There is evidence that the company\u2019s Chief Executive Officer makes a public statement in support of the company\u2019s ethics and compliance programme. However, the company receives a score of \u20181\u2019 because there is no evidence that the CEO\u2019s public statement directly addresses and mentions the company\u2019s stance against bribery and corruption. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company publishes an anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that this policy applies to all employees and board members as described in (a) and (b) in the question.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s Audit Committee, a designated board committee, is responsible for oversight of the company\u2019s ethics and compliance programme. There is evidence that this includes reviewing reports from management on the programme\u2019s performance and that the committee has authority to require that changes are made. <\/p>\n
The company also states that its Ethics & Compliance steering committee provides oversight of the ethics and compliance programme. There is evidence that the committee is comprised of senior managers and is chaired by the Executive Vice President, General Counsel and Chief Compliance Officer of Textron, who also reports to the Audit Committee.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that a designated senior executive \u2013 the Executive Vice President, General Counsel and Chief Compliance Officer - has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. There is evidence that this person has a direct reporting line to the Audit Committee, which provides oversight of the anti-bribery and corruption programme. There is also evidence of reporting and feedback activities between this person and the Audit Committee as part of the company\u2019s reporting structure.<\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company conducts annual assessments of its business units based on ethics and compliance risks. There is evidence that the results of these reviews are used to develop tailored mitigation plans. There is evidence that the results of such assessments are reported to, and reviewed by, the Audit Committee, which provides oversight of the company\u2019s compliance programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s ethics and compliance programme is subject to regular audit. There is evidence indicating that the programme is audited to ensure that it is consistent with the business risks facing the company and that the results are used to update the ethics and compliance programme. The company indicates that this process takes place as part of an annual review, and there is evidence that findings are presented to the board-level Audit Committee. There is evidence that ownership of the process to implement updates and improvements to the programme rests with the Steering Committee on Corporate Ethics and Compliance Program.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly commits to investigating incidents, and that there is a specific procedure in place to deal with whistleblowing cases. <\/p>\n
However, the company receives a score of \u20181\u2019 because publicly available information on the investigatory procedure does not describe the whole investigation process from receipt to final outcome. There is also no clear evidence that investigations are handled by an independent team or report to an independent board member. Additionally, there is no evidence that the company makes a commitment to providing whistleblowers with updates on the outcome of investigations, nor that summary information on all investigations is reviewed by a central body on at least an annual basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company assures itself of the quality of its internal investigations. <\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence indicating that the company commits to report material findings of bribery and corruption from investigations to Audit Committee. However, there is no evidence that an appropriate senior individual is responsible for ensuring that the disclosure of criminal offences to relevant authorities is evaluated and acted upon if necessary. <\/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":"
Based on publicly available information, there is evidence that the company provides a training module for employees that outlines the basic principles of its ethics and compliance programme. There is evidence that training is provided for all employees across the company\u2019s operations and geographies, and in all relevant languages. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear how often employees are required to refresh their training on this subject. There is also no clear evidence that the company\u2019s training includes an overview of the whistleblowing options available to employees.<\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company provides tailored anti-bribery and corruption training for employees in different positions based on an assessment of their role and exposure to corruption risk. There is evidence that training is provided to employees in management positions, and the company indicates that employees in high risk positions must undertake periodic training. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that it provides tailored anti-bribery and corruption training to its board members. It is also not clear from publicly available information that employees in high risk positions specifically are required to refresh their training on an annual basis. <\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company measures the effectiveness of its anti-bribery and corruption communications and training programme, by indicating that it monitors the completion rates of its online training modules. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it measures or reviews the effectiveness of its initiatives beyond completion rates, for example through dedicated questions in staff surveys or audits, on a regular basis. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, 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":"1","comments":"
Based on publicly available information, there is evidence that the company commits to support employees who refuse to act unethically, even when it might result in a loss of business. 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 specifically through anonymised surveys or other clearly stated means. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is also evidence indicating that this commitment extends to the company\u2019s business partners. <\/p>\n
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 commitment specifically through surveys, usage data, or other clearly stated means.<\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
There is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme, including an external whistleblowing service operated by a third party. There is evidence that the company\u2019s channels allow for confidential and, wherever possible, anonymous reporting and are available and accessible to all employees in all jurisdictions where the company operates. There is also evidence that the company\u2019s channels are available in all relevant languages and to the company\u2019s business partners.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has policies for conflicts of interest which apply to all employees and board members, and refer to actual, potential and perceived conflicts. The publicly available policies make specific reference to conflicts related to employee relationships, outside employment and financial interests. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its policies make specific reference to conflicts of interest concerning government relationships.<\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has procedures to identify and declare conflicts of interest, including actual, potential and perceived conflicts. For employees, the company states that the employee\u2019s Ethics & Compliance Officer or Company Legal Counsel must approve conflicts. There is evidence that Directors must report potential conflicts to the board Chairman, the CEO and the chair of the Nominating and Corporate Governance Committee. Additionally, the company makes publicly available examples of criteria for recusals of directors. The company states that breaches of its Business Conduct Guidelines, which contain policies covering conflicts of interest, will lead to disciplinary action.<\/p>\n
The company receives a score of \u20181\u2019 because there is no evidence that employees and directors are required to make conflict declarations that are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
Based on publicly available information, 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 the contracted services of politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is evidence that the company has a policy on corporate political contributions. The company\u2019s policy indicates that it may make political contributions when approved by individuals with legal expertise. In addition, there is evidence that that the company is associated with a Political Action Committee (PAC) in the United States.<\/p>\n
Since the company does not prohibit political donations and is associated with a PAC, it receives a score of \u20180\u2019 in line with the scoring criteria. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any details of its political contributions or Political Action Committee (PAC) disbursements, nor a statement that it has not made any political contributions in the last 12 months.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is evidence that the company has procedures governing charitable donations and sponsorships. There is evidence that the company publishes some information covering its charitable donations, including the recipients and amounts of donations in its annual Corporate Responsibility Report. <\/p>\n
However, the company receives a score of \u20180\u2019 because there is no clear evidence that the procedures governing charitable donations or sponsorships include measures to ensure donations are not used as vehicles for bribery and corruption. It is noted that further details may be contained in the company\u2019s Global Anti-Corruption Compliance Policy but this document is not publicly available.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company has a policy or procedure on lobbying. A summary of its Global Anti-Corruption Compliance policy refers to risk-based due diligence and oversight of lobbyists, but there is no publicly available evidence that the company has policies and controls in place to ensure that lobbying activities are conducted responsibly. <\/p>\n"},{"question":79,"commitment_area":11,"score":"1","comments":"
There is some evidence that the company provides information on its lobbying topics and activities, by providing a direct link to the United States House of Representatives Office of the Clerk website where its official disclosures can be found. <\/p>\n
However, there is no evidence that the company publishes details about its broader public policy aims or positions, nor that it discloses any further information on its own website. The company also does not publish any information about its lobbying activities outside of the United States, nor a statement that it does not lobby outside of the United States. <\/p>\n"},{"question":80,"commitment_area":11,"score":"1","comments":"
he company provides some details of its lobbying expenditure, by providing a direct link to the United States House of Representatives Office of the Clerk website where its official disclosures can be found. <\/p>\n
However, this expenditure data is not broken down into internal, external or association lobbyists and does not include an explanation of how these figures have been calculated. Furthermore, the company does not publish its lobbying expenditure worldwide. <\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality. There is evidence that this policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter, and also that it explicitly addresses the risks associated with gifts and hospitality given to public officials.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that all gifts and hospitality above certain thresholds 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":"
Based on publicly available information, there is evidence that the company's business units have specialised procurement departments which are involved, in some capacity, in the establishment and oversight of supplier relationships. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its business units require the involvement of the procurement departments for establishing new suppliers over a certain threshold. It is also unclear whether these bodies are the main bodies in charge of managing the company\u2019s supplier base and procurement activities. In addition, there is no evidence that the company assures itself of the involvement of its procurement departments at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company conducts risk-based anti-bribery and corruption due diligence when engaging or re-engaging with its suppliers. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company requires its suppliers to have adequate anti-bribery and corruption policies and procedures in place. There is evidence that the company requires suppliers to abide by its Code of Conduct for Suppliers and Other Business Partners, which prohibits bribery and facilitation payments and includes policies that cover conflicts of interest, gifts & hospitality and whistleblowing.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence to suggest that the company takes active steps to ensure that its suppliers abide by its code or have adequate anti-bribery and corruption policies and procedures in place.<\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. However, the company receives a score of \u20181\u2019 because this evidence is in the form of a simple statement and it is unclear how the company 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 relating to its suppliers, or the associated disciplinary actions.<\/p>\n"},{"question":87,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy covering the use of agents. There is evidence that the company provides limited details of the controls it has in place to mitigate the risks associated with agents.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it makes a clear commitment to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function, nor that it provides details of the corruption risks associated with the use of agents. There is also no evidence that the company specifies that its policy covering agents applies to subsidiaries and joint ventures.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
In publicly available evidence, the company states that it conducts risk-based due diligence on agents. However, the information provided is insufficiently detailed to satisfy the requirements for score \u20181\u2019.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company aims to establish the ultimate beneficial ownership of its agents and intermediaries.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is evidence that the company requires agents to adhere to its Code of Conduct for Suppliers and Other Business Partners. There is also evidence that the company includes anti-bribery and corruption compliance clauses in its contracts with these entities.<\/p>\n
However, the company receives a score of \u20180\u2019 because there is no evidence that it includes audit and termination rights in its contracts with agents and intermediaries.<\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company recognises 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 or and on behalf of the company.<\/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":"
In publicly available evidence, the company states that it conducts risk-based due diligence on joint venture partners. However, the information provided is insufficiently detailed to satisfy the requirements for score \u20181\u2019.<\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company requires joint venture partners to comply with its Business Conduct Guidelines. There is also evidence that the company requires anti-bribery and corruption clauses in its contracts with joint venture partners.<\/p>\n
However, the company scores \u20181\u2019 as it is unclear based on publicly available information how it ensures that these standards are implemented by joint venture partners in practice. There is also no evidence that the company includes audit and termination rights in its contracts with joint venture partners.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company makes a clear commitment 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 that the company has a dedicated body, department or team responsible for monitoring of its offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
There is some evidence that the company conducts risk-based anti-bribery and corruption due diligence on its offset providers and partners. However, the company receives a score of \u20181\u2019 because there is no further evidence that this process includes checks on beneficial ownership or that it seeks to assure itself of the legitimacy of the investment.<\/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":"
Based on publicly available information, 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":"
There is evidence that the company publishes a list of its subsidiaries in its annual 10-K regulatory filing. The company discloses information on its percentage ownership of each subsidiary and its country of incorporation.<\/p>\n
However, the company scores \u20181\u2019 as the list only covers certain subsidiaries and there is no evidence that the company discloses details of all of its holdings. There is also no evidence that the company discloses the countries of operation for each entity in its list.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is a publicly listed company trading on the New York Stock Exchange and therefore is automatically awarded a score of \u20182\u2019.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
The company publicly discloses that sales to the United States Department of Defense constituted approximately 24% of its consolidated revenues in 2018. However, the company receives a score of \u20180\u2019 because there is no evidence that it publishes information on the customers of at least 50% of its defence sales. <\/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\/634","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=634"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=634"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}