There is evidence that the company has a publicly stated anti-bribery and corruption commitment that outlines the company\u2019s stance against any form of bribery or corruption within the organisation. There is clear evidence that this commitment was authorised and endorsed by the company\u2019s leadership. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company publishes a clear anti-bribery and corruption policy, which specifically prohibits bribery, commercial bribery and facilitation payments. The company notes that although facilitation payments are generally prohibited, they may be permissible in certain exceptional circumstances where there is a perceived threat to life, safety or health. There is evidence that this policy applies to all employees and directors as described in (a) and (b) above. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that the Board of Directors has ultimate responsibility for the oversight of the company\u2019s anti-bribery and corruption programme. In addition, there is evidence that the company has an independent Ethics and Integrity Council that receives regular updates from the Chief Compliance Officer and has the mandate to make recommendations on ethics and anti-corruption directly to the board. The company indicates that the Board of Directors is involved in reviewing reports on the performance of the compliance programme through an annual review and evaluation process, and there is evidence that it has the authority to require that changes are made, if necessary.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior executive \u2013 the Chief Compliance Officer (CCO) \u2013 has ultimate responsibility for implementing and managing the company\u2019s anti-bribery and corruption programme. There is evidence that this individual has a direct reporting line to the Board of Directors, which provides oversight of the company\u2019s anti-bribery and corruption programme. The company also states that the CCO has a direct reporting line to the Chief Executive Officer (CEO), who is ultimately accountable for the company\u2019s compliance activities. There is evidence that the CCO engages in reporting and feedback activities with both the Board of Directors and the CEO on a regular basis, as part of the company\u2019s reporting structure. <\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
There is evidence that the company has a formal risk assessment procedure that includes anti-bribery and corruption risks, and informs the design of the compliance programme. The company states that this process is conducted continuously and there is evidence that the board reviews the results of these risk assessments on an annual basis (or more frequently if necessary). Although the company does not explicitly state that the results of such assessments are used to develop tailored mitigation plans, there is sufficient evidence that the programme is updated on this basis and so the company receives a score of \u20182\u2019. <\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s compliance program \u2013 which includes anti-bribery and corruption \u2013 is subject to a regular audit or \u2018assessment\u2019 process. There is evidence that this includes provisions for continuous improvement, supplemented by an independent or external review every three years. The company also states that findings and recommendations are presented to the Group Management Team and the Board on an annual basis. <\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a system for tracking, investigating and responding to allegations or incidents of bribery and corruption. The company publicly commits to investigating incidents promptly and there is evidence that the company has a procedure in place that stipulates documentation and actions to be taken at each step of the process. There is evidence that the company ensures the independence of its investigations, by involving the independent Ethics and Integrity Council (EIC) in the process and by noting that conflict of interest considerations are taken into account when establishing an investigation response team. <\/p>\n
In addition, although the company does not explicitly state that a central body within the organisation receives and reviews summary information on all cases on a regular basis, there is sufficient evidence to indicate that the Chief Compliance Officer and EIC fulfil this role in the process, so the company receives a \u20182\u2019. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company has appropriate arrangements in place to assure the quality of its internal investigations. There is no evidence that staff tasked with conducting investigations are properly qualified or trained to perform the function, nor does the company provide any information on how it handles complaints or concerns about the investigative procedure. Moreover, there is no evidence that the investigations procedure is subject to review at least every three years or in response to any relevant changes in the regulatory environment. <\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s investigative procedure includes a commitment to report material findings to the board and to relevant authorities, if necessary. The company indicates that the CCO \u2013 the main individual responsible for receiving allegations or incidents \u2013 provides information on compliance matters to the board on a monthly basis. There is also evidence that the company commits to report findings to relevant authorities if necessary, and based on the company\u2019s reporting and investigative structure it is clear that the CCO is responsible for this process. <\/p>\n"},{"question":63,"commitment_area":8,"score":"2","comments":"
There is evidence that the company publishes high-level data on its ethical and bribery-related incidents and investigations involving company employees. The company provides information on the number of reports received and the number of investigations launched, as well as stating that no concerns or legal proceedings were raised relating to bribery or corruption. There is evidence that this data is published on at least an annual basis, to cover cases from the most recently reported financial year. <\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides training that outlines the basic principles of its anti-bribery and corruption policy as described in the Ethical Code of Conduct and Anti-Corruption Manual, which includes the whistleblowing options available to employees. The company states that it provides e-learning modules in all relevant languages for most employees, supplemented by in-person training for the remaining staff members. There is evidence that employees are required to refresh their training on an annual basis. <\/p>\n"},{"question":65,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is some evidence that employees in certain positions receive different or tailored anti-bribery and corruption training. There is evidence in the company\u2019s publicly available documents that employees in high risk positions, middle management and board members (including external board members) are required to undertake tailored ethics and anti-corruption training. The company indicates that dilemma training for employees in high risk positions is delivered on an annual basis, as well as during the onboarding process. <\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company reviews its anti-bribery and corruption communications and training programme. The company indicates that it monitors its training and communications programme using training completion rates, as well as undertaking periodic employee surveys to ensure employee understanding. There is evidence that company monitors this on a monthly basis and reviews the overall results of any evaluations on an annual basis. <\/p>\n
Although the company does not explicitly state that this information is used to update the programme at least every three years, there is sufficient evidence to indicate that the results of such reviews are used to update the programme so the company receives a score of \u20182\u2019. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no evidence to indicate that the company\u2019s employee incentive schemes incorporate ethical or anti-bribery and corruption principles. The company provides some information on its top-level remuneration for senior management, but there is no evidence that this includes ethical targets nor that it applies to other employees. <\/p>\n"},{"question":68,"commitment_area":9,"score":"1","comments":"
The company publishes a statement that any employee who refuses to act unethically, in keeping with the company\u2019s ethical and anti-corruption values and policy, will be protected and supported even where such actions result in a disadvantage to the company. However, the company receives a score of \u20181\u2019 because there is no evidence that it assures itself of employees\u2019 confidence in this specific commitment through anonymised surveys or other clearly stated means. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption-related concerns or incidents. This policy is stated in the company\u2019s Ethical Code of Conduct, and therefore applies to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners. However, the company receives a score of \u20181\u2019 because there is no evidence that it 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\u2019s anti-bribery and corruption programme. These channels are sufficiently varied to allow the employee to raise concerns across the management chain and to relevant external bodies through the SpeakUp channel. The company states that these channels allow for confidential and, where possible, anonymous reporting. There is evidence that the company\u2019s whistleblowing channel is available and accessible to all employees in Europe, as well as an email channel that is available to those employed by the group as third parties, suppliers and joint venture partners based in other jurisdictions.<\/p>\n
Although the company states that it operates an external reporting channel (SpeakUp), it is noted that the company does not provide further details on how employees or external entities may access it. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy for conflicts of interest that explicitly applies to all employees and board members. Based on the company\u2019s publicly available information, there is evidence that this policy addresses conflicts that might arise from employee relationships, financial interests and other\/outside employment. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its policy specifically addresses or covers government relationships. <\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is evidence that the company has some procedures in place to identify, declare and manage conflicts of interest, which include reporting any potential conflicts to management and review of business assignments if a conflict arises. <\/p>\n
However, the company receives a score of \u20180\u2019 because its conflict of interest procedure does not include further details of specific controls to identify, declare and manage conflicts. For example, there is no evidence that a specific body or individual has oversight and accountability for handling cases, nor that employee declarations are held in a central register accessible by those responsible for oversight of the process. There is also no evidence that the company outlines criteria for recusals, though this information could possibly be provided in the training module on conflicts of interest. The company provides details of how any ethical concerns are handled, but it is not clear that this includes a specific procedure to handle conflicts of interest. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
Based on publicly available information, there is no evidence to indicate 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":"
Based on publicly available information, there is no evidence to indicate 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 that prohibits support of political parties or politicians, which applies to all employees and board members within the organisation. However, the company receives a score of \u20180\u2019 because although it prohibits corporate political contributions, there is evidence that the company is associated with a Political Action Committee (PAC) in the USA. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes details of its direct or indirect political contributions on an annual basis. The company indicates that its Political Action Committee in the USA may support political parties, but there is no evidence that the company publishes any details of these donations on its own website.<\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a procedure covering charitable donations and sponsorships, which includes sign-off from a three-person committee, a formal contract and certain accounting standards. There is evidence that this procedure applies to all legal entities and business units within the company. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not publish details of its sponsorships in sufficient detail. The company publishes percentages of its donations per sector, but there is no evidence that this data is updated on an annual basis and it does not include details such as the recipient, amount, country of recipient or which corporate entity made the payment.<\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence to indicate that the company requires all lobbyists acting on its behalf to follow the standards of behaviour outlined in its Ethical Code of Conduct. There is evidence that this applies to all employees, board members and third parties engaged in lobbying on the company\u2019s behalf. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company has a specific policy which defines lobbying and stipulates specific standards of conduct for those engaged in lobbying activities. There is no evidence that the company has specific controls or procedures in place for lobbyists, such as oversight mechanisms or other guidelines. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any information about its lobbying aims, topics or activities. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence to indicate that the company publishes any details about its global lobbying expenditure. <\/p>\n"},{"question":81,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality. The company\u2019s policy specifies a financial limit for all promotional expenses \u2013 noting that any gifts above that level which cannot be refused should immediately be reported to a superior \u2013 and its policy also addresses the risks associated with gifts and hospitality given to\/received from public officials. The company does not state that all gifts and hospitality above a certain threshold are recorded in a dedicated central register, the company\u2019s strict and low financial threshold on promotional expenses is sufficient to merit a score of \u20182\u2019. <\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company\u2019s procurement department is involved in the establishment and oversight of supplier relationships. The company states that a central procurement department is responsible for the onboarding and review of the supplier base, while noting that in some smaller entities this process is managed by a specific procurement or supply chain manager. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide any publicly available information to indicate that it assures itself of the procurement department\u2019s involvement in the onboarding and management process at least every three years. <\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has formal procedures in place to conduct risk-based due diligence when engaging and re-engaging with suppliers. The company indicates that the degree of due diligence is dependent on a number of factors including type, size and geographic location of the supplier, and states that various red flags and sanctions list are checked during the process. There is evidence that highest risk \u2013 termed \u2018critical\u2019 in the company\u2019s documents \u2013 are subject to enhanced due diligence and self-assessment requirements every two years. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not clearly indicate that this due diligence process includes establishing the ultimate beneficial ownership of the supplying company. There is also no clear evidence to suggest that the company might review or possibly terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated.<\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company outlines these expectations in its Supplier Conduct Principles, which stipulates standards on facilitation payments, gifts and hospitality and whistleblowing. In addition, the company states that suppliers must comply with its Ethical Code of Conduct which contains similar standards covering these areas. There is evidence that the company takes active steps to ensure that these standards are being upheld, for example by requiring that all suppliers complete a self-assessment as part of the onboarding process, conducting annual reviews on a selection of companies and by cooperating with suppliers to improve their policies if necessary. <\/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 policies and procedures in place, and that the substance of its anti-bribery and corruption programme is included in sub-contracts throughout the supply chain. The company clearly indicates in its Supplier Conduct Principles that it expects suppliers to flow down these standards throughout the supply chain, and states that it performs regular audits and reviews to assure itself that these standards are upheld in practice. <\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
Based on publicly available information, there is no evidence to indicate that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers. <\/p>\n
The company publishes a statement in its 2019 Sustainability Report that no \u201cnegative social impacts\u201d were recorded in relation to its supply chain; however it is not sufficiently clear that this relates to ethics and compliance, instead of other social considerations such as compliance around the environment or modern slavery.<\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy covering the use of consultants and sales representatives \u2013 which is understood to include agents. It is clear that this policy applies group-wide to any entities that may employ agents. There is evidence that the company commits to establishing that the use of an agent is, in each case, based on a clear need identified in a business and market plan. The company also provides details of specific controls in place to mitigate the potential risks associated with the use of agents, for example by requiring that all sales representatives undergo dedicated ethics training, by ensuring that such entities comply with its Ethical Code of Conduct and through regular reporting. There is also evidence that the company\u2019s Group-level Legal & Compliance department is responsible for oversight and due diligence of agents, which is consistent with the level of risk. <\/p>\n
Although the company does not directly address the corruption risks associated with agents, it does provide a statement on the compliance risks associated with consultants, agents and sales representatives as part of a broader statement on third parties, which is deemed sufficient for a score of \u20182\u2019 given the accompanying information. <\/p>\n"},{"question":89,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with its third parties and agents. The company indicates that agents are subject to enhanced due diligence based on the size, type and country risk. There is evidence that the company conducts due diligence during the onboarding phase and every two years throughout the business agreement, supplemented with continuous monitoring. The company\u2019s description of its due diligence process indicates that agents will only be contracted if the due diligence is approved and indicates that it is willing to review or terminate its engagement if the agreement is breached. <\/p>\n"},{"question":90,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has formal procedures in place to establish the beneficial ownership of its agents as part of the due diligence process. The company indicates that such checks take place during the onboarding phase, as well as every two years throughout the business agreement. <\/p>\n
The company receives a score of \u20181\u2019 because it does not clearly publish a statement to indicate that it would not engage or terminate its engagement with agents or intermediaries in cases where the beneficial ownership cannot be established.<\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
There is evidence that the company\u2019s anti-bribery and corruption policy applies to all agents and sales representatives acting for or on behalf of the company. The company\u2019s publicly available information indicates that agreements with all sales representatives include monitoring clauses to mitigate corruption and compliance risks, as well as audit and termination rights to detect, control and prevent breaches.<\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
There is evidence that the company addresses incentive structures for agents as a factor in bribery and corruption risk, by stipulating measures to control such processes as part of its compliance programme. The company states that remuneration for sales representatives must be proportionate to the service rendered and supported by relevant documentation, as well as noting that any payments should adhere to generally accepted accounting principles. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it places a threshold on sales-based commissions to agents so that payments to not exceed a proportion of the net fee, nor does it commit to paying agents into local bank accounts or through staged payments over the course of their contract. <\/p>\n"},{"question":98,"commitment_area":13,"score":"1","comments":"
There is evidence that the company publishes an aggregate figure of the number of agents employed to act for or on its behalf, for the most recently reported financial year. The company also publishes high-level information to indicate the regions in which these agents have been active. <\/p>\n
The company receives a score of \u20181\u2019 because the information published falls short of the level of detail required to receive a score of \u20182\u2019 such as the names of the sales representatives. <\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence to indicate that the company publishes data on ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving agents.<\/p>\n
The company publishes a statement in its 2019 Sustainability Report that no \u201cnegative social impacts\u201d were recorded in relation to its supply chain; however it is not sufficiently clear that this relates to ethics and compliance, instead of other social considerations such as compliance around the environment or modern slavery. It is also not sufficiently clear that this statement covers both suppliers and sales representatives. <\/p>\n"},{"question":100,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all of its joint venture partnerships. The company indicates that joint venture partners are subject to enhanced due diligence based on country, size, type, role, nature of the transaction and historical relationship. These criteria imply that the company undertakes enhanced due diligence for joint ventures operating in high risk countries or with high risk partners. <\/p>\n
There is also evidence to indicate that the company\u2019s due diligence includes establishing the beneficial ownership of joint venture partners and that such checks are conducted prior to entering into the contract and then every two years throughout the relationship. Although the company provides this information in relation to sales representatives, it publishes a statement that the same due diligence process applies for joint ventures and therefore it merits a score of \u20182\u2019. <\/p>\n"},{"question":101,"commitment_area":13,"score":"2","comments":"
There is evidence that the company commits to establishing and implementing anti-bribery and corruption procedures in all of its joint ventures. The company clearly states that it includes anti-bribery and corruption clauses in its joint venture contracts, and there is evidence that it requires all business partners to abide by the standards outlined in its Ethical Code of Conduct throughout the business relationship. The Ethical Code of Conduct therefore applies to all third parties and business partners, and stipulates policies and procedures prohibiting bribery and facilitation payments. The company also makes reference to audit and termination rights in its contracts, though it is noted that although this evidence applies to joint ventures, it is presented primarily in the context of sales representatives. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is some evidence that the company expects its business partners to adhere to ethical standards and that it conducts regular anti-bribery and corruption reviews of its third parties. However, there is no clear evidence to suggest that the company commits to take an active role in preventing bribery and corruption in its joint ventures, beyond requiring that such entities follow its Ethical Code of Conduct. <\/p>\n"},{"question":103,"commitment_area":14,"score":"1","comments":"
There is some evidence that the company has a procedure in place to address the corruption risks associated with offset contracting. The company states that the Group-level Business Development Department handles all offset agreements and indicates that the Legal & Compliance department handles all due diligence and monitoring of such agreements. <\/p>\n
The company receives a score of \u20181\u2019 because there is no clear evidence that the employees responsible for handling offset agreements receive tailored anti-bribery and corruption training based on the potential corruption risks associated with offsets. <\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a formal procedure in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations. The company indicates that this due diligence process includes ensuring that any offset projects or partners align with its group business strategy. There is some evidence that the company\u2019s offset due diligence process includes establishing and verifying beneficial ownership information, however it is noted that this evidence primarily relates to sales representatives and is therefore indirect. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the due diligence process for offset obligations includes checks on any conflicts of interest associated with the beneficiaries. Moreover, although there is some evidence to indicate that due diligence is repeated every two years, the company\u2019s publicly available information indicates that this primarily relates to sales representatives and therefore it is not explicitly clear that the same standards are upheld for all aspects of all offset obligations. <\/p>\n"},{"question":105,"commitment_area":14,"score":"2","comments":"
The company publishes a statement on its website to indicate that it does not employ offset agents or brokers as part of its industrial cooperation programme, choosing instead to operate directly with authorities and partner companies. Since the company has adopted this as its publicly available position, the company therefore receives a score of \u20182\u2019.<\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
Based on publicly available information, there is no evidence to indicate that the company publishes any details of its indirect offset obligations and\/or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"2","comments":"
Based on publicly available information, there is evidence that the company acknowledges the corruption risks associated with operating in different markets and it is clear that the company has a risk management procedure in lace to account for these risks. There is evidence that the company conducts enhanced due diligence and risk evaluation procedure for end users and countries identified as medium or high risk of corruption. The company\u2019s publicly available information also indicates that the results of these assessments have a direct impact on business decisions, which may include a decision not to proceed in some cases. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings on an annual basis. For each entity, the company clearly publishes the name of the subsidiary or other affiliated entity, as well as the country of incorporation. This list is published in the company\u2019s most recently published Annual Report, and is therefore understood to reflect a complete list of the company\u2019s holdings at the time of publication. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not clearly provide the country of operation for each entity.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company publishes information on its beneficial ownership. The company indicates that it has two major shareholders, Patria Oyj (50%) and the Norwegian Ministry of Trade, Industry and Fisheries (50%); thereby indicating that it is partially state-owned. The company publishes this information in its corporate reporting documents and in the publicly accessible Norwegian corporate register. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
Based on publicly available information, there is no evidence to indicate that the company publishes a breakdown of its defence sales by customer. The company provides a breakdown of sales per region, but there is no evidence that the company distinguishes defence sales from overall sales, nor that it identifies specific countries or customers within these regions. <\/p>\n"},{"question":111,"commitment_area":16,"score":"2","comments":"
There is evidence that the company publishes a breakdown of its voting rights by percentage allocated to each shareholder, alongside the percentage ownership. The company indicates that it has two major shareholders who hold equal percentages of ownership and voting rights. <\/p>\n"},{"question":112,"commitment_area":16,"score":"1","comments":"
The company provides some details of its commercial and public policy objectives in its corporate reporting documents and on its website. There is evidence that the company\u2019s key objectives are to serve the Norwegian national armed forces and to continue growing in profitability.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that these objectives are updated on an annual basis or whenever there is a change in objectives. Although some information is published in the company\u2019s Annual Report, this mainly relates to its strategy for growth rather than its core objectives, which are published on a webpage without a date. <\/p>\n"},{"question":113,"commitment_area":16,"score":"2","comments":"
The company is open and clear about the composition of its board, as well as providing details about the appointment and nomination process. The company states that its two largest shareholders nominate three board members each, with the remaining positions filled by elected employee representatives. From this information, it is clear which members are independent and which are state representatives. Although the company does not provide further details on the criteria for nomination, the evidence provided is deemed sufficient to receive a score of \u20182\u2019. <\/p>\n"},{"question":114,"commitment_area":16,"score":"0","comments":"
There is no publicly available evidence that the company has a board-level audit or risk committee.<\/p>\n"},{"question":115,"commitment_area":16,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a system to manage asset transactions. The company also publishes the final report from its independent auditors, which indicates that transactions have been scrutinised by an audit body and notes that the company\u2019s financial statements reflect all relevant Norwegian laws and regulations. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that a board-level individual or committee holds responsibility for managing asset transactions, nor does the company make it clear that all transactions are appropriately documented.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/603","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=603"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=603"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}