistleblowers with updates on the outcome of investigations. In addition, there is no evidence that information from each investigation is documented or that summary information is reviewed by a central body. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no 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 investigations to the relevant authorities if necessary. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that an appropriate senior individual is responsible for ensuring that the disclosure of material findings 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 investigations or disciplinary actions involving its employees.<\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides training that outlines the basic principles of the anti-bribery and corruption policy. The company provides this training to all employees across all divisions and countries of operation on an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that this training is provided in all appropriate languages or if the training includes the whistleblowing options available to employees. <\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk. The company\u2019s CSR report indicates that senior managers and directors receive specialised training for their roles, but it is not clear that this includes anti-bribery and corruption principles. <\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because the measures are limited to the number of personnel trained and completion rates. There is also no evidence that results are used to update specific parts of the company's anti-bribery and corruption \u2013 or compliance \u2013 communications and training programme. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company\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 company commits to support or protect employees who refuse to act unethically.<\/p>\n"},{"question":69,"commitment_area":9,"score":"0","comments":"
There is no clear evidence that the company promotes a policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents. <\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
There is evidence that the company has multiple channels to report instances of suspected corrupt activity. The company indicates that these channels are sufficiently varied to allow the employee to raise concerns across the management chain and to channels managed by independent external parties. There is evidence that the company\u2019s channels are available to all employees in all jurisdictions, including those employed by the group as third parties, and that they allow for confidential and, wherever possible, anonymous reporting. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that employees are encouraged to use the channels to seek advice about the company\u2019s anti-corruption policies, nor that the channels are available in multiple languages. <\/p>\n"},{"question":71,"commitment_area":10,"score":"0","comments":"
There is no evidence to suggest that the company has a policy to regulate conflicts of interest. <\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company has procedures to manage conflict of interest or their oversight.<\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company 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":"0","comments":"
There is some evidence that the company has a procedure on political contributions, to ensure that these payments are not used as vehicles for bribery and corruption.<\/p>\n
However, where political contributions are permitted, there is no evidence to suggest that the company requires authorisation from an individual with legal expertise. In addition, there is no clear evidence that this procedure applies to all employees, board members, third parties and other entities controlled by the company.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is some evidence that the company has a procedure on political contributions, to ensure that these payments are not used as vehicles for bribery and corruption. However, there is evidence that the company may make political contributions in some circumstances.<\/p>\n
Where political contributions are permitted, there is no evidence to suggest that the company requires authorisation from an individual with legal expertise. In addition, there is no clear evidence that this procedure applies to all employees, board members, third parties and other entities controlled by the company.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy or procedure to regulate charitable donations and sponsorships.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy and\/or procedure on lobbying.<\/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":"0","comments":"
There is no publicly available evidence that the company has a policy or procedure on gifts and hospitality.<\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is some evidence that the company\u2019s purchasing division is involved in the oversight of its supply chain. <\/p>\n
However, the extent the purchasing division is involved in the oversight of the supplier base is unclear. In addition, there is no evidence that the company requires the involvement of its procurement department in the establishment of its supplier base. <\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is no clear evidence that the company conducts due diligence on its supply chain. The company\u2019s Annual Report indicates that it evaluates and reviews its relationship with its suppliers periodically but it is not clear that this constitutes formal due diligence nor that such reviews take into account anti-bribery and corruption risks. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company clearly states that all suppliers must have, at minimum, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, as well as policies and procedures to address gifts and hospitality and whistleblowing. There is evidence that the company takes active steps to ensure this by requesting that all suppliers follow its own anti-bribery policies and procedures and by requesting them to sign an agreement to implement CSR guidelines in their company.<\/p>\n
However, the company receives a score of \u20181\u2019 there is no evidence that suppliers must have policies in place covering conflicts of interest. It is also not clear that any assurance is conducted when there is a significant change in the business relationship.<\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
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 set of supplier principles that sets the minimum standards of ethical behaviour expected 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 relating to its suppliers, or the associated disciplinary actions.<\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company has a policy to regulate the use of agents.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or 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 evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.<\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it has controls in place to mitigate these risks, such as imposing a threshold on the payment of sales commissions to agents or a requirement that remuneration is paid in stage payments or into local bank accounts.<\/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 and on behalf of the company.<\/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 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 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 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 evidence that the company addresses the corruption risks associated with offset contracting, nor that a dedicated body, department or team is responsible for monitoring its 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 all aspects of 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 the company\u2019s offset programme.<\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of its indirect offset obligations or contracts. <\/p>\n"},{"question":107,"commitment_area":15,"score":"1","comments":"
There is evidence that the company acknowledges the corruption risks associated with operating in different markets. The company indicates that it has a risk assessment procedure in place to account for business related risks, with clear risk management procedures in place. There is evidence that the results of these risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls.<\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide examples of such possible controls. In addition, the publicly available evidence on risk management procedures is not explicitly related anti-bribery and corruption, instead focusing on \u2018business-related risks\u2019 more widely. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a list of its consolidated subsidiaries and affiliates. Since this information is published in the company\u2019s Annual Report, there is evidence that this list is updated on an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because the list does not include joint ventures or the country of incorporation and operation for each entity.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed on the Tokyo and London stock exchanges and is therefore required to disclose information on its beneficial ownership to the relevant bodies, so it is automatically awarded a score of \u20182\u2019.<\/p>\n"},{"question":110,"commitment_area":15,"score":"1","comments":"
There is some evidence that the company publishes a percentage breakdown of its defence sales by customer. The company publishes a breakdown of its revenue from external customers by geographic region, which indicates that Japan accounts for approximately 58% of its sales. However, the company receives a score of \u20181\u2019 because its publicly available evidence indicates that these figures relate to overall sales rather than defence-specific 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\/601","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=601"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=601"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}