The company publishes a Code of Business Conduct which details the company's stance against bribery and corruption. There is evidence that the Code of Business Conduct was authorised and endorsed by the company's leadership in the form of an introductory message from the President and Chief Executive Officer. However, this message does not specifically mention anti-bribery and corruption and therefore a score of \u20181\u2019 applies.<\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company publishes a Code of Business Conduct, which makes specific reference to the prohibition of bribery, payments to public officials and commercial bribery. The policy states that it applies to all directors and all employees, including staff and leadership of subsidiaries. <\/p>\n
However, the company scores \u20181\u2019 as there is no evidence it prohibits facilitation payments. <\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is evidence that a designated board committee, the Audit Committee, oversees the company's ethics and compliance programme, and that this includes reviewing reports from management on the programme\u2019s performance.<\/p>\n
However, the company scores \u20181\u2019 as there is insufficient publicly available evidence that the Audit Committee reviews audits of the company\u2019s ethics and compliance programme specifically. The Audit Committee Charter also does not refer to anti-bribery and corruption directly. <\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
There is some evidence that the General Counsel has been assigned responsibility for reporting to the board on the company\u2019s compliance with the Code of Business Conduct. However, there is insufficient evidence that the General Counsel, or an alternative 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 publicly available evidence to indicate that the company has a formal risk assessment procedure which is used to inform the company\u2019s anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is evidence that the Audit Committee reviews the company\u2019s ethics and compliance programmes on at least an annual basis. However, there is no clear publicly available evidence that the company conducts internal or external audits of these programmes, including audits of the company\u2019s anti-bribery and corruption programme specifically. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company commits to investigating incidents and takes steps to ensure the independence of its investigations. There is evidence of a specific procedure in place to deal with whistleblowing cases, which stipulates documentation and actions to be taken at each step of the case, from receipt to final outcome. There is evidence to show that details about each investigation are documented and that a listing of complaints is periodically submitted to the Chair of the Audit Committee. <\/p>\n
However, the company scores \u20181\u2019 as there is no evidence that the company commits to providing whistleblowers with updates on the outcome of investigations. It is also not clear whether the Chair of the Audit Committee receives summary information on investigations on at least an annual basis. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence to indicate 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 that the company commits to report material findings of bribery and corruption from investigations to the Audit Committee. However, although the company states that it may report incidents to the appropriate authorities, there is no evidence that an appropriate senior individual is responsible for ensuring that the disclosure of criminal offences to the 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":"0","comments":"
Based on publicly available information, there is some evidence that indicates that the company provides training on laws relating to improper payments to government officials. However, there is no evidence that the company publishes any further information on its training programme and there is no clear evidence that the company provides anti-bribery and corruption training to all employees.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company tailors any anti-bribery and corruption training to 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 publicly available evidence to indicate 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":"
Based on publicly available information, there is evidence that the company reviews the incentive elements of its compensation arrangements to determine whether they encourage excessive risk-taking. However, there is no evidence that the company\u00b4s incentive schemes incorporate ethical or anti-bribery and corruption principles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is publicly available evidence to indicate that the company expects employees to act ethically. However, there is no specific evidence that the company commits to support or protect employees who refuse to act unethically, even when this might result in a loss of business. <\/p>\n"},{"question":69,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is evidence that the company has a policy of non-retaliation against whistleblowers and employees who report bribery and corruption incidents. <\/p>\n
However, the company scores \u20180\u2019as there is no clear evidence that this policy applies to those employed by the group as third parties, suppliers and joint venture partners. <\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has multiple channels to report instances of suspected corrupt activity and to seek advice on the company's anti-bribery and corruption programme. There is evidence that channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an external channel operated by an independent third party, and that these channels allow for confidential and, wherever possible, anonymous reporting. There is evidence that they are available and accessible to all employees in all jurisdictions where the company operates and in all relevant languages. <\/p>\n
However, the company scores \u20181\u2019 as there is no evidence as to whether these channels are available to the employees of third parties, including suppliers or joint venture partners. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy on conflicts of interest. The policy explicitly covers actual, potential and perceived conflicts and states that it applies to all employees and board members. It also defines employee relationships, financial interests and other employment. <\/p>\n
However, the company scores \u20181\u2019 as there is no evidence it has a policy on conflicts of interest in 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, declare and manage conflicts of interest, including actual, potential and perceived conflicts. There is reference to an individual with oversight and accountability for handling cases, the General Counsel, and the policy mentions sanctions in case of violations of the Code of Business Conduct. <\/p>\n
However, the company scores \u20181\u2019 as there is no evidence that all employee and board member declarations 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":"
There is no publicly available evidence to indicate 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 publicly available evidence to indicate 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. Based on publicly available information, there is evidence indicating that the company operates a Political Action Committee (\u2018PAC\u2019). However, there is no evidence that the company has oversight mechanisms in place in relation to the PAC.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company discloses on its website details of any political contributions or of disbursements made through the Political Action Committee (PAC) with which it is associated.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
While the company publishes some details on its sponsorship of volunteer projects, there is no publicly available evidence to indicate that the company has a policy or procedure covering both charitable donations and sponsorships.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence to indicate that the company has a policy or procedure on lobbying.<\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence to indicate 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 publicly available evidence to indicate that the company provides any details about its lobbying expenditure.<\/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 the policy addresses the risks involved with giving gifts to public officials, although it does not specifically mention public officials when discussing the risks associated with receiving gifts or hospitality. <\/p>\n
The company scores \u20181\u2019 as there is no evidence that gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process. There is also no evidence that the company\u2019s policy specifies financial or proportional limits, or different approval procedures, for different types of promotional expenses. <\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company requires that its procurement team is involved, in some capacity, in the establishment and oversight of supplier relationships. <\/p>\n
However, it is not clear from publicly available evidence that this team is the main body responsible for oversight of the company\u2019s supplier base. There is also no evidence that the company assures itself of the procurement department\u2019s involvement at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
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, by insisting that they comply with its Supply Chain Management Code of Ethics. This document explicitly refers to the prohibition of bribery, conflicts of interest and gifts and hospitality. There is evidence that the company assures itself of this when onboarding new suppliers but not necessarily when there is a significant change in the business relationship. <\/p>\n
However, the company scores \u20181\u2019 as there is no evidence that it requires that all suppliers have policies that prohibit facilitation payments nor policies related to whistleblowing.<\/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 publicly available evidence to indicate that the company publishes any data on ethical or anti-bribery and corruption investigations or associated disciplinary actions relating to its suppliers. <\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is some evidence that the company recognises the risks associated with agents. However, based on publicly available information, there is no evidence that the company has a policy covering the use of agents. <\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence to indicate 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 publicly available evidence to indicate that the company aims to establish the beneficial ownership of its agents.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence to indicate that the company 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 mention in publicly available evidence of incentive structures as a risk factor in agent behaviour. <\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence to indicate that the company publishes any details of the agents currently contracted to act for or on behalf of the company. <\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence to indicate 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 publicly available evidence to indicate that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures. There is also no evidence that it requires anti-bribery and corruption clauses in its contracts with joint venture partners. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence to indicate that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. <\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence to indicate that the company addresses the corruption risks associated with offset contracting, or that a dedicated body, department or team is responsible for monitoring of the company's offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence to indicate that the company has formal procedures in place to conduct risk based anti-bribery and corruption due diligence on its offset obligations.<\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence to indicate 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 publicly available evidence to indicate 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 clear publicly available evidence that the company acknowledges the corruption risks of operating in different markets.<\/p>\n"},{"question":108,"commitment_area":15,"score":"0","comments":"
The company publishes a list of its subsidiaries in its annual 10-K regulatory filing. However, there is no evidence that the company publishes the percentages owned, country of incorporation and countries of operation for each entity. It is also not clear whether the list of subsidiaries published constitutes a full list of the company\u2019s holdings.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is a publicly listed company with shares admitted on the New York Stock Exchange and therefore automatically scores \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
Based on publicly available information, there is evidence that the company publishes 42% of its defence sales by customer for the most recently reported financial year. The company therefore does not meet the minimum required threshold to receive a score of \u20191\u2019. <\/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\/638","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=638"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=638"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}