There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. 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":"
There is evidence that the company publishes an anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. The policy applies to anyone acting on behalf of the company, which is interpreted to include employees of subsidiary companies as well as board members and non-executive directors. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated board committee, the Audit Committee of the Supervisory Board, is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. There is evidence indicating that this includes reviewing reports from management on the programme\u2019s performance, along with the results of audits, and has the authority to ensure that required changes are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior executive, the Chief Compliance Officer, 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 board. There is evidence of reporting and feedback activities between this person and the board as part of the company\u2019s reporting structure.<\/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-corruption and bribery programme. There is evidence indicating that the Chief Compliance Officer presents the results of risk assessments to the Supervisory Board\u2019s Audit Committee and executive board as part of reporting on the company\u2019s compliance risk management system. There is also evidence indicating that the results of such reviews are used to develop tailored mitigation plans and to update specific parts of the company's compliance 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. There is evidence this includes provisions for continuous improvement, supplemented by internal and external audits. There is also evidence that high-level audit findings are presented to the board, with ownership assigned to the internal audit department to monitor improvements to the anti-bribery and corruption programme. There is evidence that these audits are conducted four to five times a year. <\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
There is evidence that the company publicly commits to investigating incidents, and there is a specific procedure in place to deal with whistleblowing cases, which stipulates documentation and actions to be taken at each step, from receipt to final outcome. This includes a commitment to notifying whistleblowers on the outcome of the investigation. There is evidence indicating that investigations are conducted by the company\u2019s compliance team and overseen by the company\u2019s independent Ombudsman. There is evidence that information on each investigation is documented and reviewed on an ongoing basis by the company\u2019s compliance organisation.<\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
There is evidence that the company assures itself of the quality of its internal investigations, including those reported through whistleblowing channels. Any complaints about the handling of concerns and investigations are overseen by an appropriate senior management officer and a procedure is in place to handle the escalation of complaints. There is some indication that the company reviews its procedure in response to any changes in the regulatory environment. <\/p>\n
However, there is no evidence that the company mentions specific training for the staff conducting investigations. There is also no evidence that the company reviews its investigations procedure at least every three years. <\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
There is evidence that the company reports material findings of bribery and corruption from investigations to the board. The company states that it will cooperate with the relevant authorities to resolve matters if necessary. <\/p>\n
However, there is no clear 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 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 a training module that outlines the basic principles of its anti-bribery and corruption policy, including the whistleblowing options available to employees. There is evidence that the company provides this training to all employees across its divisions and countries of operation, and that employees are required to take annual refresher courses. There is evidence that the training is provided in all appropriate languages. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is some evidence that employees in certain positions receive tailored anti-bribery and corruption training on an annual basis. The company refers to risk-specific training for management and employees involved in sales or purchasing. <\/p>\n
However, the company does not refer specifically to tailored training for board members. <\/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 appear to be limited to tracking the number of personnel trained. There is no evidence the 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":"0","comments":"
There is no clear 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, 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 has a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents that explicitly applies to all employees across the organisation. There is also evidence that the company\u2019s whistleblowing line is open to external business partners.<\/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 anti-bribery and corruption programme. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an independent Ombudsman. These channels allow for confidential and, wherever possible, anonymous reporting. They are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners, and in multiple relevant languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence that the company has a policy that defines conflicts of interest, including actual and potential conflicts. The policy covers employee relationships, financial interests, government relationships, and other employment. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is some evidence that the company has procedures to identify, declare and manage conflicts of interest. There is evidence that the Compliance Organisation is responsible for handling cases and that disciplinary measures will apply for breaches of the company\u2019s policy.<\/p>\n
However, 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 mentions examples of criteria for recusal. <\/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. <\/p>\n
However, the controls that the policy has to assess and regulate the employment of current or former public officials are too vague.<\/p>\n"},{"question":74,"commitment_area":10,"score":"1","comments":"
The company states that it does not contract serving politicians, however, it does provide evidence which suggests that an active politician serves on its supervisory board. <\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
There is evidence that the company permits political contributions, and therefore receives a score of \u20180\u2019. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company discloses details of its political contributions.<\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is some evidence that the company has a policy covering both charitable donations and sponsorships.<\/p>\n
However, the company does not publish sufficient detail of the donations to receive a score of \u20182\u2019.<\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy on lobbying. <\/p>\n
However, the company sores \u20181\u2019 as there is no evidence that it defines lobbying or the practices comprising responsible lobbying. The company mentions that consultants and lobbyists are subject to high compliance standards, however, there is no evidence that the company publishes specific details of these standards or controls, or information about oversight mechanisms that apply to all types of lobbyists. <\/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 provides any details about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is some evidence that the company has a policy on the giving and receipt of gifts and hospitality to ensure they are not used for bribery. This policy refers to the risks associated with gifts and hospitality given to public officials. The policy also specifies financial or proportional limits or different approval procedures for different types of promotional expenses. <\/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":"1","comments":"
There is evidence that the company's procurement department is involved in the establishment and oversight of supplier relationships. There is evidence that the procurement department is the main body responsible for oversight of the company\u2019s supplier base. <\/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 due diligence on all new suppliers. There is evidence that the company might be willing to review or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated. There is evidence that due diligence includes checks on ultimate beneficial ownership and that higher risk suppliers are subject to enhanced due diligence. <\/p>\n
However, it is unclear how frequently due diligence is repeated on existing suppliers. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company takes active steps to ensure this by requiring that all suppliers follow its Supplier Code of Conduct, which prohibits corruption, and refers to policies to address conflicts of interest and gifts and hospitality. There is evidence that the company assures itself of its suppliers\u2019 adherence to this through ongoing monitoring throughout the lifecycle of the relationship. <\/p>\n
However, there is no evidence that the company requires all suppliers to have in place policies that prohibit facilitation payments as well as procedures covering whistleblowing.<\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
There is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place and that the substance of its anti-corruption and bribery programme and standards are included in subcontracts throughout the supply chain. This evidence is in the form of a clear statement, short description or set of supplier principles that sets the minimum standards of ethical behaviour expected 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 some evidence the company has a policy on the use of agents as part of its business partner management programme and addresses the corruption risks associated with the use of agents. The company\u2019s controls include due diligence on agents. There is 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. The policy applies company-wide, to all subsidiaries and joint ventures. <\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
There is evidence that the company conducts anti-bribery and corruption due diligence prior to engaging with its third parties and agents. There is evidence that highest risk intermediaries are subject to enhanced due diligence. <\/p>\n
However, there is no evidence that due diligence is conducted at least every two years or when there is a significant change in the business relationship. <\/p>\n"},{"question":90,"commitment_area":13,"score":"1","comments":"
There is evidence that the company asks agents to disclose their beneficial ownership to the company, and it verifies this information, as part of its due diligence processes. <\/p>\n
However, there is no evidence that it commits to independently verify beneficial ownership information of high risk agents, and it does not verify the information both before onboarding and over the course of the business relationship. The company does not commit to reviewing or potentially terminating its engagement with agents or intermediaries if 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. 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 some evidence that the company recognises renumeration structures for agents as a factor in bribery and corruption risk. <\/p>\n
However, there is no evidence that it imposes a threshold on the payment of sales commissions to agents, and there is no evidence of a requirement that remuneration is paid in stage payments or into local bank accounts.<\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any details of the agents currently contracted to act for 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 prior to entering and while operating in a joint venture. There is evidence to suggest that higher-risk joint ventures are subject to enhanced due diligence. <\/p>\n
However, it is not clear whether the due diligence process includes checks on beneficial ownership or whether due diligence is repeated at least every two years.<\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies in all of its joint ventures. <\/p>\n
However, it is unclear how the company ensures this in practice. <\/p>\n"},{"question":102,"commitment_area":13,"score":"2","comments":"
There is evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. There is clear evidence to support the company's commitment, through practical examples and a statement of possible controls that it may implement.<\/p>\n"},{"question":103,"commitment_area":14,"score":"1","comments":"
There is evidence that the company recognises corruption risks associated with offset contracting. The company has a dedicated body, department or team involved in managing offset obligations. There is evidence that this team is responsible for monitoring 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. Additionally, there is little evidence of policies and processes to address the corruption risks associated with offset contracting. <\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
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, and that it assures itself of the legitimacy of the investment. <\/p>\n
However, the process does not specifically mention checks on beneficial ownership and conflict of interest and there is no evidence that the company refreshes this due diligence continuously or at least when there is a significant change in the business relationship or nature of the partner. <\/p>\n"},{"question":105,"commitment_area":14,"score":"N\/A","comments":"
The company indicates that in 2019 it contracted no offset brokers or agents. <\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
The company does not publish any details about the beneficiaries of its indirect offset projects. <\/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 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":"
There is evidence that the company publishes a list of its fully consolidated subsidiaries and non-fully consolidated holdings. For each entity, the company discloses its percentage ownership. There is evidence that this list is current and updated on at least an annual basis. The list is accompanied by a statement that it is complete at the time of publication to the best of the company\u2019s knowledge.<\/p>\n
However, it is unclear whether the locations listed are the countries of incorporation or operation or both. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is publicly listed on the Berlin Stock Exchange and therefore receives a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
While the company publishes a breakdown of its defence sales by region, there is no evidence that the company publishes a breakdown of its defence sales by customer. The company indicates that its sales in the German market account for 40.6% of its sales, but this does not meet the minimum threshold of the 50% required to receive a score of \u20181\u2019. <\/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\/619","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=619"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=619"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}