The company has a publicly stated anti-corruption commitment, which details the company's stance against any form of 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":"
The company publishes a Code of Conduct, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that this Code applies to all of those employed across the group, including subsidiaries and joint ventures. <\/p>\n"},{"question":56,"commitment_area":7,"score":"0","comments":"
The company\u2019s anti-bribery and corruption programme is overseen by the Compliance, Ethics and Anti-Fraud Committee, which is a management-level committee. There is no evidence to suggest that any other committee at board level has oversight of the company\u2019s anti-bribery and corruption programme, or that an individual board member is responsible for overseeing the programme. <\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
There is evidence that a managerial-level individual has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. The company states that the Group Compliance Officer is responsible for leading the company\u2019s risk prevention programme and is a member of the Compliance, Ethics and Anti-Fraud Committee. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that this individual has a direct reporting line to the board or a designated board committee. Although the Group Compliance Officer is a member of the Compliance, Ethics and Anti-Fraud Committee, this is a managerial committee and not a board-level committee.<\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
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 states that this review is conducted biannually and the results are provided to group management. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that these results are reviewed at board level or by a designated board committee. The company also has a broader Enterprise Risk Management system, and the results of this risk mapping are provided to the Audit and Risk Committee. However, based on publicly available information, it is not clear that the Enterprise Risk Management process includes a review of bribery and corruption risks.<\/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 and external audit. The company\u2019s internal audit function conducts a continuous review of the company\u2019s trade compliance system. The company also states that its entire anti-bribery and corruption programme was audited by an external company, the Agency in charge of Providing Technological Information (\u201cADIT), in May 2017. This certification lasts for three years, and the company states that this reflects high standards and international best practice. <\/p>\n
However, the company receives a score of \u20181\u2019 because several details about its audit procedures remain unclear. For instance, it is not clear whether the trade compliance system includes the anti-bribery and corruption programme. Moreover, it is not clear that the external audit completed in May 2017 is a regular undertaking that takes place at least every two years. Ownership and responsibility for the process is also unclear and there is no publicly available evidence that audit findings are presented to the Board or a designated board committee. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company commits to investigating incidents and to providing whistleblowers with updates on the outcome of investigations. The company indicates that it has a Fraud Officer tasked with undertaking internal procedures for investigations. Although the company does not specifically state that a central body receives and reviews summary information on investigations, there is evidence that the Fraud Officer reports to the Compliance, Ethics and Anti-Fraud Committee and that this group meets several times a year. <\/p>\n
However, the company receives a score of \u20181\u2019 because the company only provides limited information on its systems for tracking, investigating and responding to bribery and corruption allegations or incidents on its website. It does not provide information on the whole investigation process from receipt to final outcome and it is unclear whether all investigations are handled by an independent team and\/or report to an independent board member. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company assures itself of the quality of its internal investigations. There is no information provided on the qualifications or the training of the company\u2019s Fraud Officer responsible for undertaking its investigations. Moreover, there is no publicly available information on the handling of complaints about the investigation process, such as those responsible for handling such complaints and whether that person is of an appropriately senior level or function within the company. 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":"0","comments":"
There is no publicly available evidence that the company\u2019s investigative procedure includes a commitment to report material findings to the Board. There is also no evidence that an appropriately senior individual is responsible for reporting criminal conduct to the relevant authorities. <\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
The company does not publish any 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 a training module to all employees that outlines the basic principles of the anti-bribery and corruption policy. It is clear that training is provided to all group companies worldwide. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is unclear how regularly this training is conducted or whether employees are required to refresh their training. There is also no publicly available information on the content of the training module, so it is unclear whether the training covers the whistleblowing options available to employees. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is some evidence that that employees in certain positions receive different or tailored anti-bribery and corruption training. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not make specific reference to all three categories of employee as referred to in the question. It is also unclear how frequently training is conducted. <\/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 company receives a score of \u20181\u2019 because the review measures described in its publicly available evidence are limited to data collection and completion rates. Information memos are issued on an annual basis, but it is not fully clear whether the results of these measures are used to update specific parts of the company\u2019s anti-bribery and corruption programme. It is also unclear whether the company\u2019s anti-corruption certification by an external company, the Agency in charge of Providing Technological Information (\u201cADIT\u201d), includes a review of training. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company\u2019s incentive schemes incorporate ethical or anti-bribery and corruption principles. Publicly available descriptions of the structure of company\u2019s Corporate Officer and Chief Executive Officer compensation packages do not refer to anti-bribery and corruption. The company briefly mentions that employee compensation accounts for individual commitment to issues such as workplace health and safety and compliance with international labour conventions, but there is no evidence to suggest that this includes 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 and protect employees who refuse to act unethically. The company makes a clear commitment to business integrity, even if it means a loss of business. However, this is not accompanied or reinforced by a statement that the company will support and protect those who refuse to act unethically. There is also no evidence that the company assures itself of its employee\u2019s confidence in this statement through anonymised surveys or other clearly stated means. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is evidence that the company has a policy of non-retaliation and non-discrimination against employees who make reports. The policy applies to all employees across the organisation, including those employed by the Group as third parties, suppliers and joint venture partners. <\/p>\n
However, the company receives a score of \u20181\u2019 because 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 whistleblowing and advice channels that allow for anonymous and confidential reporting. Employees may raise concerns or ask questions about bribery and corruption-related issues through direct means \u2013 by consulting a supervisor or a compliance or human resources professional \u2013 or indirectly through a dedicated email address. This whistleblowing line is operated by an external party 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. There is also evidence that the company\u2019s whistleblowing and advice line is available in all relevant languages. <\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence that the company formally addresses conflict of interest as a corruption risk, and that it has a clear policy defining possible conflicts, including those actual, potential and perceived. This policy explicitly covers all of the categories of possible conflicts listed in the question guidance, specifically employee relationships, government relationships, financial interest and other employees. This policy applies to all employees. The management of conflicts of interest for board members is covered separately in the rules covering the board of directors.<\/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, potential and perceived conflicts both for employees and members of the Board. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that a specific body or individual has oversight and accountability for handling conflict of interest cases involving employees. There is also no evidence that the employee and board member declarations are held in a dedicated register that is accessible to those responsible for oversight of the process. The company also does not provide examples of criteria for recusals. <\/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. This policy stipulates that any former public agents recruited by the company will be subject to a cooling-off period.<\/p>\n
However, the company receives a score of \u20181\u2019 because its policy is insufficiently detailed. The company states that a cooling-off period of three years will apply in France, as dictated by French conflict of interest laws, but the company\u2019s approach to cooling-off periods in other jurisdictions is not clear. There is also no evidence of additional controls regulating the employment of current or former public officials, for example whether senior compliance officer (or equivalent) approval is required for the initiation of employment discussions or whether it imposes restrictions on their activities once employed. <\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company reports details of the contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"2","comments":"
The company publishes a clear statement that it prohibits corporate political contributions. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":""},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a clear policy and procedure covering both charitable donations and sponsorships, whether made directly or through corporate foundations. There is evidence that the company has measures in place to ensure that such expenditures are not used as vehicles for bribery and corruption. For example, the company specifies criteria for acceptable donations, conducts due diligence on recipients and outlines procedures for senior compliance officer sign-off based on financial thresholds. <\/p>\n
However, the company receives a score of \u20181\u2019 because it only publishes limited details on its charitable contributions and sponsorships. Although its 2018 Registration Document contains some details, it does not list the details of the recipient, amount, country of recipient and which corporate entity made the payment. <\/p>\n"},{"question":78,"commitment_area":11,"score":"2","comments":"
There is evidence that the company has a policy and procedure that defines lobbying and sets out the values and behaviours that constitute the spirit of \u2018responsible\u2019 lobbying. The company states that all internal and external lobbyists must comply with the standards of ethical behaviour outlined in its Code of Conduct. This policy applies to all employees and third parties lobbying on the company\u2019s behalf, and states that breaches could result in disciplinary action or termination of contract. The company\u2019s Responsible Lobbying Charter applies to the Safran Group, which has been understood to include all employees and board members. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
The company does not publish any information on its lobbying aims, topics or activities. The company commits to complying with French law requiring it to declare lobbying activities to the French High Authority for Transparency in Public Life; however, this information is not on the company\u2019s website. The company provides a link to the relevant law but does not provide a direct link to its own declarations. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
The company does not provide any details about its global lobbying expenditure on its website. The company commits to complying with French law requiring it to declare lobbying expenditure to the French High Authority for Transparency in Public Life; however, this information is not presented on the company\u2019s own website. The company provides a link to the relevant law but does not provide a direct link to its own declarations. <\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy on the giving and receipt of gifts and hospitality. There is evidence that this policy explicitly addresses the risks associated with gifts and hospitality given to and\/or received from domestic and foreign public officials by requiring prior authorisation from the company\u2019s Trade Compliance Officer. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register that is accessible to those responsible for oversight of the process. The policy also does not specify financial or proportional limits for different types of gifts. <\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company's procurement department is involved in the establishment and oversight of supplier relationships. It is clear that procurement departments, whether at group or entity levels, are the main bodies responsible for this work. It is not explicitly stated in company materials that they are involved in all supplier relationships or that their involvement is required for establishing new suppliers over a certain threshold. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company assures itself of the procurement department\u2019s involvement in this process at least every three years. It is not explicitly stated that the company\u2019s anti-corruption certification provided by the Agency in charge of Providing Technological Information (\u201cADIT\u201d), includes a review of procurement processes.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company conducts risk-based anti-bribery and corruption due diligence when engaging or re-engaging with its suppliers. The company simply states that it conducts internal and external due diligence on every business partner, which might be understood to include suppliers. It does not provide any further details on its anti-bribery and corruption due diligence procedures, such as the scope of due diligence, whether this is risk-based and how frequently due diligence is conducted. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company states that it expects all suppliers to have policies in place that prohibit bribery and facilitation payments, as well as procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. Anti-bribery and corruption clauses are included in the company\u2019s contracts with suppliers.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is unclear how the company ensures this in practice. For example, it does not specify that the company assures itself of this through in-depth assessments or audits of each suppliers\u2019 policies when onboarding new suppliers and\/or when there is a significant change in the business relationship.<\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
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. <\/p>\n
However, the company receives a score of \u20181\u2019 because this evidence is in the form of a simple statement and it is unclear how the company does this in practice.<\/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 clear policy and procedure to control the use of agents, which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. This policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures.<\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company conducts due diligence on its agents and intermediaries. The company states that it conducts an annual review of business partner due diligence throughout the contractual relationship, as well as undertaking a methodical selection process prior to engagement. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not specify that high risk agents or intermediaries are subject to enhanced due diligence. <\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company aims to establish the beneficial ownership of its agents as part of its due diligence. There is no evidence that the company commits to not engaging or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established. <\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is no clear evidence that the company\u2019s anti-bribery and corruption policy applies to its agents and intermediaries, nor that the company includes clauses in its contracts with such entities to detect and prevent bribery and corruption. The company addresses business partners in its Code of Conduct, but does not explicitly state that all agents must abide by these standards when acting for or on behalf of the company. <\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company considers its payments and compensation as a risk factor in agent behaviour. The company indicates that agent compensation should be appropriate and consistent with market price. There is also evidence that payments are properly documented and authorised by the appropriate department. <\/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 to agents. The company does not state that it makes stage payments nor that agents must be paid into local bank accounts. <\/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":"0","comments":"
There is some evidence that the company conducts due diligence on its joint ventures at the start of the relationship, but provides no further information about its due diligence procedures beyond that. There is also no indication that the company conducts due diligence throughout the relationship, nor that this process is based on an assessment of corruption risks. <\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no clear evidence that the company commits to incorporating anti-bribery and corruption policies and procedures in its joint venture partnerships, nor that it requires anti-bribery and corruption clauses in its contracts with such partners. The company states that its Code of Conduct may be adopted by its joint venture partners, but this is not a requirement and there is no evidence that the company takes action if not adopted.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to taking an active role in preventing bribery and corruption in its joint ventures. The company states that its Code of Conduct may be adopted by its joint venture partners, but this is not a requirement and there is no evidence that the company takes action if not adopted.<\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company formally addresses the corruption risks associated with offset contracting, nor that a dedicated body, department or team is responsible for monitoring of the company's offset activities. Although the company addresses the corruption risks associated with agents and intermediaries, there is no evidence that this applies to offset activities or brokers. <\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company conducts risk-based anti-bribery and corruption due diligence on its offset obligations. The company states in its 2018 Registration Document that it conducts due diligence on all business partners, but it is not sufficiently clear whether agents working on offset agreements are included in this definition, nor whether it applies to all aspects of the obligation. <\/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\u2019s offset programme. <\/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":"1","comments":"
There is evidence that the company acknowledges the corruption risks associated with operating in different markets and that it has a dedicated assessment process in place to assess such risks. <\/p>\n
However, this does not include clear risk management procedures and there is no evidence to suggest that the results of these assessments have an impact on business decisions or trigger the implementation of additional controls.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes a list of its consolidated companies and subsidiaries, along with the percentage ownership for each. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the list includes non-fully consolidated holdings. Additionally, although the company lists the country of the subsidiary, it is unclear whether this relates to the country of operation or incorporation. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is publicly-listed on multiple stock exchanges \u2013 including London, Paris and Euronext \u2013 and therefore automatically receives a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
The company does not publish details of its defence sales by customer. <\/p>\n"},{"question":111,"commitment_area":16,"score":"2","comments":"
The company is publicly-listed on multiple stock exchanges, and therefore is not required to disclose information on its beneficial owners. The company nevertheless provides information on shareholder voting rights in its public materials. <\/p>\n"},{"question":112,"commitment_area":16,"score":"2","comments":"
There is evidence that the company publishes information on its commercial and public policy objectives. There is evidence that this information is updated on an annual basis or whenever there is a change in objectives. <\/p>\n"},{"question":113,"commitment_area":16,"score":"2","comments":"
There is evidence that the company is open and clear about the nomination process, appointment and composition of its Board of Directors and provides details of its board members. The company discloses details of its nomination process, including the criteria for nomination, which company representatives are involved in the nomination, and who makes the final appointment decision. For each board member, the company discloses whether that person has any connection to the company or the state or is an independent director.<\/p>\n"},{"question":114,"commitment_area":16,"score":"2","comments":"
There is evidence that the company\u2019s Audit Committee is composed of a majority of independent directors.<\/p>\n"},{"question":115,"commitment_area":16,"score":"2","comments":"
There is some evidence that the company has a system in place to manage asset transactions. The company states that transactions above a certain financial threshold are subject to prior board approval, and there is evidence that these decisions are documented. Financial results from asset acquisitions or disposals are made publicly available in the company\u2019s accounts. There is evidence that the company\u2019s Audit and Risk Committee is responsible for reviewing financial statements relating to asset acquisitions and disposals.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/625","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=625"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=625"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}