There is evidence that the company has a publicly stated anti-bribery and corruption statement. However, the company receives a score of \u20181\u2019 because this statement does not directly mention anti-bribery and corruption. The company makes a general commitment, authorised and supported by the President of the company, to participate in the voluntary initiative the United Nations Global Compact (UNGC). <\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has an anti-bribery and corruption policy as part of its Code of Conduct. However, the company receives a score of \u20181\u2019 because it does not make specific reference to facilitation payments and it is not clear that the policy applies to board members. <\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
Based on publicly available information, there is evidence that the Board of Directors and the CSR division oversee the Code of Conduct, which includes the company\u2019s anti-bribery and corruption policy. However, there is no evidence to suggest that the Board engages in formal oversight functions, such as reviewing reports from management or results of informal and external audits. <\/p>\n
There is also evidence that the company has a Risk Management Committee and a Compliance Committee. However, it is unclear whether either of these bodies provide oversight of the company's anti-bribery and corruption programme specifically.<\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
There is no publicly available evidence that a specific senior executive or managerial-level employee has ultimate responsibility for implementing and managing the company\u2019s anti-bribery and corruption programme. The company has a Chief Compliance Officer, however it is not stated that his\/her remit includes implementing and managing the company\u2019s anti-bribery and corruption programme. <\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
There is some evidence that the company has a formal risk management procedure, however there is no evidence that this is used to inform and tailor the company\u2019s anti-bribery and corruption programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is evidence that the company has an internal auditing division that audits the state of compliance and risk management across the group\u2019s businesses. However, there is no clear evidence that the company\u2019s anti-bribery and corruption programme is subject to internal or external audit. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company commits to investigating incidents, and there is a specific procedure in place to deal with whistleblowing cases. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide information on the investigative procedure from receipt to outcome, nor is it clear that investigations are handled by an independent team that reports to an independent board member. There is no evidence that the company commits to providing whistleblowers with updates on the outcome of investigations and it is not clear that information from each case is appropriately documented. There is also no evidence that a central body reviews summary information on all open cases on a regular 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, if necessary, to the 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-related investigations or disciplinary actions involving its employees. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company provides a training module on compliance to all employees that outlines the whistleblowing options available to them. There is evidence that this compliance training included a specific anti-bribery and corruption module in 2014, however it is not clear whether the company provides an anti-corruption module regularly or since 2014. In addition, there is no evidence that the training is provided to all employees across all divisions, all countries and regions of operation or in all appropriate languages. <\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk. Although there is evidence that managers receive tailored training on compliance matters, it is unclear whether this training includes a specific section on anti-bribery and corruption. <\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is some evidence that the company measures the effectiveness of its compliance training through fixed point observations and a compliance awareness survey. However, it is not clear whether this training includes anti-bribery and corruption so the company receives a score of \u20180\u2019. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is evidence that the company aims to make the decision-making process around compensation for its Board Members and Executive Directors transparent and objective. However, there is no evidence that the company\u2019s incentive schemes incorporate ethical principles specifically nor is it clear that this applies for all employees. <\/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":"0","comments":"
Based on publicly available information, there is evidence that the company has a policy of non-retaliation against whistleblowers and employees who report bribery and corruption incidents, which explicitly applies across the organisation. <\/p>\n
However, the company receives a score of \u20181\u2019 because 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":"0","comments":"
Based on publicly available information, there is some evidence that the company has provides channels for employees to report instances of suspected corrupt activity.<\/p>\n
However, the company receives a score of \u20180\u2019 because there is no publicly available evidence to indicate how they can be accessed. It is not explicitly clear that these channels allow for anonymous or confidential reporting, nor is there evidence that the company provides externally-operated channels (i.e. by an independent third party). The company also does not provide evidence to indicate whether employees can use these channels to seek advice on the company\u2019s anti-bribery and corruption programme. Furthermore, the channels are not explicitly available to all employees in any country of operation, or in multiple languages, or to any employees of third parties, suppliers or joint venture partners. <\/p>\n"},{"question":71,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the company has a policy on conflict of interest. <\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company has procedures to manage conflict of interest or their oversight. <\/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 some evidence that the company has a policy on political contributions, indicating that such donations are permitted in line with local laws and company regulations. There is no evidence that authorisation from an individual with legal expertise is required.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any details of its political contributions. <\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is evidence that the company has a procedure covering charitable donations. However, there is no evidence that this policy includes measures to ensure donations are not used as vehicles for bribery and corruption, for example, by specifying criteria for donations, procedures for senior sign-off, or due diligence on recipients. There is also no evidence that the company addresses or has measures in place to regulate sponsorships, nor is there evidence to indicate that the company does not engage in such contributions. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available 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 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":"0","comments":"
The company states that it has a policy on the giving and receipt of gifts and hospitality, but it receives a score of \u20180\u2019 because it does not make details about the contents of this policy publicly available. There is no evidence that the policy specifies financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no evidence that it addresses the risks associated with gifts and hospitality given to or received from domestic or foreign public officials, nor is there evidence that gifts and hospitality over a certain threshold are recorded in a central register that is accessible to those responsible for oversight of the process. <\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company requires and ensures the involvement of its procurement department in the establishment and oversight of its supplier base. There is some evidence that the company has a procurement policy which outlines the company\u2019s approach to selecting and managing suppliers, but this does not assign responsibility for oversight to a specific body, department or team. <\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its suppliers. There is some evidence that the company has a procedure for the selection of suppliers, but it is not clear that this includes due diligence and\/or anti-corruption considerations. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies in place. The company states that all suppliers are requested to refrain from engaging in bribery \u2013 including through gift-giving, entertainment and political donations \u2013 however there is no mention of conflicts of interest or whistleblowing. There is also no evidence that the company takes steps to assure itself that these standards are in place when there is a significant change in the business relationship. <\/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-related investigations relating to its suppliers, or related disciplinary actions. <\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company has a policy covering the use of agents. <\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries. <\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to establish the beneficial ownership of its agents. <\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that shows 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 addresses incentive structures as a risk factor in agent behaviour or that it incorporates ethical principles into agent incentive structures.<\/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":"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":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its joint ventures.<\/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, nor is there evidence that it requires anti-bribery and corruption clauses in its contracts with 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, nor is there evidence that a dedicated body, department or team is responsible for monitoring of the company\u2019s offset activities. <\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company conducts 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 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":"0","comments":"
There is some evidence that the company acknowledges the risks of operating in different countries. However, there is no evidence that the company considers bribery and corruption risks specifically, nor is there evidence that it has a dedicated assessment procedure in place to assess such risks and inform the company\u2019s operations in high risks markets. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
Based on publicly available information, there is evidence that the company publishes a list of its affiliated companies. However, the company receives a score of \u20181\u2019 because it is not clear whether the list covers all consolidated subsidiaries or holdings, and it does not include further details such as the percentage ownership, country of incorporation and country of operation for all entities. <\/p>\n
There is an indication that the information is complete at the time of publication, but it is unclear how frequently the company updates this information. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed on the Tokyo Stock Exchange and is therefore automatically eligible for a score of \u20182\u2019. In addition, the company publishes information on its major shareholders in its Annual Report. <\/p>\n"},{"question":110,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a percentage breakdown of its sales by geographic region, with the exception of Japan and China identified on a country\/customer level. The company receives a score of \u20181\u2019 because it is apparent from this data that Japan accounts for approximately 70% of the company\u2019s sales, however there is evidence to indicate that this includes overall sales rather than defence specifically. <\/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\/609","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=609"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=609"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}