The company publishes a general commitment to high ethical principles, but there is no evidence that the company makes a public anti-bribery and corruption commitment that is authorised and endorsed by its senior leadership. <\/p>\n"},{"question":55,"commitment_area":7,"score":"0","comments":"
There is no evidence that the company has a comprehensive anti-bribery and corruption policy. The company publishes some information about its internal controls and its commitment to adhere to high ethical standards, but there is no evidence that it has a specific an anti-bribery and corruption 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 managerial-level employee 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 that is used to inform the company\u2019s anti-bribery and corruption programme. The company publishes some information on its risk management procedures, but it is not clear that there are any procedures to identify and reduce certain risks related to bribery or corruption.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is some evidence that the company\u2019s compliance systems are subject to regular internal audit, however it is not clear that this includes the company\u2019s anti-bribery and corruption programme. The company also states that it regularly evaluates and assesses its corporate governance and risk management systems to ensure regulatory compliance, but makes no specific reference to anti-bribery or corruption.<\/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 takes steps to assure 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\u2019s investigative procedure includes a commitment to report material findings to board members and the relevant authorities.<\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company publishes 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 for its employees.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company provides tailored 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 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 has a commitment 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 has either whistleblowing or advice channels for employees to report allegations or incidents of suspected bribery or corruption.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a conflict of interest policy, and it is clear that this policy addresses conflicts related to financial interests, employee relationships and outside employment opportunities. There is also evidence that this policy applies to all employees. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is evidence to suggest that the policy published on its website is a template copied elsewhere, so the extent to which the company has incorporated these policies into its own operations is unclear. In addition, the policy does not explicitly apply to all board members, nor does it specifically address and cover conflicts of interest concerning government relationships. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company states that its supervisory board, as well as designated independent directors, are responsible for managing and resolving conflicts of interest. The company also states that employees must gain approval from the supervisory board before accepting outside employment, in order to avoid conflicts of interest. <\/p>\n
However, there is no clear evidence that all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process. Beyond outside employment opportunities, the policy does not mention examples of criteria for recusals. The policy also does not state that disciplinary measures will apply if breached. <\/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 that prohibits, or at minimum regulates, corporate political contributions.<\/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":"0","comments":"
There is some evidence that the company has policies and procedures covering both charitable donations and sponsorships, but there is no evidence that these include specific controls or measures to ensure that such donations are not used as vehicles for bribery and corruption.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no 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 publishes 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 and hospitality.<\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company requires the involvement of its procurement department in the establishment and\/or 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 evidence that the company publishes any information regarding its approach to 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 commits 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 considers incentive schemes as a risk factor in agent behaviour.<\/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 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 and there is no evidence it requires anti-bribery and corruption clauses in its contracts with joint venture partners.<\/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 the company's offset activities.<\/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 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 evidence that the company acknowledges the corruption risks of operating in different markets, nor that risk assessment procedures are used to inform the company\u2019s operations in high risk markets.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings. The company states that the list represents all of the company\u2019s holdings. The list also includes information on percentage ownership and country of incorporation for each entity. There is some evidence that this list is updated on an annual basis since the information appears in the company\u2019s Annual Report. <\/p>\n
However, the company receives a score of \u20181\u2019 because the data does not clearly specify the country of operation for each entity. <\/p>\n"},{"question":109,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company discloses clear information on its beneficial ownership. The company indicates that the Uzbek national rail company owns over 20% of its shares, without providing further information on its precise shareholding or other possible shareholders. There is some indication that the company is either partially or fully state-owned. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes data on the identity of any of its defence customers.<\/p>\n"},{"question":111,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company publishes information on its shareholder voting rights.<\/p>\n"},{"question":112,"commitment_area":16,"score":"1","comments":"
The company publishes some limited information about its objectives, which is primarily to support the Ministry of Defence of Uzbekistan. However, there is no evidence that these objectives are updated on an annual basis. <\/p>\n"},{"question":113,"commitment_area":16,"score":"0","comments":"
The company publishes some information on the nomination and appointment process for its board.<\/p>\n
However, the company receives a score of \u20180\u2019 because it does not make sufficient information about its board members or the process publicly available. The company discloses the identities of board members but does not indicate whether a board member is a financial beneficiary, an executive, a state representative, or an independent director.<\/p>\n"},{"question":114,"commitment_area":16,"score":"0","comments":"
The company publishes a statement that its audit committee may include independent and executive directors. <\/p>\n
However, the company receives a score of \u20180\u2019 because there is no clear evidence that the committee is, or must be, composed of a majority of independent directors. Although the company publishes some sample information on audit committee regulations, it indicates that these are not enforced or in place.<\/p>\n"},{"question":115,"commitment_area":16,"score":"1","comments":"
There is some evidence that the company has a system in place to manage asset transactions, with responsibility for the management of transactions held at board level. There is evidence that the company\u2019s major transactions are subject to scrutiny by an audit body. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that all transactions are documented, nor that the company publicly discloses the financial results from asset acquisitions. <\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/630","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=630"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=630"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}