Based on publicly available information, there is evidence that the company makes a general commitment to anti-bribery and corruption. However, the company receives a score of \u20180\u2019 because there is no evidence that this commitment is directly authorised or supported by its leadership.<\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
Based on publicly available information, there is evidence that the company publishes an anti-bribery and corruption policy that specifically prohibits bribery, payments to public officials and facilitation payments. There is evidence that this policy applies to all employees across the organisation. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the policy addresses and covers commercial bribery. It is also not clear from publicly available information whether the policy applies to board members. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated board committee \u2013 the Risk and Sustainability Committee \u2013 provides oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from management on the programme\u2019s performance and there is evidence that this committee has the authority to require changes are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior executive has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. There is evidence that this person has a direct reporting line to the board or board committee that provides oversight of the anti-bribery and corruption programme.<\/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 company indicates that the results of risk assessments are reviewed by the board on 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 anti-bribery and corruption programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
There is evidence that the company\u2019s anti-bribery and corruption programme is subject to a regular audit process to ensure the programme is consistent with best practice and the business risks facing the company, with audit findings being presented to the board annually. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the audit process includes provisions for continuous improvement, supplemented by an internal or external audit at least every two years.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company commits to investigating incidents and there is a specific procedure in place to deal with whistleblowing cases, which stipulates documentation and actions to be taken at each step. There is evidence that investigations are conducted independently and are overseen by the board-level Audit Committee handles the internal investigations. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear whether the policy covers the investigation process from receipt to final outcome. There is also no evidence of a commitment to provide whistle-blowers with updates on the outcome of investigations, there is no evidence that the information on each investigation is documented and no summary information is reviewed by a central body.<\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company has procedures in place to ensure the quality of its investigations. The company indicates that the Audit Committee may review findings of internal investigations if necessary, however it is not clear that this process \u2013 or additional procedures \u2013 are in place to ensure quality as described in the question scoring criteria. <\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
There is some evidence that the company reports material findings of bribery and corruption from investigations to the board. However, the company receives a score of \u20181\u2019 because there is no evidence that an appropriate senior individual is responsible for ensuring that the disclosure of criminal offences to relevant authorities is evaluated and acted upon if necessary.<\/p>\n"},{"question":63,"commitment_area":8,"score":"1","comments":"
Based on publicly available evidence, the company publishes some high-level information on its corruption-related incidents and investigations involving employees on an annual basis. This information includes the number of investigations launched and the number of confirmed incidents related to corruption. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not include information on the number of reports received, including the number received through whistleblowing channels.<\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides a training module that outlines the basic principles of the anti-bribery and corruption policy. There is also evidence that this training is provided to all employees and that they are required to refresh their knowledge on an annual basis. Based on the company\u2019s Code of Business Conduct and Ethics, there is evidence that this training covers the whistleblowing options available to employees. Although it is not explicitly stated that training is provided in all countries and regions of operation, there is sufficient evidence to receive a score of \u20182\u2019. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that employees in certain positions receive different or tailored anti-bribery and corruption training every two years. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide information on the types of positions that receive this tailored training, so it is not clear that it covers employees in high risk positions, middle management, nor board members. <\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company reviews its anti-bribery and corruption communications and personnel training programme.<\/p>\n
However, the company receives a score of \u20181\u2019 because the measures are limited to the number of personnel trained. There is no evidence that the company assures itself of this on at least an annual basis and it is unclear that results are used to update specific parts of the company's anti-bribery and corruption communications and training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
There is evidence that the company\u2019s incentive schemes incorporate ethical and anti-bribery and corruption principles.<\/p>\n
However, the company receives a score of \u20181\u2019 as there is no evidence to suggest that incentives are designed to reward behaviour in line with the company\u2019s ethical values as identified through performance appraisals or conduct in the workplace. It is also unclear whether the policy does not apply to high-risk employees, such as sales roles.<\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company commits to support or protect employees who refuse to act unethically.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
Based on publicly available evidence, the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents that explicitly applies to all employees across the organisation, including those employed by the group as third parties, including suppliers.<\/p>\n
However, the company receives a score of \u20181\u2019 as there is no evidence that it 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":"1","comments":"
Based on publicly available evidence, the company has multiple channels to report instances of suspected corrupt activity. These channels are sufficiently varied to allow the employee to raise concerns across the management chain and through a hotline operated by a external independent party. These channels allow for confidential and anonymous reporting. They are available and accessible to all employees in all relevant jurisdictions where the company operates, including those employed by the group as third parties, suppliers and in all relevant languages. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that these channels are available to employees of joint ventures. There is also no clear evidence that the reporting channels may be used by employees to seek advice or ask questions about the company\u2019s anti-bribery and corruption programme. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is some evidence that the company addresses potential and perceived conflicts of interest in its Code of Business Conduct. It is clear that this policy applies to all employees. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company has a formal policy to define and address conflicts of interest, beyond a high-level statement. The company\u2019s statement also does not specifically make reference to actual, potential or perceived conflicts arising from employee relationships, financial interests, government relationships and other employment. <\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company has procedures to manage conflict of interest or their oversight.<\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is evidence that the company addresses the risks associated with the employment of public officials, by providing details of the board appointment process. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its policy includes any specific controls to assess and regulate the employment of current or former public officials.<\/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":"0","comments":"
Based on publicly available information, there is evidence that the company has a procedure to regulate political contributions, to ensure that these payments are not used as vehicles for bribery and corruption. This policy indicates that political contributions and donations are permitted, in line with the company\u2019s approval procedure and all relevant laws. The company therefore receives a score of \u20180\u2019.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company discloses any details of its political contributions.<\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a procedure covering both charitable donations and sponsorships. The company publishes some information about the recipients of its major donations. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its procedures for charitable donations include specific controls to ensure that such contributions are not used as vehicles for bribery or corruption; for example, by specifying criteria for donations, procedures for senior sign-off, or due diligence on recipients. There is also no evidence that the company publishes a full list of all charitable donations and sponsorships made in the past 12 months. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy on lobbying. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any information on its lobbying aims, topics or activities.<\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company provides any details about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is evidence that the company addresses the giving and receipt of gifts and hospitality in its Code of Business Conduct. <\/p>\n
However, the company receives a score of \u20180\u2019 because it does not provide further details of its policy to indicate that it has procedures in place to ensure that such promotional expenses are not used as vehicles for bribery and corruption. <\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company\u2019s procurement department is involved, in some capacity, in the establishment and oversight of supplier relationships. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that the procurement department is the main body responsible for oversight of the company\u2019s supplier base and there is no evidence that the company assures itself of the procurement department\u2019s involvement at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company conducts risk-based anti-bribery and corruption due diligence on its suppliers. The company indicates that it screens all suppliers during the onboarding process and that this screening includes ESG considerations; however there is no clear evidence that this includes anti-corruption topics, nor that suppliers are subject to different levels of due diligence based on risk. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company indicates that all suppliers must have policies in place that prohibit foreign and domestic bribery, prohibit facilitation payments, as well as policies and procedures to address conflicts of interest and gifts and hospitality. There is evidence that the company takes active steps to ensure these policies are upheld. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that the company requires its suppliers to have whistleblowing channels in place. It is also not clear whether the company assures itself of this only when onboarding new suppliers or when there is a significant change in the business relationship. <\/p>\n"},{"question":85,"commitment_area":12,"score":"0","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, by including a principle on this in its Vendor Code of Conduct. However, the company receives a score of \u20181\u2019 because it is not clear 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 or the associated disciplinary actions relating to its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company has a policy covering the use of agents. The company indicates that it communicated its anti-corruption policies to intermediaries; however there is no clear evidence that the company formally addresses the corruption risks associated with the use of agents or that it provides details of specific controls to mitigate these risks. <\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no clear evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging with its third parties. The company indicates that it evaluates and screens third party intermediaries, but there is no evidence that high risk intermediaries are subject to enhanced due diligence, nor that highest risk intermediaries are subject to enhanced due diligence and there is no evidence that the process is repeated at least every two years. <\/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.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is evidence that the company\u2019s anti-bribery and corruption policy applies to agents and intermediaries, and that it includes anti-bribery and corruption clauses in its contracts with such entities. <\/p>\n
However, the company receives a score of \u20180\u2019 because there is no evidence that it explicitly includes audit and termination rights in its contracts with these entities. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company has incentive structures as a risk factor in agent behaviour.<\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any details of the agents currently contracted to act for or and on its behalf.<\/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 to agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is some evidence that the company conducts due diligence (\u201cscreening\u201d) on its business partners. However, the company receives a score of \u20180\u2019 because it is not clear whether this includes joint venture partners, nor is there evidence to indicate that this screening covers anti-corruption principles or is based on an assessment of risk. <\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.<\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company addresses the corruption risks associated with offset contracting, nor that it has a dedicated body, department or team responsible for monitoring the company's offset activities. The company indicates that offset contracts are reviewed by the Risk and Sustainability Committee, but it does not provide further information on the potential risks or team responsible for their oversight.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations.<\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
There is no evidence 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":"0","comments":"
There is no evidence that the company publishes any details of its offset obligations or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no publicly available evidence that the company acknowledges the corruption risks of operating in different markets.<\/p>\n"},{"question":108,"commitment_area":15,"score":"2","comments":"
There is evidence that the company publishes a list 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, the country of incorporation and countries of operation. There is evidence that this list is current and updated on at least an annual basis, and the fact that the information is included in the Annual Report indicates that that the list is complete at the time of publication.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed in the United States and Germany and is therefore not required to disclose its beneficial ownership as outlined in the scoring criteria, so automatically receives a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes details of its defence sales by customer. The company publishes some information on its defence and commercial revenue by geographical area, but it does not indicate customers.<\/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\/627","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=627"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=627"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}