There is evidence that the company\u2019s CEO makes a commitment to integrity and high ethical standards in business conduct. The CEO also endorses the company\u2019s Statement of Business Ethics, which prohibits bribery and corruption and makes a commitment to comply with anti-bribery laws. <\/p>\n
However, the company\u2019s senior leadership does not specifically mention corruption and bribery. <\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
The company publishes outlines of its anti-bribery and corruption policies, contained in its Statement of Business Ethics. This policy, which prohibits bribery, commercial bribery and payments to public officials, explicitly applies to all employees and board members.<\/p>\n
However, the policy does not extend beyond a general commitment to comply with anti-bribery laws and regulations, and does not specifically prohibit facilitation payments. Additionally, the company does not specify whether the policy also applies to employees and the leadership of subsidiaries and other controlled entities. <\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is evidence that the board and its Audit Committee is ultimately responsible for the oversight of the company's anti-bribery and corruption programme.<\/p>\n
However, the company receives a score of \u201a1\u2018 because there is insufficient evidence to suggest that the board or its committees engage in formal oversight functions of the anti-corruption programme, such as reviewing reports from management and ensuring that required changes are implemented.<\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
There is no evidence that the company has a specific managerial-level employee who holds ultimate responsibility for implementing and managing the company\u2019s anti-bribery and corruption programme. <\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company has a formal risk assessment procedure that is used to inform the company\u2019s anti-bribery and corruption programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is no clear evidence that the company\u2019s anti-bribery and corruption programme is subject to audit or review. <\/p>\n"},{"question":60,"commitment_area":8,"score":"0","comments":"
There is evidence that the company commits to investigate incidents raised through its ethics hotline. However, the company does not provide information specific procedures in place to deal with whistleblowing cases, which stipulates documentation and actions to be taken at each step.<\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
There is some evidence that the company assures itself of the quality of its investigations by specifying that where employees feel their complaint was mishandled, they may contact a confidential hotline. <\/p>\n
However, there is no evidence that the company assures itself of the quality of both incident investigations and whistleblowing cases, there is no evidence that staff conducting investigations are properly trained, and it is unclear who is responsible for handling complaints about the investigation process itself. There is also no evidence that the company reviews its investigations procedure at least every three years or in response to any changes in the regulatory environment.<\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company has an investigative procedure which includes a commitment to report material findings to the board.<\/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 to all employees on its Statement Of Business Ethics, which outlines the basic principles of its ethics and anti-corruption programme, including whistleblowing options available to employees. The company states that training is provided for all new hires and is repeated bi-annually.<\/p>\n
However, the company receives a score of \u20181\u2018 because there is no evidence that training is systematically provided to all employees across all divisions, all countries of operation and in all relevant languages. <\/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.<\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company 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 company\u2019s incentive schemes incorporate ethical or anti-bribery and corruption principles.<\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is evidence that the company states that employees must not engage in unethical practices, even if it results in lost business. However, there is no evidence that the company explicitly commits to protecting or supporting employees in such situations.<\/p>\n"},{"question":69,"commitment_area":9,"score":"0","comments":"
There is evidence that the company promotes a clear non-retaliation policy and states that employees who breach this policy will face disciplinary action. However, the company cannot receive a score of \u20181\u2019 because it does not explicitly state that this policy applies company-wide to include those employed by the group as third parties, suppliers and joint venture partners. There is also 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 both whistleblowing and advice channels. <\/p>\n
However, the company receives a score of \u20181\u2019 because the company does not state that these channels are available to all employees in any country of operation, or in multiple languages, or to any employees of third parties, suppliers or joint venture partners. The evidence also indicates that the company only operates internal channels. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy covering actual and perceived conflicts of interest, which applies to all employees and board members. The company makes explicit reference to possible conflicts concerning other employment, and, for its senior executives, personal relationships. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the policy includes conflicts concerning financial interests, employee relationships, or government relationships for all employees. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company states that for directors, the Audit Committee is responsible for handling declarations of conflicts of interest, and provides criteria for recusals for directors. <\/p>\n
However, it is not clear whether these same controls apply to all employees, and the company does not state that all declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process. <\/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 no evidence that the company has a policy regarding commercial political contributions.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company discloses details of its political contributions.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy or procedure covering both charitable donations and sponsorships.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes a policy 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 provides 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 policy and procedure on the giving and receipt of gifts and hospitality, which also addresses the risks associated with gifts and hospitality given to and received from domestic or foreign public officials.<\/p>\n
The company, however, receives a score of \u20181\u2019 because its 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 some capacity, in the establishment and oversight of supplier relationships. Evidence indicates that this department is the main body responsible for oversight of the company\u2019s supplier base.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is unclear if the involvement of the procurement department is required for establishing new suppliers over a certain threshold. There is also no evidence that the company assures itself of the procurement department\u2019s involvement at least every three years. <\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
The company states that it will only work with suppliers that have equivalent ethical policies. However, there is insufficient evidence indicating that it conducts risk-based anti-corruption due diligence on its supply chain.<\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
The company states that suppliers must meet a certain standard of ethical business conduct. However, it does not refer to any specific anti-bribery and corruption measures that its suppliers must have in place, such as specific policies prohibiting domestic bribery and facilitation payments, or policies covering conflicts of interest, gifts & hospitality.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no 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 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 clear policy covering the use of agents.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company states that it 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":"0","comments":"
There is no evidence that the company mentions 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 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 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 and or 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 contracts, and there is no evidence that 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 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 offset obligations and contracts. <\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company\u2019s operations in high risk markets. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes a list of all its holdings, including subsidiaries, non-fully consolidated holdings and joint ventures. This data includes an indication of percentage of ownership and country of incorporation, and is updated on an annual basis. The list is accompanied by a statement that it is accurate at the time of publication, to the best of the company\u2019s knowledge. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not include the country of operation for each entity. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is a publicly listed on the New York Stock Exchange and is therefore automatically awarded a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
Although the company discloses that the US government is a major source of its total sales, there is no evidence that the company provides a percentage breakdown of at least 50% of its defence sales by customer. <\/p>\n"},{"question":111,"commitment_area":16,"score":"N\/A","comments":""},{"question":112,"commitment_area":16,"score":"N\/A","comments":""},{"question":113,"commitment_area":16,"score":"N\/A","comments":""},{"question":114,"commitment_area":16,"score":"N\/A","comments":""},{"question":115,"commitment_area":16,"score":"N\/A","comments":""}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/602","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=602"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=602"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}