There is evidence that the company has a publicly stated commitment to anti-bribery and corruption, however there is no evidence that this statement is authorised and endorsed by the a senior leadership figure. <\/p>\n"},{"question":55,"commitment_area":7,"score":"0","comments":"
The company publishes some anti-bribery and corruption guidance on its website, but it does not provide further details of specific controls that would constitute a comprehensive anti-bribery and corruption policy. Although the company states that it prohibits bribery and corruption, it does not address payments to public officials or facilitation payments, nor does it indicate that it applies to all employees and board members. <\/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 executive or 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.<\/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 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 the board or, if necessary, to 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":"1","comments":"
There is evidence that the company provides training on anti-bribery and corruption, which appears to include the whistleblowing options available to employees. However, it is unclear how frequently training is conducted and whether it is systematically provided to all employees across all divisions, all countries\/regions of operation or in all appropriate languages.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company tailors its anti-bribery and corruption training for 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":"1","comments":"
There is some evidence that the company commits to support and protect employees who refuse to act unethically. The company states that integrity and ethical principles are key corporate values and encourages employees to speak up if they have any concerns. 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":"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 a whistleblowing line for employees to raise concerns or report suspected incidents of bribery or corruption. There is evidence that this channel allows for anonymous reporting. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it provides an externally operated channel (i.e. one operated by a third party), nor is there clear evidence that reports are treated confidentially or that the channel can be used to seek advice on the company\u2019s anti-bribery and corruption policy. There is also no clear evidence that the channel is available to all employees in any country of operation, in multiple languages, or to any employees of third parties, suppliers or joint venture partners. <\/p>\n"},{"question":71,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the company has a conflict of interest policy.<\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company has procedures in place for managing 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 discloses 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 and\/or procedure covering charitable donations and\/or sponsorships.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy and\/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 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. The company states business associates must meet a certain standard of ethical business conduct, but does not specifically refer to a publicly available anti-bribery and corruption policy that applies specifically to suppliers. <\/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 on 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, nor does the company commit to not engaging or terminate its engagement with agents or intermediaries if beneficial ownership cannot be established.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is no clear evidence that the company\u2019s anti-bribery and corruption policy applies to agents or that it 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's incentive structures for agents are designed to minimise risks of bribery and corruption or that incentive structures are recognised 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 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 conducts 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 its behalf. <\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of its offset obligations and\/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, or that risk assessment procedures 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 publishes a list of its subsidiaries or affiliated entities.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is a wholly-owned subsidiary of Griffon Corporation, a company publicly listed on the New York Stock Exchange. The company is therefore not required to disclose information on its ownership and 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 any details 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\/632","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=632"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=632"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}