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. It is clear that this commitment was 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, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members as described in (a) and (b) above, regardless of their seniority.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated board committee, the Risk and CSR Committee, is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from management on the programme\u2019s performance, along with the results of internal audits, and has authority to ensure that required changes are made. <\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a senior executive at the company, the Chief Ethics Officer and Company Secretary, has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. This individual has a direct reporting line to the board, and there is evidence of reporting and feedback activities between this person and the board, such as attendance or participation at board-level committees. In addition, the company states that its CEO has primary responsibility for the application of the anti-bribery and corruption programme, and that the Chief Ethics Officer reports to the CEO. <\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
There is evidence that the company has a formal bribery and corruption risk assessment procedure that is used to improve its anti-corruption and bribery programme. This process is overseen by the Risk and CSR Committee which reports on its activities to the board. The committee reviews the company\u2019s statements on risk exposures which are included in the Annual Report and it is stated that the bribery and corruption risk assessment is conducted at least annually. It is clear that the findings of risk assessments are used to develop tailored mitigation plans and to update specific parts of the company's anti-bribery and corruption programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
The company states that its anti-bribery and corruption programme is subject to a regular assurance process to ensure the programme is consistent with the business risks facing the company. This explicitly includes provisions for continuous improvement, supplemented by periodic internal audits. The Group Head of Internal Audit reports regularly to the board-level Risk and CSR Committee on the operation of internal control and risk management processes which has ownership for planned updates and improvements to the anti-bribery and corruption programme.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
The company publicly commits to investigating incidents. The Risk and CSR Committee, which is composed of three non-executive directors, has a mandate to conduct investigations into ethical impropriety, which can be understood to include bribery and corruption. The Audit Committee receives a summary report on issues raised through the whistleblower system and major findings of internal investigations on a regular basis. There is evidence that the company\u2019s procedure covers the whole process from receipt to final outcome, and there is some evidence regarding how each investigation is documented. The company commits to informing whistleblowers of the outcome of the investigation, if they so wish.<\/p>\n
However, it is not clear whether all investigations are handled independently, and it is not clear whether the company commits to establishing root causes, putting in place remediation plans as a result of the findings of its investigations. COME BACK TO THIS<\/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 annually. <\/p>\n
However, there is no evidence that the company assures itself of the quality of both incident investigations and whistleblowing cases, there is no evidence that staff conducting investigations are properly trained, and it is unclear who is responsible for the handling of complaints about the investigative procedure itself. <\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
The company does not publish any data on ethical or bribery and corruption investigations or disciplinary actions involving its employees. <\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
The company does not publish any data on ethical or bribery and corruption investigations or disciplinary actions involving its employees. <\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides training \u2013 embedded in a business ethics course \u2013 that outlines the principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees. The company provides this training to all employees across the group on an annual basis and in all appropriate languages. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
The company states that it provides tailored training on its anti-bribery and corruption programme to employees in high risk positions on a bi-annual basis. Board members receive annual business ethics training. <\/p>\n
However, it is unclear whether this is tailored and the company does not refer to tailored training for middle management. <\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme. <\/p>\n
However, the measures are too simplistic, the frequency of the assurance is unclear, and there is no evidence that results are used to update specific parts of the company's anti-bribery and corruption communications and training programme. <\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company incorporates ethical considerations into its approach to incentives, however, the company\u2019s approach to incentives is unclear to the extent that it cannot satisfy the requirements to receive a score of \u20181\u2019.<\/p>\n"},{"question":68,"commitment_area":9,"score":"1","comments":"
The company clearly states that any employee who refuses to act unethically, in keeping with the company\u2019s anti-corruption commitments, will be protected and supported, even where such actions result in a loss of business or another disadvantage to the company. <\/p>\n
However, there is no evidence that the company assures itself of its employees\u2019 confidence in this statement through anonymised surveys or other means. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
The company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. This applies to all employees across the group. The company also expects that its suppliers\u2019 employees are free to report concerns without fear of retaliation.<\/p>\n
However, it is not explicitly stated that the same is true for all third parties employed by the group, including joint venture partners. There is also 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 the employee to raise concerns across the management chain and to relevant external bodies, and they allow for confidential and anonymous reporting. The channels are described in the company\u2019s Code of Conduct, which applies to all employees across the group, including third parties. The external channel is available in multiple countries and in English, French and Dutch.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
The company has a conflict of interest policy which refers to actual and potential conflicts and applies to all employees and board members. The policy covers employee relationships, financial interests and other employment. <\/p>\n
However, it does not cover government relationships. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
The company has procedures for managing and declaring conflicts, including actual and potential conflicts, with disciplinary measures applying when the policy is breached. Publicly available information shows that the Risk and CSR Committee has ultimate oversight and accountability for the conflict of interest policy.<\/p>\n
However, it is not clear from publicly available information whether 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 company\u2019s policy also does not mention examples of criteria for recusals. Although the company also refers to a Managing Conflicts of Interest Group Procedure, this is not available on its website. <\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
While there is evidence that the company acknowledges that the employment of former public officials may require additional scrutiny, there is no further publicly available information on its policy and\/or procedures.<\/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":"2","comments":"
The company publishes a statement that it does not make political donations. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
The company indicates that it does not make political donations. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a clear policy covering both charitable donations and sponsorships, whether made directly or through corporate foundations, to ensure that such donations are not used as vehicles for bribery and corruption. There is evidence that the policy includes measures to ensure this, for example, by specifying criteria for donations, procedures for senior sign-off, or due diligence on recipients. <\/p>\n
The company does not publish sufficient detail concerning donations made, such as the amounts donated. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
The company makes reference to an Engagement with Politicians and Political Donations Instruction Document, however this is not available on the company\u2019s website. Therefore, there is no publicly available evidence that is sufficiently detailed in relation to the company\u2019s policy and\/or procedure on lobbying to satisfy the requirements of score '1'. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
The company does not publish any information on its lobbying aims, topics or activities. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
The company does not provide any details about its global lobbying expenditure. <\/p>\n"},{"question":81,"commitment_area":11,"score":"2","comments":"
There is evidence that the company has a policy on the giving and receipt of gifts and hospitality with clear 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 the different types of promotional expense that employees may encounter. The policy also explicitly addresses the risks associated with gifts and hospitality given to and\/or received from domestic and foreign public officials, by specifying a different financial threshold. The company's policy includes a clear statement that all gifts and hospitality above certain thresholds 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":"1","comments":"
There is evidence that the company's procurement department is involved, in some capacity, in the establishment and oversight of supplier relationships. <\/p>\n
However, 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":"1","comments":"
There is evidence that the company has formal procedures to conduct risk-based due diligence when engaging and re-engaging with its suppliers. The due diligence process explicitly includes establishing the ultimate beneficial ownership of the supplier. Highest risk suppliers are stated to be subject to enhanced due diligence. <\/p>\n
However, there is no evidence to suggest that the company might be willing to review or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence process cannot be mitigated and due diligence is only conducted before engaging with new suppliers and is not repeated at least every two years or whenever there is a change in the business relationship. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. It is explicitly stated that all suppliers must have, at a minimum, policies that prohibit bribery and facilitation payments, as well as policies and procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. There is some evidence that the company takes active steps to ensure this, by requiring suppliers to put in place policies and procedures to ensure they comply with the company\u2019s Supplier Code of Conduct. <\/p>\n
However, it is unclear whether the company assures itself that such policies are in place 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 any associated disciplinary actions. <\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has a clear policy to control the use of agents which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. This policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures. <\/p>\n"},{"question":89,"commitment_area":13,"score":"2","comments":"
The company has formal procedures 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. All agents and highest risk intermediaries are subject to enhanced due diligence. The company commits to not engaging with agents or intermediaries where the risks identified in the due diligence cannot be mitigated.<\/p>\n"},{"question":90,"commitment_area":13,"score":"1","comments":"
There is evidence that the company asks of agents to disclose their beneficial ownership to the company, and it verifies this information, as part of its due diligence processes. The company suggests that it will not engage with agents or intermediaries if beneficial ownership cannot be established.<\/p>\n
However, there is no evidence of a commitment to independently verify beneficial ownership information of high risk agents, nor does the company verify the information both before onboarding and over the course of the business relationship. <\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
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. All agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include clear audit rights and termination rights to detect, control and prevent breaches.<\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
There is evidence that incentive structures for agents are highlighted and addressed as a factor in bribery and corruption risk. <\/p>\n
However, based on publicly available information, 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. The company refers to a Use of Commercial Intermediaries Group Procedure but this is not publicly acessible.<\/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":"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 partnerships. At a minimum, the company states that this includes establishing the ultimate beneficial ownership of the partner company, with enhanced due diligence where required. <\/p>\n
However, evidence suggests that due diligence is only conducted before engaging joint ventures and is not repeated at least every two years. <\/p>\n"},{"question":101,"commitment_area":13,"score":"2","comments":"
There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies and procedures in all of its joint ventures by requiring the adoption of its own anti-bribery and corruption programme. The company states that it will only enter into joint ventures if anti-bribery and corruption clauses are included in the contract, specifying clear audit and termination rights to detect, control and prevent breaches.<\/p>\n"},{"question":102,"commitment_area":13,"score":"2","comments":"
There is evidence that company commits to take an active role in preventing bribery and corruption in all of its joint ventures. There is some evidence to support the company's commitment, through a statement of possible controls that it may implement, dependent on the context.<\/p>\n"},{"question":103,"commitment_area":14,"score":"1","comments":"
There is evidence that the company has policies and procedures in place to address corruption risks associated with offset contracting and ensures any offset partners adhere to its anti-bribery and corruption standards through appropriate contractual clauses. The company has a dedicated body, department or team responsible for the monitoring and oversight of the company\u2019s offset activities throughout the lifecycle of each project. <\/p>\n
However, there is no evidence that all employees within the team receive tailored anti-bribery and corruption training.<\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
There is clear evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations. This process specifically includes checks on the beneficial ownership of any offset brokers or beneficiaries. As part of this process, the company's policy also commits to establishing and verifying that the offset obligation proposed is founded on a legitimate rationale. <\/p>\n
However, it is unclear whether the company refreshes the due diligence every two years and whether it conducts conflict of interest checks as part of the process. <\/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 and\/or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"2","comments":"
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 specific risks, with clear risk management procedures in place. The results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes a list of its subsidiaries and other related undertakings in its annual report, which includes percentages owned and countries of incorporation. There is evidence that the list is complete at the time of publication to the best of the company\u2019s knowledge. <\/p>\n
However, the company does not provide the country of operation for each subsidiary. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is publicly listed on a regulated market in the UK and therefore automatically receives a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"2","comments":"
The company discloses the customers that account for 88% of its sales, which are predominantly in the defence sector. This data is correct up 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\/615","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=615"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=615"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}