Based on public evidence, the company has a publicly stated anti-bribery corruption statement, which is endorsed by its leadership.<\/p>\n
However, this statement is weak, indirect and unspecific, and makes only a general commitment to comply with anti-bribery principles.<\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
Based on public evidence, the company publishes an explicit anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery and payments to public officials. This policy clearly applies to all employees and board members, regardless of their seniority. <\/p>\n
However, the company does not refer to commercial bribery or facilitation payments. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
Based on public information, there is evidence that the board or a designated board committee oversees the company's anti-bribery and corruption programme. There is evidence to suggest that it engages in formal oversight functions, such as reviewing reports from management or the results of internal and external audits.<\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
Based on public information, there is no clear evidence that a managerial-level individual has been assigned ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. <\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
Based on public information, there is some evidence that the company has a formal risk assessment that informs the design of its anti-bribery and corruption policy. There is evidence that the results of risk assessments are reviewed annually at board level and that the results of such reviews are used to develop tailored mitigation plans and to update specific parts of the company's anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is no clear evidence that the company\u2019s anti-bribery and corruption programme is subject to audit or review.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
Based on public evidence, the company commits to investigating incidents and there is a specific procedure in place to deal with whistleblowing cases.<\/p>\n
However, there is no evidence that the procedure covers the whole investigation from receipt to outcome, or that investigations are handled by an independent team which reports to an independent board member. There is also no evidence of a commitment to providing whistleblowers with updates on the outcome of investigations or that each investigation is documented, with summary information reviewed by a central body.<\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company assures itself of the quality of its internal investigations.<\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company has an investigative procedure which includes a commitment to report material findings to the board or relevant authorities.<\/p>\n"},{"question":63,"commitment_area":8,"score":"1","comments":"
The company publishes some high-level information on its ethics and compliance-related incidents and investigations involving company employees. The data covers the number of reports received and is updated on an annual basis. <\/p>\n
However, the information that the company publishes does not cover the number of investigations launched, and the number of disciplinary actions as a result of investigation findings. It is also unclear whether the information applies to employees at all levels, i.e. board members or other executives. <\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
Based on public information, there is evidence that the company provides training that outlines the principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees. The company provides this training to all employees across all divisions and countries of operation, and in all appropriate languages. There is evidence that compliance trainings are undertaken annually by the employees. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
Based on public information, the company states that employees in certain positions receive different or tailored anti-bribery and corruption training. <\/p>\n
However, these positions are unclear and the company does not make specific reference to all three categories of employee referred to in the question.<\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
Based on public information, there is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme on an annual basis. <\/p>\n
However, the measures are too simplistic and 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":"
There is no evidence that the company\u2019s incentive schemes incorporate ethical or anti-bribery and corruption principles.<\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company commits to support or protect employees who refuse to act unethically.<\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":"
Based on public evidence, the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents that explicitly applies to all employees across the organisation, including those employed by the group as third parties. The company assures itself of its employees\u2019 confidence in this commitment by monitoring the usage data of the whistleblowing channels. <\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
Based on public evidence, the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. 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 reporting. They are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties.<\/p>\n"},{"question":71,"commitment_area":10,"score":"0","comments":"
There is no evidence to suggest that the company has a policy on conflicts of interest.<\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company has a conflict of interest policy, nor a procedure to manage conflicts of interest or of their oversight.<\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company has a conflict of interest policy, nor 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 has a conflict of interest policy, nor 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 to follow all relevant local laws and regulations when making political contributions. Since there is no evidence that the company prohibits or places controls on political donations, the company receives a score of \u20180\u2019.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company discloses details of its political contributions.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy or procedure covering both charitable donations and sponsorships<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy or procedure on lobbying.<\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence to suggest that the company publishes details of the aims and topics of the lobbying activities it carries out. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company provides any details about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
Based on public information, there is evidence that the company has a policy on gifts and hospitality that addresses the risks associated with gifts and hospitality given to domestic and foreign public officials.<\/p>\n
However, the policy does not specify financial or proportional limits or different approval procedures for different types of promotional expenses and there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.<\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
Based on public evidence, the company has formal procedures to conduct due diligence on its suppliers. <\/p>\n
However, there is no evidence that the due diligence process includes checks on, at least, ultimate beneficial ownership. There is also evidence that due diligence is only conducted before engaging suppliers and the frequency of the checks is unclear. There is no evidence to suggest that the company might be 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":"1","comments":"
Based on public information, there is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. It is explicitly stated that all suppliers must have, at a minimum, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, as well as policies and procedures to address gifts and hospitality, and whistleblowing.<\/p>\n
However, the company does not explicitly state that all suppliers must have conflict of interest policies, it is unclear how the company ensures this in practice and there is no evidence to suggest that the company takes active steps to ensure that its suppliers have adequate anti-bribery and corruption policies and procedures in place. It is also unclear whether this assurance is conducted when onboarding new suppliers and\/or when there is a significant change in the business relationship.<\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
Based on public information, there is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. <\/p>\n
However, this evidence is in the form of a simple statement and it is unclear how the company does this in practice.<\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.<\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company has a clear policy covering the use of agents.<\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
Based on public evidence, the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with its third parties. <\/p>\n
However, the company states only that it conducts due diligence on third parties, without specifying agents or high risk intermediaries, and it is not clear that agents and highest risk intermediaries are subject to enhanced due diligence. Additionally, due diligence is only conducted before engaging agents and is not repeated at least every two years or when there is a significant change in the business relationship.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company aims to establish the beneficial ownership of its agents.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.<\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company mentions incentive structures as a risk factor in agent behaviour.<\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any details of the agents currently contracted to act for 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":"0","comments":"
Based on public information, there is no clear evidence that the company undertakes due diligence when entering into a joint venture partnership. While there is evidence that the company conducts due diligence on third parties that it employs, it does not make reference to doing so for its joint venture partners. <\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.<\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company addresses the corruption risks associated with offset contracting, and there is no evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations.<\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company\u2019s offset programme.<\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of its offset obligations and 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. The results of risk assessments have a direct impact on business decisions and 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":"
Based on public evidence, the company publishes a list of its consolidated subsidiaries on an annual basis.<\/p>\n
However, the list does not include all of the company\u2019s holdings and it is not accompanied by a statement that it is complete at the time of publication to the best of the company\u2019s knowledge. Additionally, the company does not provide the percentage of ownership or the countries of incorporation and operation for each entity. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is publicly listed on the Tokyo Stock Exchange and therefore automatically receives a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes a breakdown of its defence sales by customer. <\/p>\n"},{"question":111,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":112,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":113,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":114,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":115,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/606","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=606"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=606"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}