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":"
The company publishes a clear anti-bribery and corruption policy, which specifically prohibits 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) 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 \u2013 the Public Policy and Corporate Responsibility Committee \u2013 is responsible for oversight of the company's anti-bribery and corruption programme. There is evidence that the Committee\u2019s oversight function includes reviewing reports from management on the programme\u2019s performance and the results of internal audits, and there is evidence that the committee has the authority to require that changes are made. <\/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 company\u2019s Chief Ethics and Compliance Officer \u2013 has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the Public Policy and Corporate Responsibility Committee, which oversees the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between the Chief Ethics and Compliance Officer and this committee. <\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a formal bribery and corruption risk assessment procedure that informs the design of its anti-bribery and corruption programme. The company indicates that the board reviews the results of risk assessments on an annual basis. There is evidence that these results 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":"
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. This includes provisions for continuous improvement, supplemented by an internal audit every year. There is also evidence that the board reviews high-level audit findings. The company indicates that its Internal Audit department is responsible for implementing updates and improvements to the risk management procedures and, by extension, 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 and takes steps to ensure the independence of its investigations. It commits to establishing root causes, putting in place remediation plans and reporting investigative findings to senior management and the board. For whistleblowing cases, there is a procedure in place that stipulates documentation and actions to be taken at every step of the case, from receipt to final outcome. The company indicates that at the conclusion of investigations it provides feedback to the individual who submitted the report. There is also evidence that the Public Policy and Corporate Responsibility Committee receives summary information on investigations on at least an annual basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company assures itself of the quality of its internal investigations, including those reported through whistleblowing channels. There is evidence indicating that the staff conducting investigations are properly qualified and the company reviews its investigation process on a biannual basis. The company indicates that it conducts regular anti-corruption self-assessments to assure itself of the proper functioning of its systems, and there is some indication that complaints about the investigation process may be submitted through the company\u2019s multiple reporting channels. <\/p>\n"},{"question":62,"commitment_area":8,"score":"2","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 Policy & Corporate Responsibility Committee of the Board of Directors. The company\u2019s Anti-Corruption & International Agreements, Ethics and Litigation and Global Security Services departments are responsible for ensuring the disclosure of criminal offences to relevant authorities. <\/p>\n"},{"question":63,"commitment_area":8,"score":"2","comments":"
The company publishes high-level data from ethics-related incidents and investigations involving company employees at all levels. This includes the number of reports received, including the number received through whistleblowing channels, the number of investigations launched, and the number of disciplinary actions as a result of investigation findings. There is evidence that this data covers the most recently reported financial year.<\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides training to all employees through its ethics and compliance education and training programme. This outlines the principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees. The company indicates that employees are required to undertake annual refresher modules on the anti-bribery and corruption programme. There is also evidence that the training is provided to all employees, across all divisions and countries of operation, and in all appropriate languages.<\/p>\n"},{"question":65,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the that the company provides tailored anti-bribery and corruption training to employees in different roles based on their exposure to corruption risk, with reference to the three categories of employee referred to in (a), (b) and (c) in the question. There is evidence that employees in high risk positions are required to undertake and refresh their training on at least an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company measures and reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme on at least an annual basis. The company does this through dedicated questions in annual staff surveys. There is evidence that the results of such reviews 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":"
Based on publicly available information, there is some evidence that the company incorporates accountability principles and adherence to the company\u2019s values in its employee performance reviews. The company indicates that only those who meet these expectations are eligible for performance-based compensation. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further information on how such assessments impact the company\u2019s bonus or reward schemes. There is also no clear evidence to indicate that, where financial rewards are part of incentive schemes, there are procedures in place to ensure that they are proportionate to the base salary in the case of high risk employees. <\/p>\n"},{"question":68,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. This policy explicitly applies to all employees across the organisation, including those engaged by the group as third parties and business partners. There is evidence that the company commits to assure itself of its employees\u2019 confidence in this commitment through employee surveys and monitoring the number of reports to the company\u2019s ethics department.<\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":""},{"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 anti-bribery and corruption programme. Channels are sufficiently varied to allow employees to raise concerns across the management chain, as well as through an external channel operated by an independent third party. These channels allow for confidential and, wherever possible, anonymous reporting. <\/p>\n
In addition, there is evidence to indicate that these channels are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, and in all relevant languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy that defines conflicts of interest, including actual, potential and perceived conflicts. The company\u2019s policy explicitly covers conflicts of interest concerning employee relationships, financial interests and external employment, as well as government relationships. In addition, there is evidence that its conflict of interest policy applies to all employees and board members, as well as to all employees of subsidiaries and other controlled entities.<\/p>\n"},{"question":72,"commitment_area":10,"score":"2","comments":"
Based on publicly available information, there is evidence the company has procedures to identify, declare and manage conflicts of interest. The company states that all employee and board member declarations of actual and potential conflicts of interest are recorded in a dedicated tool that is accessible to those responsible for oversight of the process. <\/p>\n
There is evidence that potential or actual conflict of interest declarations are reviewed and overseen by a designated body, namely the company\u2019s Ethics and Business Conduct Office, which holds ultimate accountability for its implementation and the handling of individual cases. The company\u2019s description of conflicts of interest procedures also includes termination as a potential punitive measure for breach of the policy.<\/p>\n"},{"question":73,"commitment_area":10,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy which outlines controls to assess and regulate employment, offers of employment and consultancy engagement with current and recently departed public officials. The company requires approval from the office of the General Counsel or Ethics Office prior to the initiation of any employment discussions with former or current public officials, as well as requiring a review of actual, potential or perceived conflicts of interest. There is also evidence that the company\u2019s policy includes placing restrictions on their activities if such conflicts of interest are identified, which is understood to include restrictions on job functions as well as implementing a potential cooling off period. <\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
Based on publicly available information, 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":"
Based on publicly available information, there is evidence that the company has a policy on political contributions. The company states that it has not made direct corporate political donations since 2015 and does not intend to do so in the future. <\/p>\n
However, the company scores \u20180\u2019 because there is evidence that contributions may be permissible in certain circumstances with appropriate authorisation. There is also evidence that the company is associated with a Political Action Committee (PAC) in the United States.<\/p>\n"},{"question":76,"commitment_area":11,"score":"2","comments":"
The company states publicly that it has not made any corporate political contributions since 2015. In addition, there is evidence that the company publishes details of the contributions and disbursements made through its Political Action Committee (PAC) in the United States, by providing this information on its website. There is evidence that this information includes details of the recipient, amount and state of the recipient and that it is updated and released on a regular basis.<\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has policies covering both charitable donations and sponsorships to ensure that they are not used for corrupt purposes. There is evidence that the company\u2019s policies include measures to ensure proper oversight.<\/p>\n
The company discloses some details of both its charitable contributions and sponsorship activities but receives a score of \u20181\u2019 because it does not publish comprehensive details of these donations, including data on the amount donated, the recipient entity and the corporate entity which made the donation.<\/p>\n"},{"question":78,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy on responsible lobbying which applies to all employees, board members and any third parties engaged in lobbying activities on the company\u2019s behalf. The company indicates that its Public Policy and Corporate Responsibility Committee is responsible for reviewing and providing oversight of all lobbying activities. There is evidence that the company conducts due diligence on lobbyists, which are required to act in accordance with its Code of Conduct.<\/p>\n"},{"question":79,"commitment_area":11,"score":"1","comments":"
There is evidence that the company discloses some details about its lobbying activities, by providing a direct link to its quarterly Federal Lobbying Reports. These reports indicate the legislative topics on which the company conducts lobbying in the United States. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide details about its broader public policy aims or positions. The company also does not publish any information about its lobbying activities outside of the United States. <\/p>\n"},{"question":80,"commitment_area":11,"score":"1","comments":"
There is evidence that the company publishes some details of its lobbying expenditure, by providing direct links on its website to its Federal Lobbying Reports up to the most recently reported financial year. This expenditure data is broken down by corporate entity, geography, and internal, external and association lobbying. <\/p>\n
However, the company receives a score of \u20181\u2019 because the data provided only accounts for company\u2019s lobbying activities in the United States and therefore it is not clear that this covers all of the company\u2019s lobbying activities in all applicable jurisdictions. <\/p>\n"},{"question":81,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has policies and procedures on gifts and hospitality, which include clear procedures designed to ensure that promotional expenses are bona fide and not used for bribery. The company\u2019s policies establish financial limits and approval procedures for the different types of promotional expense that employees may encounter. <\/p>\n
In addition, there is evidence that the company\u2019s policies address the risks associated with gifts and hospitality given to and\/or received from domestic and foreign public officials by establishing different financial thresholds. The company indicates that all gifts and hospitality above certain thresholds are recorded in a dedicated central register that is accessible to those responsible for oversight of the process. <\/p>\n"},{"question":82,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence that the company requires the involvement of its procurement department in the establishment of new supplier relationships and that this department is responsible for providing oversight of the company's supplier base. There is evidence indicating that the company assures itself that proper procedures regarding the onboarding of suppliers are followed on at least an annual basis.<\/p>\n"},{"question":83,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence the company has formal procedures to conduct risk-based due diligence when engaging and re-engaging with any suppliers. The due diligence process includes establishing the ultimate beneficial ownership of the supplying company with the highest risk suppliers subject to enhanced due diligence. The company indicates that this process is conducted at least every two years or as a result of changes in the business relationship such as contract modifications. There is evidence that the company's due diligence procedure is accompanied by a clear statement that the company will terminate or not proceed with a supplier relationship if a red flag identified in due diligence cannot be mitigated.<\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, 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 adhere to, or maintain its own policies equivalent to, its Code of Conduct. There is evidence that this document prohibits domestic and foreign bribery, corrupt activity and contains procedures to manage conflicts of interest, gifts and hospitality, and whistleblowing and reporting procedures. <\/p>\n
In addition, there is evidence that the company requires its suppliers to comply with the Code of Conduct as part of the contractual agreement. There is some evidence that the company conducts assurance when onboarding new suppliers and on an ongoing basis.<\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, 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. There is evidence that the company includes a provision in its terms and conditions that none of the supplier\u2019s subcontractors are permitted to violate any of the anti-corruption regulations, laws or policies referenced in the supplier terms and conditions. <\/p>\n"},{"question":86,"commitment_area":12,"score":"1","comments":"
There is evidence that the company publishes high-level data from ethical incidents and investigations, and that this includes reports from and about suppliers and contractors. The data includes the number of allegations made and the number of disciplinary actions as a result of investigation findings. This data is published at regular intervals, on at least an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because the data is not disaggregated to show supplier data as separate from other types of individuals, such as company employees.<\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
There is publicly available evidence that the company has a policy to control the use of agents, which addresses the associated corruption risks 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, based on a legitimate business need. The company states that this policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures where the company has a controlling interest. <\/p>\n"},{"question":89,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence 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, or when there is a significant change in the business relationship. There is evidence that agents and high-risk third parties and contractors are subject to enhanced due diligence. <\/p>\n
In addition, the company indicates that it will not employ agents in cases where due diligence cannot rule out a foreign-government ownership interest, which indicates \u2013 though indirectly \u2013 that it commits to potentially terminating engagement with third parties where a red flag cannot be mitigated. <\/p>\n"},{"question":90,"commitment_area":13,"score":"2","comments":"
The company states that it has formal procedures to establish the beneficial ownership of agents prior to engaging them, and at least every two years and\/or when there is a significant change in the business relationship. There is evidence that the company\u2019s due diligence involves checks on foreign government ownership interests of third parties, which is assumed to also apply to beneficial ownership in general. In addition, there is evidence that the company undertakes to independently verify this beneficial ownership information. There is some indication that 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":"
Based on publicly available information, there is evidence the company\u2019s Anti-Corruption Policy and Code of Conduct apply 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, which include audit and termination rights.<\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
There is some publicly available evidence that the company addresses incentive structures for agents as a factor in bribery and corruption risk. There is evidence that there are oversight processes to ensure that incentive structures are reasonable and commensurate with the services rendered.<\/p>\n
The company, however, receives a score of \u20181\u2019 because there is no clear evidence that it imposes a threshold on the payment of sales commissions to agents. There is also no clear requirement that remuneration is paid in stages 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 behalf of the company.<\/p>\n"},{"question":99,"commitment_area":13,"score":"1","comments":"
There is evidence that the company publishes high-level data from ethical incidents and investigations, and that this includes reports from and about third parties. The data includes the number of allegations made and the number of disciplinary actions as a result of investigation findings. This data is published at regular intervals, on at least an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because the data is not disaggregated to show third party data as separate from other types of individuals, such as company employees.<\/p>\n"},{"question":100,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on its joint ventures. For foreign joint ventures, this includes conducting anti-bribery and corruption due diligence on both the entity and its activities prior to entering into a partnership, and then every two years and\/or when there is a significant change in the business relationship. There is also some indication that this due diligence process also applies to domestic joint venture partners (i.e. all prospective partners). <\/p>\n
In addition, the company states that this process includes establishing ultimate beneficial ownership. There is evidence that the company conducts enhanced due diligence for high-risk joint ventures. <\/p>\n"},{"question":101,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s Anti-Corruption Policy applies to joint venture partners. The company also states that it includes anti-corruption clauses in its contracts with all business partners, which include audit and termination rights.<\/p>\n"},{"question":102,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company commits to take an active role in preventing bribery and corruption in all its joint ventures. There is evidence to support the company's commitment. The company states that it conducts regular activity reporting, deposit and expenditure reviews, site visits, quality control checks, and exercises its audit rights where appropriate.<\/p>\n"},{"question":103,"commitment_area":14,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy and procedure in place to address the corruption risks associated with offset contracting and ensures any offset partners adhere to its anti-bribery and corruption standards through appropriate contractual clauses. There is evidence that the company has a dedicated department responsible for the monitoring and oversight of its offset activities throughout the lifecycle of each project. The company indicates that all employees within this department receive anti-bribery and corruption training.<\/p>\n"},{"question":104,"commitment_area":14,"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 on its offset obligations. The company indicates that it refreshes this due diligence once every two years, or whenever there is a significant change in the business relationship or nature of the offset partner. There is evidence that due diligence includes checks on beneficial ownership and conflicts of interest. As part of the process, the company also commits to assure itself of the legitimacy of the investment.<\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of the offset agents or brokers contracted to act for or on behalf of its offset programme. <\/p>\n"},{"question":106,"commitment_area":14,"score":"1","comments":"
The company publishes some information about the total size of its offset investment obligations, as well as some information concerning its indirect offset beneficiaries. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes data to cover all of its indirect offset obligations and\/or contracts on a regular basis, such as the name of the company or organisation receiving the investment and the country in which the recipient entity is based.<\/p>\n"},{"question":107,"commitment_area":15,"score":"2","comments":"
Based on publicly available information, there is evidence that the company acknowledges the corruption risks associated with operating in different markets, and that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. The company indicates that the results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls, and the company provides examples of such controls. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes some information about its significant subsidiaries as part of its annual regulatory filings in the United States. This information includes the name and country of incorporation of the subsidiary. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is evidence to indicate that the company has other international subsidiaries not included on this list, which indicates that this does not represent a full list of all the company\u2019s holdings. There is also no evidence that the company discloses the country of operation nor its percentage ownership for each entity. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence to indicate that the company is publicly traded on the New York Stock Exchange and it is therefore not required to disclose beneficial ownership further, so the company receives a score of \u20182\u2019. There is also evidence that the company discloses details of its shareholders with a stake of 5 percent or more on its public website. <\/p>\n"},{"question":110,"commitment_area":15,"score":"2","comments":"
Based on publicly available information, there is evidence that the company publishes details about its defence sales by customer. In its Annual Report, the company discloses that the United States government accounts for 69 percent of its sales in the most recently reported financial year; while an additional 13 percent of sales were made through the United States government to foreign militaries. The company indicates that the U.S. Department of Defence is its principal customer, noting that it also sells to U.S. intelligence agencies, the Department of Homeland Security, the Federal Aviation Authority and the National Aeronautics and Space Administration (NASA). The company also discloses that defence sales to Saudi Arabia constitute approximately five percent of its 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\/618","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=618"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=618"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}