There is no evidence that the company publishes a commitment to ethical or anti-bribery and corruption standards that is authorised and endorsed by the company\u2019s leadership. Although the company\u2019s Code of Business Conduct reflects a commitment to high business standards, this is not supported by a public statement from the company\u2019s leadership and therefore the company receives a score of \u20180\u2019. <\/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 defines and prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and directors as listed in the question.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that the board is ultimately responsible for oversight of the company's anti-bribery and corruption programme. There is evidence that this includes reviewing reports from management on the programme\u2019s performance, including the results of internal audits, and that the board has the authority to require that changes are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that a designated senior executive \u2013 the Chief Compliance Officer \u2013 has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the board, which provides oversight of the company\u2019s anti-bribery and corruption programme. There is also evidence of reporting and feedback activities between this person and the board 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 bribery and corruption risk assessment procedure that informs the design of its anti-bribery and corruption programme. There is evidence that the company uses the results of risk assessments to develop tailored mitigation plans and to update specific parts of the company's anti-bribery and corruption programme. Although it is not explicitly clear that the board reviews the results of risk assessments, there is evidence that the Compliance Committee conducts reviews on at least an annual basis of medium and high risk operational areas, and that this committee submits an Annual Report to the board. <\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
There is evidence that the company\u2019s anti-bribery and corruption programme is subject to a regular review process to ensure the programme is consistent with best practice and the business risks facing the company. There is evidence that this includes provisions for continuous improvement, supplemented by audit procedures. There is also evidence that high-level audit findings are presented to the board, with clear ownership for any updates and improvements to the anti-bribery and corruption programme. Although it is not explicitly clear that such audits or reviews are conducted at least every two years, the company refers to \u2018annual audit plans\u2019 and so the evidence is deemed sufficient for a score of \u20182\u2019. <\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
There is evidence that the company commits to investigating allegations and incidents of bribery and corruption objectively and independently. There is evidence that the company has a specific procedure in place to deal with whistleblowing cases, which includes informing whistleblowers of the outcome of the investigation, and stipulates documentation and actions to be taken at each step. A senior central body of the company \u2013 the Compliance Committee \u2013 receives and reviews summary information of all incidents and their status in the organisation on a quarterly basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
There is some evidence that the company assures itself of the quality of its internal investigations. It states that staff tasked with conducting investigations are properly qualified and trained to perform the function. <\/p>\n
However, the company receives a score of \u20181\u2019 because the company does not provide any details about how it handles complaints about the handling of concerns and investigations. There is also no evidence that it 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":"1","comments":"
There is evidence that the company\u2019s Compliance Committee is responsible for ensuring that the disclosure of criminal offences to the relevant authorities is evaluated and acted upon if found necessary.<\/p>\n
The company receives a score of \u20181\u2019 because while there is evidence that material findings of bribery and corruption from investigations are reported to the Compliance Committee, there is no clear evidence that the company commits to report material findings to the board.<\/p>\n"},{"question":63,"commitment_area":8,"score":"1","comments":"
The company publishes some high-level data on its compliance-related incidents and investigations involving company employees. The data includes the number of reports received through its complaints channel, and the number of disciplinary actions as a result of investigation findings. There is evidence that this information is published on an annual basis covering cases from the past 12 months. <\/p>\n
However, the company receives a score of \u20181\u2019 because the data provided does not include information on the number of investigations launched. Furthermore, the data is not disaggregated to specifically show the number anti-bribery and corruption-related incidents and investigations. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides training to its employees that outlines the principles of its anti-bribery and corruption policy, and that it covers the procedure for reporting unusual or suspicious transactions. <\/p>\n
The company scores \u20181\u2019 because although there is evidence that corruption training takes place once a year, it is not specified whether all employees are required to attend this training, and therefore it is unclear how frequently employees are required to undertake or refresh their training on anti-bribery and corruption. It is also not clear from the available evidence that training is provided to all employees across all divisions, in all countries\/regions of operation or in all appropriate languages.<\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides different or tailored anti-bribery and corruption training to senior and middle managers. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it provides tailored training to all the different categories of employees listed in the question, including board members or other employees in high-risk roles. Moreover, there is no clear evidence that employees in high-risk positions are required to undertake and refresh their training on at least an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company reviews the effectiveness of its anti-bribery and corruption training programme. There is evidence that the anti-bribery and corruption training programme is evaluated annually to ensure it is kept up-to-date with legal changes, and that the company conducts employee surveys to measure the effectiveness of its training to some extent. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it uses the results of these surveys to update specific parts of its anti-bribery and corruption training and communications programme. It is also not clear how frequently these surveys take place, and therefore whether the company assures itself of the effectiveness of its communications and training programme on at least an annual basis. <\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company\u2019s incentive schemes incorporate ethical and anti-bribery and corruption principles. <\/p>\n
However, the company receives a score of \u20181\u2019 because the publicly available evidence on this topic comes in the form of a short statement. It is not clear whether incentives are designed to reward behaviour in line with the company\u2019s ethical values as identified through performance appraisals or conduct in the workplace and there is no evidence that the company acknowledges that financial rewards must be proportionate to the base salary in the case of high risk employees, such as sales roles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company publicly commits to support or protect employees who refuse to act unethically.<\/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 compliance-related allegations. There is evidence that this applies to all employees across the organisation, including those employed by the group as third parties. <\/p>\n
However, the company receives a score of \u20181\u2019 because whilst the company publishes some data indicating that it tests employees\u2019 belief in the company\u2019s general commitment to anti-corruption and compliance, there is no evidence that it specifically assures itself of its employees\u2019 confidence in the company\u2019s non-retaliation commitment, either 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 multiple whistleblowing and advice channels for employees to report instances of suspected corrupt activity or seek advice on the company\u2019s anti-bribery and corruption programme. The company states that it assures the confidentiality and anonymity of reports received through its whistleblowing channel, and there is evidence that the channels are available to all employees and third parties. <\/p>\n
However, the company receives a score of \u20181\u2019 because the evidence suggests that the company only offers internally operated channels and does not provide an option for reporting allegations to a hotline managed by an independent third party. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy that covers conflicts of interest, which refers to actual, potential and perceived conflicts arising from employee relationships, financial interests and other employment. There is evidence that this policy applies to all employees and board members.<\/p>\n
However, the company receives a score of \u20181\u2019 because its policy does not clearly cover conflicts which arise from government relationships.<\/p>\n"},{"question":72,"commitment_area":10,"score":"2","comments":"
There is evidence that the company has procedures to identify, declare and manage conflicts of interest, actual, potential and perceived. There is evidence that declarations of conflicts of interest are recorded in a dedicated register and that they are reviewed and overseen by a designated body with ultimate accountability for the handling of individual cases. The company states that disciplinary actions will apply if its policy is breached and also gives examples of criteria for recusals. <\/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":"2","comments":"
There is evidence that the company has a clear statement that it prohibits political contributions. There is evidence that corporate political contributions \u2013 whether made directly or indirectly, or whether made by the company itself or by any other entity or individual acting on the company's behalf \u2013 are prohibited under any circumstance.<\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
The company states that it makes no political contributions and is therefore exempt from scoring on this question.<\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
The company has a clear policy and set of procedures covering both charitable donations and sponsorships, whether made directly or through corporate foundations, to ensure that such donations are not used as vehicles for bribery and corruption. The policy stipulates measures to ensure this through procedures for senior sign-off, criteria for donations and due diligence on recipients. The company publishes details and a description of the non-profit and charitable organisations it has supported in the most recent reporting year, which is updated annually. This is accompanied by a sum total of donations made. <\/p>\n
The company receives a score of \u20181\u2019 because its published data on charitable donations does not include details such as a breakdown of individual sums donated to each of the organisations listed. The company also does not provide clear information on the country of each recipient organisation.<\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
There is some evidence that the company has a policy and procedures on lobbying. This includes evidence that the company requires that due diligence is conducted on external lobbyists before hiring them, as well as during the business relationship. The company\u2019s anti-corruption policy gives a brief description of lobbying, which emphasises the legitimacy of the activity, whilst also acknowledging the corruption risk it presents. <\/p>\n
However the company scores \u20181\u2019 because beyond stating that lobbying activities must adhere with laws and regulations, the policy doesn\u2019t mention certain standards of conduct or specific oversight mechanisms that apply to lobbying activities. Additionally, the company\u2019s policy only makes reference to external lobbyists and third parties, and does not mention internal lobbyists, or specify that the standards outlined apply to all employees and directors. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes information on its lobbying aims, topics or activities. <\/p>\n
The company states that in the most recent reporting year it did not contract any lobbying services, however this suggests that it relates to externally contracted activities only. It is therefroe not sufficiently clear that it did not conduct any lobbying activities at all, and so a score of \u20180\u2019 applies.<\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company provides details about its global lobbying expenditure.<\/p>\n
Although the company states that in the most recent reporting year it did not contract out any lobbying services, it is not sufficiently clear that it did not conduct any lobbying activities at all, and so a score of \u20180\u2019 applies.<\/p>\n"},{"question":81,"commitment_area":11,"score":"2","comments":"
There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with clear procedures designed to ensure that such promotional expenses are not used as vehicles for bribery and corruption. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. There is evidence that the company also addresses the risks associated with gifts given to and\/or received from public officials. The company's policy includes a clear statement that all gifts and hospitality above certain thresholds are recorded in a dedicated register that is accessible to the Chief Compliance Officer and Compliance Committee, who are responsible for oversight of the process.<\/p>\n"},{"question":82,"commitment_area":12,"score":"2","comments":"
There is evidence that the company\u2019s Procurement Committee is the main body that is involved in, and responsible for, oversight of supplier relationships. The company states that this committee is responsible for verifying and approving proposals to establish new suppliers, and stipulates procedures to escalate the matter if the committee cannot reach a decision. Moreover, there is evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through regular internal audit and quality assurance checks. <\/p>\n
Although the company does not explicitly state that it conducts this type of assurance every three years, a score of \u20182\u2019 has been awarded based on supporting evidence. <\/p>\n"},{"question":83,"commitment_area":12,"score":"2","comments":"
There is evidence that the company has formal procedures to conduct risk-based due diligence when engaging and re-engaging with its suppliers. The due diligence process explicitly includes establishing the ultimate beneficial ownership of the supplying company, and there is evidence that highest risk suppliers are subject to enhanced due diligence. There is evidence that this process is conducted on an ongoing basis, and when there is a significant change in the business relationship. There is also evidence that suggests that the company is willing to review and 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":"
There is evidence that the company requires that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company states that all of its business partners (which is understood to include suppliers) must comply with the standards outlined in its anti-corruption manual, which prohibits bribery, facilitation payments and specify procedures on conflicts of interest, gifts and whistleblowing. There is evidence that the company assures itself of this when onboarding new suppliers, by introducing anti-corruption clauses in their contracts, and on an ongoing basis, by having monitoring rights on its suppliers to ensure their continued compliance with these policies. <\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
Although the company states that it conducts legal reviews on sub-contractors, there is no clear 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":"1","comments":"
The company publishes a statement that no supplier wrongdoing was determined during the most recent reporting year relating to violations of its Code of Business Conduct, which covers bribery and corruption. The company\u2019s publicly available evidence indicates that this information is updated annually. <\/p>\n
However, the company receives a score of \u20181\u2019 because the data published does not include the number of reports received, nor investigations launched.<\/p>\n"},{"question":87,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has a policy covering the use of agents which addresses the corruption risks associated with the use of agents and provides details of controls to mitigate these risks. There is evidence that this policy applies to all divisions within the organisation which might employ agents, including subsidiaries. <\/p>\n
However, while the company\u2019s policy indicates that it conducts an assessment of the economic rationale of working with high-risk entities, it is not clear from publicly available evidence that the company takes steps to establish and verify that the use of agents is necessary to perform a legitimate business function. <\/p>\n"},{"question":89,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging any agents and intermediaries, and when there is a significant change in the business relationship. There is evidence that highest risk intermediaries are subject to enhanced due diligence. There is evidence that suggests that the company will not engage or terminate its engagement with agents or intermediaries where the risks identified in the due diligence process cannot be mitigated.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is evidence that the company aims to establish the beneficial ownership of its agents. However, there is no publicly available evidence that the company commits to not engaging or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.<\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. The company states that all agents and third parties are subject to anti-bribery and corruption clauses in their contracts, which include clear audit and termination rights to detect, control and prevent breaches.<\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company addresses incentive structures for agents as a factor in bribery and corruption risk. The company states that specific measures are in place to manage this risk, such as requiring that payments to agents be made into EU-registered banks and restricting the type and quantity of transactions. The company also states that due diligence is carried out to check for signs of possible corruption prior to awarding agents \u201csuccess fees\u201d. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that agents receive remuneration in staged payments over the course of their contract, based on clear milestones. There is also no mention of proportionality as a factor in determining agent remuneration. <\/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 its behalf.<\/p>\n"},{"question":99,"commitment_area":13,"score":"1","comments":"
The company publishes a statement that no agent wrongdoing was uncovered during the most recent reporting year, in relation to violations of its Code of Business Conduct, which covers bribery and corruption. The company\u2019s publicly available evidence indicates that this information is updated annually. <\/p>\n
However, the company receives a score of \u20181\u2019 because the data published does not include the number of reports received, nor investigations launched.<\/p>\n"},{"question":100,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on its joint venture partners. The company states that it conducts enhanced due diligence on joint ventures operating in high-risk countries or with high risk partners. There is evidence that the company conducts due diligence both prior to entering into a joint venture and on both the entity and its activities once established, or when there is a significant change in the business relationship. There is also evidence that the company\u2019s due diligence procedures include establishing the ultimate beneficial ownership of the partner company.<\/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 policies and procedures in its joint ventures. There is evidence that the company requires its business partners, which is understood to include joint venture partners, to comply with its anti-corruption manual, which prohibits foreign and domestic bribery and facilitation payments. The company indicates that it includes this requirement as a contractual clause, which also specifies audit and termination rights to detect, control and prevent breaches.<\/p>\n"},{"question":102,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company commits to take an active role in preventing bribery and corruption when engaging with third parties, which is understood to include when it engages with joint venture partners. However, the information in relation to this is insufficiently detailed to satisfy the requirements of score \u20182\u2019.<\/p>\n"},{"question":103,"commitment_area":14,"score":"1","comments":"
There is some evidence that the company has a policy in place to address the corruption risks associated with offset contracting. The company indicates that it has a dedicated body involved in managing offset obligations, but it is not clear that this team is responsible for monitoring the company\u2019s offset activities throughout the lifecycle of each project. There is also no evidence that all employees within the team receive tailored anti-bribery and corruption training.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There 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 indirect offset obligations and\/or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"2","comments":"
There is evidence that the company acknowledges the corruption risks associated with operating in different markets, and that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. There is evidence that the results of risk assessments inform the development and implementation of additional controls. The company provides examples of such possible controls.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings, including the percentage owned and country of incorporation for each entity. There is evidence to suggest that the information is complete 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 is unclear whether the list includes all of the company\u2019s non-fully consolidated holdings, and the company does not provide information about the countries of operation for all of its subsidiaries. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company publishes a statement to indicate that is a Spanish state-owned enterprise, with 100% of shares owned by the Spanish State-Owned Industrial Holding Company (SEPI). <\/p>\n
Details of the company\u2019s ownership are also disclosed in the global beneficial ownership register Open Ownership, available through www.openownership.org.<\/p>\n"},{"question":110,"commitment_area":15,"score":"1","comments":"
The company publishes some information regarding its major customers for its defence sales. There is evidence that the company\u2019s main customer is the Spanish military and that export sales accounted for 38% of its revenue in the most recently reported year. It is understood that the company is only active in the defence sector and therefore that this information represents its defence sales.<\/p>\n
However, whilst the company discloses high-level details in relation to some of its export markets, it receives a score of \u20181\u2019 because it does not provide a clear breakdown of at least 80% of its defence sales by customer. <\/p>\n"},{"question":111,"commitment_area":16,"score":"2","comments":"
The company publishes a statement that 100% of shares owned by the Spanish State-Owned Industrial Holding Company (SEPI). Therefore, it is understood that the company does not have any other shareholders and that the Spanish state holds 100% of voting rights.<\/p>\n"},{"question":112,"commitment_area":16,"score":"2","comments":"
There is evidence that the company publishes details of its commercial and public policy objectives in its Annual Report and on its website. There is evidence that these objectives are updated on an annual basis.<\/p>\n"},{"question":113,"commitment_area":16,"score":"1","comments":"
The company publishes clear information about the composition of its board. For each board member, the company discloses whether that person has any connection to the company or the state or is an independent director.<\/p>\n
The company, however, receives a score of \u20181\u2019 because its nomination and appointment process is not entirely clear. For instance, the company does not publish criteria for nomination, which company representatives are involved in the nomination, and who makes the final appointment decision.<\/p>\n"},{"question":114,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company\u2019s audit committee is composed of majority independent directors. While there is evidence that the company\u2019s executive-level audit committee is composed of non-company directors, the information provided shows that that all three of its members represent the state and therefore a score of \u20180\u2019 applies.<\/p>\n"},{"question":115,"commitment_area":16,"score":"0","comments":"
The evidence in relation to whether the company has a system in place to manage asset transactions is insufficient to satisfy the requirements of score \u20181\u2019.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/605","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=605"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=605"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}