There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. There is evidence that this commitment is authorised and endorsed by the company's leadership. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
The company publishes an explicit anti-bribery and corruption policy, the Ethical Code of Conduct, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery and facilitation payments. There is evidence that this policy applies to all employees and board members as described in (a) and (b) in the question.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that a designated board committee, the Audit Committee, is ultimately responsible for the oversight of the company's ethics and compliance programme. There is evidence that this includes reviewing reports from management on the programme\u2019s performance. <\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that a designated senior executive \u2013 the General Counsel and Chief Compliance Officer \u2013 has ultimate responsibility for implementing and managing the company's ethics and compliance programme. There is evidence that this person has a direct reporting line to the board and the Audit Committee and there is evidence of reporting between this person and the board and Audit Committee as part of the company\u2019s reporting structure.<\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has a formal risk assessment procedure which covers the ethical, bribery and corruption risks facing the company\u2019s operations. There is evidence that the results of these assessments are reviewed at board level, with responsibility assigned to the Audit Committee. <\/p>\n
The company receives a score of \u20181\u2019, however, because there is no clear evidence that the results of risk assessments are used to update the company\u2019s anti-bribery and corruption programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s entire anti-bribery and corruption programme is subject to a regular audit process to ensure the programme is consistent with best practice and the business risks facing the company. There is evidence that this explicitly includes provisions for continuous improvement, supplemented by an internal and external audit every year. There is also evidence that high-level audit findings are presented to the board, with clear ownership assigned to the Audit Committee for planned updates and improvements to the anti-bribery and corruption programme. <\/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 that serious investigations are handled by external professionals to ensure independence. There is also evidence that information on each investigation is properly recorded.<\/p>\n
However, there is no evidence that the company publishes information covering the whole investigative process, from receipt to final outcome, nor is there evidence of a public commitment to providing whistleblowers with updates on the outcome of investigations. Although there is evidence that the Audit Committee is informed of serious cases immediately, publicly available information indicates that it receives information on other investigations biannually. <\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company assures itself of the quality of its internal investigations including incident investigations and whistleblowing cases. There is some evidence that staff conducting investigations are properly trained\/qualified. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it has a procedure in place to handle complaints about the investigation process. Furthermore, while there is evidence that the company has revised its investigations process recently, there is no evidence that the company systematically reviews its investigations procedure at least every three years or in response to any changes in the regulatory environment.<\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company commits to report material findings of bribery and corruption from investigations to the board. <\/p>\n
However, there is no evidence that an appropriate senior individual is 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":"2","comments":"
The company makes a public statement that there were no reports, investigations or disciplinary actions relating to employees during the most recent reporting year. There is evidence that the company publishes and updated this information on an annual basis. <\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides training for its employees on the principles of its Ethical Code of Conduct, which contains its anti-bribery policy and covers the whistleblowing options available. There is evidence that the company provides this training to all employees across all divisions, all countries of operation and in all appropriate languages. The company states that employees are required to undertake this training annually. <\/p>\n"},{"question":65,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company tailors its ethical training programme to the different levels of risk faced by employees in different roles, with specific reference to the categories of employee referred to in the question. There is evidence indicating that employees working in high risk positions, such as those in sales and procurement, are required to refresh their training on at least an annual basis. <\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company reviews its ethical communications and training programme, and that the results of such reviews are used to update specific parts of the programme, as demonstrated by its personnel surveys. <\/p>\n
However, the company states that personnel surveys are undertaken every two or three years. There is therefore no clear evidence that the company assures itself of the quality of its training programme on at least an annual basis. <\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company\u2019s incentive schemes incorporate ethical and anti-bribery and corruption principles. There is evidence that the company\u2019s incentives are designed to reward behaviour in line with the company\u2019s ethical values as identified through performance appraisals, and that the company offers non-monetary rewards such as remote working and job rotation.<\/p>\n
However, there is no evidence in publicly available information that the company tailors its approach for employees in high risk positions, such as those in sales roles. There is also no clear evidence that financial rewards must be proportionate to employees\u2019 salaries in the case of high-risk employees. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company clearly commits to support or protect employees who refuse to act unethically in the workplace. <\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. The company\u2019s whistleblowing line is open to external stakeholders and there is evidence indicating that the company extends its policy on non-retaliation to these parties. There is also evidence that the company assures itself of its employees\u2019 confidence in this commitment through employee surveys.<\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's ethical and compliance programme. There is evidence that the company\u2019s channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an external body outside the organisation. These channels allow for anonymous reporting and are available to all employees in all jurisdictions where the company operates, including those employed by external stakeholders.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy for conflicts of interest covering both actual and potential conflicts. There is evidence indicating that the policy covers employee relationships and financial interests, and there is evidence that the policy applies to all employees and board members including those at subsidiaries.<\/p>\n
However, there is no evidence that the company\u2019s policy addresses perceived conflicts. There is also no clear evidence that its policy covers possible conflicts arising from government relationships and other employment.<\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual and potential conflicts. The company indicates that its General Counsel oversees the handling of cases and that disciplinary measures apply if the policy is breached. <\/p>\n
However, there is no evidence that the policy mentions examples of criteria for recusal. In addition, although the company states that it maintains a register of related parties, there is no clear evidence that all employee and board member conflict declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process.<\/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":"2","comments":"
There is evidence that the company publicly reports details of the contracted and retained services of serving politicians, including the name and position of the individual, the services for which they have been retained and fees paid to each individual. There is evidence that this list is updated on an annual basis. <\/p>\n"},{"question":75,"commitment_area":11,"score":"2","comments":"
There is evidence that the company prohibits corporate political contributions or any other monetary benefit to political parties, candidates or individuals holding office. There is evidence to indicate that this policy applies across the organisation. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
The company states that it makes no political contributions and is therefore exempt from scoring on this question.<\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy and procedure covering both charitable donations and sponsorships. There is evidence that the company specifies criteria for donations. There is also evidence that the company publishes information on its major charitable donations and sponsorships for 2018; however, it is not clear whether this represents all of the company\u2019s donations nor whether this list is updated on an annual basis.<\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy and procedure on lobbying, which includes guidelines for responsible lobbying behaviour and outlines standards of conduct. There is evidence that the policy applies to all employees and board members. <\/p>\n
However, there is no evidence that the policy mentions specific oversight mechanisms that apply to all types of lobbyists. There is evidence that the company has a document entitled \u201cInstructions on Lobbying and Opinion Forming\u201d which may contain further information on its policy, but this document does not appear to be publicly available.<\/p>\n"},{"question":79,"commitment_area":11,"score":"2","comments":"
There is evidence that the company publishes a list of the topics on which it lobbies, including a description of its core positions, their relevance to the company and stakeholders, and the activities it carries out. There is evidence to indicate that these points represent the aims and topics on which the company conducts lobbying activities across its operations. In addition, there is evidence that this list is updated regularly.<\/p>\n"},{"question":80,"commitment_area":11,"score":"1","comments":"
The company publishes some information on its lobbying expenditure to indicate that it has not engaged any lobbyists in the past two years and therefore it has not made any lobbying expenditure to external parties. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not publish full details of its global lobbying expenditure, for example the amount spent on internal lobbyists and lobbying activities. There is also no evidence that the company publishes its spending on association lobbying, nor a statement that it does not engage in such activities.<\/p>\n"},{"question":81,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. There is evidence that the policy addresses the risks associated with gifts and hospitality given to public officials, and that it establishes financial limits for different types of gifts and hospitality. There is evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register accessible to those responsible for oversight of the process<\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company\u2019s procurement department is involved, in some capacity, in the establishment of supplier relationships. <\/p>\n
However, there is no evidence that the involvement of the procurement department is required for establishing all new suppliers. There is 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":"2","comments":"
Based on publicly available information, there is evidence that the company has formal procedures to conduct due diligence on all of its suppliers. There is evidence that the due diligence process includes checks on beneficial ownership and that the highest risk suppliers are subject to enhanced due diligence. There is evidence that the company conducts due diligence when engaging or re-engaging with suppliers, and that in instances when red flags highlighted in the due diligence process cannot be mitigated it will not engage with the supplier. <\/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. There is evidence that the company requires its suppliers to sign a declaration at the outset of its relationship stating that they will not engage in bribery and unethical conduct, and there is also evidence that the company expects its suppliers to adhere to its Code of Conduct, which is inclusive of bribery, facilitation payments, conflicts of interest, gifts and hospitality and whistleblowing, or to adopt similar policies. The company states that for critical suppliers it ensures this through contractual terms. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear publicly available evidence that the company requires anti-bribery and corruption contractual terms for all of its suppliers, nor that it takes active steps to ensure compliance with these standards in practice.<\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company takes steps to ensure that the substance of its ethical and compliance programme is required of sub-contractors throughout the supply chain. However, the company receives a score of \u20181\u2019 because it is not clear how the company does this in practice. <\/p>\n"},{"question":86,"commitment_area":12,"score":"2","comments":"
The company makes a public statement that there were no reports, investigations or disciplinary actions relating to suppliers during the most recent reporting year.<\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy covering the use of agents. There is also evidence that the company recognises and accounts for the heightened bribery and corruption risks associated with the use of third party agents by dedicating special attention to this area in its internal audits. There is evidence that the company has specific controls to mitigate the corruption risks associated with using agents, and there is evidence that it establishes that the use of an agent is, in each case, necessary to perform a legitimate business function.<\/p>\n"},{"question":89,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging any agents and intermediaries, at least every two years. There is evidence that all agents and highest risk intermediaries are subject to enhanced due diligence, and that the company commits to not engaging or terminating its engagement with agents or intermediaries where risks identified in the due diligence cannot be mitigated. <\/p>\n"},{"question":90,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company seeks to establish the ultimate beneficial ownership of agents and intermediaries as part of its due diligence process. There is evidence indicating that this scope of due diligence is repeated at least every two years, and that the company commits to not engaging or terminating an agent relationship if ultimate beneficial ownership cannot be established. <\/p>\n
However, there is no clear evidence that the company seeks to independently verify the ultimate beneficial ownership of its highest risk agents and intermediaries.<\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
There is evidence that the company\u2019s Ethical Code of Conduct applies to all agents and intermediaries acting for or on behalf of the company. There is evidence that all agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include audit and termination rights. <\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence the company highlights incentive structures for agents as a factor in bribery and corruption risk. There is evidence that the company monitors the activities of its agents before making payments.<\/p>\n
However, there is no evidence that the company\u2019s policy stipulates further controls on such payments, such as imposing a threshold on the payment of sales commissions to agents. There is also no evidence that the company requires payments to be made in stage payments or into local bank accounts.<\/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 its behalf. <\/p>\n"},{"question":99,"commitment_area":13,"score":"2","comments":"
The company publishes a statement that it received no reports of misconduct, launched no investigations and applied no disciplinary action against agents and intermediaries during the most recent reporting period. <\/p>\n"},{"question":100,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, 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 partnerships prior to entering into the venture and at least every two years thereafter. There is also evidence indicating that due diligence includes establishing the ultimate beneficial ownership of the partner company, with enhanced due diligence for joint ventures operating in high risk countries or with high risk partners. <\/p>\n"},{"question":101,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, the company commits to establishing and implementing anti-bribery and corruption policies in all of its joint ventures by developing a programme based on the company\u2019s existing policies. The company also states that it includes anti-corruption clauses in contracts with joint venture partners and there is evidence that these clauses include audit and termination rights.<\/p>\n"},{"question":102,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company commits to take an active role in preventing bribery and corruption in all its joint ventures. However, there is no evidence that the company provides practical details to support this statement or to indicate how it might do so in practice.<\/p>\n"},{"question":103,"commitment_area":14,"score":"1","comments":"
Based on publicly available information, there is evidence that the company recognises the ethical and compliance risks associated with offset contracting, but there is limited evidence of policies and processes to address these. There is evidence that the company has a dedicated department involved in managing its offset obligations, and this department is understood to be responsible for monitoring company\u2019s offset activities throughout the lifecycle of each project.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that all employees within the team receive tailored anti-bribery and corruption training on the potential corruption risks associated with offsets. <\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
Based on publicly available information, there is 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
However, there is no evidence that the process specifically includes checks on beneficial ownership and conflicts of interest. There is also no evidence that the company seeks to assure itself of the legitimacy of the investment or that the company refreshes due diligence continuously or at least when there is a significant change in the business relationship or nature of the partner. <\/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 its offset programme. <\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
Based on publicly available information, there is evidence that the company participates in indirect offset arrangements. However, there is no evidence that the company publishes details about the beneficiaries of these projects. <\/p>\n"},{"question":107,"commitment_area":15,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company acknowledges the corruption risks of operating in different markets. There is evidence that it assesses country risk as part of its due diligence processes, which it conducts when operating internationally. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that 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":"1","comments":"
Based on publicly available information, there is evidence that the company publishes lists of its consolidated subsidiaries and non-fully consolidated holdings. The publicly available lists include the percentages owned and the countries of incorporation for each entity. There is evidence that the company publishes this information on an annual basis. <\/p>\n
However, there is no evidence that the company publishes further information on the country or countries of operation for each entity. <\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
Based on publicly available information, there is evidence that the company discloses its control structure and beneficial ownership on its website. The company indicates that the State of Finland owns 50.1% of its shares, while the remaining 49.9% of shares are held by a company affiliated with the Norwegian defence company Kongsberg Gruppen ASA. <\/p>\n
The company receives a score of \u20181\u2019 because there is no evidence that its ownership information is disclosed in a freely available and readily accessible central public register. Basic information on the company can be found in the Finnish corporate register, but further details on its ownership and shareholders is not freely accessible. <\/p>\n"},{"question":110,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes some information on its major customers, indicating that defence products and maintenance account for 92% of its net sales and that Finland accounted for approximately 67% of its sales in the most recently reported financial year. Within Finland, the company states that its main customer is the Finnish Defence Forces. <\/p>\n
However, the company receives a score of \u20181\u2019 because the company does not provide further information on its major customers for defence sales specifically. The company provides some information on its sales outside of Finland, but not in the form of percentages or figures to indicate the extent of these relationships.<\/p>\n"},{"question":111,"commitment_area":16,"score":"2","comments":"
There is evidence that the company publishes information about its shareholder voting rights alongside its ownership information. <\/p>\n"},{"question":112,"commitment_area":16,"score":"2","comments":"
There is evidence that the company publishes its commercial and public policy objectives on an annual basis. <\/p>\n"},{"question":113,"commitment_area":16,"score":"2","comments":"
There is evidence that the company publishes details about the composition of its board of directors. For each board member, the company discloses whether that person has any connection to the company or the state or is an independent director. The company also publishes information on the director nomination and appointment process. There is evidence that the Nomination and Compensation Committee has responsibility for this process and is composed of non-company and non-executive directors<\/p>\n"},{"question":114,"commitment_area":16,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s audit committee is composed of a majority of independent directors. <\/p>\n"},{"question":115,"commitment_area":16,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a system in place to manage asset transactions, with transactions being documented and subject to audit. There is evidence that the financial results from asset acquisitions are published in the company\u2019s reports. There is also evidence suggesting that responsibility for managing asset transactions is held at board level. <\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/611","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=611"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=611"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}