The company has a publicly stated anti-corruption commitment, which details the company's stance against any form of corruption within the organisation, including bribery. It is clear that this commitment is authorised and endorsed by the company's leadership.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
The company publishes an explicit anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees regardless of their seniority and all members of a management executive committee and it applies to all entities controlled by the group. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that the Compensation, Appointments, Ethics and CSR Committee, which is a designated board committee, is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. It receives reports on the results of the company\u2019s compliance programme from the Group Ethics and Social Responsibility Committee (CERSE), a managerial level committee which is tasked with the implementation of the anti-bribery and corruption programme. This includes reporting against an action plan on ethics and corporate social responsibility. In addition, the Audit, Accounts and Risks Committee, a board-level committee, receives annual reporting on the results of the company\u2019s compliance programme. <\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior executive, the Director of Group Ethics, Compliance and Governance, has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. This individual is the Head of the Group Ethics, Compliance and Governance and chairs the Group Ethics and Social Responsibility Committee (CERSE), which presents an action plan to the Chairman and CEO and also reports on its activities to the Appointments, Ethics and CSR Committee. <\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
There is evidence that the company has a formal bribery and corruption risk assessment procedure that informs the design of the anti-corruption and bribery programme and is overseen by the Audit, Accounts and Risks Committee.<\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
The company states clearly that its entire anti-bribery and corruption programme is subject to a regular assurance process to ensure the programme is consistent with best practice and the business risks facing the company. This explicitly includes provisions for continuous improvement, supplemented by an external audit every year and regular internal audits. There is also evidence that high-level audit findings are presented to the board, with clear ownership assigned to units and\/or individuals for planned updates and improvements to the anti-bribery and corruption programme.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
The company publicly commits to investigating incidents promptly, independently and objectively. Investigations are managed by the Committee for Ethics and Corporate Social Responsibility (\u2018CERSE\u2019) to ensure independence. The company provides some information about reporting procedures and processes. For whistleblowing cases, there is a procedure in place that stipulates documentation and actions to be taken at every step of the case, from receipt to final outcome. The company commits to inform whistleblowers of the outcome, if they so wish.<\/p>\n
However, it is not clear whether the company commits to reporting investigative findings to senior management and the board. It is also not clear whether summary information of all incidents is reviewed by a senior central body on a regular basis. <\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
There is evidence that the company assures itself of the quality of its internal investigations, including those reported through whistleblowing channels. The company explicitly states that staff tasked with conducting investigations are properly qualified and trained to perform the function. There is evidence of how complaints and investigations are managed and there is a procedure for the escalation of complaints. <\/p>\n
However, there is no publicly available evidence that the company reviews its investigations procedure at least every three years or in response to any changes in the regulatory environment. There is also no information about how complaints about the investigation process itself are handled or who is responsible for doing so. <\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
There is evidence that the company commits to report material findings of bribery and corruption to board level Audit, Accounts and Risks Committee. In its publicly available investigation procedures it is implied that members of CERSE evaluate whether to instigate legal proceedings. <\/p>\n
However, it is unclear whether this suggests the company will inform relevant authorities in case of material findings of bribery and corruption. <\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
The company 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":"1","comments":"
There is evidence that the company provides a training module that outlines the basic principles of its anti-bribery and corruption policy, including the whistleblowing options available to employees. There is some evidence that the company provides this training to all employees across all divisions and countries of operation, and in all appropriate languages. The company states that dependent on an assessment of their exposure to corruption risk, some employees are required to undertake refresher courses or modules on the anti-bribery and corruption programme at least every three years.<\/p>\n
However, there is no evidence that all employees are required to undertake refresher trainings at least every three years. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is evidence that employees in certain positions receive different or tailored anti-bribery and corruption training. The company states in its public materials that training is aimed at employees that are most exposed to corruption risks. It makes specific reference to tailored training for employees in high risk positions, board members and middle management. <\/p>\n
Although there is evidence that the company\u2019s training plan is updated annually, the company indicates that training for employees in high risk positions is refreshed every three years, rather than on an annual basis. <\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
There is evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme. There is evidence that the company has a system to do this, through dedicated questions in staff surveys. The company commits to assuring itself of this annually. <\/p>\n
However, it is unclear that results are used to update specific parts of the company's anti-bribery and corruption communications and training programme. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, 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":"1","comments":"
Based on publicly available information, there is no evidence that the company commits to support or protect employees who refuse to act unethically, even when it results in a loss of business. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
The company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents in the company\u2019s Compliance Code of Conduct. This applies to all employees of the group as well as other stakeholders that engage with the group. <\/p>\n
However, there is no evidence that the company assures itself of its employees\u2019 confidence in its commitment to non-retaliation through surveys, usage data, or other clearly stated means. <\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
The company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's 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. These channels allow for confidential and, wherever possible, anonymous reporting. The company\u2019s whistleblowing line is open to all employees and third parties, suppliers and joint venture partners. There is evidence that channels are available in all relevant languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
The company has a policy for conflicts of interest which applies to all employees and board members. The policy refers to actual, potential and perceived conflicts and as well as conflicts associated with employee relationships, financial interests, government relationships, and other employment. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has procedures for identifying, declaring and managing conflicts of interest. The company\u2019s public documents refer to an individual conflict of interest declaration which can be completed. Potential or actual conflict of interest declarations are reviewed and overseen by the Remuneration, Appointments, Ethics and Corporate Social Responsibility Committee, which is ultimately accountable for handling individual cases. The company mentions criteria for recusals and states that disciplinary measures also apply if employees breach the company\u2019s policy on conflicts of interest.<\/p>\n
However, there is no evidence that all employee and board member 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":"
Based on publicly available information, there is no evidence that the company has a clear 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":"2","comments":"
The company publishes a clear statement that it does not make corporate political contributions. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":""},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy and procedure covering both charitable donations and sponsorships. Both charitable activities and sponsorships undertaken on the company\u2019s behalf must be reviewed by the Legal Department and the Head of Group Ethics, Compliance and Governance. There is evidence that due diligence is conducted on recipients and that the company specifies criteria for donations. <\/p>\n
However, the company does not publish details of the charitable donations and sponsorships it makes. <\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, the company has some procedures on lobbying. The company indicates that it ensures that lobbyists acting on behalf of Naval Group conform with regulations on lobbying activities everywhere they are carried out, and in some instances complete transparency and declaration obligations. <\/p>\n
However, lobbying is not broadly defined, the company does not outline behaviours comprising responsible lobbying practices, and there is no evidence that the policy applies company-wide to all employees, board members and third parties engaged in lobbying activities on the company\u2019s behalf. Specific controls and guidelines for lobbying are unclear. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
The company does not publish any information on its lobbying aims, topics or activities.<\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
The company does not provide any details about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"2","comments":"
There is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality with clear procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy also explicitly addresses the risks associated with gifts and hospitality given to and\/or received from domestic and foreign public officials, by specifying a different financial threshold for approvals. The company's policy includes a clear statement that all gifts and hospitality above certain thresholds are recorded in the company\u2019s compliance software. This information is reviewed by the Group Ethics, Compliance and Governance Department. <\/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. The company says that it has an independent procurement organisation that ensures separation of decision-making with regard to suppliers and competitive bidding. The procurement department coordinates a procurement policy orientation committee where supplier lists are approved. There is evidence that the procurement department is involved in the establishment of new suppliers. The procurement director additionally chairs a committee responsible for assessing supplier risks. <\/p>\n
However, there is no evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means, such as an audit, at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
The company has formal procedures to conduct risk-based due diligence when engaging and re-engaging with any suppliers. The due diligence process explicitly includes, at minimum, establishing the ultimate beneficial ownership of the supplying company. Highest risk suppliers are stated to be subject to enhanced due diligence. The company's due diligence procedure is accompanied by a clear statement that supplier relationships will be subject to review, and potential termination, if any red flags highlighted in the due diligence cannot be mitigated. <\/p>\n
However, due diligence is updated at least every three years rather than every two years. <\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
There is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company\u2019s Supplier Code of Conduct requires suppliers to have their own policies that prohibit bribery and cover conflicts of interest and whistleblowing. Although the Supplier Code of Conduct does not explicitly refer to prohibition of facilitation payments and policies on gifts and hospitality, suppliers are separately expected to follow the company\u2019s own integrity principles, which cover all of these areas. The company assures itself of its suppliers\u2019 adherence to these principles when onboarding new suppliers and throughout the duration of the supplier relationship, through the inclusion of audit and termination rights in its contracts. <\/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 promoted throughout the supply chain. This evidence is in the form of a clear statement, short description or 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":"1","comments":"
There is evidence that the company has a policy on the use of agents. The company indicates that it has a dedicated team that works with agents, and states in its Compliance Code of Conduct that agents are subject to monitoring. <\/p>\n
However, the company does not have a comprehensive policy covering agents and it is unclear how the company assesses the corruption risks around agents and the specific controls it has put in place to mitigate these risks. The company also does not explicitly commit to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. <\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging or re-engaging any agents and intermediaries. All agents and highest risk intermediaries are subject to enhanced due diligence. The company commits to not engaging or terminating its engagement with agents or intermediaries where the risks identified in the due diligence cannot be mitigated.<\/p>\n
However, due diligence is repeated at least every three years, rather than every two years, as required for a score of \u20182\u2019. <\/p>\n"},{"question":90,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has formal procedures to establish the beneficial ownership of agents prior to engaging them. The company commits to not engaging or terminating its engagement with agents or intermediaries where ultimate beneficial ownership cannot be established.<\/p>\n
However, the company receives a score of \u20182\u2019 because these check are conducted every three years and not at least every two years and there is no evidence of a commitment to independently verify beneficial ownership information of high risk agents. <\/p>\n"},{"question":91,"commitment_area":13,"score":"1","comments":"
There is evidence the company\u2019s anti-bribery and corruption policy applies to agents and intermediaries, and that it includes anti-bribery and corruption clauses in its contracts with such entities, with clear audit and termination rights. <\/p>\n
However, the company states that such clauses apply in general to subcontractors without referencing agents specifically.<\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
There is evidence that incentive structures for agents are highlighted and addressed as a factor in bribery and corruption risk. <\/p>\n
However, there is no evidence that the company imposes a threshold on the payment of sales commissions to agents, and\/or there is no requirement that remuneration is paid in stage payments or into local bank accounts.<\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
The company does not publish any details of the agents currently contracted to act for and\/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":"1","comments":"
There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering and while operating with all third parties, including joint ventures. There is evidence that the company\u2019s due diligence explicitly includes checks on the ultimate beneficial ownership of the partner company. <\/p>\n
However, there is no evidence to suggest that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence. In addition, it is unclear how frequently due diligence is repeated. <\/p>\n"},{"question":101,"commitment_area":13,"score":"2","comments":"
The company explicitly commits to establishing and implementing anti-bribery and corruption policies and procedures in all of its joint ventures by requiring the adoption of its own anti-bribery and corruption programme in its joint ventures. In its public materials, the company states that it includes anti-corruption clauses in its contracts with stakeholders. These clauses include clear audit and termination rights to detect, control and prevent breaches. <\/p>\n"},{"question":102,"commitment_area":13,"score":"2","comments":"
The company explicitly commits to take an active role in preventing bribery and corruption in all of its joint ventures. There is clear evidence to support the company's commitment, through a statement of possible controls that it may implement.<\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is some evidence that the company addresses the corruption risks associated with offset contracting, however there is no evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities and therefore the company receives a score of \u20180\u2019. <\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
There is 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
However, the process does not specifically mention checks on beneficial ownership and conflicts of interest and there is no evidence that the company seeks to assure itself of the legitimacy of the investment. In addition, it is not clear that the company refreshes this due diligence at least every two years or when there is a significant change in the business relationship or nature of the partner. <\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
The company does not publish 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":"1","comments":"
In its 2017 and 2018 CSR Reports, the company publishes examples of its direct and indirect offset projects and the names of some of the beneficiaries. The level of detail provided is sufficient that the beneficiary of the offsets are identifiable. There is evidence that this information is updated annually. <\/p>\n
However, it is unclear whether this is a complete list of the company\u2019s offset beneficiaries. <\/p>\n"},{"question":107,"commitment_area":15,"score":"2","comments":"
The company acknowledges the corruption risks associated with operating in different markets, and there is evidence that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. The results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
In its annual Financial Report, the company publishes a list of its consolidated and non-fully consolidated subsidiaries and the percentages owned. <\/p>\n
However, the company does not indicate that the list is complete at the time of publication to the best of the its knowledge and does not provide details on the countries of incorporation and operation for all entities.<\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
The company discloses its shareholders in its annual Financial Report. <\/p>\n
Although there is evidence that it files this information with the French commercial registry, this is not freely publicly accessible, and the company therefore does not meet the criteria for a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
In its annual Financial Report, the company says it has 50 naval customers worldwide. However, it does not provide any further details on these customers as a percentage of its defence sales.<\/p>\n"},{"question":111,"commitment_area":16,"score":"0","comments":"
The SOE does not publish sufficient details of its shareholder voting rights either in the public materials on its website or in freely available commercial registries. <\/p>\n"},{"question":112,"commitment_area":16,"score":"2","comments":"
The SOE's commercial and public policy objectives are made publicly available on its website, and there is evidence that they are updated on an annual basis or whenever there is a change in objectives. <\/p>\n"},{"question":113,"commitment_area":16,"score":"2","comments":"
The SOE is open and clear about the nomination process, appointment and composition of its board and provides details of its board members. The SOE discloses details of its nomination process, including the criteria for nomination, which company representatives are involved in the nomination and who makes the final appointment decision. For each board member, the SOE discloses whether that person has any connection to the company or the state or is an independent director.<\/p>\n"},{"question":114,"commitment_area":16,"score":"0","comments":"
There is no evidence that the SOE's Audit, Accounts and Risks Committee is composed of a majority independent directors. <\/p>\n"},{"question":115,"commitment_area":16,"score":"0","comments":"
The SOE does not publish any details about its management of asset transactions.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/604","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=604"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=604"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}