There is evidence that the company publishes a clear statement on its anti-bribery and corruption commitment, which details the company\u2019s stance against any form of bribery or corruption within the organisation. There is evidence that this commitment was authorised and endorsed by the company\u2019s leadership. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company publishes a clear anti-bribery and corruption policy, which specifically defines and prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that this policy applies to all employees and directors.<\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is evidence that the board oversees the company's anti-bribery and corruption programme. There is evidence that this includes reviewing reports from management on the programme\u2019s performance, along with the results of internal audits. However, the company receives a score of \u20181\u2019 because there is no evidence to suggest that the board has the authority to require that changes are made. While there is some indication that the company has an Anti-Corruption Committee, the evidence suggests that this is not a board-level committee.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior executive \u2013 in this case the Compliance Officer \u2013 has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. The company indicates that this person has a direct reporting line to the board. There is evidence of reporting and feedback activities between this person and the board as part of the company\u2019s reporting structure, both through the CEO and the General Counsel.<\/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 informs the design of the anti-bribery and corruption programme. There is evidence that suggests that the board of directors reviews the company\u2019s risk profile \u2013 presented by the Chief Compliance Officer \u2013 on at least an annual basis. The company states that the Chief Compliance Officer determines on a yearly basis whether a new risk assessment is required, with a full assessment conducted at least every three years. There is evidence that the results of such reviews 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":"
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. This includes provisions for continuous improvement, supplemented by an internal audit conducted on an annual basis. There is also evidence that high-level audit findings are presented to the board, with clear ownership assigned to the Compliance Officer for planned updates and improvements to the anti-bribery and corruption programme.<\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
There is evidence that the company publicly commits to investigating incidents promptly and objectively, and that the company takes steps to ensure the independence of its investigations. There is evidence that the company commits to putting in place remediation plans and reporting investigative findings to senior management and the board. For whistleblowing cases, there is evidence that the company has a procedure in place which covers the investigation process from receipt to final outcome, and the company commits to ensure whistleblowers are informed of the outcome. The evidence states that a senior central body of the company receives and reviews summary information of all incidents and their status on a quarterly basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company assures itself of the quality of its internal investigations. The company states that systems are in place and that an Internal Auditor has access to information on the process; however there is no clear evidence that staff tasked with conducting investigations are properly trained to perform the function, nor that there is a procedure in place to receive and escalate, if necessary, complaints about the investigative procedure. <\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
There is clear evidence that the company commits to report material findings of bribery and corruption from its investigations to the board. There is evidence that an appropriate senior individual is ultimately responsible for ensuring that the disclosure of criminal offences to relevant authorities is evaluated and acted upon if found necessary.<\/p>\n"},{"question":63,"commitment_area":8,"score":"1","comments":"
The company publishes some high-level information on ethics and compliance-related complaints involving its employees. This information includes the number of reports received and the number of disciplinary actions. <\/p>\n
However, the company receives a score of \u20181\u2019 because this information does not cover the past 12 months, nor does it cover the number of reports received through whistleblowing channels and the number of investigations launched. The company also does not explicitly state that this ethics data includes details of bribery or corruption related incidents.<\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides training that outlines the basic principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees. There is evidence that the company provides this training to all employees and in all appropriate languages. However, the company receives a score of \u20181\u2019 because it is unclear how frequently employees are required to refresh their training on anti-bribery and corruption.<\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides tailored anti-bribery and corruption training to employees in different roles based on their exposure to corruption risk, with specific reference to the three categories of employee referred to in (a), (b) and (c) of the question. However, there is no evidence that employees in high risk positions specifically are required to undertake and refresh their training on at least an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
There is evidence that the company measures and reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme. There is evidence that the company has a system to do this, for example through risk assessments, feedback from employees and results of internal audits and the company commits to assuring itself of this on at least on an annual basis. There is evidence that the results of such reviews are then used to update specific parts of the company's anti-bribery and corruption communications and training programme, with a review of the programme taking place on an annual basis.<\/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 evidence that the company commits to support or protect employees who refuse to act unethically. <\/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. There is evidence to indicate that this policy extends to any individual who wishes to report an incident, including all employees of suppliers, third parties and joint venture partners. <\/p>\n
However, the company receives a score of \u20181\u2019 as 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":"1","comments":"
There is evidence 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, by telephone, email or mail. There is evidence that these channels allow for confidential and anonymous reporting. There is some evidence these channels are open to all employees and third parties, although the company does not refer to employees of suppliers and joint venture partners specifically. <\/p>\n
However, the company receives a score of \u20181\u2019 as the evidence suggests that it only offers internally operated channels, with no evidence of an external channel operated by an independent third party. It is also unclear whether the channels are available in all relevant languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence that the company formally addresses conflict of interest as a corruption risk, and has a policy for conflicts of interests that covers actual, potential and perceived conflict of interests. The policy refers to financial interests, employee relationships, government relationships and other employment. There is evidence that this policy applies to all employees, suppliers and business partners associated with the company, which is understood to also include all board members, third parties and employees of joint ventures. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company states that it forms committees to handle conflicts of interests which include representatives from the human resources and legal departments as well as a member of the executive team. There is evidence which indicates that employees who breach the company\u2019s policies are subject to disciplinary action.<\/p>\n
However, the company receives a score of \u20181\u2019 as there is no 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. There is also no evidence that the company provides examples of criteria for recusals.<\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is some evidence that the company has a policy that addresses the risks associated with the employment of public officials. The company states that it follows local laws and regulations concerning cooling-off periods related to hiring current or former government officials. <\/p>\n
However, the company receives a score of \u20181\u2019 as it does not publish sufficient detail regarding specific controls to assess and regulate the employment of current or former public officials, such as requiring senior approval for the initiation of employment discussions or stipulating that any cooling off period must be for 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":"2","comments":"
The company publishes a clear statement that it prohibits corporate political contributions, whether made directly or indirectly. Since this evidence appears in the company-wide Anti-Corruption Policy, it is understood that this applies to all employees of the company including directors, third parties, suppliers and joint venture partners.<\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
There is evidence that the company prohibits corporate political contributions so the company is exempted from scoring on this question. <\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
The company publishes a clear statement that it does not make charitable donations. However, the company receives a score of \u20180\u2019 because there is no evidence that it has a policy or procedure covering sponsorships, nor does the company publish a clear statement that it does not make sponsorships. <\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
There is evidence that the company outlines certain standards of conduct and oversight mechanisms that apply to all types of business partners, including lobbyists. The company states that it only conducts lobbying in the U.S., where it observes all the required registration and licencing conditions for lobbyists; however, there is no publicly available evidence that it has a policy that defines lobbying or responsible lobbying and that applies to all employees, board members and third parties lobbying on the company\u2019s behalf. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any information on its lobbying aims, topics or activities.<\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any details about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy on the giving of gifts and hospitality to domestic and foreign public officials, 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 the different types of promotional expense that employees may give to public officials. <\/p>\n
There is evidence that all gifts and hospitality given are recorded in a computerized system for managing business courtesies, however the company receives a score of \u20181\u2019 because it is not explicit whether this is accessible and reviewed by those responsible for oversight of the process. Furthermore, there is no publicly available evidence that the company\u2019s policy addresses gifts and hospitality given to individuals other than public officials, nor does it cover any procedures for the receipt of gifts and hospitality by company employees. <\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company requires the involvement of its procurement department in the establishment or oversight of its supplier base.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct due diligence when engaging and re-engaging with all business partners, which includes suppliers. There is evidence that the process includes obtaining ownership information for business partners, although the company does not specifically commit to establishing ultimate beneficial ownership. There is evidence that higher risk business partners are subject to enhanced due diligence and that the company states that it will not engage with a business partner if red flags highlighted in the due diligence process cannot be mitigated. <\/p>\n
However, while the company states that the due diligence process is conducted at least every two years or when there is a significant change in the business relationship for its highest risk business partners, it is not clear how frequently the company conducts due diligence on standard suppliers, i.e. those not identified as high risk.<\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
There is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company states that all suppliers must have, at minimum, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, as well as policies and procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. There is evidence that the company takes active steps to ensure this, for example by requiring that all suppliers follow its own anti-bribery policies and procedures. The company states that it obtains written agreements from suppliers to comply with anti-corruption laws. The company assures itself of this when onboarding new suppliers or when there is a significant change in the business relationship.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.<\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.<\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has a procedure to control the use of agents which addresses the corruption risks associated with their use 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. There is evidence the 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":"
There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging any business partners, which includes agents and intermediaries. The company states that due diligence may be adjusted for certain business partners based on the risks identified and recognises the risks associated with agents, indicating that agents and highest risk intermediaries are subject to enhanced due diligence. There is also evidence that the due diligence process is conducted at least every two years or when there is a significant change in the business relationship. Furthermore, the company\u2019s policy includes a commitment to not engage or terminate its engagement with business partners where the risks identified in the due diligence cannot be mitigated. <\/p>\n"},{"question":90,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has formal procedures to establish the beneficial ownership of agents prior to engaging them, and when there is a significant change in the business relationship. There is evidence that the company operates, as a minimum, a risk based beneficial ownership verification policy, whereby all agent provided information is independently verified. The company commits to not engaging or terminating its engagement with agents or intermediaries where ultimate beneficial ownership cannot be established. <\/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. The company states that all agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, with 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. The company lists a number of red flags which can lead to a termination of a relationship with business partners, which suggest that remuneration to agents is usually required to be paid in stage payments and into local bank accounts. <\/p>\n
However, the company receives a score of \u20181\u2019 as there is no evidence that it imposes a proportionate threshold on the payment of sales commissions to agents. <\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any details of the agents currently contracted to act for, or on its behalf.<\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical, bribery or corruption-related investigations, or the associated disciplinary actions involving agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on all of its business partners, which includes joint venture partnerships. The company states that this includes obtaining ownership information for business partners, although the company does not specifically commit to establishing ultimate beneficial ownership. There is evidence that the company has provisions in place to identify high risk business partners and to conduct enhanced due diligence on business partners located in high risk countries, which is understood to apply to joint ventures. Furthermore, there is evidence that the company conducts anti-bribery and corruption due diligence when entering into a joint venture and repeated at least every two years or when there is a significant change in the business relationship. <\/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 includes anti-bribery and corruption clauses in its joint venture contracts, with clear audit and termination rights. <\/p>\n"},{"question":102,"commitment_area":13,"score":"2","comments":"
There is evidence the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. There is evidence to support the company's commitment through examples of the controls it implements in its affiliate companies and the provision of training on anti-bribery and corruption to business partners.<\/p>\n"},{"question":103,"commitment_area":14,"score":"1","comments":"
There is evidence that the company has a policy and procedure in place to address the corruption risks associated with offset contracting. There is also evidence that those involved in offsets (\u201coffset facilitators\u201d) are required to adhere to the company\u2019s anti-bribery and corruption standards through appropriate contractual clauses. In addition, the company states that it provides tailored anti-bribery and corruption training to employees involved in offset arrangements. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that this individual, or another body, department or team, is responsible for monitoring the company\u2019s offset activities throughout the lifecycle of each project. The company states that the Compliance Officer is responsible for monitoring relationships with all business partners, but it is not clear whether this individual holds responsibility for all aspects of the company\u2019s offset activities or if another body, department or team is involved. <\/p>\n"},{"question":104,"commitment_area":14,"score":"2","comments":"
There is 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. There is evidence that this process specifically includes checks on the beneficial ownership of any offset brokers or beneficiaries, and any conflict of interest risks associated with the brokers or beneficiaries. As part of this process, the company's policy also commits to reviewing the legitimacy and rationale of its offset projects. Furthermore, the company states that its partners are monitored on an ongoing basis and that high risk partners are subject to due diligence every two years, which is understood to include offset obligations. There is also evidence that the company requests information on any material changes to any previously agreed offset obligations.<\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company\u2019s offset programme.<\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of its offset obligations and\/or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"2","comments":"
There is evidence that 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 company\u2019s publicly available evidence indicates that 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":"0","comments":"
The company publishes the corporate logos of its subsidiaries or affiliated entities and their relevant geographic region. However, the company receives a score of \u20180\u2019 because the company does not publish clear information about its subsidiaries and non-fully consolidated holdings, such as the percentage ownership, country of incorporation and countries of operation. There is also no indication that the list is current or updated on an annual basis. <\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
There is some evidence that the company is a state-owned enterprise owned by the government of Israel. However, the company receives a score of \u20181\u2019 because it does not provide publish clear information to indicate that the government of Israel is its sole beneficial owner.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes information on its defence sales. <\/p>\n"},{"question":111,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company publishes details of its shareholder voting rights. Although there is evidence to indicate that the company is government-owned, it is not clear from this statement that the government is the sole entity that holds shares or voting rights in the company.<\/p>\n"},{"question":112,"commitment_area":16,"score":"1","comments":"
There is evidence that the state-owned enterprise publishes some information about its objectives. However, the company receives a score of \u20181\u2019 as there is no evidence that they are updated on at least an annual basis.<\/p>\n"},{"question":113,"commitment_area":16,"score":"0","comments":"
There is no evidence that the state-owned enterprise makes information about its board members publicly available.<\/p>\n"},{"question":114,"commitment_area":16,"score":"0","comments":"
There is no publicly available evidence that the state-owned enterprise has an audit committee. <\/p>\n"},{"question":115,"commitment_area":16,"score":"1","comments":"
There is some evidence that the state-owned enterprise has a system in place to manage asset transactions, which must be documented.<\/p>\n
However, the company receives a score of \u20181\u2019 as there is no evidence that responsibility for managing asset transactions is held at board level. It is also unclear whether asset transactions are subject to scrutiny by an audit body. There is no evidence that the financial results from asset acquisitions are made publicly available in the company\u2019s reports. <\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/617","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=617"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=617"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}