There is no evidence that the company makes a public commitment to ethical or anti-bribery and corruption standards.<\/p>\n"},{"question":55,"commitment_area":7,"score":"0","comments":"
There is no evidence that the company publishes an anti-bribery and corruption or ethics and compliance policy.<\/p>\n"},{"question":56,"commitment_area":7,"score":"0","comments":"
There is no evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.<\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
There is no evidence that a specific senior individual has ultimate responsibility for implementing and managing the company\u2019s anti-bribery and corruption programme. <\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company has a formal risk assessment procedure which is used to inform the company\u2019s anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company\u2019s anti-bribery and corruption programme is subject to audit or review.<\/p>\n"},{"question":60,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company has a publicly stated procedure for dealing with bribery and corruption allegations, incidents or whistleblowing reports.<\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company assures itself of the quality of its internal investigations.<\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company has an investigative procedure that includes a commitment to report material findings to the board or 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":"0","comments":"
There is no evidence that the company provides anti-bribery and corruption training to its employees.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk.<\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is no evidence 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":"
There is no evidence that the company\u2019s employee incentive schemes incorporate ethical or 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 or protect employees who refuse to act unethically.<\/p>\n"},{"question":69,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company has a policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.<\/p>\n"},{"question":70,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company provides either whistleblowing or advice channels for its employees to ask questions and raise concerns about suspected bribery or corruption.<\/p>\n"},{"question":71,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the company has a policy on conflicts of interest.<\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the company has procedures in place to manage conflicts of interest or their oversight.<\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company has a policy regulating 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":"
There is no evidence that the company has a policy on corporate political contributions.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any details of its political contributions.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy or procedure covering charitable donations or sponsorships.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy or procedure 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":"
There is no publicly available evidence that the company has a policy or procedure on gifts or hospitality.<\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company requires and ensures the involvement of its procurement department in the establishment and oversight of its supplier base.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain.<\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required 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 the associated disciplinary actions.<\/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.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.<\/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 no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.<\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company addresses 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 and\/or 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 agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its joint ventures.<\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no 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 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":"
There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on all aspects of its offset obligations. <\/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 its 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.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company acknowledges the corruption risks of operating in different markets.<\/p>\n"},{"question":108,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes a list of its subsidiaries or other affiliated entities.<\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
The company does not disclose detailed information about its beneficial ownership and control structure. It does not disclose whether any individual owns 25% or more of shares or voting rights, and does not publish information on a global register such as OpenOwnership. However, there is some evidence to indicate that the company is an entity established by the Defence Industry Executive Committee of the government of Turkey and affiliated with the Turkish Armed Forces, and this information is sufficient to indicate a degree of state ownership. The company therefore receives a score of \u20181\u2019.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes a breakdown of its defence sales by customer. There is some evidence to indicate that the company exists primarily to serve the Turkish Armed Forces (TAF) and Undersecretariat for Defence Industries (SSM), but it is not clear whether these are the company\u2019s only customers or whether it also makes other foreign or domestic sales. <\/p>\n"},{"question":111,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company publishes details of its shareholder voting rights. There is some evidence to indicate that the company is, at least partially, owned by the government of Turkey but it is not clear whether any other individuals or entities may hold shares or voting rights in the company. <\/p>\n"},{"question":112,"commitment_area":16,"score":"1","comments":"
There company publishes some limited information about its objectives to become a leading defence company and provide support to the Turkish Armed Forces (TAF). However, the company receives a score of \u20181\u2019 because its objectives beyond that are unclear and there is no evidence that these objectives are updated on at least an annual basis. <\/p>\n"},{"question":113,"commitment_area":16,"score":"0","comments":"
The company publishes some information about its board members, including their name and position. However, the company receives a score of \u20180\u2019 because it does not publish further details about which (if any) board members are independent, nor does it make any information on the board nomination and appointment process publicly available.<\/p>\n"},{"question":114,"commitment_area":16,"score":"0","comments":"
There is no publicly available evidence that the company has an audit committee, nor that is composed of a majority of independent directors.<\/p>\n"},{"question":115,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company publishes any details about its management of asset transactions.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/628","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=628"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=628"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}