Based on publicly available information, there is evidence that the company has a publicly stated anti-corruption commitment which details its stance against corruption and bribery within the organisation. It is clear that this commitment was authorised and endorsed by the company's leadership.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that the company publishes a clear anti-bribery and corruption policy that prohibits bribery, facilitation payments, payments to public officials and commercial bribery. The company indicates that its policy applies to all groups as specified in (a) and (b) in the question. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that the board is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. The company also indicates that an Ethics Committee provides oversight of certain anti-corruption activities, with a direct reporting line to the board. There is evidence that the board\u2019s responsibilities include reviewing reports from management on the programme\u2019s performance, along with the results of internal and external audits, and there is evidence that it has the authority to require that any necessary changes are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
Based on publicly available information, there is evidence that a managerial-level individual \u2013 the Head of CSR & Compliance \u2013 has been assigned ultimate responsibility for implementing and managing the company's anti-corruption compliance programme. It is clear that this person has a direct reporting line to the board. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence to indicate that the Head of CSR & Compliance is a senior executive.<\/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 in place that informs the design of its anti-bribery and corruption programme. The company indicates that the results of risk assessments are reviewed by the board on at least an annual basis, or when the results of the risk assessments reveal significant findings. 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":"2","comments":"
There is evidence that the company\u2019s entire 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. This includes provisions for continuous improvement, supplemented by an internal audit annually. There is also evidence that high-level audit findings are presented to the board, with ownership assigned to individuals for planned updates and improvements to the anti-bribery and corruption programme.<\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
Based on publicly available evidence, the company publicly commits to investigating incidents promptly, independently and objectively. There is evidence that the company takes steps to ensure the independence of its investigations. It commits to establishing root causes, putting in place remediation plans and reporting investigative findings to senior management and the board. <\/p>\n
For whistleblowing cases, there is evidence that the company has a procedure in place that stipulates documentation and actions to be taken at every step of the case, from receipt to final outcome, and the company commits to ensure whistleblowers are informed of the outcome, if they so wish. A senior central body of the holding or parent company receives and reviews summary information of all incidents and their status in the organisation and its subsidiaries, on an annual basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"2","comments":"
There is evidence that the company assures itself of the quality of its internal investigations, including those reported through whistleblowing channels. There is evidence that the company provides specific training for the staff tasked with conducting investigations. The company indicates that any complaints about the handling of concerns and investigations are overseen by an appropriate senior management officer and that it has a procedure in place to handle the escalation of complaints. The company\u2019s investigations procedure is subject to review at least every three years, or in response to any relevant changes in the regulatory environment.<\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company makes a clear commitment to report material findings of bribery and corruption from investigations to the board. There is also evidence that an appropriate senior individual is ultimately responsible for ensuring that the disclosure of criminal offences to relevant authorities is evaluated and acted upon if found necessary. <\/p>\n"},{"question":63,"commitment_area":8,"score":"2","comments":"
The company makes a public statement that there were no reports, investigations or disciplinary actions relating to employees during the most recent reporting year. There is evidence that the company publishes and updated this information on an annual basis. <\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides training that outlines the principles of the anti-bribery and corruption policy including the whistleblowing options available to employees. The company provides this training to all employees, across all divisions and countries of operation and in all appropriate languages. The company states that employees are required to undertake refresher trainings on the anti-corruption programme at least every two years.<\/p>\n"},{"question":65,"commitment_area":9,"score":"2","comments":"
There is evidence that the company tailors its anti-bribery and corruption training programme to the different levels of risk facing employees in different roles, with specific reference to those in high risk positions, middle management and board members. There is evidence that employees working in high risk positions are required to refresh their training in this area on at least an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company reviews its anti-bribery and corruption communications and personnel training programme. The company assures itself of this on a continuous basis through the monitoring of training and there is evidence that results are used to update parts of the company's anti-bribery and corruption communications and training programme. The company indicates that its training programme is updated on this basis every two years. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company\u2019s incentive schemes for employees incorporate ethical and anti-corruption principles. The company states that it reviews its incentive structures to ensure that they do not undermine the its anti-corruption efforts and commitment, however it does not provide further details on the way in which such schemes are designed. <\/p>\n"},{"question":68,"commitment_area":9,"score":"2","comments":"
There is evidence that the company commits company to protect and support any employee who refuses to act unethically, in keeping with the company\u2019s ethical and anti-bribery and corruption values and policy, even where such actions result in a loss of business or other disadvantage to the company. There is evidence that the company assures itself of its employees' confidence in this commitment through anonymised surveys.<\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. This policy applies to all employees across the organisation, including those engaged by the group as third parties, suppliers and joint venture partners. There is evidence that the company assures itself of its employees\u2019 confidence in this commitment through surveys.<\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-corruption compliance programme. The company indicates that its channels are sufficiently varied to allow employees to raise concerns across the management chain and to external. These channels allow for confidential and, wherever possible, anonymous reporting. <\/p>\n
In addition, there is evidence that the company\u2019s channels are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners, and in all relevant languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy for conflicts of interest that covers actual and perceived conflicts of interest. The company\u2019s policy specifically addresses possible conflicts arising from employee and government relationships, financial interests and other employment. In addition, there is evidence that this policy applies to all employees and board members. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has some procedures in place to identify, declare and manage conflicts of interest, including actual and potential conflicts. The company states that employees should seek advice in instances where potential conflicts of interest arise. The company provides one example of a criterion for recusal. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that all employee and board member declarations are held in a dedicated central register that is accessible by those responsible for oversight of the process. There is also no indication that a central body or senior individual is responsible for oversight and accountability of handling cases, nor that the policy states that disciplinary measures will apply if the policy is breached. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the company has a policy regulating the employment of current or former public officials.<\/p>\n"},{"question":74,"commitment_area":10,"score":"2","comments":"
The company publishes a clear statement that it does not engage or contract the services of serving politicians. <\/p>\n"},{"question":75,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy on corporate political contributions. The company clearly states all political contributions, whether by the company itself or by any other entity or individual acting on the company's behalf, are prohibited in all circumstances.<\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
The company publishes a clear statement that it does not make any political contributions, and therefore it is exempt from scoring on this question. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy and procedure covering charitable donations and sponsorships. There is evidence that these policies include measures to ensure that such donations are not used as vehicles for bribery and corruption. The company indicates that all contributions must be appropriately registered. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it specifies criteria for donations, procedures for senior sign-off on donations or that it requires due diligence to be undertaken on recipients. There is also no evidence that the company publishes full details of all charitable donations made on an annual basis, including details of the recipient, amount, country of recipient and which corporate entity made the payment.<\/p>\n"},{"question":78,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy on lobbying. There is evidence that the company has guidelines in place that describe responsible lobbying behaviour and outline the standards of conduct expected from lobbyists. There is also evidence that the company has specific oversight mechanisms in place. This policy applies to all employees, board members and third parties lobbying on the company\u2019s behalf.<\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company publishes any information on its lobbying aims, topics or activities. The company provides some information on its memberships with trade associations and organisations, and indicates that its involvement in public affairs primarily takes place through these channels, but it does not provide further information on its aims or the topics on which it lobbies. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any details of its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"2","comments":"
There is evidence that the company has a policy on the giving and receipt of gifts and hospitality with clear procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy also addresses the risks associated with gifts and hospitality given to and received from domestic and foreign public officials. <\/p>\n
In addition, the company's policy includes a clear statement that all gifts and hospitality above certain thresholds are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.<\/p>\n"},{"question":82,"commitment_area":12,"score":"2","comments":"
There is evidence that the company requires the involvement of its procurement department in the establishment of new suppliers. This department is ultimately responsible for providing oversight of the company's supplier base. There is evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means, such as an audit, at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has formal procedures to conduct due diligence on its suppliers. There is evidence to suggest that highest risk suppliers are subject to enhanced due diligence.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its due diligence includes checks on the ultimate beneficial ownership of suppliers. Furthermore, there is no evidence that the company repeats due diligence at least every two years or whenever there is a change in the business relationship. There is also no evidence to suggest that the company might be willing to review or terminate supplier relationships if a red flag highlighted in the due diligence cannot be mitigated. <\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company states that all contracts with suppliers include the company\u2019s anti-corruption provisions. In addition, the company requires that suppliers adhere to its Code of Conduct for Suppliers and Service Providers, which prohibits bribery and facilitation payments, and stipulates procedures to address conflicts of interest, gifts and hospitality and whistleblowing. There is evidence that the company assures itself of this when onboarding new suppliers, and includes audit rights in its contracts with suppliers to ensure their continued compliance.<\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company takes steps to ensure that the substance of its anti-corruption programme is required of sub-contractors throughout its supply chain. However, the company receives a score of \u20181\u2019 because it does not provide further details on how it ensures 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 disciplinary actions involving its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a clear policy to control the use of agents which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. There is evidence that this policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures. <\/p>\n"},{"question":89,"commitment_area":13,"score":"2","comments":"
Based on publicly available evidence, the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging or re-engaging any agents and intermediaries. The company states that it conducts this due diligence at least every two years or when there is a significant change in the business relationship, and indicates that all agents and highest risk intermediaries are subject to enhanced due diligence. There is evidence that the company commits to not engaging or terminating its engagement with agents or intermediaries where the risks identified in the due diligence cannot be mitigated. <\/p>\n"},{"question":90,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has formal procedures in place to establish the beneficial ownership of agents prior to engaging them, and that it repeats this process at least every two years or when there is a significant change in the business relationship. The company idicates that it operates a risk based beneficial ownership verification policy, whereby all agent provided information is verified and high risk agent\u2019s information is verified. There is evidence that the company commits to not engaging or terminating its engagement with agents or intermediaries where ultimate beneficial ownership cannot be established. <\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
There is evidence that the company\u2019s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. In addition, there is evidence that all agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include clear audit rights and termination rights to detect, control and prevent breaches.<\/p>\n"},{"question":92,"commitment_area":13,"score":"2","comments":"
There is evidence that incentive structures for agents are explicitly highlighted and addressed as a factor in bribery and corruption risk. The company commits to only paying agents into local bank accounts, and indicates that its payments reflect the value they create for the company.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company\u2019s approach to agent incentives includes a clear threshold on sales-based commissions to agents so that payments do not exceed a proportion of the net fee to the agent. There is also no evidence that remuneration to agents is paid in staged payments over the course of their contract, based on clear milestones.<\/p>\n"},{"question":98,"commitment_area":13,"score":"1","comments":"
There is evidence that the company publishes an aggregate figure of the number of marketing consultants or agents that it currently employs. However, the company receives a score of \u20181\u2019 because it does not provide further information on its agents, nor is there evidence that this list is published or updated on an annual basis. <\/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 disciplinary actions involving its agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering and while operating in a joint venture. There is evidence that the company conducts enhanced due diligence for joint ventures operating in high risk countries or with high risk partners. <\/p>\n
However, it is not clear that the company\u2019s due diligence includes checks on the ultimate beneficial ownership of the partner company. In addition, there is evidence that its due diligence is only conducted before engaging joint ventures and is not repeated at least every two years.<\/p>\n"},{"question":101,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company requires its joint ventures to maintain its own ethics and compliance program and requires anti-bribery and corruption clauses in its contracts with joint venture partners. The company states that it includes audit and termination rights in its contracts with business partners.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company commits to taking an active role in the prevention of bribery and corruption in all of its joint ventures. <\/p>\n"},{"question":103,"commitment_area":14,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has policies and procedures in place to address corruption risks associated with offset contracting. The company indicates that it ensures any offset partners adhere to its anti-bribery and corruption standards through appropriate contractual clauses. <\/p>\n
In addition, there is evidece that the company has a dedicated body, department or team responsible for the monitoring and oversight of the company\u2019s offset activities throughout the lifecycle of each project. The company indicates that all employees within this body, department or team receive tailored anti-bribery and corruption training based on the potential corruption risks associated with offsets.<\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
Based on publicly available information, there is evidence that the company conducts due diligence on all business partners as part of its involvement in an offset project. There is also evidence that the company seeks to assure itself of the legitimacy of offset obligations. <\/p>\n
However, there is no evidence that the company\u2019s due diligence includes checks on beneficial ownership or conflict of interest. It is also not clear that the company refreshes this due diligence continuously or when there is a significant change in the business relationship or the nature of the partner.<\/p>\n"},{"question":105,"commitment_area":14,"score":"2","comments":"
The company publishes a statement that it does not employ any agents or brokers as part of its offset programme. Since the company has adopted this as its publicly available position, the company therefore receives a score of \u20182\u2019.<\/p>\n"},{"question":106,"commitment_area":14,"score":"1","comments":"
Based on publicly available information, the company publishes some information about the beneficiaries of its offset projects. However, the company receives a score of \u20181\u2019 because there is no evidence that this represents a comprehensive list of its offset projects, nor is it clear that the details provided relate specifically to indirect offset projects. It is also not clear that this information is published and updated on at least an annual basis. <\/p>\n"},{"question":107,"commitment_area":15,"score":"1","comments":"
Based on publicly available information, there is evidence that the company acknowledges the corruption risks associated with operating in different markets and there is evidence that it has a dedicated assessment process in place to assess such risks. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further information on its risk management procedures and there is no evidence to suggest that the results of these assessments have an impact on business decisions or trigger the implementation of additional controls. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
Based on publicly available information, 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 and the country of incorporation. There is evidence that this list is current and updated on at least an annual basis and complete at the time of publication. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that this list includes the country or countries of operation for each entity. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that information about the company\u2019s beneficial ownership is publicly available. The company discloses the name of the entity that is its legal owner in its publicly available reporting documents. In addition, there is evidence that the company\u2019s full beneficial ownership information \u2013 including the names, addresses and voting rights of all individuals with an ownership stake \u2013 is available in a freely accessible national corporate register and through a global corporate register. This information indicates that the company has six beneficial owners, each with a 20% share of voting rights. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
The company publishes some information on its defence sales per geographic region and per business division. However, there is no evidence that the company publishes any information on its defence sales by major country or 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\/633","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=633"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=633"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}