Based on publicly available evidence, the company publishes a Code of Ethics and Conduct, which includes an anti-bribery and corruption commitment and policy, and is authorised by the company\u2019s leadership. However, the leadership statement itself relates to ethics and integrity instead of directly referring to anti-bribery and corruption, so the company receives a score of \u20181\u2019.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
Based on publicly available evidence, the company publishes an explicit anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that this policy applies to all employees and board members. <\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is some evidence that the Board of Directors oversees the company's anti-bribery and corruption programme. However, there is no evidence that it engages in formal oversight functions, such as reviewing reports from management or receiving the results of audits. <\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
There is some evidence that a designated senior executive \u2013 the Chairman and CEO \u2013 has ultimate responsibility for implementing and managing the company\u2019s anti-bribery and corruption programme, through the Compliance Office. There is some evidence of a reporting line between this individual and the Board of Directors, which is responsible for oversight of the programme. However, the company receives a score of \u20181\u2019 because the level of involvement of the Chairman and CEO in the day-to-day management of the programme is insufficiently clear and evidence of reporting activities is lacking.<\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
There is some evidence that the company has a formal bribery and corruption risk assessment procedure that informs the design of the anti-corruption and bribery programme. However, the company receives a score of \u20181\u2019 because there is no evidence that the results of risk assessments are reviewed at board level on an annual basis.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is evidence that the company\u2019s anti-bribery and corruption programme is subject to audit and that the findings from such reviews are used to update the programme. However, the company receives a score of \u20180\u2019 because there is no evidence indicating the frequency of these audits or where responsibility for this process lies.<\/p>\n"},{"question":60,"commitment_area":8,"score":"0","comments":"
There is insufficient public evidence that the company has a system for tracking, investigating and responding to bribery and corruption allegations or incidents. Although there is evidence that the company provides information on its whistleblowing hotline, there is no evidence that it provides any further details on how cases are handled at each step in the process. There is no evidence that the company takes steps to ensure the independence of its investigations, nor that it requires documentation of case material. There is also no evidence that the company commits to inform whistleblowers of the outcome of investigations and there is no evidence that a senior central body reviews summary information of all incidents and their status on a regular basis. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company takes steps to assure itself of the quality of its internal investigations, for example by ensuring that staff conducting investigations are properly trained and outlining a procedure to handle complaints about the reporting or investigation process.<\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company commits to report material findings of investigations to the board or relevant authorities.<\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company publishes 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. However, the company receives a score of \u20181\u2019 because there is no evidence that training is provided to all employees systematically, across all divisions, in all countries\/regions of operation or in all appropriate languages, nor is there evidence of how frequently employees are required to undertake or refresh their training.<\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is some evidence that employees in certain positions receive different or tailored anti-bribery and corruption training. The company refers specifically to senior management and employees in high risk positions. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that board members receive this enhanced training. There is also no evidence that training for employees in high risk positions is refreshed on at least an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company measures or reviews the effectiveness 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 employee 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 promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, which explicitly applies to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it assures itself of employees\u2019 confidence in this commitment through surveys, usage data, or other clearly stated means.<\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
There is evidence that the company has multiple channels to report instances of suspected corrupt activity, and to seek advice on the company's anti-bribery and corruption programme. There is evidence that these channels are sufficiently varied to allow employees to raise concerns across the management chain and to an external channel operated by an independent third party, and that these channels allow for confidential and, wherever possible, anonymous reporting. There is also evidence that they are available and accessible to all employees, in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners. Although there is no evidence that the company\u2019s hotline is available in all relevant languages, a score of \u20182\u2019 has been awarded on the basis that there is no evidence that the company operates overseas and therefore no other languages would be necessary.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company formally addresses conflicts of interest as a corruption risk, and that it has a policy and procedure that defines possible conflicts, including those actual, potential and perceived. There is evidence that the policy covers employee relationships, financial interests and other employment. However, the company receives a score of \u20181\u2019 because there is no evidence that its policy references or addresses government relationships as a possible category of conflict. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is some evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company indicates that the Compliance Office is responsible for this process.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that all employee and board member declarations are held in a central register that is accessible to those responsible for oversight of the process. There is also no evidence that the policy mentions examples of criteria for recusals or that it states that disciplinary measures will apply if breached. <\/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":"0","comments":"
There is evidence that the company has a policy on political contributions, which generally prohibits such donations but indicates that they may be permissible under certain circumstances. In such cases, the company states that contributions must receive authorisation from the Board of Directors. There is evidence that this policy applies to all employees, board members, third parties and other entities controlled by the company. <\/p>\n
However, the company receives a score of \u20180\u2019 because there is no evidence that it has a blanket prohibition on political contributions.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that company discloses any details of its political contributions.<\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is some evidence that the company has a policy covering both charitable donations and sponsorships, whether made directly or through corporate foundations. There is evidence that the company has internal procedures in place to ensure that such donations are not used to improperly influence business decisions, such as appropriate due diligence, documentation and sign-off. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes any details of its charitable donations or sponsorships, such as details of the recipient, amount, country of recipient and which corporate entity made the payment. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy on lobbying.<\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any information on its lobbying aims, topics or activities.<\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any details about its global lobbying expenditure. <\/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, which includes procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. The policy also explicitly addresses the risks associated with gifts and hospitality given to and\/or received from domestic and foreign public officials. The company's policy includes a statement that all gifts and hospitality above certain thresholds are recorded in a dedicated register.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its policy specifies financial or proportional limits, or different approval procedures for different types of promotional expenses. <\/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":"
There is evidence that the company has formal procedures to conduct risk-based due diligence when engaging and re-engaging with suppliers. The due diligence process explicitly includes establishing the ultimate beneficial ownership of the supplying company. 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, the company receives a score of \u20181\u2019 because there is no evidence that higher risk suppliers are subject to enhanced due diligence. In addition, there is no evidence that the company includes suppliers in its definition of \u201cIntervening Third Parties\u201d referenced in its policy. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is evidence that the company requires that its suppliers have adequate anti-bribery and corruption policies and procedures in place. There is evidence that the company requires that all third parties must observe the company\u2019s own Anti-corruption Policy document, which is inclusive of policies that prohibit foreign and domestic bribery, prohibit facilitation payments, as well as policies and procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. <\/p>\n
However, the company receives a score of \u20181\u2019 because the evidence suggests that it only assures itself of this when onboarding new suppliers and there is no evidence that it does so when there is a significant change in the business relationship. In addition, although there is evidence that the company requires suppliers to sign task orders, it is unclear what the contractual obligations are under such agreements, and it is therefore unclear whether the company assures itself in practice of its suppliers\u2019 adherence to its anti-bribery and corruption policies. Finally, there is no evidence that the company\u2019s policies relating to intervening third parties includes suppliers in its definition. <\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no 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":"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 some evidence that the company has a policy covering the use of agents. However, the company receives a score of \u20181\u2019 because there is no evidence that its policy addresses the potential corruption risks associated with the use of agents, nor that it explicitly commits to establishing 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 its agents. There is evidence that 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, the company receives a score of \u20181\u2019 because there is no evidence that agents and highest risk intermediaries are subject to enhanced due diligence. There is also no evidence that the company repeats due diligence at least every two years or when there is a significant change in the business relationship.<\/p>\n"},{"question":90,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company aims to establish the ultimate beneficial ownership of its agents and intermediaries, and that it commits to independently verifying this information as part of its due diligence process. <\/p>\n
However, the company receives a score of \u20181\u2019 because, although there is evidence that the company\u2019s relationships may be terminated if red flags cannot be mitigated, there is no evidence that this would apply as a rule if ultimate beneficial ownership cannot be established. <\/p>\n"},{"question":91,"commitment_area":13,"score":"0","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 indicates that it includes anti-bribery and corruption clauses in its contracts with agents and that business relationships with those that violate its policy may be terminated. <\/p>\n
However, the company receives a score of \u20180\u2019 because there is no evidence that it includes audit rights in its contracts with these entities and it is therefore unclear how it assures itself of its suppliers\u2019 compliance with its policy in practice.<\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company addresses incentive structures and remuneration for agents as a factor in bribery and corruption risk. The company\u2019s anti-corruption policy lists several red flags relating to agent payment, such as risks stemming from payments to overseas accounts, cash payments, payments to a third party who has no relationship to the business operation, or excessive commission fees. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company imposes a threshold on the payment of sales commissions to agents, nor that there is a requirement that agent remuneration is paid in stage payments.<\/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":"1","comments":"
There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on all of its joint venture partners. The company states that this includes establishing the ultimate beneficial ownership of the partner company.<\/p>\n
However, the company receives a score of \u20181\u2019 because 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 due diligence is repeated at least every two years. <\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
There is evidence that the company considers potential anti-bribery and corruption risks when entering into a joint venture. However, the company receives a score of \u20181\u2019 because there is no evidence that it takes steps to detect, control and prevent breaches through the inclusion of audit and termination rights in its contracts with joint venture partners.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publicly 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 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 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 or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"1","comments":"
There is evidence that 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 risks, with risk management procedures in place.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence to suggest that the results of these assessments have an impact on business decisions or trigger the implementation of additional controls. <\/p>\n"},{"question":108,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes a list of its subsidiaries. <\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
The company discloses information on its beneficial ownership structure on its website. However, the company receives a \u20181\u2019 because there is no evidence that it also discloses its ownership in an open data format. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes any data on its defence sales or customers. <\/p>\n"},{"question":111,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company publishes any details of its shareholder voting rights. Although the company publishes information on its shareholders, it cannot be assumed that these percentages automatically translate to voting rights. <\/p>\n"},{"question":112,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company publishes any information on its commercial or public policy objectives.<\/p>\n"},{"question":113,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company publishes any information about its board members or the composition, nomination and appointment process.<\/p>\n"},{"question":114,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company has an audit committee.<\/p>\n"},{"question":115,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company publishes 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\/608","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=608"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=608"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}