In its Ethics Charter, the company has a publicly stated commitment to \u2018integrity\u2019 and \u2018high ethical standards\u2019 which is authorised and endorsed by the company\u2019s leadership. <\/p>\n
However, the statement does not explicitly refer to anti-bribery and corruption. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that 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 and board members as described in (a) and (b) above, regardless of their seniority.<\/p>\n"},{"question":56,"commitment_area":7,"score":"0","comments":"
There is no publicly available evidence that the company has a designated board committee or individual board member responsible for oversight of its anti-corruption programme. On its website the company refers to an Ethics and Compliance Committee which meets biannually and \u2018ensures the proper implementation of the anti-corruption program\u2019. However, it is not stated that this is a board-level committee and its membership and mandate are not clear from publicly available materials. <\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
There is evidence that a designated senior executive, the Group Compliance Officer, 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 chair of the board.<\/p>\n
However, there is no evidence of reporting and feedback activities between this person and the board as part of the company\u2019s reporting structure; for example, through attendance or participation at board-level committee meetings.<\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
There is evidence that the company has a bribery and corruption risk assessment procedure that informs the design of its anti-corruption and bribery programme. <\/p>\n
However, it is unclear how frequently risk assessments are undertaken and there is no evidence that the results are reviewed at board level.<\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
The company states that its compliance programme is subject to review by its internal audit team, and there is evidence that the results of these reviews are used to update the programme. <\/p>\n
However, it is not clear how frequently audits are undertaken, the company does not explicitly state that the entire anti-corruption programme is audited to ensure it is consistent with best practice and the business risks facing the company. There is also no evidence that audit findings are presented to the board. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
The company publicly commits to investigating incidents, and there is a specific procedure in place to deal with whistleblowing cases. <\/p>\n
However, this procedure does not cover the whole investigation process from receipt to final outcome, it is unclear whether investigations are handled by an independent team and\/or report to an independent board member, and the company does not indicate whether information on each investigation is documented and if a central body reviews summary information on the status of investigations on a regular or annual basis.<\/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\u2019s investigative procedure includes a commitment to report material findings to the board or the relevant authorities.<\/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. The evidence indicates that this training is provided to all employees. <\/p>\n
However, it is unclear how frequently training is refreshed and whether the training is provided in all appropriate languages. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
The company states that employees in certain positions receive tailored anti-bribery and corruption training, including employees in high risk positions and managers. <\/p>\n
However, it is not clear how frequently this training takes place and the company does not make specific reference to board members as a category of employee requiring tailored training. <\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no publicly available 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 publicly available evidence that the company 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 has a publicly available policy of non-retaliation against whistleblowers, which applies to employees and directors, as well as employees of third parties or members of the general public. <\/p>\n
However, there is no evidence that the company assures itself of its employees\u2019 confidence in this commitment through surveys, usage data, or other clearly stated means. <\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
The company has some whistleblowing and advice channels, which allow confidential reporting. These channels are available to employees across the group as well as those employed by third parties or members of the public. <\/p>\n
However, the company does not appear to offer anonymous channels or any externally operated channels. The channels are also not explicitly available to all employees in any country of operation, and in all relevant languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
The company has a policy for conflicts of interest which applies to employees and directors of the company. This covers actual, potential and perceived conflicts. The policy covers employee relationships, financial interests and other employment. <\/p>\n
However, the company does not refer to government relationships.<\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
The company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. This includes disciplinary measures for breaching the company\u2019s procedures.<\/p>\n
However, the company does not state 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. There is also no reference to a specific body or individual with oversight and accountability for handling cases and the policy does not mention examples of criteria for recusal.<\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no publicly available 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 publicly available 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 prohibits corporate political contributions. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
The company prohibits corporate political contributions and therefore receives \u2018N\/A\u2019 for this question. <\/p>\n"},{"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 to ensure donations are not used as vehicles for bribery and corruption. <\/p>\n
However, the company does not publish any details of its donations.<\/p>\n"},{"question":78,"commitment_area":11,"score":"2","comments":"
The company has a policy and procedure that defines lobbying and sets out the values and behaviours that constitute \u2018responsible\u2019 lobbying. The company outlines certain standards of conduct and oversight mechanisms that apply to all of the company\u2019s employees and partners. It provides clear guidelines on what behaviours are acceptable and unacceptable and on the corruption risks associated with lobbying. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
The company does not publish any information on its lobbying aims, topics or activities on its website. The company states that it transmits a register of lobbying activity to the French Authority for the Transparency of Public Life, but this is not provided on the company\u2019s website nor is there a direct link to the material. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is evidence that the company provides limited details about its lobbying expenditure in France on the website of the French Authority for the Transparency of Public Life. However, this information is not published to its own website nor does the company provide a direct link to the relevant information. <\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy on the giving and receipt of gifts and hospitality. This addresses the risks associated with gifts and hospitality given to and\/or received from domestic and foreign public officials. The company indicates that gifts and hospitality must be recorded. <\/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 gifts and hospitality are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process. <\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company has a purchasing department, which is involved, in some capacity, in the establishment and oversight of supplier relationships. <\/p>\n
However, there are limited details available regarding the role of the purchasing department and its interaction with business units. For example, the company does not state that the involvement of the purchasing department is required for establishing any new suppliers over a certain threshold. It is not clear that the purchasing department is the main body responsible for oversight of the company\u2019s supplier base and there is no evidence that the company assures itself of the purchasing department\u2019s involvement at least every three years. <\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
The company has formal procedures to conduct due diligence on its suppliers, which include checks on ultimate beneficial ownership. There is also evidence to suggest that the highest risk suppliers are subject to enhanced due diligence <\/p>\n
However, it is unclear whether due diligence is repeated after onboarding and if so how frequently. There is also no evidence to suggest that the company might be willing to review and\/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence process cannot be mitigated. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard. The company indicates that ensures this through the inclusion of anti-bribery and corruption clauses in its contracts with suppliers, and that prior to engaging suppliers it conducts an assessment of their business practices to ensure they meet its own standards. <\/p>\n
However, the company does not explicitly state that all suppliers must have, at least, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, and\/or policies that cover conflicts of interest, gifts & hospitality, or whistleblowing. Additionally, it is unclear whether the company assures itself of its suppliers\u2019 anti-bribery and corruption policies and procedures when there is a significant change in the business relationship.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards is required throughout the supply chain. <\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions. <\/p>\n"},{"question":87,"commitment_area":13,"score":"1","comments":"
The company has a clear policy and procedure to control the use of agents which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. <\/p>\n
However, the company does not explicitly commit to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. It is also not specified whether this policy applies to subsidiaries and joint ventures.<\/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 with agents and intermediaries. <\/p>\n
However, the company does not explicitly state that agents and highest risk intermediaries are subject to enhanced due diligence. It is also unclear whether the company repeats due diligence when it re-engages agents and intermediaries, or how frequently its due diligence is reviewed. <\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is some evidence that the company aim to identify the beneficial ownership of its agents and intermediaries. 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":"0","comments":"
There is evidence that the company includes anti-bribery and corruption clauses in its contracts with third parties, however, there is no publicly available evidence to suggest that it includes audit and termination rights in its contracts with these entities. <\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
There is evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company indicates that agents must paid in local bank accounts, and acknowledges that sales commissions are a higher risk form of remuneration. <\/p>\n
However, there is no evidence that the company imposes a threshold on the payment of sales commissions to agents, and there is no requirement that remuneration is paid in stage payments.<\/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 due diligence on its joint venture partners. The company indicates that its procedures include identifying the ultimate beneficial ownership of its partners. <\/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. It is also unclear whether or how frequently due diligence on joint venture partners is repeated. <\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company accounts for anti-bribery and corruption considerations when entering into a joint venture, through the inclusion of anti-corruption clauses and obligations in its contracts with them. <\/p>\n
However, it is unclear how it ensures this in practice and it does not specify that it takes steps to detect, control and prevent breaches through the inclusion of audit and termination rights in its contracts with its partners.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. While it includes anti-corruption contractual clauses in its contracts with its third parties, it does not provide any further public information on practical steps it might take to prevent bribery and corruption in its joint venture partnerships.<\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting. 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":"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 industrial partners, as part of its offset obligations. This process includes checks on beneficial ownership. <\/p>\n
However, the company does not specifically mention checks on conflicts of interest and there is no evidence that the company seeks to assure itself of the legitimacy of the investment. The company also does not state if or how frequently due diligence is repeated.<\/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":"0","comments":"
The company does not publish any details of its offset obligations and\/or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company\u2019s operations in high risk markets. The description of the company\u2019s risk assessment procedure does not explicitly refer to country risk.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes a list of subsidiaries on its website. <\/p>\n
However, it is not clear whether this is a complete list of the company\u2019s holdings. The list also does not include the percentages owned, country of incorporation and\/or countries of operation for each entity, nor is it accompanied by a statement that it is complete at the time of publication to the best of the company\u2019s knowledge. It is unclear how frequently it is updated.<\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
The company discloses some details on persons or entities with significant holdings in the company. <\/p>\n
However, it does not refer to relevant individuals by name along with their percentage ownership in the company or any accompanying details necessary to identify natural persons. The company only discloses its ownership on its website and not in a freely available central public register or in open data format; it is also not publicly listed on a stock exchange.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
The company does not publish details of its defence sales by customer. On its website, the company says that over 100 armies use its equipment, but details regarding its customer base are not publicly available. <\/p>\n"},{"question":111,"commitment_area":16,"score":"0","comments":"
The company does not publish details of its shareholder voting rights. On its website, the company indicates that the French state has a golden share in the company. However, it does not provide further information on the shareholder voting rights this confers and how this might differ from other shareholders. <\/p>\n"},{"question":112,"commitment_area":16,"score":"0","comments":"
The company does not publish its commercial or public policy objectives. <\/p>\n"},{"question":113,"commitment_area":16,"score":"0","comments":"
On its website, the company provides the names of its senior management team only and does not list any board members. The governance structure between the company and its parent company, KNDS, is not fully clear from the public domain. Neither the company nor KNDS provide information on their websites regarding the nomination and appointment processes for directors. KNDS does not provide clear information about the composition of its board, for example whether each board member is: a financial beneficiary; an executive; a state representative; or an independent director. <\/p>\n"},{"question":114,"commitment_area":16,"score":"0","comments":"
Based on publicly available information, it is unclear whether the company has an audit committee. Although the company refers to audit reviews of its compliance programme, the company does not disclose information regarding its audit governance structure on its website. <\/p>\n"},{"question":115,"commitment_area":16,"score":"0","comments":"
The company 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\/607","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=607"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=607"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}