There is evidence that the company publishes a general anti-bribery and corruption commitment as part of its Code of Ethics. The Code of Ethics is endorsed by the company\u2019s CEO. However, the company receives a score of \u20181\u2019 because the statement from the CEO does not specifically mention and address the company\u2019s stance against bribery and corruption, referring instead to integrity and highest ethical standards. <\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company publishes an anti-bribery and corruption policy as part of its Code of Ethics. There is evidence that this policy clearly prohibits bribery and facilitation payments. This policy applies to all staff and board members, as well as the staff and leadership of its wider corporate group. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that its anti-corruption policy prohibits commercial bribery and payments to public officials. <\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is some publicly available evidence that the company\u2019s Executive Board is responsible for oversight of its anti-bribery and corruption programme. However, the company receives a score of \u20181\u2019 because there is no further evidence to suggest that it engages in formal oversight functions or that it has the authority to require that changes are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
There is evidence that a managerial-level individual has been assigned ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. However, the company receives a score of \u20181\u2019 because it is not clear that this individual is a senior executive and there is no clear evidence that they have a direct reporting line to the company\u2019s board of directors. <\/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 the anti-corruption and bribery programme. However, the company receives a score of \u20181\u2019 because there is no evidence that it conducts such corruption risk assessments annually, or that the results of assessments are reviewed at board level. <\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
There is evidence that the company's anti-bribery and corruption programme is subject to regular internal review, led by the company\u2019s HR manager, and that this individual is responsible for implementing necessary changes to the programme.<\/p>\n
However, the company receives a score of \u20181\u2019 because the frequency of such reviews is unclear and there is no evidence that findings are presented to the board.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
The company publicly 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. The company also states that it will provide whistleblowers with updates on the outcome of investigations.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that investigations are handled by an independent team or report to an independent board member. In addition, the company does not provide further information on its investigative process, from receipt to final outcome. There is also no evidence that a central body reviews summary information on investigations on at least an annual basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company takes steps to ensure the quality of its investigations.<\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company has an investigative procedure which includes a commitment to report material findings of corruption to the board of directors. The company indicates that it may report findings from investigations to relevant authorities if necessary, but there is no evidence that a senior individual is responsible for ensuring that such disclosures are evaluated and acted upon. <\/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 incidents, investigations or disciplinary actions involving its employees. <\/p>\n"},{"question":64,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company provides anti-bribery and anti-corruption training to its employees.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company provides anti-bribery and corruption training to its employees, nor that it tailors this training to certain 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 effectiveness of its anti-bribery and corruption training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company\u2019s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles.<\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company commits to support and 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":"1","comments":"
There is evidence that the company provides confidential whistleblowing and reporting channels for its employees. The company indicates that reports may be made anonymously, but there is evidence that the company discourages anonymous reporting to avoid abuses of the channel. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it provides employees with an external reporting channel, such as an independently operated hotline. There is also no evidence that reports made through the company\u2019s channels are confidential. In addition, there is no clear evidence that these channels are available to all employees in any country of operation, or in multiple languages, or to any employees of third parties, suppliers or joint venture partners.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy on conflicts of interest, which applies to all employees and board members. The company\u2019s policy makes specific reference to possible conflicts arising from financial interests and personal relationships. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that its policy defines and addresses possible conflicts arising from government relationships or outside employment opportunities. It is also not clear that the company\u2019s policy addresses actual, potential and perceived 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 identify, declare and manage conflicts of interest. The company indicates that employees who become aware of a conflict must report this information to the HR manager, however the company does not provide any further details on this process or any oversight mechanisms.<\/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 publishes details of any contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
There is evidence that the company has a policy on corporate political contributions, which states that such donations to political parties or movements are permitted. The company indicates that such support must not be connected to any public sector opportunity, and states that any donations must be transparent. <\/p>\n
The company receives a score of \u20180\u2019 because there is evidence to indicate that it does not prohibit 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 some evidence that the company has a policy covering both sponsorships and charitable donations.<\/p>\n
However, the company receives a score of \u20180\u2019 because there is no evidence that provides specific information on the criteria or controls in place to ensure that donations are not used as vehicles for bribery and corruption. For example, there is no evidence that its controls include a measures for senior sign off on donations or due diligence on recipients. There is also no evidence that the company publishes any information on its donations made in the most recently reported financial year.<\/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 publishes any details about its global lobbying expenditure. <\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy and procedure on the giving and receipt of gifts and hospitality. The company states that any gifts offered must be proportionate in value and indicates that employees in high risk positions, such as sales, must not accept gifts. There is evidence that employees much report gifts to a superior in such cases. <\/p>\n
The company receives a score of \u20181\u2019 because it does not provide any information on further controls in place to ensure such expenses are not used as vehicles for bribery and corruption. For example, there is no evidence that it specifies financial or proportional limits or different approval procedures for different types of promotional expenses, nor does it address the risks associated with gifts and hospitality given to\/received from domestic or foreign public officials. In addition, there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.<\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is some evidence to suggest that the company's 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. There is also 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":"1","comments":"
There is evidence that the company conducts due diligence on all third parties, including suppliers. The company states that it is willing to review and\/or terminate a supplier relationship if a red flag highlighted during due diligence cannot be mitigated.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its due diligence includes checks on ultimate beneficial ownership. In addition, there is no evidence that highest risk suppliers are subject to enhanced due diligence, and it is not clear how frequently it conducts such checks. There is no evidence that this takes place at least every two years or when there is a change in the business relationship.<\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard. The company indicates that external partners must be familiar with its anti-corruption programme, but it is not clear that suppliers themselves are required to establish and implement anti-corruption procedures within their own organisations. <\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no publicly available 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 or the associated disciplinary involving its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company publishes a policy on the use of agents.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is some evidence that the company has procedures in place to conduct risk-based anti-bribery and corruption due diligence on its external partners, however there is no clear evidence to indicate that this includes agents. In addition, there is no evidence that agents and highest risk intermediaries are subject to enhanced due diligence, nor that due diligence is repeated every two years and\/or when there is a significant change in the business relationship.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company aims to establish the ultimate beneficial ownership of its agents and intermediaries as part of its due diligence procedure. <\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is some evidence that the company\u2019s Code of Ethics applies to sales representatives; however there is no clear evidence that this includes agents and intermediaries, nor is it clear that the company includes anti-bribery and corruption clauses in its contracts with these individuals or entities. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company considers incentive structures as a risk factor in agent behavior.<\/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 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 publicly available evidence that the company has formal procedures in place to conduct anti-bribery and corruption due diligence on its joint venture partners. The company indicates that it conducts checks on its external partners, however there is no clear evidence to suggest that this includes joint ventures.<\/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. In addition, there is no evidence that the company 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 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":"
There is some evidence that the company recognises the corruption risks associated with offset contracting. However, there is no evidence that the company has a dedicated body, department or team that is responsible for monitoring the company\u2019s offset activities, nor does it indicate that employees within this department receive dedicated training on the possible corruption risks associated with offsets. <\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no publicly available 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 its offset programme.<\/p>\n"},{"question":106,"commitment_area":14,"score":"N\/A","comments":"
The company publishes a statement to indicate that it does not participate in indirect offset projects as a matter of policy, due to the possible corruption risks associated with such activities. The company is therefore exempt from scoring on this question. <\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is some evidence that the company acknowledges the corruption risks associated with operating in different markets, however there is no clear evidence that the company has risk assessment procedures in place to identify such risks. There is also no evidence that the results of risk assessments are used to inform the company\u2019s operations in high risk markets. <\/p>\n"},{"question":108,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company provides a list of its fully consolidated subsidiaries and non-fully consolidated holdings. The company provides information on one subsidiary, but it is not clear whether this represents all of the company\u2019s holdings, nor is there evidence that the company provides further details such as its percentage ownership or country of incorporation\/operation for the entity. <\/p>\n"},{"question":109,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes information about its beneficial ownership or control structure on its website. There is no evidence that the company states that no individual owns 25% or more of shares or voting rights. In addition, although some information about the company appears to be available via the global beneficial ownership register openownership.org, there is no evidence that this data includes percentage ownership information. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is some evidence that the company publishes information on its main markets, however there is no evidence that it provides a percentage breakdown of its 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\/631","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=631"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=631"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}