The company\u2019s code of conduct details the company's stance against bribery and corruption. It is clear that this document was authorised and endorsed by the company's leadership. <\/p>\n
However, the messages from leadership do not specifically mention anti-bribery and corruption and therefore a score of \u20181\u2019 applies.<\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
The company publishes an anti-bribery and corruption policy which makes specific reference to the prohibition of bribery, payments to public officials and commercial bribery. There is evidence that this policy applies to all employees and board members of the company.<\/p>\n
However, the company scores \u20181\u2019 as there is no evidence its policy prohibits facilitation payments. The company\u2019s policy also does not extend beyond a general commitment to comply with anti-bribery laws.<\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is evidence that a designated board committee, the Audit Committee, is ultimately responsible for the oversight of the company's ethics programme. This includes reviewing reports from management on the programme\u2019s performance on at least an annual basis.<\/p>\n
However, the company scores \u20181\u2019 as there is insufficient publicly available evidence that the Audit Committee reviews audits of the company\u2019s ethics programme specifically. The Audit Committee Charter also does not refer to anti-bribery and corruption directly. <\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior executive, the Chief Ethics and Compliance Officer, has ultimate responsibility for implementing and managing the company's ethics programme. It is clear that this person has a direct reporting line to the Audit Committee which provides oversight of the company\u2019s ethics programme. 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":"0","comments":"
There is no clear evidence that the company has a formal risk assessment procedure which is used to inform the company\u2019s anti-bribery and corruption programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is evidence that the Audit Committee reviews the company\u2019s ethics and compliance programme on an annual basis. However, it does not clearly state that it audits the programme or whether the findings of its review process are used to update the programme.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company commits to investigating incidents and that it has a procedure for documenting and handling whistleblower reports. The company\u2019s Ethics and Compliance Office is responsible for conducting investigations.<\/p>\n
However, the company does not publish details of its whole investigation process from receipt to final outcome, nor is there evidence that it commits to providing whistleblowers with updates on the outcome of investigations. While the company states that the Chief Ethics and Compliance Officer has the authority to provide information on investigations to the Audit Committee, there is no clear evidence that the committee receives summary information of all investigations relating to bribery and corruption incidents on a regular or annual basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
There is some evidence that the company assures itself of the quality of its internal investigations, by stating that employees with concerns about the actions or decisions of the Ethics and Compliance Office may contact the General Counsel. <\/p>\n
However, there is no evidence that the company assures itself of the quality of both incident investigations and whistleblowing cases, it is unclear whether all staff conducting investigations are properly trained or qualified, and there is no evidence that the company 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":"
There is evidence indicating that the company reports material findings of bribery and corruption to the Audit Committee, a designated board committee. <\/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":"0","comments":"
There is no evidence that the company publishes high-level results from incident investigations and disciplinary actions.<\/p>\n"},{"question":64,"commitment_area":9,"score":"0","comments":"
While the company states that it provides training to its employees, there is no clear evidence that the training covers anti-bribery and corruption.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no clear evidence that the company provides anti-bribery and corruption training for its employees based on an assessment of their role and exposure to corruption risk.<\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company\u2019s incentive schemes incorporate ethical or anti-bribery and corruption principles.<\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no clear evidence that the company commits to support or protect employees who refuse to act unethically, even when it might result in a loss of business. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is evidence the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, which applies company-wide. There is some evidence that the company extends this commitment to third parties including 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":"
There is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's ethics programme. Channels are sufficiently varied to allow employees to raise concerns across the management chain and to a relevant external body. These channels allow for confidential and anonymous reporting. There is evidence indicating the channels are available to all employees in any country of operation and in all relevant languages. There is also evidence indicating that the company\u2019s whistleblowing line is open to third parties including suppliers.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence the company has a policy that defines conflicts of interest, including actual, potential and perceived conflicts. The policy explicitly covers all of the categories of possible conflicts listed in the guidance, namely employee and government relationships, financial interests and other employment. The company states that this policy applies to all employees and board members, and those conducting work on its behalf. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is some evidence the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company states that employees should consult their manager, the Human Resources Department, the Ethics and Compliance Officer or Legal Department if they are uncertain about the company\u2019s policies and procedures. Disciplinary measures apply to individuals which breach the company\u2019s code of conduct. <\/p>\n
However, there is no reference to a specific body or individual with oversight and accountability for handling cases, nor is there evidence that all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process. The policy also does not mention examples of criteria for recusals. <\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy that addresses the risks associated with the employment of public officials. The company states that it conducts screening of current and former government employees. <\/p>\n
However, there is no 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. There is also no evidence the company requires senior compliance officer (or equivalent) approval for the initiation of any employment discussions nor that it conducts a review of actual, potential or perceived conflicts of interest.<\/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 generally prohibits political contributions, but these are permissible in certain circumstances. The company also operates a Political Action Committee. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
The company does not disclose on its website any details of political contributions made by the company or its PAC.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
Although the company publishes some information regarding its charitable contributions, there is no evidence that the company has a policy and\/or procedure covering both charitable donations and sponsorships. There is also no evidence that the company has 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.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
Based on public information, there is some evidence that the company has a policy on lobbying. Employees must coordinate with the Legislative Affairs Department before engaging in activity which might constitute lobbying. <\/p>\n
However, the company does not define lobbying or responsible lobbying in publicly available evidence. There is no mention of certain standards of conduct or specific oversight mechanisms that apply to all types of lobbyists. It is also unclear based on publicly available evidence whether the policy applies to third parties and other entities controlled by the company.<\/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 on the giving and receipt of gifts and hospitality with procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits, along with an approval procedure for different types of expenses. The policy also explicitly addresses the risks associated with gifts and hospitality given to or received from domestic and foreign public officials. <\/p>\n
However, there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process. <\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no publicly available 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":"0","comments":"
There is some evidence to suggest that the company conducts due diligence on its supply chain, however, the company does not provide sufficient detail to receive a score of \u20181\u2019. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. Suppliers are required to comply with the company\u2019s Contingent Worker Code of Conduct, which prohibits bribery and facilitation payments, and also includes procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. <\/p>\n
However, there is no clear evidence that the company assures itself of this when onboarding new suppliers and when there is a significant change in the business relationship. <\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
There is 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. It ensures this by requiring that its suppliers obtain its written approval before engaging any subcontractors, and that subcontractors adhere to its Code of Conduct. <\/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 related to the use of agents. <\/p>\n
However, the company does not provide details of specific controls to mitigate the corruption risks associated with the use of agents. There is also no evidence that the company commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. In addition, it is unclear whether the company\u2019s policy also applies to subsidiaries and joint ventures. <\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no publicly available 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 publicly available evidence that the company aims to establish the beneficial ownership of its agents.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is evidence that the company\u2019s code of conduct, The Standard, applies to agents and intermediaries. However, there is no publicly available evidence that the company incorporates anti-corruption clauses in contracts with its agents and intermediaries, which include clear audit and termination rights.<\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company's incentive structures for agents are designed to minimise risks of anti-bribery and corruption.<\/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 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 publicly available evidence that the company conducts anti-bribery and corruption due diligence on its joint venture partners.<\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures. There is also no evidence that the company requires anti-bribery and corruption clauses in its contracts with joint venture partners.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.<\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company addresses the corruption risks associated with offset contracts, nor that the company has a dedicated body, department or team which is responsible for monitoring of 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":"
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 subsidiaries on an annual basis. This list includes the country and U.S. state of incorporation for each entity. <\/p>\n
However, it is unclear whether the list includes all of the company\u2019s holdings. The list also does not include the percentages owned or 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":"0","comments":"
The company does not publish the customers of at least 50 percent of its defence sales. <\/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\/612","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=612"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=612"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}