There is evidence that the company has a publicly stated anti-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 specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. The company states that the policy applies to all employees and directors, and there is further evidence that it also applies to all employees and the leadership of the company\u2019s wider corporate group. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a designated board committee \u2013 the Audit Committee \u2013 that is ultimately responsible for the oversight of the company's ethics programme. This includes reviewing reports from management on the programme\u2019s performance, along with the results of audits and ensuring that required 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 General Counsel \u2013 has ultimate responsibility for implementing and managing the company's ethics programme. It is clear that this person has a direct reporting line to the board committee that provides oversight of the ethics programme. 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-bribery and corruption programme. The results of risk assessments are reviewed by the board on at least an annual basis. There is evidence that the results of such reviews are used to develop mitigation plans.<\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
There is some evidence that the company\u2019s anti-bribery and corruption programme is subject to internal audit and that findings are presented to the Audit Committee and the board. The company indicates that the Audit Committee is responsible for evaluating the company\u2019s anti-corruption and that it tasks internal auditors to evaluate and update specific areas of the programme on an annual basis. There is also evidence that the company conducts regular audits on a per-country basis, with evidence suggesting that it conducts approximately three per year. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not specify that its entire programme is audited to ensure that it is consistent with high standards of best practice and the business risks facing the company. <\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
There is evidence that the company has a system for tracking, investigating and responding to bribery and corruption allegations or incidents, including those reported through whistleblowing channels. There is evidence that the company takes steps to ensure the independence of its investigations, conducts a root cause analysis and reports investigative findings to 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, and the company commits to informing whistleblowers of the outcome, if they so wish. The Ethics and Compliance Board and the Board of Director\u2019s Audit Committee receive statistics and information on investigation results on at least a quarterly basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
There is evidence that the company assures itself of the quality of both its internal investigations and whistleblowing procedures. The company indicates that investigations are undertaken by the company\u2019s most senior compliance officers, and it is therefore assumed that they are properly qualified and trained to undertake the investigations. There is also some evidence that the investigation team is overseen by the Ethics and Compliance Board. <\/p>\n
However, the company makes no mention of how complaints about the investigation process might be handled or whether they are appropriately escalated. There is also no evidence that the company reviews its investigations procedure at least every three years or in response to any changes in the regulatory environment. <\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
There is evidence that he company commits to report material findings of bribery and corruption from internal investigations to the Audit Committee, the designated board committee responsible for anti-corruption, and the Ethics and Compliance Board, a managerial-level committee. Although the company does not explicitly make reference to a senior individual responsible for ensuring the disclosure of criminal offences to relevant authorities, there is sufficient evidence to indicate that the head of the Ethics and Compliance Board \u2013 the Saab General Counsel \u2013 is responsible for this process. <\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence to indicate that the company publishes data on ethical or bribery and corruption investigations or disciplinary actions involving its employees. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides anti-bribery and corruption training that outlines the basic principles of the Code of Conduct, which includes the whistleblowing options available to employees. There is evidence that the training is provided to all employees across all divisions and all countries of operation. The Board of Directors and the Group Management of Saab receive anti-bribery training every three years.<\/p>\n
However, it is unclear how frequently training is conducted for employees. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is evidence that employees in certain positions receive tailored anti-corruption training, namely employees in high risk positions, middle management and board members. <\/p>\n
However, there is no evidence that training for employees in high risk positions or middle managers is refreshed on at least an annual basis. <\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence to indicate that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
The company\u2019s approach to incentives is not sufficiently clear to receive a score of \u20181\u2019 and the company also makes no mention of ethics or integrity in relation to its incentive schemes. <\/p>\n"},{"question":68,"commitment_area":9,"score":"1","comments":"
The company clearly states that any employee who refuses to act unethically, in keeping with the company\u2019s anti-corruption commitments, will be protected and supported, even where such actions result in a loss of business. <\/p>\n
However, there is no evidence that the company assures itself of its employees\u2019 confidence in this statement through anonymised surveys or other clearly stated means. <\/p>\n"},{"question":69,"commitment_area":9,"score":"0","comments":"
The company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. The company states that this policy applies to all employees without exception. However, it is not clear whether the hotline is available to those employed by the group as third parties, suppliers and joint venture partners, and the company therefore receives a score of \u20180\u2019. There is also no evidence that the company assures itself of its employees\u2019 confidence in this commitment through surveys, usage data, or other clearly stated means.mmitment through surveys, usage data, or other clearly stated means.<\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has multiple whistleblowing and advice channels. The channels \u2013 which the company states can be used for both whistleblowing and to seek advice \u2013 allow for confidential and, wherever possible, anonymous reporting. The company also offers an externally-operated channel and these options are available to all employees in any country of operation and in multiple languages. The company indicates that the whistleblowing channels are accessible across the entire group. <\/p>\n
However, there is no publicly available evidence that the channels are available to employees of third parties, suppliers or joint venture partners. Additionally, it is not clear how employees can access the hotline. <\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence that the company formally addresses conflicts of interest as a corruption risk and has a clear policy that defines conflicts of interest, including actual and potential conflicts. The policy covers employee relationships, government relationships, financial interests and other employment. There is evidence that the policy applies to all employees and board members, including those of subsidiaries and other controlled entities.<\/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, including actual and perceived conflicts. <\/p>\n
However, there is no publicly available evidence that all employee and board member declarations are held in a dedicated register or central depository and there is no reference to a specific body or individual with oversight and accountability for handling cases. There is no publicly available evidence that the company provides examples of criteria for recusals nor that disciplinary measures will apply if the company\u2019s procedures are breached. <\/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. <\/p>\n
However, the company does not describe any 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, undertaking a conflict of interest review and imposing restrictions on activities if risks are identified, or stipulating a cooling-off period of 12 months.<\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence to indicate 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 does not make any contributions to political parties or activities. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":""},{"question":77,"commitment_area":11,"score":"1","comments":"
There is some evidence that the company has a policy and procedure covering both charitable donations and sponsorships. The company\u2019s policy provides details of procedures to prevent the risk of bribery and corruption, such as senior sign-off requirements and reporting obligations. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not publish sufficient detail of the donations made, including details of the recipient, amount, country of recipient and which corporate entity made the payment.<\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy on lobbying, which includes a definition of lobbying. The policy mentions specific oversight mechanisms that apply to all types of lobbyists and there is evidence that this applies company-wide. The company indicates that it includes anti-bribery and compliance clauses in its contracts with lobbyists. <\/p>\n
However, there is no evidence that the company has further guidelines that inform responsible lobbying behaviour or expected standards of conduct. Additionally, it is not clear that the lobbying policy applies to employees conducting lobbying activities on the company\u2019s behalf. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any detailed information on its lobbying aims, topics or activities. The information it does provide is insufficient for it to receive a score of \u20181\u2019. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence to indicate that the company publishes any details about its global lobbying expenditure. <\/p>\n"},{"question":81,"commitment_area":11,"score":"2","comments":"
There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with clear procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy also explicitly addresses the risks associated with gifts and hospitality given to and\/or received from public officials. The company's policy indicates that all gifts and hospitality are recorded. Where gifts cannot be politely refused they are held in a gift repository.<\/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 suppliers. The company indicates that this department is ultimately responsible for providing oversight of the company's supplier base. The company assures itself that proper procedures regarding suppliers are followed through an audit every year.<\/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 with all suppliers, with the highest risk suppliers being subject to enhanced due diligence. The company indicates that the due diligence process aims to establish the ownership of its suppliers. The company also states that supplier relationships will be subject to review, and potential termination, if any red flags highlighted in the due diligence process cannot be mitigated. <\/p>\n
However, although the company states that it plans supplier audits on a priority basis each year, there is no publicly available evidence that due diligence is repeated at least every two years or when there is a significant change in the business relationship.<\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place which cover conflicts of interest and gifts and hospitality. The company ensures this through contractual terms and assures itself of this when onboarding new suppliers. <\/p>\n
However, there is no publicly available evidence that the company requires its suppliers to have, at a minimum, policies that cover whistleblowing and prohibit facilitation payments. <\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
There is evidence that the company encourages its suppliers to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. <\/p>\n
However, this is in the form of a simple statement and it is unclear how the company assures itself of this in practice. <\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence to indicate that the company publishes any data on ethical or anti-bribery and corruption investigations or associated disciplinary actions relating to its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has a policy covering the use of agents, which also applies to those engaged by subsidiaries and joint ventures. The policy addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. The policy also explicitly commits to establishing and verifying 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":"
Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with its third parties and agents. Agents and the highest risk intermediaries are subject to enhanced due diligence. The company states that due diligence is conducted before engaging agents and remains valid for two to four years, depending on the risk level. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not repeat due diligence for all of its agents and intermediaries at least every two years or when there is a significant change in the business relationship.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is publicly available evidence that the company aims to establish the ultimate beneficial ownership of its agents and intermediaries, but the company makes no clear commitment to not engage or to terminate a third party relationship 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":"
Based on publicly available information, there is evidence that the compensation structures for agents are highlighted and addressed as a factor in bribery and corruption risk. There is also evidence that the company has specific controls in place to manage the risk, which include a threshold on the payment of sales commissions to agents and requiring that payments are only be made into local bank accounts. <\/p>\n
However, there is no evidence that the company requires that payments be staged over the course of their contracts and based on clear milestones. <\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence to indicate 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":"0","comments":"
There is no publicly available evidence to indicate 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 into a joint venture. There is evidence that this due diligence is conducted for every joint venture partnership and it is clear that the company\u2019s due diligence includes checks on the ownership of joint venture partners. <\/p>\n
However, there is no evidence to suggest that high-risk joint ventures (i.e. those operating in high risk markets or with high risk partners) are subject to enhanced due diligence and that due diligence is repeated at least every two years.<\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company commits to establishing and implementing anti-bribery and corruption policies in all of its joint ventures. The company requires joint ventures in which it has a controlling interest to apply the company\u2019s rules and procedures for corruption prevention. Joint ventures in which the company has a minority stake are required to adhere to Saab\u2019s Supplier Code of Conduct or commit to follow an equivalent set of core principles. The company includes termination rights in its contracts with joint venture partners. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that the company includes audit rights in its joint venture contracts. <\/p>\n"},{"question":102,"commitment_area":13,"score":"1","comments":"
The company explicitly commits to take an active role in preventing bribery and corruption in all of its joint ventures. <\/p>\n
However, the company does not provide any further information or practical details to support this statement.<\/p>\n"},{"question":103,"commitment_area":14,"score":"2","comments":"
Based on publicly available information, there is evidence that the company addresses and has procedures in place to address the corruption risks associated with offset contracting. There is evidence that the company requires that its offset partners adhere to its anti-bribery and corruption standards through contractual clauses. The company states that the Group Industrial Co-operation team is responsible for managing offset obligations and monitoring the company\u2019s offset activities throughout the lifecycle of each project. There is evidence that employees involved in industrial cooperation projects receive tailored anti-bribery and corruption training.<\/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. The process specifically mentions checks on ownership and conflict of interest. There is also evidence that the company seeks to assure itself of the legitimacy of the investment. <\/p>\n
However, there is no evidence that the company refreshes due diligence at least every two years or when there is a significant change in the business relationship or nature of the partner.<\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence to indicate 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":"1","comments":"
There is evidence that the company publishes information some about the beneficiaries of its indirect offset projects. <\/p>\n
However, this is insufficiently detailed and there is no evidence that this covers all of the company\u2019s offset projects or meets the other criteria in the guidance. <\/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 has a risk assessment process and management procedures in place to account for these specific risks. There is evidence that the results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. The company provides some examples of these controls. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
Based on publicly available information, there is evidence that the company publishes full lists of its fully consolidated subsidiaries and non-fully consolidated holdings, including any associates, joint ventures and other related entities. For each entity, the company discloses its percentage ownership. There is also evidence that the lists are current, updated on at least an annual basis and complete at the time of publication to the best of the company\u2019s knowledge. The company publishes the country of incorporation for each entity. <\/p>\n
However, the company does not publish the countries of operation for each entity. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is publicly listed on a regulated marked in the European Economic Area and therefore automatically receives a score of \u20182\u2019.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
The company does not publish the customers of at least 50% of its defence sales and therefore cannot 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\/623","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=623"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=623"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}