The company\u2019s Code of Conduct details the company's stance against bribery and corruption. It is clear that the Code of Conduct was authorised and endorsed by the company's leadership. <\/p>\n
However, the company\u2019s leadership does not specifically mention anti-bribery and corruption and therefore a score of \u20181\u2019 applies.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
The company publishes an explicit anti-bribery and corruption policy which makes specific reference to the prohibition of bribery of all types, payments to public officials and facilitation payments. This policy clearly applies to all employees and board members. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that the Audit Committee of the board of directors provides oversight of the company\u2019s anti-bribery and corruption programme. This includes reviewing reports from management on the programme\u2019s performance, and there is evidence that the designated board committee has the authority to require that changes are made. <\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior executive, the Vice President and Chief Ethics and 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 Audit Committee. There is evidence of reporting and feedback activities between this person and the Audit Committee as part of the company\u2019s reporting structure. <\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
There is evidence that the company has a formal bribery and corruption risk assessment procedure that informs the design of the anti-bribery and corruption programme. There is evidence that the results of risk assessments are reviewed at board level, and are used to develop tailored mitigation plans and to update specific parts of the company's anti-bribery and corruption programme. <\/p>\n
However, it is unclear whether risk assessments are reviewed at least annually or when they reveal significant findings. <\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
Although the company\u2019s Audit Committee provides oversight of the anti-bribery and corruption programme, there is no publicly available evidence that the company regularly audits this programme. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company has a system for tracking, investigating and responding to bribery and corruption allegations or incidents. The company commits to promptly investigating incidents and there is evidence that reports and investigations are documented and received by independent teams. There is evidence that the company has a specific procedure in place to deal with whistleblowing cases, which are handled by an external party, and whistleblowers have the option to receive updates on the outcome of investigations. The Audit Committee receives reports concerning the company\u2019s whistleblowing line and summary information investigations on a quarterly basis. <\/p>\n
However, the company\u2019s stated procedures do not cover the whole investigation process from receipt of the report to final outcome, and so receives a score of \u20181\u2019. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
The company states that individuals handling whistleblowing reports have received training in ensuring that the reports remain confidential. Further statements indicate that the Global Ethics and Compliance Team ensures that investigative procedures are followed. However, there is insufficient publicly available evidence that the company assures itself of the quality of its internal investigations.<\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
The company makes a clear commitment to report material findings of bribery and corruption from investigations to the board. An appropriate senior individual, the Vice President, Chief Ethics, Compliance and Sustainability Officer, is ultimately responsible for ensuring that the disclosure of criminal offences to relevant authorities is evaluated and acted upon if necessary.<\/p>\n"},{"question":63,"commitment_area":8,"score":"1","comments":"
The company publishes summary data of the number of reports received on its whistleblowing service relating to violations of its Code of Conduct, including bribery and corruption incidents. The data relates to employees at all levels and is published annually.<\/p>\n
The data, however, does not include information on the number of investigations launched, nor disciplinary action taken as a result of investigation findings.<\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
The company states that employees in certain positions receive tailored anti-bribery and corruption training. <\/p>\n
However, these positions are unclear and do not make specific reference to all three categories of employee referred to in the question. Additionally, the company does not state that training for employees in high risk positions is refreshed on at least an annual basis.<\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company reviews its anti-bribery and corruption communications and training programme annually. <\/p>\n
However, the measures described for doing so appear overly simplistic and are limited to completion rates. There is also no evidence that the results of such reviews are used to update specific parts of the training programme. <\/p>\n"},{"question":66,"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":67,"commitment_area":9,"score":"0","comments":"
There is insufficient evidence that the company commits to support or protect employees who refuse to act unethically. <\/p>\n"},{"question":68,"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 that explicitly applies to all employees across the organisation, including those employed by the group as third parties and suppliers.<\/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":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 that explicitly applies to all employees across the organisation, including those employed by the group as third parties and suppliers.<\/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":"2","comments":"
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 employees to raise concerns across the management chain and to a relevant external organisation. These channels allow for confidential and, wherever possible, anonymous reporting. There is also evidence that these reporting channels are available and accessible to employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners, and in all relevant languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy on conflicts of interest, which covers actual, potential and perceived conflicts. The policy refers to employee relationships, financial interests and external employment as categories of conflict. The policy applies to all employees and board members, including those of subsidiaries and other controlled entities.<\/p>\n
However, there is no publicly available evidence that the company\u2019s policy covers conflicts of interest related to 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, including actual, potential and perceived conflicts. There is evidence that the Global Ethics & Compliance department has oversight and accountability for handling cases. There is evidence that all employee and board member declarations are held in a dedicated central depository that is accessible to those responsible for oversight of the process. The description of this procedure also includes examples of criteria for recusals and a description of the potential punitive measures for breaches of the policy.<\/p>\n"},{"question":73,"commitment_area":10,"score":"2","comments":"
There is evidence that the company has a policy and\/or procedure, which includes controls to assess and regulate employment and offers of employment to former public officials. As a minimum, the policy requires senior compliance officer (or equivalent) approval for the initiation of any employment discussions with former or current public officials, a review of actual, potential or perceived conflict of interest and restrictions on their activities if such conflicts of interest are identified. There is also evidence that the company has a policy to implement a cooling-off period of at least 12 months before such public officials are permitted to have any form of contact or relationship with their former organisation on the company\u2019s behalf.<\/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 permits political contributions in some instances, and has a political action committee. The company therefore receives a score of \u20180\u2019. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
The company does not disclose any details of its political contributions on its website. <\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
While the company discloses some information on its charitable contributions, there is no evidence that the company has a policy and\/or procedure covering both charitable donations and sponsorships.<\/p>\n"},{"question":78,"commitment_area":11,"score":"2","comments":"
There is evidence that the company has a policy on lobbying, which includes guidelines on responsible lobbying activities. This policy applies company-wide to all employees, board members and third parties engaged in lobbying activities on the company\u2019s behalf. The company provides details on certain standards of conduct comprising responsible lobbying behaviour and describes oversight mechanisms, which apply to all types of lobbyists. <\/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.<\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
The company does not publish any information on its global lobbying expenditure on its website.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. The policy addresses the risks associated with gifts and hospitality given to public officials. The company also states that all gifts and hospitality expenditures must be documented.<\/p>\n
However, the company does not specify financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no evidence that all gifts and hospitality received, above a certain threshold, are recorded in a centrally held register, which is accessible to those responsible for oversight of the process. Although the company references a separate gifts and entertainment policy, it is not publicly available.<\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company's procurement department is responsible for oversight of the company\u2019s supplier base. <\/p>\n
However, in publicly available evidence the company does not does not state that the involvement of the procurement department is required for establishing any new suppliers over a certain threshold. There is also no evidence that the company assures itself of the procurement department\u2019s involvement at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
In publicly available evidence, the company simply states that it conducts due diligence on third parties, without providing any further details. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company ensures that all its suppliers have anti-bribery and corruption policies in place. The company states that at a minimum, suppliers must adhere to its Code of Conduct and Supplier Code Of Conduct, which prohibit bribery, and include provisions addressing conflicts of interest, gifts and hospitality, and whistleblowing. There is evidence that the company monitors its suppliers and may terminate relationships if they are found to be noncompliant with its policy. <\/p>\n
However, there is no publicly available evidence that the company conducts assurance when onboarding new suppliers or when there is a significant change in the business relationship. <\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
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 insufficient publicly available evidence that the company has a policy which addresses the corruption risks associated with the use of agents, or that it includes details of controls to mitigate these risks.<\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company has formal procedures to conduct due diligence on its agents. <\/p>\n
However, in publicly available evidence, it is not clear whether agents and the 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 and\/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 and intermediaries.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is some evidence that the company\u2019s anti-bribery and corruption policy applies to agents and intermediaries. Although the company indicates that it may include termination rights in its contracts with these entities, it does not mention audit rights. <\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
There is some evidence that incentive structures for agents are acknowledged as a factor in bribery and corruption risk. <\/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 or into local bank accounts.<\/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":"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.<\/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.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its offset obligations.<\/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.<\/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.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes a list of its consolidated subsidiaries on an annual basis. This includes the country of incorporation of each entity.<\/p>\n
However, it is not clear that the list includes all of the company\u2019s holdings. The list also does not include the percentages owned and countries of operation for each entity. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is publicly listed on the New York Stock Exchange and therefore automatically receives a score of \u20182\u2019.<\/p>\n"},{"question":110,"commitment_area":15,"score":"2","comments":"
The company publishes a percentage breakdown for at least 80% of its defence sales by customer. There is evidence that this data is correct to the most recently reported financial year.<\/p>\n"},{"question":111,"commitment_area":16,"score":"N\/A","comments":""},{"question":112,"commitment_area":16,"score":"N\/A","comments":""},{"question":113,"commitment_area":16,"score":"N\/A","comments":""},{"question":114,"commitment_area":16,"score":"N\/A","comments":""},{"question":115,"commitment_area":16,"score":"N\/A","comments":""}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/610","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=610"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=610"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}