The company has a publicly stated commitment to high ethical principles, which is reflected in statements from the chief executive and general counsel. <\/p>\n
However, the company receives a score of \u20181\u2019 because these statements do not specifically mention anti-bribery and corruption. <\/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. There is evidence that this policy applies to all employees and directors of the company, as well as the staff and leadership of subsidiaries and other controlled entities.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated board committee \u2013 the Safety, Ethics and Sustainability Committee \u2013 is responsible for oversight of the company\u2019s anti-bribery and corruption programme. According to publicly available documents, this includes reviewing reports from management on the programme\u2019s performance. Although the company does not explicitly mention that this committee reviews the results of internal and external audits of its anti-bribery and corruption programme, the company receives a score of \u20182\u2019 due to significant evidence that it reviews reports on the implementation and progress of ethics policies.<\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
There is evidence that a managerial-level individual \u2013 the Head of Ethics and Compliance \u2013 has been assigned ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. This individual has a clear reporting line to the board and there is further evidence of reporting and feedback activities between the Head of Ethics and Compliance and the board as part of the company\u2019s reporting structure.<\/p>\n
However, the company receives a score of \u20181\u2019 because the Head of Ethics and Compliance is not a senior executive. <\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
There is evidence that the company\u2019s risk management system incorporates compliance risk, which includes anti-bribery and corruption factors. Compliance risk assessments are reviewed by the Safety, Ethics and Sustainability Committee (a designated board committee), while the board has overall responsibility for risk management. The company indicates that it uses the risk assessment process to update its internal control framework. There is additional evidence indicating that the results of risk assessments are reviewed by the board on at least an annual basis. <\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
The company states clearly that its entire anti-bribery and corruption programme is subject to regular internal and external audits to ensure the programme is consistent with best practice and the business risks facing the company. This process explicitly includes provisions for continuous improvement. There is also evidence that high-level audit findings are presented to the board\u2019s Audit Committee, with ownership on implementing planned and required changes to the company\u2019s anti-bribery and corruption programme assigned to senior members of the ethics and compliance department or other management areas, as appropriate. <\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
There is evidence that the company commits to investigating incidents and that there is a specific procedure in place to deal with whistleblowing cases. This procedure covers the whole investigation process from receipt to outcome, and it is clear that information on each investigation is documented. Additionally, the company states that investigations are conducted by subject matter experts or independent managers, and commits to providing feedback to whistleblowers. The Safety, Ethics and Sustainability Committee regularly receives reports on issues raised through the company\u2019s whistleblowing line and reviews the results of investigations. <\/p>\n"},{"question":61,"commitment_area":8,"score":"2","comments":"
There is evidence that the company assures itself of the quality of both its internal and whistleblowing investigations. Whistleblowing reports are initially handled by an independent external party whose staff receive specialist training; reports are then passed to internal investigations teams, which are generally managed by subject matter experts or independent managers supported by human resources. The company also states that internal investigations are handled to the same standards as whistleblowing cases, and it utilises specialist in-house investigators or specialist investigators. The company\u2019s Safety, Ethics and Sustainability Committee reviews the company\u2019s procedures for investigations and recommends any changes to the board on an ongoing basis, at least annually. Additionally, the company has a process for handling complaints about the investigations process, which are escalated to either the company\u2019s Head of Ethics and Compliance, General Counsel or the Chairman of the Safety, Ethics and Sustainability Committee.<\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
There is evidence that the company\u2019s Safety, Ethics and Sustainability Committee refers reports on potential incidents and anti-bribery and corruption issues, raised through direct and whistleblowing channels, to the board. The company additionally states that its Head of Ethics and Compliance is responsible for evaluating investigation findings and disclosing criminal offences to relevant authorities if necessary.<\/p>\n"},{"question":63,"commitment_area":8,"score":"2","comments":"
The company publishes high-level data on ethical or bribery and corruption-related incidents and investigations involving company employees. There is evidence that this information is published on an annual basis and covers the number of reports received through internal channels and through the company\u2019s whistleblowing channel. The company additionally publishes data on the number of investigations launched and disciplinary actions taken related to breaches of the company\u2019s code of conduct. <\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides ethics and compliance training to all of its employees worldwide. The company states that, in 2018, this training focused on its Code of Conduct, which includes the company\u2019s anti-bribery and corruption policy as well as the whistleblowing options available to employees. There is evidence that employees receive mandatory training on an annual basis, and that this applies to all employees in all jurisdictions in which the company operates. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is evidence that the company requires employees in high risk positions to undertake dedicated training on anti-bribery and corruption, with refresher training every two years. <\/p>\n
However, there is no evidence that board members and middle managers receive anti-bribery and corruption training tailored to their roles.<\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
There is evidence that the company measures the efficacy of its anti-bribery and corruption communications and training programme and that the company also uses the results of such reviews to modify and update specific parts of its training and communications programme. The company publishes data on the number of personnel trained and completion rates, as well as the number of reports received through the company\u2019s whistleblowing line. There is evidence that this information is gathered on an annual basis and is reviewed by the internal audit department. <\/p>\n"},{"question":67,"commitment_area":9,"score":"2","comments":"
There is evidence that the company\u2019s incentive schemes for employees are designed to promote ethical behaviour and discourage corrupt practices. The company indicates that managers who fail to complete training on the company\u2019s Code of Conduct are subject to capped performance reviews. The remuneration policy for directors outlined in the company\u2019s Annual Report indicates that a breach of the Code of Conduct will result in a penalty and there is also evidence indicating that executive and manager remuneration is subject to ethical conduct appraisal. Additionally, the company states that it does not offer bonuses based on purely financial targets for sales roles.<\/p>\n"},{"question":68,"commitment_area":9,"score":"2","comments":"
The company publishes a clear commitment to support employees who refuse to act unethically even when doing so results in lost business. There is also further evidence that the company assures itself of employees\u2019 confidence in this commitment through monitoring of reporting data and employee interviews. <\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":"
The company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, which explicitly applies to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners. There is additional evidence that the company assures itself of employees\u2019 confidence in this commitment through monitoring of incident reporting data.<\/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 a relevant external body. 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 all relevant languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
The company formally addresses conflicts of interest as a corruption risk and has a clear policy and procedure which defines conflicts, including those actual, potential and perceived. The policy is outlined in the company\u2019s Code of Conduct, which applies to all employees and board members, including those of subsidiaries and other controlled entities. The company\u2019s policy documents make reference to conflicts of interest concerning employee and government relationships, financial interests and outside employment. <\/p>\n"},{"question":72,"commitment_area":10,"score":"2","comments":"
There is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. Employees are required to submit conflict of interest reports to the Ethics and Compliance team, which reviews the reports and oversees the process. The company has additional procedures in place for members of its board of directors, and states that disciplinary measures will apply if these policies are breached. The company additionally publishes a statement that all employee and board member declarations of actual and potential conflicts of interest are recorded in a dedicated register or central depository that is accessible to members of the company\u2019s Ethics and Compliance Team.<\/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 directors, employees or consultants from the public sector. The company states that recent government officials are not permitted to be involved in activities which may give the company an undue advantage. The company states that all new hires, including those from the public sector are required to submit a conflict of interest disclosure.<\/p>\n
However, the company receives a score of \u20181\u2019 because its policy does not describe specific controls to assess and regulate the employment of current or former public officials, such as requiring a 12-month cooling off period before employment discussions can begin or controls preventing new public sector recruits from representing the company to their former organisation. <\/p>\n"},{"question":74,"commitment_area":10,"score":"2","comments":"
The company publishes a statement that it does not contract serving politicians due to the risk of potential conflicts of interest. <\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
The company publishes a statement that it prohibits corporate political contributions, however, it indicates that it does have a Political Action Committee in the US. It therefore receives a score of \u20180\u2019. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
The company does not publish information about the recipients of the donations made by its PAC. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy and procedure covering both charitable donations and sponsorships. The company\u2019s definition of charitable contributions includes financial donations, as well as employee time and in-kind gifts, and it provides a list of legitimate reasons for making these types of contributions. There is clear evidence that the company\u2019s policy on charitable contributions and sponsorships includes specific controls to prevent bribery and corruption, such as Ethics and Compliance Officer approval, due diligence on beneficiaries and detailed record keeping. <\/p>\n
However, the company receives a score of \u20181\u2019 because \u2013 despite stating in its \u2018Our Group Policies\u2019 document that it reports this information on its website \u2013 there is no publicly available evidence that the company publishes details of its global contributions. <\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy and procedure on lobbying which applies company-wide to all employees, board members and third parties engaged in lobbying on the company\u2019s behalf. The company recognises lobbying as a corruption risk and defines lobbying broadly and states that anyone undertaking lobbying activities on behalf of the company must first undergo risk-based due diligence and also act with honesty, integrity and transparency. There is also evidence that all lobbying activities require prior authorisation and oversight from the Government Relations team. The company indicates that it only contracts one external party for lobbying services.<\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide any further guidelines on the behaviours that constitute \u2018responsible\u2019 lobbying, beyond compliance with local laws, regulations and the company\u2019s own policies. <\/p>\n"},{"question":79,"commitment_area":11,"score":"1","comments":"
The company publishes limited details of the topics on which it lobbies. <\/p>\n
However, the information disclosed lacks supporting details of the aims and significant topics or the activities that were carried out.<\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
The company does not publish any details about its global lobbying expenditure on its website. <\/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 not used as vehicles for bribery and corruption. 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 public officials by specifying different financial thresholds and approval procedures. 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 the Ethics and Compliance team. <\/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 specialist procurement teams in the establishment and oversight of its supplier base. There is also evidence that these teams are the main department involved in the establishment of all supplier relationships. There is additionally evidence that the company assures itself of proper procedures practiced by its procurement teams by way of an audit 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 its suppliers. The company states that the level of due diligence varies depending on the level of risk presented by the third party. In instances where red flags identified over the course of the due diligence process cannot be mitigated, the company states that it may terminate the relationship. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear whether these checks include establishing the ultimate beneficial ownership of the supplying company. There is also no evidence to indicate how frequently due diligence is undertaken and whether this is repeated at least every two years or whenever there is a change in the business relationship. <\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
There is evidence that the company requires all of its suppliers to abide by its Global Supplier Code of Conduct, which prohibits bribery and facilitation payments, and covers conflicts of interest, gifts and hospitality, and whistleblowing. Compliance with the Global Supplier Code of Conduct is a contractual requirement although companies may also adhere to their own Code of Conduct, provided it is aligned to the same principles. The company states that it includes audit and termination rights in its contracts with suppliers to ensure their compliance. <\/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 is communicated throughout the supply chain. The company makes a clear statement that sub-contractors should follow the principles set out in its Supplier Code of Conduct and recommends that suppliers establish supply chain management processes to integrate the requirements of this code.<\/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 policy covering the use of agents and third parties, which extends to agents engaged by its suppliers and other entities acting on behalf of the company. The company\u2019s policy stipulates various controls to mitigate the corruption risks presented by agents. These controls include: activity reporting procedures for agents, mandatory anti-corruption training, requirements for senior sign off, due diligence and ongoing monitoring of activities. The policy also commits to establishing that the use of agents is, in each case, necessary to perform a legitimate business function.<\/p>\n"},{"question":89,"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 engaging and re-engaging with all third parties. Due diligence on agents is repeated at least every three years. There is further evidence that all agents and highest risk intermediaries are subject to enhanced due diligence, which is repeated every one or two years. There is also evidence that the company will not engage, or will terminate an agent agreement if a risk identified in the due diligence process cannot be mitigated. <\/p>\n
However, the company states that high risk third parties are subject to due diligence every three years and not at least every two years and\/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 independently verifies this information, as part of its due diligence processes. It does so at least every three years, but for higher risk agents every one or two years. The company states that higher risk third parties are contractually required to inform the company of any beneficial ownership changes. There is also evidence that the company will review and potentially terminate an agent relationship if ultimate beneficial ownership cannot be established or if the ownership structure is seen to present too great a corruption risk. <\/p>\n
However, there is no evidence that the company verifies beneficial ownership information for all agents at least every two years and\/or when there is a significant change in the business relationship. <\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
The company states that all agents and third parties must adhere to standards equivalent to standards equivalent to the company\u2019s Anti-Corruption Policy. According to publicly available evidence, 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":"
The company addresses and highlights incentive structures for agents, namely commissions payments, as a factor in bribery and corruption risk. The company states that in some cases it will impose restrictions on agents\u2019 payments and incentive structures, including a threshold on commissions. The company states that its Ethics and Compliance Team must approve all payments to agents. The company states that it will only pay agents into local bank accounts, unless there are exceptional mitigating circumstances, in which it requires approval from the Ethics and Compliance Team.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company imposes a threshold on the payment of sales commissions in all agent agreements, and there is no evidence the company requires that remuneration to agents is paid in stage payments. <\/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 prior to entering all joint venture partnerships. Evidence indicates that the due diligence process includes checks on the ultimate beneficial ownership of the partner company, and that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is unclear how frequently due diligence is repeated and whether this is at least every two years.<\/p>\n"},{"question":101,"commitment_area":13,"score":"2","comments":"
There is evidence that the company\u2019s Code of Conduct includes anti-bribery and corruption provisions as well as a prohibition on facilitation payments, and applies to its controlled joint ventures. The company also states that it will work with other joint venture partners to adopt the same requirements. The company states that it will only enter into joint ventures if anti-bribery and corruption clauses are included in the contract, which include clear audit and termination rights to detect, control and prevent breaches.<\/p>\n"},{"question":102,"commitment_area":13,"score":"2","comments":"
The company explicitly 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, by way of specialist training and ethics and compliance resources and guidance that the company provides for employees of joint ventures, as well as submitting the joint venture\u2019s anti-corruption procedures to a regular audit and review process. <\/p>\n"},{"question":103,"commitment_area":14,"score":"1","comments":"
There is evidence that the company recognises corruption risks associated with offset contracting, and the company also has a dedicated department, the Corporate Offset Group, which oversees all the company\u2019s offset obligations. There is evidence that this department is involved, at least partially, in the establishment and oversight of all the company\u2019s offset obligations throughout the project lifecycle. The company states that this department works alongside the company\u2019s Ethics and Compliance Team to scope and mitigate corruption risks.<\/p>\n
However, there is no evidence that all employees within the Corporate Offset Group receive tailored anti-bribery and corruption training based on the potential corruption risks associated with offsets.<\/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. There is evidence indicating that due diligence on all offset obligations includes checks on beneficial ownership. The company states that for all offset obligations it conducts assurance of the legitimacy of the investment. The company states that it continuously monitors offset projects for signs of risk, business misconduct and corruption and that due diligence is repeated when there is a significant change in the business relationship or nature of the partner. Due diligence is otherwise repeated every three to five years, depending on the risk profile of the project. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its due diligence procedures include a review of potential conflicts of interest associated with brokers or beneficiaries. <\/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. <\/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. The company provides examples of such possible controls.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes a list of its subsidiaries in its Annual Report, which includes the percentage ownership of each entity. This list covers fully consolidated and non-fully consolidated holdings, including any associates, joint ventures and other related entities. The list includes information on the registered addresses of each entity. <\/p>\n
However, the company does not list the subsidiaries\u2019 countries of operation. Supporting information on the company\u2019s website provides information on the country of operation for only some of the entities listed in the annual report. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is publicly-listed on the London Stock Exchange and therefore automatically receives a score of \u20182\u2019.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There company does not publish information regarding its main defence sales by customer. Although the company disaggregates its defence sales from other business segments, it does not provide any information on its customers. <\/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\/622","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=622"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=622"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}