Based on publicly available information, there is evidence that the company\u2019s leadership endorses the company\u2019s Statement on Ethics and Business Conduct, which outlines the company\u2019s zero tolerance stance toward bribery and corruption. The company receives the score of \u20181\u2019 because its leadership statement does not directly mention bribery and corruption. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that the company publishes a clear anti-bribery and corruption policy, which specifically prohibits bribery, commercial bribery and facilitation payments. The policy applies to directors and all employees 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 responsibility for oversight of the company\u2019s anti-bribery and corruption programme sits at board level. Both the company\u2019s Ethics Overview Committee and the board itself engage in formal oversight functions such as reviewing reports from management on the programme\u2019s performance, along with the results of audits, and there is evidence that these entities have the authority to require that changes are made. <\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that a designated senior executive, the Group Company Secretary and General Counsel, has ultimate responsibility for implementing and managing the company\u00b4s anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the Ethics Overview Committee and the board, both of which provide oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this person and the board as part of the company\u2019s reporting structure. <\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has an annual process for enterprise risk assessment, which appears to include assessments of bribery and corruption risks. The board exercises oversight of the company\u2019s risk assessment procedures. <\/p>\n
However, the company receives a score of \u20191\u2019 because there is no clear publicly available evidence that the results of risk assessments are used to update the company\u2019s anti-bribery and corruption programme and develop tailored mitigation plans.<\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
There is publicly available evidence that the company\u2019s anti-bribery and corruption programme is subject to regular review to determine whether the programme is effective in combatting bribery and corruption. There is evidence indicating that the mandate of the company\u2019s internal audit function includes reviewing the company\u2019s anti-bribery and corruption controls. The company states that the internal audit function reviews all business units on a two or three-year cycle. It reports directly to the Audit Committee, which also conducts an annual review of the company\u2019s anti-bribery and corruption systems.<\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company publicly commits to investigating incidents and there is a specific procedure in place to deal with whistleblowing cases. There is evidence that the company takes steps to ensure the independence of its investigations, by requiring that responsibility for handling whistleblower reports be held by an independent director. The company states that all reports received through its whistleblowing channel will be reviewed and receive a response.<\/p>\n
In addition, there is evidence that the company provides whistleblowers with updates on the outcomes of investigations and that information on each investigation is documented. There is evidence that the company\u2019s Audit Committee receives reports on non-compliance with its anti-bribery and corruption programme on an annual basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company assures itself of the quality of its internal investigations. The company states that its investigations procedure is subject to review on an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the staff conducting investigations are properly trained or qualified. In addition, there is no publicly available evidence that the company has a process in place to handle complaints about the investigation process.<\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company reports breaches of its compliance programme to its Audit Committee, a designated board 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":"1","comments":"
There is evidence that the company publishes some high-level results about the reports received through its whistleblowing system in the past 12 months. <\/p>\n
However, based on publicly available information, it is not clear whether this includes investigations involving company employees at all levels. In addition, there is no evidence that the company publishes information about reports received through non-whistleblowing channels and any related investigations or disciplinary actions. <\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides a training module that outlines the basic principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees. The company states that all employees are required to complete anti-bribery training on an annual basis. In its 2019 Annual Report, the company indicates that 95% of its employees have completed the training, indicating that training is systematically provided to all employees, in all divisions and in all countries\/regions of operation. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that employees in certain positions receive tailored anti-bribery and corruption training based on their roles or exposure to corruption risk. The company mentions that it provides dedicated training for employees in high-risk positions. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it provides tailored training for middle management and board members. The company also does not specify whether employees in high risk positions must refresh their training on at least an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company reviews its communications and personnel training programme. However, the company receives a score of \u20181\u2019 because the measures appear to be limited to tracking training completion rates. There is no clear evidence that the results 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":"0","comments":"
Based on publicly available evidence, there is no clear evidence that the company\u2019s approach to employee incentive schemes is designed to incorporate ethical behaviour and discourage corrupt practices. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is some evidence that the company will support employees who refuse to act unethically. However, the company does not specify that it will do so even where such actions result in a loss of business to the company and there is no evidence that the company assures itself of its employees\u2019 confidence in this statement through clearly stated means, such as surveys. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is some evidence indicating that this policy applies to all employees across the organisation, including those employed by the group as third parties. <\/p>\n
However, 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":"2","comments":"
Based on publicly available information, there is evidence that the company has multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. Channels are sufficiently varied to allow the employee to raise concerns across the management chain and to external parties through an independently-operated hotline. These channels allow for confidential and, wherever possible, anonymous reporting. There is some evidence indicating that the whistleblowing channels are available to all employees, including those employed by the group as third parties, and in all relevant languages. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has a policy for conflicts of interest. The policy makes reference to actual and potential conflicts of interest. There is evidence that the company has procedures on conflicts of interest for employees and board members.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear publicly available evidence that its policy covers perceived conflicts, nor does it define the types of relationships or conflicts covered under its policy. In addition, there is no evidence that the policies apply to subsidiaries and other controlled entities. <\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
Based on publicly available information, there is some evidence that the company has procedures to identify, declare and manage conflicts of interest. The company indicates that directors are required to report actual or potential conflicts to the board, while employees are advised to discuss the matter with their line manager. <\/p>\n
However, the company receives a score of \u20190\u2019 because it does not provide further information on its procedures for handling conflicts of interest, such as identifying a specific body or individual with oversight and accountability for handling cases. There is also no evidence that the company records all employee and board member declarations in a dedicated central register that is accessible to those responsible for oversight of the process, nor that it provides a description of criteria for recusals or disciplinary measures. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the company has a policy regulating the employment of current or former public officials. <\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company publicly reports details of the contracted services of serving 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 publishes a clear statement that it does not make political contriubtions, and there is evidence that this applies to the company as a whole and its subsidiaries. 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":"
The company publishes a clear statement that it does not make corporate political contributions of any kind. However, there is no evidence that the company publishes details of the contributions made by its Political Action Committee (PAC), nor a link to its official disclosures in the United States, and therefore it receives a score of \u20180\u2019.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is evidence that the company has a policy covering charitable donations. However, there is no clear evidence that the company has a policy covering sponsorships, nor that its policy on donations includes specific controls to ensure that they are not used for bribery. There is also no evidence that the company publishes any details about the charitable contributions made in the most recently reported financial year.<\/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 lobbying expenditure. <\/p>\n"},{"question":81,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality. The company\u2019s policy specifies financial limits for gifts and addresses the risks associated with gifts given to and received from public officials by indicating that they are not permitted. The company states that all gifts and hospitality above a certain threshold are recorded in central registers for each of its business units, which are accessible to those responsible for oversight of the process. <\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no clear evidence that the company requires the involvement of its procurement department in the establishment and oversight of its suppliers. The company refers to a Procurement Council body in its 2019 Annual Report, however there is no further publicly available evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company conducts risk-based anti-bribery and corruption due diligence on all third parties, which can be understood to include suppliers. The company indicates that the highest risk third parties are subject to enhanced due diligence, and due diligence is repeated every two years. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the company might be willing to review and\/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated. There is also no evidence that the company\u2019s due diligence processes include checks on the ultimate beneficial ownership of suppliers.<\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
There is evidence that the company includes anti-bribery provisions in its contracts with all third parties, which provide for termination rights in the event of policy breaches. However, the company receives a score of \u20180\u2019 because there is no clear evidence that it requires suppliers to have adequate anti-bribery and corruption policies in place that prohibit bribery or facilitation payments, or procedures in place covering conflicts of interest, gifts and hospitality and whistleblowing.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no publicly available 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 incidents, investigations or disciplinary actions relating to its suppliers. <\/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. The company provides some information on controls to mitigate corruption risks associated with the use of agents. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it clearly 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":"
Based on publicly available information, there is evidence that the company has procedures in place to conduct risk-based anti-bribery and corruption due diligence on agents. The company indicates that due diligence on agents is risk based and repeated at least every two years. The company\u2019s bid approval process includes an assessment of anti-bribery compliance risks.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents as part of its due diligence.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is evidence that the company\u2019s anti-bribery and corruption policy applies to agents. There is also evidence that the company\u2019s agreements with third parties contain anti-bribery provisions which provide for termination in the event of policy breaches. <\/p>\n
However, the company receives a score of \u20180\u2019 because there is no evidence that it includes audit rights in its contracts with agents. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company addresses 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 or bribery and corruption related investigations, incidents or disciplinary actions involving agents. <\/p>\n"},{"question":100,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has procedures in place to conduct risk-based anti-bribery and corruption due diligence on its joint venture partners. The company states that due diligence is repeated on all third parties every two years, although it does not mention joint venture partners specifically. There is also evidence that higher risk partners are subject to enhanced due diligence. <\/p>\n
The company receives a score of \u20181\u2019 because there is no evidence that the due diligence process includes checks on the ultimate beneficial ownership of the partner company.<\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is evidence that the company includes anti-bribery and corruption clauses in its contracts with all third parties, which include termination rights. However, the company does not refer to joint venture agreements specifically. The company scores \u20180\u2019 as there is no evidence that it 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 publicly available 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":"1","comments":"
Based on publicly available information, there is evidence that the company recognises the corruption risks associated with offset contracting. There is evidence that the company has a dedicated team involved in managing and monitoring offset obligations throughout the lifecycle of each project. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it provides further details on the processes that it has in place to address the risks associated with offset contracting. In addition, there is no clear evidence to suggest that all employees within the offset team receive tailored anti-bribery and corruption training. <\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has formal procedures in place to conduct due diligence on its offset obligations. There is evidence that the company seeks to assure itself of the legitimacy of the investment. <\/p>\n
However, the compay receives a score of \u20181\u2019 because the company\u2019s publicly available policy does not specifically mention checks on beneficial ownership and conflicts of interest. There is also no evidence that the company refreshes this due diligence continuously or when there is a significant change in the business relationship or nature of the partner. <\/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 and contracts. <\/p>\n"},{"question":107,"commitment_area":15,"score":"1","comments":"
Based on publicly available information, there is some evidence the company acknowledges the corruption risks associated with operating in different markets. The company uses Transparency International\u2019s Corruption Perceptions Index as part of its risk-based approach to due diligence in order to identify risks. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it has risk management procedures related to high risk markets. There is also no clear evidence that the results of these assessments have an impact on business decisions.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings. This list includes the percentage owned and country of incorporation of each entity, and is updated on an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the list includes the countries of operation of each entity. It is also unclear whether joint venture partnerships would be included in the list.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed on the London Stock Exchange, and therefore it is not required to disclose further information on its beneficial ownership to receive a score of \u20182\u2019. The company also publishes information on its website about its shareholders with interests in the company in excess of 3%. <\/p>\n"},{"question":110,"commitment_area":15,"score":"1","comments":"
The company publishes a percentage breakdown of its sales by costumer, comprising 57% of its sales. There is also evidence that the data is correct up to the most recently reported financial year. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not publish information on its customers to account for at least 80% of its sales. It is also not clear whether these figures represent defence sales or overall company sales including from commercial products. <\/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\/640","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=640"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=640"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}