There is no evidence that the company has a publicly stated anti-bribery and corruption commitment that is authorised and endorsed by its senior leadership. The company indicates that it does not tolerate corruption in its corporate policies, however this is not accompanied by a statement or similar indication of support from its leadership. <\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company publishes an anti-bribery and corruption policy and accompanying ethics polices which outline the company\u2019s commitment to anti-corruption laws and clearly prohibit bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that the company\u2019s policies apply to all employees, including employees of subsidiaries, third parties and joint ventures. <\/p>\n
The company receives a score of \u20181\u2019 because there is no clear evidence that the company\u2019s policies on anti-corruption apply to board members or senior leadership, including non-executive directors.<\/p>\n"},{"question":56,"commitment_area":7,"score":"0","comments":"
Based on publicly available information, there is some evidence to indicate that the Commission on Corporate Ethics and Conflict of Interest Regulation provides oversight of the company\u2019s anti-bribery and corruption programme. However, the company receives a score of \u20180\u2019 because the responsibilities of the Commission are not clear and there is no evidence that this body is represented at board level or that it has the authority to require that changes to the programme are made. <\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
There is evidence that the company\u2019s President has primary responsibility for implementing and managing the company\u2019s anti-bribery and corruption programme. Since the President sits on the Board of Directors, it is understood that this individual has a direct reporting line to the board on any issues relating to anti-corruption. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence of reporting and feedback activities between the President and the board in relation to anti-bribery and corruption. <\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
There is evidence that the company has a formal bribery and corruption risk assessment procedure that informs the design of the anti-corruption and bribery programme. The company indicates that it assesses and reviews the corruption risks that it faces on a regular basis, at least once a year. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the results are reviewed at board level.<\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
There is evidence that the company\u2019s anti-bribery and corruption programme is subject to a regular internal audit process, which is used to inform and strengthen the company\u2019s anti-corruption programme. However, the company receives a score of \u20181\u2019 because there is also no evidence that audit findings are presented to the board of directors. It is also not clear that the entire programme is audited to ensure that it is consistent with high standards of best practice and the business risks facing the company. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly commits to investigating incidents and that it has a specific procedure in place to deal with whistleblowing cases. There is also evidence that each report of corruption-related incidents is documented. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide publicly available information on the whole investigation process from receipt to final outcome, nor does it commit to providing whistleblowers with updates on the outcome of investigations if they so wish. In addition, there is no evidence that that investigations are handled by an independent team or that a central body reviews summary information on cases.<\/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 its internal investigations.<\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
There is evidence that the company commits to report material findings of bribery and corruption to the relevant authorities and to cooperate with law enforcement agencies where necessary. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that a dedicated senior individual is ultimately responsible for ensuring that the disclosure of criminal offences is evaluated and acted upon, if necessary. Although the company indicates that its President is responsible for deciding whether to initiate an internal investigation, there is no further evidence to indicate that this individual is responsible for reporting externally or for ensuring that material findings from investigations are reported to the board. <\/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 incidents, investigations or disciplinary actions involving its employees.<\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides a training module that outlines the basic principles of the anti-bribery and corruption policy, including the reporting channels available to employees. The company indicates that this training is provided to all employees, including those of subsidiaries and affiliated companies. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence to indicate how frequently employees are required to undertake this training on anti-corruption. There is also no evidence that training is provided to all employees across all divisions, all countries and regions of operation or in all appropriate languages. <\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk. There is some indication that the company may provide individual training to employees involved in foreign activities, but it is not clear what this training might involve or how frequently it is conducted. <\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption communications or training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company\u2019s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles.<\/p>\n"},{"question":68,"commitment_area":9,"score":"1","comments":"
The company clearly states that any employee who refuses to act unethically, in keeping with the company\u2019s anti-corruption commitments, will be protected and supported, even where such actions result in a loss of business or another disadvantage to the company. <\/p>\n
However, there is no evidence that the company assures itself of its employees\u2019 confidence in this statement through anonymised surveys or other clearly stated means.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. The company indicates that this policy applies to all employees across the organisation. It is noted that the non-retaliation policy applies to counterparties of the company, but it does not make specific reference to those employed as third parties, suppliers or joint venture partners. <\/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 provides whistleblowing channels for its employees, which are available to all employees in the organisation and to those employed by third parties. <\/p>\n
However, the company receives a score of \u20181\u2019 because the company only offers internally operated reporting channels and there is no evidence that employees may use these channels to seek advice in addition to reporting incidents. The company also indicates that anonymous reports are not allowed and will not be investigated. In addition, it is not whether the channels are available to all employees in any country of operation, or in multiple languages, or to employees of suppliers or joint venture partners.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
The company provides a clear definition of actual and potential conflicts of interest and there is evidence that it has a policy which covers conflicts of interest arising from employee relationships and financial interests. However, there is no evidence that the policy addresses conflicts arising from other employment or government relationships. In addition, there is no clear evidence that the applies to all employees and board members.<\/p>\n
It is noted that the company makes reference to an internal policy entitled \u201cRegulations on Conflicts of Interest\u201d, but this does not appear to be publicly available.<\/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, including actual and potential conflicts. There is also evidence that some employees are required to declare any conflicts of interest. The company states that the Commission on Corporate Ethics and Conflict of Interest Regulation is responsible for managing conflicts of interest. <\/p>\n
The company receives a score of \u20181\u2019 because there is no evidence that employee and board member declarations are held in a dedicated central register that is accessible to those responsible for oversight of the process. There is also no evidence that the company\u2019s policy provides examples of criteria for recusals, nor does it indicate that disciplinary measures will apply if breached. <\/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 evidence that the company reports details of the contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"2","comments":"
The company publishes a clear statement that it does not make any corporate political contributions under any circumstances to any party, candidate or campaign. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
The company publishes a clear statement that it does not make any political contributions, and is therefore exempt from scoring on this question. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company recognises charitable donations and sponsorships as possible corruption risks and that it has a policy in place to cover such activities. The company publishes some information about the projects that it supports in its Annual Reports, however it does not provide full details of each donation such as the recipient, amount donated and country of recipient. The company indicates that further details of controls and criteria to ensure that such donations are not used as vehciles for bribery and corruption can be found in a separate document, which does not appear to be publicly available. <\/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 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 on gifts and hospitality which establishes a financial threshold on offering gifts and addresses the risks associated with gifts and hospitality given to\/received from domestic or foreign state officials. <\/p>\n
However, there is no evidence that all gifts and hospitality submissions are recorded in a dedicated central register or database that is accessible to those responsible for oversight of the process. It is noted that the company makes reference to a separate gifts and hospitality policy, but this document does not appear to be publicly available. <\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is evidence that the company\u2019s procurement department is involved in the establishment and oversight of all supplier relationships. It is clear that this specialised procurement department is the main body responsible for oversight of the company\u2019s supplier base.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is 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":"1","comments":"
There is evidence that the company has formal procedures in place to conduct due diligence on all counterparties, which is understood to include suppliers. The company indicates that it reviews and may terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated. <\/p>\n
However, there is no evidence that due diligence includes checks on ultimate beneficial ownership, nor that highest risk suppliers are subject to enhanced due diligence. It is also not clear how frequently such checks are conducted. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is evidence that the company expects that its contractors meet a certain standard of ethical business conduct when conducting work. The company also indicates that it includes an anti-corruption clause in its contracts with partners which prohibits bribery. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that all suppliers must have, at least, policies in place that prohibit facilitation payments, and procedures covering conflicts of interest, gifts & hospitality, or whistleblowing. In addition, there is no evidence that the company assures itself that suppliers meet such standards when there is a change in the business relationship. <\/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 incidents, investigations or disciplinary actions relating to its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company has a clear policy on the use of agents.<\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging and when re-engaging its foreign third parties. Although the company does not specifically identify these third parties as agents or high risk intermediaries, it is understood that such a process would apply to these entities. <\/p>\n
The company receives a score of \u20181\u2019 because it is not clear whether due diligence is repeated at least every two years and\/or when there is a significant change in the business relationship.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no evidence 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 evidence that the company\u2019s anti-bribery and corruption policy applies to all agents and intermediaries, nor that it includes anti-corruption clauses in its contracts with such entities. The company states that it includes anti-corruption clauses in its contracts with third parties, but it is not clear that this includes agents nor is there evidence that such contracts include audit rights. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence tat the company addresses incentive structures as a risk factor in agent behaviour, nor is there evidence that the company has incentive structures for agents which are designed to minimise risks of anti-bribery and corruption.<\/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 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 its 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 into and while operating in a joint venture. However, there is no evidence that the company\u2019s due diligence includes checks on the ultimate beneficial ownership of the partner company. In addition, there is no evidence to suggest that high risk joint ventures are subject to enhanced due diligence, or that such checks are repeated at least every two years throughout the business relationship. <\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
The company publishes a statement that it will not participate in joint venture partnerships which violate its anti-corruption or corporate ethics policies. There is also evidence that it includes anti-corruption clauses in contracts with joint ventures which include termination rights, however there is no evidence that such clauses include audit rights. The company does not provide any further publicly available information on how it ensures that any joint venture partnerships adhere to its anti-corruption standards. <\/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":"0","comments":"
There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence 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 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 and\/or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company acknowledges the corruption risks of operating in different markets, nor that risk assessment procedures are used to inform the company\u2019s operations in high risk markets.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a list of its subsidiaries and holdings on its website. However, the company does not publish further details such as the percentage ownership, country of incorporation or countries of operation for each entity. It is therefore not clear which companies are material (principal\/significant\/main) subsidiaries, and which are associated or joint ventures. In addition, there is no indication that this list is complete or up-to-date for the most recently reported financial year; the company\u2019s Annual Report indicates that some information on subsidiaries may be restricted due to national legislation. <\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
The company discloses some information on its major shareholders to indicate that it is majority owned by the Russian government through the Federal Property Management Agency and state corporation \u201cRostec\u201d. However, there is no evidence that the company\u2019s ownership information is available in open data format, nor that it is published in a freely accessible central public register, so the company receives a score of \u20191\u2019.<\/p>\n
It is noted that this information was correct as of March 2019; the company indicates that it no longer publishes information on its ownership due to a change in national legislation.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes any information on its defence sales by customer.<\/p>\n"},{"question":111,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company publishes details of its shareholder voting rights. The company\u2019s shareholding structure indicates that the Russian government is the main controlling entity, but the company does not provide a percentage breakdown of voting rights per shareholder. <\/p>\n"},{"question":112,"commitment_area":16,"score":"2","comments":"
There is evidence that the company\u2019s commercial and public policy objectives are made publicly available on its website and in its Annual Reports. There is also evidence that these objectives are updated on an annual basis.<\/p>\n"},{"question":113,"commitment_area":16,"score":"0","comments":"
The company publishes some information on the selection process for choosing board members and provides some details on the steps that it takes to verify independence. The company also publishes some information on the number of independent members and the number of state representatives on its board, however it should be noted that this information has not been updated due to a change in national legislation. <\/p>\n
The company receives a score of \u20180\u2019 because there is no evidence that it provides clear information on the board nomination and appointment process, nor is there evidence that it publishes current information on the status of its board members. <\/p>\n"},{"question":114,"commitment_area":16,"score":"1","comments":"
The company publishes a statement that its Audit Committee is composed exclusively of independent directors. However, there is no evidence that the company provides further details to support this statement in its most recently published Annual Report, such as the names and status of each board member on the Audit Committee. <\/p>\n"},{"question":115,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company publishes any details about the management of asset transactions.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/641","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=641"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=641"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}