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. There is clear evidence 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 clear anti-bribery and corruption policy and accompanying business ethics codes, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members as described in (a) and (b) in the question.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a designated board committee that is ultimately responsible for the oversight of the company's ethics programme. There is evidence that this includes reviewing reports from management on the programme\u2019s performance, and the company indicates that this committee has authority to require that changes are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that a designated senior executive has ultimate responsibility for implementing and managing the company's ethics programme. The company indicates 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":"
Based on publicly available information, there is evidence that the company has a formal bribery and corruption risk assessment procedure that informs the design of the ethics programme. There is evidence indicating that 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 tailored mitigation plans and to update specific parts of the company's ethics programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s ethics programme is subject to a regular audit process to ensure the programme is consistent with the business risks facing the company. This includes provisions for continuous improvement, supplemented by an internal or external audit every year. There is also evidence that high-level audit findings are presented to the board, with clear ownership assigned to an individual for planned updates and improvements to the ethical programme.<\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, 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 actions and documentation to be taken at each step. It covers the whole investigation process from receipt to final outcome and there is a commitment to providing whistleblowers with updates on the outcome of investigations. <\/p>\n
In addition, there is evidence indicating that all investigations are handled by independent teams, and that central bodies, the company\u2019s Corporate Responsibility Committee and Executive Committee, review the status of cases on a regular basis. <\/p>\n"},{"question":61,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company assures itself of the quality of both its whistleblowing and internal investigations. The company provides information on how complaints about the investigation process are handled and who is responsible for handling such complaints; that person is of an appropriate senior level within the company. The company indicates that internal investigations are carried out by appropriately trained individuals. In addition, there is evidence that the company reviews its investigation procedure periodically and at least every two years. <\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s investigative procedure includes a commitment to report material findings of bribery and corruption from investigations to the board. The company also indicates that the Group General Counsel is responsible for ensuring that the disclosure of criminal offences to relevant authorities is evaluated and acted upon, if found necessary.<\/p>\n"},{"question":63,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company publishes some high-level information on ethics and compliance-related incidents and investigations involving its employees. This data includes the number of reports received, number of reports received through whistleblowing channels, number of investigations launched, and the number of disciplinary actions as a result of investigation findings. This data is updated on an annual basis, and there is evidence to suggest that this data includes details of bribery or corruption-related incidents, investigations and disciplinary actions.<\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides training that outlines the principles of its anti-bribery and corruption programme, including the whistleblowing options available to employees. The company provides this training to all employees across all divisions and countries of operation and in all appropriate languages. The company indicates that employees are required to undertake refresher courses on at least an annual basis.<\/p>\n"},{"question":65,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides tailored anti-bribery and corruption training for employees in high-risk positions, middle management and board members. The company states that the training is tailored to these groups based on an assessment of their role and exposure to corruption risk. There is evidence indicating that this training is refreshed on an annual basis. <\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company reviews its anti-corruption communications and training programme regularly to ensure that its standards reflect best practice. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company conducts assurance on at least an annual basis, nor that the results of these reviews are used to update specific parts of the company's training programme. In addition, there is no clear evidence that the company has a system or specific measures in place for reviewing the efficacy of its training programme. <\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company\u2019s incentive schemes incorporate ethical principles. The company indicates that it conducts performance appraisals, which consider values-based behaviour. The company also indicates that employees are only eligible for financial bonuses if they complete annual anti-corruption training and have not been found in breach of the Code of Conduct. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is clear evidence that incentives or rewards must be proportionate to the employee\u2019s salary in the case of high-risk employees. <\/p>\n"},{"question":68,"commitment_area":9,"score":"1","comments":"
There is clear evidence that the company commits to support and protect any employee who refuses to act unethically, in keeping with the company\u2019s anti-corruption commitments, even where such actions result in a loss of business or another disadvantage to the company. <\/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 statement through anonymised surveys or other clearly stated means. <\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, which applies to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners. There is some indication that the company assures itself of confidence in this system through randomized interviews with employees who have reported ethics incidents to ensure that they did not feel like they experienced any acts of retaliation.<\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's ethics programme. There is evidence that the company\u2019s channels are sufficiently varied to allow the employee to raise concerns across the management chain and through external channels operated by an independent third party. <\/p>\n
There is evidence that the company\u2019s 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":"
Based on publicly available information, there is evidence that the company formally addresses conflicts of interest as a corruption risk and has a clear policy and procedure that defines conflicts of interest, including actual, potential and perceived conflicts. There is evidence that this policy covers all of the categories of possible conflicts listed in the guidance. The company indicates that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities.<\/p>\n"},{"question":72,"commitment_area":10,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. There is evidence that the company has a dedicated register for recording conflicts of interest. The company states that disciplinary measures will apply if its conflict of interest policies are breached and gives a number of examples of criteria for recusals. The company outlines the oversight and reporting structure governing conflicts of interest cases, with responsibility for regulating cases held between middle management and the relevant divisional Ethics and Compliance Office.<\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy that addresses the risks associated with the employment of public officials, and screens each new recruit from the public sector for potential conflicts of interest, implementing controls if risks are subsequently identified.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it requires senior compliance officer (or equivalent) approval for the initiation of any employment discussions with former or current public officials. There is also no evidence that the company has a policy to implement a cooling-off period of at least 12 months before such public officials are permitted to have any form of contact or relationship with their former organisation on the company\u2019s behalf.<\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company publishes details of the contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is evidence that the company has a policy and procedure on political contributions to ensure that these payments are not used as vehicles for bribery and corruption. The policy applies to all employees and board members across the group. The company states that its policy is to not make political donations but that such a donation would require signoff from the Board of Directors, with input from an individual with legal expertise, namely the Group General Counsel. There is also evidence that the company is associated with a Political Action Committee in the United States, which requires the signoff of a Divisional CEO with input from the company\u2019s Divisional General Counsel.<\/p>\n
Since the company does not prohibit political donations and is associated with a PAC, it receives a score of \u20180\u2019 in line with the scoring criteria. <\/p>\n"},{"question":76,"commitment_area":11,"score":"2","comments":"
The company publishes a statement that it has not made any corporate political donations in the most recently reported financial year, and states that it intends to continue with this approach. <\/p>\n
In addition, there is evidence that the company publishes details of the contributions and disbursements made through its Political Action Committee (PAC) in the United States, by providing links to its FEC filings and Open Secrets. There is evidence that this information includes details of the recipient, amount and state of the recipient and that it is updated and released on a regular basis.<\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy covering charitable donations and sponsorships. There is evidence that the company takes steps to ensure that any donations are legal, appropriate and ethical, and any donations must be signed off by a manager. In addition, the company indicates that it records all charitable donations and sponsorships in an online register. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes details of all charitable donations made in the past 12 months, including details of the recipient, amount, country of recipient and which corporate entity made the payment. The company mentions some donations and projects in its reporting documents, but there is no evidence that it provides a total figure or a comprehensive list of donations made to cover all of the company\u2019s activities.<\/p>\n"},{"question":78,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy on lobbying. The company defines lobbying and highlights the corruption risks associated with such activities, as well as identifying some guidelines for \u2018responsible\u2019 lobbying activity. In addition, there is some evidence that the company has specific controls and oversight mechanisms in place, by stipulating that all lobbying activities must be authorised by the Divisional CEO or appropriate Government Relations lead. There is evidence that this policy and procedure applies to all employees, board members and third parties lobbying on the company\u2019s behalf. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no publicly available 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 publicly available evidence to indicate that the company provides any details about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy and procedure 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. <\/p>\n
In addition, the policy also clearly addresses the risks associated with gifts and hospitality given to and received from public officials. The company's policy includes a clear statement that all gifts and hospitality above certain thresholds are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.<\/p>\n"},{"question":82,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence that the company requires the involvement of its procurement department in the establishment of new suppliers. This department is ultimately responsible for providing oversight of the company's supplier base. The company assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means at least every year. <\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has formal procedures to conduct due diligence on all of its suppliers. There is also evidence to suggest that the highest risk suppliers are subject to enhanced due diligence. The company states that it conducts due diligence monitoring throughout the life cycle of its relationship with suppliers. There is evidence that the company might be willing to review and\/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that its due diligence includes checks on beneficial ownership and the frequency of checks on suppliers is also unclear. It is noted that the company has a document called \u201cThird Party Legal and Ethical Compliance Due Diligence\u201d but this does not appear to be accessible in the public domain.<\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company states that all suppliers must have, at minimum, policies that prohibit bribery, facilitation payments as well as policies and procedures to address conflicts of interest, gifts and hospitality and whistleblowing. There is evidence that the company takes active steps to ensure this by requiring that all suppliers follow the Supplier Code of Conduct and the company\u00b4s Code of Conduct, and there is evidence that the company assures itself of this when onboarding new suppliers.<\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, 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 ethics programme and standards are included in subcontracts throughout the supply chain. This evidence is in the form of a 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 associated disciplinary actions. <\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy covering the use of agents. The policy addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. 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. In addition, there is evidence that this policy applies to subsidiaries and owned joint ventures.<\/p>\n"},{"question":89,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-
\nbased anti-bribery and corruption due diligence prior to engaging and re-engaging with its third parties and agents. There is also evidence to indicate that higher risk agents and third parties are subject to enhanced due diligence. The company indicates that it undertakes due diligence on all third parties during the onboarding process and that it refreshes these checks every three years, with ongoing monitoring throughout the lifecycle of the contract; the level of information provided on these checks is sufficient to receive a score of \u20182\u2019. <\/p>\n
It is noted that the company references a document called \u201cThird Party Legal and Ethical Compliance Due Diligence\u201d but this does not appear to be accessible in the public domain.<\/p>\n"},{"question":90,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company seeks to establish the beneficial ownership of its agents and intermediaries as part of its due diligence process. The company indicates that it undertakes such checks regularly and that any red flags identified may trigger additional reviews.<\/p>\n
However, the company receives a score of \u20181\u2019 because it does not specifically commit to not engaage or terminate an agreement if beneficial ownership cannot be established.<\/p>\n"},{"question":91,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company\u2019s anti-bribery and corruption policy applies to agents and that it includes anti-corruption clauses in its contracts with such entities or individuals. There is some evidence that the company includes termination rights in its contracts with these entities. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the company includes audit rights in its contracts with all agents and intermediaries.<\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company addresses incentive structures for agents as a factor in bribery and corruption risk. The company indicates that fees must be reasonable and not provide an incentive to act improperly, as well as stipulating specific sign off procedures for all agent payments. In addition, the company commits to only provide payments as specified in the contract and to making all payments into a designated bank account. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company imposes a proportional or other threshold on the payment of sales commissions to agents. There is also no clear evidence that remuneration is made in stage payments throughout the lifecycle of the contract. <\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any details of the agents currently contracted to act for and\/or on behalf of the company. <\/p>\n"},{"question":99,"commitment_area":13,"score":"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":"2","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 entering and while operating in a joint venture. There is evidence that this due diligence is conducted for every joint venture partnership (\u201cstrategic partners\u201d) and that this includes checks on the beneficial ownership of the partner company. The company indicates that it undertakes due diligence on all strategic partners during the onboarding process and that it refreshes these checks every three years, with ongoing monitoring throughout the lifecycle of the contract for high-risk partners; the level of information provided on these checks is sufficient to receive a score of \u20182\u2019. <\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company commits to establishing and implementing anti-bribery and corruption policies in its joint ventures. The company states that it includes anti-bribery and corruption provisions in its joint venture contracts and there is evidence indicating that contracts include termination rights. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that it takes steps to detect, control and prevent breaches through the inclusion of audit rights in all its joint venture contracts.<\/p>\n"},{"question":102,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. However, the company receives a score of \u20181\u2019 because it does not provide any further information on the steps that it takes to assure itself of this.<\/p>\n"},{"question":103,"commitment_area":14,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy of not entering into offset agreements. However, the company states that it has inherited an offset agreement as a result of a recent acquisition; the company indicates that it does not plan to enter into any further offset arrangements. <\/p>\n
The company\u2019s publicly available policies recognise the corruption risks associated with offset arrangements, and there is clear evidence that the company has undertaken due diligence on the process. The company also states that its Executive and Investment Committee is responsible for reviewing and approving offset arrangements. Although the company does not have a dedicated body, department or team responsible for offset activities, there is evidence to suggest that the company rarely enters into such agreements and therefore the measures stipulated are deemed sufficient for a score of \u20182\u2019. <\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has formal procedures in place to conduct anti-bribery and corruption due diligence on offset obligations. There is also evidence that the company seeks to assure itself of the legitimacy of the investment.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that this process specifically includes checks on beneficial ownership or conflict of interest. There is also 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":"1","comments":"
The company publishes a statement to indicate that it currently employs one consultant to provide compliance advice in relation to its offset programme. Although the company does not provide any further details of this individual or entity, there is sufficient evidence to indicate that no other consultants act for or on behalf of the company\u2019s offset programme, so the company receives a score of \u20181\u2019. <\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes details of the beneficiaries of the offset project it has recently inherited as part of an acquisition. The company indicates that its ongoing offset arrangement contributes to a requirement placed on a local contractor under Canada\u2019s Industrial and Technological Benefits Policy (ITB), but does not provide any further details about the project or direct beneficiary.<\/p>\n"},{"question":107,"commitment_area":15,"score":"2","comments":"
Based on publicly available information, there is evidence that the company acknowledges the corruption risks associated with operating in different markets and there is evidence that it has a dedicated assessment process in place to assess such risks. There is evidence to suggest that the results of these assessments trigger the implementation of additional controls and have an impact on business decisions.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings. The list includes all of the company\u2019s holdings, showing the percentage ownership and country of incorporation for each entity. There is evidence that this list is updated on an annual basis due to its inclusion in the company\u2019s Annual Report. <\/p>\n
However, the company receives a score of \u20181\u2019 because the list does not include the countries of operation for each entity.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence to indicate that the company is publicly traded on the London Stock Exchange, a regulated market in the UK, and it is therefore not required to disclose beneficial ownership further, so the company receives a score of \u20182\u2019. The company publishes a statement to confirm this in its corporate reporting documents.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
The company publishes some information on its customers, indicating that 55 percent of its order intake for the most recently reported financial year came from the United Kingdom. However, the company receives a score of \u20180\u2019 because there is evidence to indicate that this figure includes both defence and non-defence orders, so there is no clear indication of the company\u2019s percentage of defence sales by customer.<\/p>\n"},{"question":111,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":112,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":113,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":114,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":115,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/626","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=626"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=626"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}