There is evidence that the company\u2019s General Director makes a clear endorsement of the company\u2019s anti-corruption programme, which supports a zero tolerance stance against all forms of corruption within the organisation.<\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company publishes an anti-bribery and corruption policy, which applies to all of the company\u2019s employees and members of senior management. There is evidence the policy prohibits all forms of commercial bribery.<\/p>\n
However, there is no evidence the company\u2019s policy applies to the staff and leadership of subsidiaries and other controlled entities, nor does it explicitly apply to all of the company\u2019s board members. There is also no evidence the company\u2019s policy explicitly prohibits facilitation payments or payments to public officials.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that the company has a commission, the Commission for Corruption Risk Assessment, which oversees the company\u2019s anti-bribery and corruption programme along with the General Director. This includes reviewing reports from management and implementing changes. The company states that this Commission submits reports to the General Director, a member of the company\u2019s board of directors. There is evidence that the General Director subsequently ensures that proposed changes are implemented to the company\u2019s anti-corruption programme.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a named manager, the Commissioner of the company\u2019s Commission for Corruption Risk Assessment, is responsible for managing and implementing the company\u2019s anti-corruption programme. It is clear that this individual has a reporting line to the General Director, the company\u2019s most senior executive and a member of the board of directors.<\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
There is evidence the company conducts a corruption risk assessment of its entire anti-corruption programme at least once annually. The results of assessments are reviewed by the company\u2019s Commission for Corruption Risk Assessment, which submits a report to the General Director, who approves suggested measures to implement to reduce and eliminate identified corruption risks. <\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
There is evidence that the company\u2019s anti-corruption programme is subject to an external audit at least once every three years. There is evidence indicating that the audit is based on an assessment of the business risks facing the company. The company introduces changes and modifies its programme based on the results of audits and assessments. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company commits to investigating incidents and has a specific procedure to deal with whistleblowing cases. The company describes the whole investigation process from receipt to final outcome, and there is evidence that all cases are documented. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that investigations are handled by an independent team or report to an independent board member. The company also makes no commitment in publicly available evidence to providing whistleblowers with updates on the outcome of investigations. There is additionally no evidence that summary information of investigations is reviewed by a central body.<\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company assures itself of the quality of investigations, for example by indicating that staff conducting investigations are properly trained, by implementing a policy to handle complaints about the process or by reviewing the investigation process every three years. <\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
There is evidence that the company informs law enforcement of material findings of corruption offenses. <\/p>\n
However, there is no evidence that material findings of bribery and corruption are reviewed by the company\u2019s board. While findings from investigations are presented to the General Director, in publicly available evidence the company does not name an appropriate senior individual specifically responsible for reviewing the need for reporting criminal offences to authorities.<\/p>\n"},{"question":63,"commitment_area":8,"score":"1","comments":"
The company publishes some high-level data on the disciplinary actions resulting from corruption and bribery incidents of its employees. However, the company receives a score of \u20181\u2019 because it is not clear that this is data updated on an annual basis and the data does not clearly include information on the number of reports received (including those received through whistleblowing channels), or the number of investigations launched. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides a training module outlining the basic principles of the anti-bribery and corruption policy, although there is no specific reference to training on the whistleblowing options available to employees. The company requires all new employees to take a mandatory briefing on the company\u2019s anti-corruption programme and on relevant anti-corruption laws and regulations. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not explicitly state that training is provided systematically to employees across all its operations and geographic locations, and in all appropriate languages. Based on publicly available evidence, it is unclear how frequently training is conducted. <\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company provides tailored 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":"1","comments":"
There is some evidence that the company submits its anti-corruption training programme to regular reviews as part of audits and reviews of its wider programme. The company states that it adapts its training programme based on the reports of management and the corruption risks identified. There is also some evidence that the company monitors employee attendance at anti-corruption training events.<\/p>\n
The company, however, receives a score of \u20181\u2019 because it is not clear from publicly available information that the company has clear systems in place to measure the effectiveness of its anti-corruption training and communications programme, nor is it clear that such measures would be employed to enhance and improve the programme. There is also no evidence that it conducts this assurance on a regular basis.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company\u2019s incentive schemes incorporate ethical or anti-bribery and corruption principles.<\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no evidence the company makes a specific public commitment to protect employees who refuse to act unethically, even when it might result in a loss of business. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is some evidence the company commits to protecting and supporting both employees who report corruption incidents and whistleblowers across the organisation. There is some evidence the company\u2019s whistleblowing line is open to third parties and it is inferred that the company\u2019s policy of non-retaliation extends to these parties.<\/p>\n
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 through surveys, usage data, or other clearly stated means.<\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
There is evidence that the company operates both whistleblowing and advice channels and that these channels allow for anonymous and confidential reporting. The company additionally states that these channels are available to business partners.<\/p>\n
However, the company receives a score of \u20181\u2019 because evidence indicates that the company offers only internally operated channels. There is also no evidence that these channels are available in all appropriate languages and in all countries of operation.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is some evidence the company has a conflicts of interest policy, which refers to actual and potential conflicts, and makes specific reference to personal financial interests.<\/p>\n
However, the company receives a score of \u20181\u2019 because in publicly available evidence it does not make specific reference to employee relationships, government relationships or outside employment. The policy also does not refer to perceived conflicts. In publicly available evidence the company does not explicitly state that its policy applies to all board members. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is some evidence the company has procedures to identify, declare and manage conflicts of interest, including actual and potential conflicts. The policy outlines some examples of criteria for recusals and states that disciplinary measures will apply if breached. There is evidence that different individuals are designated responsible for resolving conflicts of interest dependent on the position of the relevant employee or manager. The company does not refer to a specific body or individual with oversight and accountability for handling all cases.<\/p>\n
The company receives a score of \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 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 publicly available evidence that the company publishes details of the contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
There is evidence that the company has a policy to restrict political donations in order to prevent corruption. However, the company does not provide further details of its policy and it is not clear from publicly available that the company prohibits political contributions as outlined in the scoring criteria. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
The company does not disclose any details of its political contributions.There is no evidence that the company publishes any details of its political contributions.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is evidence that the company\u2019s anti-corruption programme includes restrictions on charitable donations but it provides no further detail in publicly available evidence. There is no evidence that the company has a policy on sponsorships. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy or procedure on lobbying.<\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any information on its lobbying aims, topics or activities.<\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any details about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy and procedures on the giving and receipt of gifts and hospitality. This policy includes a financial threshold, which is set by law, although the company does not disclose the specific amount. There is evidence that the company addresses the risks associated with gifts and hospitality given to public officials. <\/p>\n
The company requires employees to notify the Commissioner of the Commission for Anti-Corruption Risk Assessment in writing about gifts given and received. However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that this information is recorded in a dedicated register that is accessible to the Commissioner.<\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company requires the involvement of its procurement department in the establishment or oversight of its supplier base.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct due diligence before engaging with all suppliers, and that this process includes checks on beneficial ownership. There is some evidence that the company would be willing to terminate a relationship or not engage a supplier if a red flag identified in due diligence could not be mitigated.<\/p>\n
However, there is no evidence that high risk suppliers are subject to enhanced due diligence nor that due diligence is repeated at least every two years or when there is a change in the business relationship.<\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.<\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.<\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company has a policy covering the use of agents or intermediaries.<\/p>\n"},{"question":89,"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 engaging with third parties.<\/p>\n
However, the company states that it conducts due diligence on third parties, without specifying agents or high risk intermediaries. Additionally, it is not clear that agents and highest risk intermediaries are subject to enhanced due diligence. There is also 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":90,"commitment_area":13,"score":"0","comments":"
There is evidence that the company aims to independently verify the beneficial ownership of third parties through the use of corporate registries and databases. The company conducts these checks prior to engaging. However, there is no evidence due diligence is repeated at least every two years or when there is a significant change in the business relationship.<\/p>\n
The company scores \u20180\u2019 as it does not explicitly state that it would be willing to not engage or terminate an agent relationship in the event that beneficial ownership cannot be established. <\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
The company states that it may include anti-corruption clauses in contracts with third parties, without mentioning agents and intermediaries specifically. There is no evidence that this applies to all agent agreements nor that the company includes audit and termination rights in its contracts with these entities.<\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
The company makes no mention of 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 on its behalf.<\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical, bribery or corruption-related investigations, incidents or the associated disciplinary actions involving agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
There is evidence the company conducts due diligence on its business partners but in publicly available evidence it makes no specific reference to joint ventures.<\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
The company states that it may include anti-corruption clauses in contracts concluded with third parties, without specifying joint venture partners. There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.<\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor that a dedicated body, department or team is responsible for oversight and management of the company\u2019s offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence 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 evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its 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":"
There is no publicly available 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":"
The company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings and indicates that all of the company\u2019s holdings are located in Ukraine. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that the list is up to date nor that the data is updated on at least an annual basis. There is also no publicly available evidence that the company publishes information on its percentage ownership in each of its holdings.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company publishes information to indicate that it is wholly-owned by the Ukrainian state. This information is available both on the company\u2019s website and on a free, national corporate register.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
The company publishes some information about its primary defence customers, however this information is presented as a list of countries and not a percentage breakdown of its total defence sales by customer per year.<\/p>\n"},{"question":111,"commitment_area":16,"score":"N\/A","comments":"
The company publishes information to indicate that it is wholly-owned by the Ukrainian state and there is no evidence that any other entities hold shares or voting rights, so the company is exempt from scoring on this question. <\/p>\n"},{"question":112,"commitment_area":16,"score":"1","comments":"
There is evidence that the company publishes some information about its objectives, however it receives a score of \u20181\u2019 because there is no clear evidence that these objectives are updated on at least an annual basis.<\/p>\n"},{"question":113,"commitment_area":16,"score":"0","comments":"
The company discloses the names of members of its board of directors but does not publish any further information about their roles or the nomination and appointment process. <\/p>\n"},{"question":114,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company\u2019s audit committee is composed of a majority of independent directors.<\/p>\n"},{"question":115,"commitment_area":16,"score":"1","comments":"
There is evidence that the company has a system in place to manage asset transactions, with responsibility held at board level. <\/p>\n
However, it is unclear and not specified in publicly available evidence whether asset transactions are consistently subject to scrutiny by an audit body. There is also no clear evidence that all major asset transactions are documented. There is also no evidence that financial results from asset acquisitions are made publicly available by the company.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/639","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=639"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=639"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}