The company has a publicly stated anti-bribery and corruption commitment, which details its stance against any form of bribery or corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company\u2019s executive board. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
The company publishes an anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members as described in (a) and (b) above.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that the company\u2019s board, with assistance from two designated board committees, the Audit Committee and the Executive Board Department for Compliance and Legal, is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from management on the programme\u2019s performance, along with the results of internal and external audits, and ensuring that required changes are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior executive \u2013 the Chief Compliance Officer \u2013 has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme and that this person has a direct reporting line to the Executive Board member responsible for Legal & Compliance. There is evidence of reporting and feedback activities between this person and the board as part of the company\u2019s reporting structure through participation in Board and Audit Committee meetings. This person is also responsible for a larger network of compliance managers and officers in different Group companies and business divisions. <\/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 that informs the design of its anti-bribery and corruption programme. 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. The company states that its risk assessment procedure is continually updated. The company states that risk assessments are conducted continuously and that the results of these assessments are reviewed by the board at least quarterly.<\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
There is evidence that the company\u2019s compliance programme is subject to a regular audit process to ensure that it is consistent with best practice and the business risks facing the company. This includes provisions for continuous improvement and is supplemented by external audits. The company\u2019s annual reports show that it conducted such audits in 2017\/18 and 2018\/19. The company states that high level audit findings are presented to the board on at least a quarterly basis, and that ownership for implementing recommended changes is assigned to the Corporate Compliance Department. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is some evidence that the company has a system for tracking, investigating and responding to bribery and corruption allegations or incidents, including those reported through whistleblowing channels. There is some evidence that the company documents investigations and updates whistleblowers on progress. There is evidence that investigations are handled by an independent team. The company publishes an overview of its investigations process, from receipt to final outcome. <\/p>\n
However, there is no publicly available evidence that a central body reviews summary information on investigations on a regular or annual basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"2","comments":"
There is some evidence that the company assures itself of the quality of its internal investigations and that the staff conducting investigations are properly trained and qualified. The company states that its Head of the Investigation Department and Chief Compliance Officer oversee the handling of complaints about the investigations process. The company additionally states that it reviews its investigations process regularly and in response to any changes in the regulatory environment.<\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
There is evidence that the company reports material findings of bribery and corruption from investigations to the board. The company states that its Chief Compliance Officer 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":"1","comments":"
The company publishes some high-level information on its ethics and compliance-related incident reports received, including through whistleblowing channels, and subsequent investigations involving company employees at all levels, including board members. <\/p>\n
However, the data is insufficiently detailed, and does not include exact figures of the number of reports received, the number of investigations launched, and the number of disciplinary actions as a result of investigation findings. There is also no evidence that the company publishes this data on an annual basis. <\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
There is some evidence that the company provides a training module that outlines the basic principles of its anti-bribery and corruption policy, including the whistleblowing options available to employees. The company states that training is delivered to all employees across all divisions and countries of operation, and in all appropriate languages. Although the company does not provide a specific timeframe, there is evidence that employees undertake training regularly (at least every three years). <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","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 the three categories of employee referred to in the question. <\/p>\n
However, the company states that employees in high-risk positions must refresh their training in this area regularly but does not specify if this occurs on at least an annual basis. <\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
There is evidence that the company reviews its anti-bribery and corruption communications and personnel training programme through KPI measures of participant and fulfilment rates. In addition, the company reviews the effectiveness of training through staff evaluations, surveys and workshops. The company commits to assuring itself of this on a continuous basis. There is evidence that the results of such reviews are used to update specific parts of the company's anti-bribery and corruption communications and training programme. <\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company incorporates ethical and anti-corruption principles in its incentive schemes for its employees and executives by way of ethical conduct evaluations as part of performance appraisals. The company states that incentives are denied on the basis of compliance infractions.<\/p>\n
However, there is no evidence that the company ensures that financial rewards are proportionate to the salaries of high-risk employees. Although the company indicates that more detail on these measures can be found in an appendix, this document is not publicly available.<\/p>\n"},{"question":68,"commitment_area":9,"score":"2","comments":"
There is evidence that the company expects employees to act ethically, even if this could result in loss of business, and that it assures itself of employees\u2019 confidence in this commitment through surveys.<\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":"
There is evidence that the company promotes a policy of non-retaliation against whistleblowers who report concerns via its reporting system, which is open to all company employees and those employed by the group as third parties. 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":"
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. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and to relevant external bodies. These channels allow for confidential and, wherever possible, anonymous reporting. They are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as external parties, and in all relevant languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence that the company formally addresses conflicts of interest as a corruption risk, and has a policy that defines conflicts of interest, including those actual, potential and perceived. This policy covers employee relationships, financial interests, government interests and other employment and applies to all employees and board members.<\/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. Employees must declare conflicts of interest in writing to their superiors and the responsible Compliance Officer or Regional Compliance Officer. The company provides examples of criteria for recusals and also states that disciplinary measures will apply if the conflicts of interest policy is breached. The company states that it has a central repository for conflict of interest declarations when it is assessing candidates for leadership positions, which is accessible to the compliance officers responsible for overseeing the process. <\/p>\n
However, there is no evidence that the company has a unified repository which holds all employee and board member declarations and which is accessible to those responsible for overseeing conflict of interest management across the organisation. <\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy that addresses the risks associated with the employment of public officials. The company indicates that it implements a cooling-off period when recruiting such officials as legally required. <\/p>\n
However, the policy does not indicate whether the cooling-off period is at least 12-months long or whether it requires senior compliance officer approval for the initiation of any employment discussions with former or current public officials.<\/p>\n"},{"question":74,"commitment_area":10,"score":"2","comments":"
The company publishes a clear statement that it has a policy to not contract serving politicians at any level. <\/p>\n"},{"question":75,"commitment_area":11,"score":"2","comments":"
The company publishes a statement that it prohibits corporate political contributions. Corporate political contributions whether by the company itself or by any other entity or individual acting on the company's behalf are prohibited under any circumstance.<\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
The company states that it makes no political contributions and is therefore exempt from scoring on this question.<\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is some evidence the company has a policy on charitable donations and sponsorships. <\/p>\n
However, the company does not publish details of the donations made.<\/p>\n"},{"question":78,"commitment_area":11,"score":"2","comments":"
There is evidence that the company has a policy that defines lobbying which applies to all employees and board members, and also applies to both internal and external lobbyists. The company states that all lobbyists are contractually obliged to adhere to the same standards as outlined in the company\u2019s Code of Conduct. There is evidence of specific controls in place regulating lobbyists\u2019 activities, including due diligence, audit rights, anti-corruption clauses and payment subject to specific, agreed activities. <\/p>\n"},{"question":79,"commitment_area":11,"score":"1","comments":"
The company publishes limited details of the topics on which it lobbies through an active link to an external online register maintained by the European Union. <\/p>\n
However, it does not publish information on the aims of its activities in the European Union. There is also no evidence that the company publishes details of the aims and topics of its lobbying activities in all jurisdictions in which the company operates. <\/p>\n"},{"question":80,"commitment_area":11,"score":"1","comments":"
The company publishes a summary of the costs incurred via its lobbying activities in Germany and in the European Union covering the most recent financial year. <\/p>\n
However, the data provided does not cover the company\u2019s lobbying activities in all jurisdictions. Additionally, the company\u2019s dataset is lacking sufficient detail: it does not provide a breakdown of spending by corporate entity, or differentiate between internal or external lobbyists, or association lobbying expenditures. <\/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 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 explicitly addresses the risks associated with gifts and hospitality given to and\/or received from domestic and foreign public officials, by specifying a different financial threshold. There is further evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated 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 specialist procurement in the establishment of all new supplier relationships. The company states that these departments are ultimately responsible for providing oversight of the company's supplier base. There is also evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through regular audits of the company\u2019s procedures at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence the company conducts risk-based anti-bribery and corruption due diligence when engaging or re-engaging with suppliers. The company states that its suppliers perform a self-assessment, however, there is no clear evidence that prior to engaging suppliers the company carries out due diligence or other screening checks designed to identify bribery and corruption risks. <\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
There is evidence that the company ensures that all of its suppliers have adequate anti-bribery and corruption policies and procedures in place, including in relation to conflicts of interest, gifts and hospitality, as well as a prohibition of facilitation payments. There is evidence that the company takes active steps to ensure this by requiring that all suppliers follow its own Supplier Code of Conduct or have comparable standards in place. The company conducts assurance when onboarding new suppliers. Additionally, there is evidence that the company assures itself of its suppliers\u2019 standards of conduct periodically throughout the business relationship. The company states that its whistleblowing channels are open to all suppliers and sub-contractors. <\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
There is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place and that the substance of its anti-corruption and bribery programme and standards are included in sub-contracts throughout the supply chain. The company states that it ensures this commitment in practice by requiring suppliers to sign a declaration that they will adhere to the standards in the company\u2019s Code of Conduct in all its dealings with suppliers. The company also publishes a clear anti-corruption statement that all suppliers are obliged to endorse and adhere to in their operations. <\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
While there is evidence the company commits to investigating incidents involving suppliers, 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":"2","comments":"
There is evidence that the company has a policy covering the use of agents, which highlights the corruption risks associated with agents and provides details of controls to mitigate these risks, including due diligence on agents. The company also states that its policy applies to all companies in its corporate group, including subsidiaries and joint ventures. The company indicates that it commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. <\/p>\n"},{"question":89,"commitment_area":13,"score":"2","comments":"
There is some evidence that the company conducts due diligence on its agents, and enhanced due diligence on highest-risk agents. The company commits to termination of the relationship if the highlighted risks cannot be mitigated. The company states that it conducts due diligence both before establishing a relationship with a new agent, and when re-engaging with an existing agent. Additionally, the company states that due diligence on all agents is repeated every two years. <\/p>\n"},{"question":90,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has formal procedures to establish the beneficial ownership of business partners before forming a relationship with a new agent, and when re-engaging with an existing agent. The company commits to not engaging with an agent if there are concerns around beneficial ownership. There is some evidence that the company independently verifies the beneficial ownership of the highest-risk agents. The company additionally states that the due diligence process for all agents, including checks on ultimate beneficial ownership, is repeated every two years.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","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. All agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include audit rights. <\/p>\n
However, the company does not explicitly state that it includes termination rights in its contracts with agents and therefore receives a score of \u20180\u2019. <\/p>\n"},{"question":92,"commitment_area":13,"score":"2","comments":"
There is evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. There is evidence the company has a threshold regarding maximum commission payments to agents and requires compensation to be proportionate and reasonable in relation to the activities carried out. The company states that it prohibits cash payments and will only make payments into local bank accounts, apart from in exceptional circumstances where the agent provides sufficient justification. <\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
The company states that it publishes its business relationships with agents only in case of mutual agreement. However, there is no evidence that the company has published 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":"
The company publishes limited information in relation to certain investigations involving agents. However, there is no evidence the company publishes data on all ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving 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 also evidence that the company\u2019s due diligence process includes checks on ultimate beneficial ownership.<\/p>\n
However, there is no evidence that joint ventures operating in high-risk markets or with high-risk partners, such as state-owned enterprises, are subject to enhanced due diligence. There is no evidence that due diligence is repeated at least every two years or when there is a significant change in the business relationship<\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies in all of its joint ventures. The company states that it ensures robust policies and procedures are implemented in all joint ventures, by incorporating the venture into its own anti-corruption programme if the company is the majority shareholder. Otherwise the company states that it works jointly to develop a programme based on the same anti-corruption principles. The company states that all joint venture contracts contain anti-corruption clauses and that audit and termination rights are applied in joint venture agreements if it is deemed necessary.<\/p>\n
However, the company receives a score of \u20181\u2019 because it does not include audit and termination rights as standard in all of its joint venture partnerships. <\/p>\n"},{"question":102,"commitment_area":13,"score":"2","comments":"
The company explicitly commits to take an active role in preventing bribery and corruption in all of its joint ventures. There is clear evidence to support the company's commitment through practical examples. <\/p>\n"},{"question":103,"commitment_area":14,"score":"1","comments":"
The company recognises the corruption risks associated with offset contracting and there is evidence that there is a specific department, the Industrial Cooperation Department, involved in managing the company\u2019s offset obligations across divisions and for the duration of the project lifecycle. The company also states that its business unit most commonly involved in offset contracting, the Marine Systems business unit, has a specific department dedicated to overseeing and managing all aspects of its offset obligations.<\/p>\n
However, it is unclear whether the staff of this department is given anti-corruption training specific to their role. <\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
The company states that it has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations, either carried out by the offset team within the Marine Systems Business Unit or by the company\u2019s Compliance Department. The company states that the due diligence process includes checks on ultimate beneficial ownership, a screening of possible conflicts of interest and an assurance of the legitimacy of the investment. There is evidence that the company refreshes its due diligence on offset service providers every two years. <\/p>\n
However, it is not clear that the company refreshes due diligence on all aspects of its offset obligations continuously or at least when there is a significant change in the business relationship or nature of the partner.<\/p>\n"},{"question":105,"commitment_area":14,"score":"1","comments":"
The company discloses that it does not currently contract any third party offset service providers or brokers. It is unclear if this is due to the introduction of a policy to no longer use these kinds of service providers. <\/p>\n
The company receives a score of \u20181\u2019 because it is unclear whether the company updates this information annually. Furthermore, the company suggests that it will not disclose information about its offset brokers going forward. <\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
The company does not publish any details of its offset obligations and\/or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"2","comments":"
There is evidence that the company acknowledges the corruption risks associated with operating in different markets, and has a risk assessment process in place to account for these specific risks, with clear risk management procedures. The results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. The company provides examples of such possible controls.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings on an annual basis. The list provides information on the company\u2019s percentage ownership and the country of incorporation of each entity. <\/p>\n
However, the company does not publish information on the countries of operation for each entity.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is publicly listed on a regulated marked in the European Economic Area. It therefore automatically receives a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
The company publishes some information about its defence customers. However, the data the company provides does not make reference to specific government customers or provide a percentage breakdown of its sales. <\/p>\n"},{"question":111,"commitment_area":16,"score":"N\/A","comments":""},{"question":112,"commitment_area":16,"score":"N\/A","comments":""},{"question":113,"commitment_area":16,"score":"N\/A","comments":""},{"question":114,"commitment_area":16,"score":"N\/A","comments":""},{"question":115,"commitment_area":16,"score":"N\/A","comments":""}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/637","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=637"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=637"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}