The company publishes a statement that it has a zero-tolerance approach to all forms of corruption, which forms part of its Anti-Corruption Policy and has been signed off by the company\u2019s General Director. Since there is evidence that he General Director is the most senior figure within the organisation, the company receives a score of \u20182\u2019. <\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company publishes an Anti-Corruption Policy which prohibits bribery and corruption. The company\u2019s policy states that it applies to all the company\u2019s staff and all employees of subsidiaries and companies under the company\u2019s control. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company\u2019s policy specifically prohibits facilitation payments or payments to state officials, and while it includes a definition of commercial bribery, it is not entirely clear that this practice is prohibited. Furthermore, there is no clear evidence that the policy applies to all board members, including non-executive directors.<\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is some evidence that the Audit Committee of the Board of Directors is responsible for oversight of the company\u2019s anti-corruption programme. However, the company receives a score of \u20181\u2019 because there is no indication that the committee\u2019s oversight responsibilities include formal oversight functions such as reviewing reports from management or the results of audits. <\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
There is some evidence in the company\u2019s Anti-Corruption Policy that the Deputy Managing Director of Security has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. There is some indication that this individual, alongside other managers engaged in managing and implementing the anti-corruption programme, has a direct reporting line to General Director of the company.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear whether this individual is a senior executive, nor whether this individual is the main individual responsible for implementing aspects of the anti-bribery and corruption programme. <\/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-bribery and corruption programme. However, the company receives a score of \u20181\u2019 because there is no clear evidence that risk assessments are reviewed at board level or on at least an annual basis.<\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
There is some evidence to suggest that the company\u2019s anti-bribery and corruption programme is subject to annual review. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence 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. The company\u2019s publicly available information mentions external auditors and experts, but their role and the frequency of their engagement is not specified. In addition, although there is evidence that the Audit Committee evaluates the implementation of the anti-corruption program, it is not clear whether audit findings are presented to the board, nor is it clear where ownership for implementing changes resulting from audits lies.<\/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 specific procedures in place to deal with whistleblowing cases, which are set out in a corporation-wide policy published by the company\u2019s parent company and available on its website. These procedures stipulate documentation and actions to be taken at every step of the case, from receipt to final outcome, and the company commits to ensure whistleblowers are informed of the outcome, if they so wish. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that investigations are handled by an independent team and\/or report to an independent board member, nor that summary information on cases is reviewed by a central body on a regular basis.<\/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 some evidence that the company commits to report any incidents of corruption to law enforcement agencies. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company commits to report findings of corruption to the board. There is also 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":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption related incidents, investigations or disciplinary actions involving its employees.<\/p>\n"},{"question":64,"commitment_area":9,"score":"0","comments":"
There is some evidence that the company provides employees with anti-corruption training, which includes an explanation of the company\u2019s policies and the law regarding anti-corruption. <\/p>\n
However, the company receives a score of \u20180\u2019 because it is not clear that the training covers the whistleblowing options available to employees, nor is there evidence to suggest that training is provided to all employees across all divisions or all countries regions of operation. Furthermore, there is no evidence to indicate how frequently training is conducted.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company provides tailored anti-bribery and corruption training to its employees based on an assessment of their role or exposure to corruption risk. The company states that the category of trainees should be taken into account when organising training, but it is unclear whether that includes the three categories of employee listed in the question, nor is it clear how frequently such training is provided. <\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company measures or reviews the effectiveness of its communications or training on anti-bribery and corruption. The company states that it analyses the results of anti-corruption initiatives, but it is not clear that this includes measuring effectiveness, nor that it applies specifically to its employees understanding of its training and communications. <\/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":"0","comments":"
There is no evidence that the company commits to support or protect employees who refuse to act unethically. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is evidence that the company has a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. The company\u2019s policies indicate that this applies to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it 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 some evidence that the company provides whistleblowing channels for its employees, which allow for anonymous reporting of allegations or incidents. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company provides an option for employees to report to an external or independent third party, nor is it clear that the channels may be used to seek advice on the company\u2019s anti-corruption policies. There is also no clear evidence that these channels are available to all employees in any country of operation, or to any employees of third parties, suppliers or joint venture partners. The company does not indicate whether these channels are available in multiple languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy covering conflicts of interest, which is referenced on its website and in its Anti-Corruption Policy. The company\u2019s publicly available information indicates that employees must declare any actual, potential or perceived conflicts, and there is evidence that its policy covers possible conflicts arising from financial interests, other employment or corporate relationships, and personal relationships.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its policy addresses possible conflicts arising from government relationships. It is noted that the company\u2019s full policy document does not appear to be available in the public domain. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has procedures in place to identify, declare and manage conflicts of interest. The company states that the Deputy General Manager of Security is ultimately responsible for organising all anti-corruption activities, including the management of conflicts of interest, and that departmental managers are also assigned partial responsibilities in this area.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that all employee and board member declarations are held in a dedicated central register that is accessible to those responsible for oversight of the process. The company also indicates that it has a Commission for regulating conflicts of interest, but does not provide further details on this in its publicly available information. There is also no evidence that the company provides examples of criteria for recusals, nor does the company indicate that disciplinary measures will apply if the policy is breached. It is noted that the company has full procedures on the identification and management of conflicts of interest, however this document does not appear to be available in the public domain. <\/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":"0","comments":"
There is no publicly available evidence that the company has a policy to regulate or prohibit corporate political contributions. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes details of its political contributions, nor does it provide a clear statement that it makes no such donations. <\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy on charitable donations or sponsorships. There is evidence that the company mentions charitable donations in its anti-corruption policy, but it does not provide any further information on measures to ensure that such expenses are not used as vehicles for bribery and corruption. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy and\/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":"0","comments":"
There is no publicly available evidence that the company has a policy on gifts and hospitality. There is evidence that the company mentions gifts and hospitality in its anti-corruption policy, but it does not provide any further information on measures to ensure that such expenses are not used as vehicles for bribery and corruption.<\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
The company states that it adheres to its parent company\u2019s procurement policy, which indicates that the procurement department is involved, in some capacity, in the establishment of supplier relationships throughout the corporation\u2019s holdings. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear whether the procurement department 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":"1","comments":"
There is some evidence in group-wide procurement regulations that the company conducts anti-corruption due diligence on suppliers. The company\u2019s Anti-Corruption Policy also indicates that it conducts due diligence on all business partners and counterparties, without making specific reference to suppliers.<\/p>\n
The company receives a score of \u20181\u2019 because there is no publicly available evidence that the company conducts checks on ultimate beneficial ownership, or that highest risk suppliers are subject to enhanced due diligence. It is not clear that the company repeats due diligence at least every two years or whenever there is a change in the business relationship. The company\u2019s policy also does not explicitly state 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. <\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
There is no clear evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard. The company states that it disseminates anti-corruption policies and standards amongst its partner organisations, but it does not indicate that this includes suppliers and there is no further evidence to indicate that the company assures itself that its suppliers meet these standards on a regular basis. <\/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 related incidents, investigations or disciplinary actions relating to its suppliers. <\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company has a policy to regulate the use of agents. The company states that it only does business with reputable counterparties and contractors but does not provide sufficient information that could be considered a policy on the legitimate use of agents, or measures to mitigate the corruption risks associated with the use of agents. <\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no clear evidence that the company conducts anti-bribery and corruption due diligence when engaging or re-engaging with agents or intermediaries. <\/p>\n
The company states that it has procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging with counterparties, however it does not clearly specify that this applies to agents or high-risk intermediaries. In addition, the company\u2019s publicly available information indicates that it only conducts due diligence checks prior to engaging third party contractors; there is no evidence that such checks are 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 or intermediaries.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is no clear evidence that the company\u2019s Anti-Corruption Policy applies to agents and intermediaries, nor that it includes audit rights and termination clauses in its contracts with such third parties. <\/p>\n
The company states that its Anti-Corruption Policy applies to all entities with which it has a contractual relationship, however it is not clear from the company\u2019s publicly available information that this may include agents or intermediaries. The company does not mention audit or termination rights as part of its contractual agreements. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no publicly available information that the company's incentive structures for agents 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 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 its agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its joint venture partners. The company indicates that it conducts due diligence on its counterparties, but it is not sufficiently clear that this includes joint ventures and therefore the company receives a score of \u20180\u2019. <\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures. The company indicates that it includes anti-corruption clauses in its contractual agreements with counterparties, but it is not sufficiently clear that this includes joint venture partners, nor does the company indicate that such clauses include audit and termination rights. <\/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 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 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.<\/p>\n"},{"question":108,"commitment_area":15,"score":"0","comments":"
The company publishes some information about its affiliated companies, however based on publicly available information the company only publishes the name of the companies. There is no evidence that the company publishes further information such as whether the companies are subsidiaries or other associates, joint ventures or related entities, nor does it publish details such as percentage ownership, country of incorporation and country of operation for each entity. In addition, there is no evidence to indicate whether this is a full list of the company\u2019s holdings, or how frequently this list is updated. <\/p>\n"},{"question":109,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company discloses clear information on its beneficial ownership and control structure. <\/p>\n
The company indicates that it does not disclose its ownership information pursuant to legislative developments in the Russian Federation. Prior to this, until 2018 the company disclosed the identity of one major shareholder and noted that this entity was the only shareholder with an ownership stake greater than 5%. In its Annual Report, the company indicates that it belongs to the Rostec Corporation group.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes a percentage breakdown of 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.<\/p>\n"},{"question":112,"commitment_area":16,"score":"1","comments":"
The company publishes some information about its corporate objectives and activities, which include producing and developing products, services and research for the Ministry of Defence of the Russian Federation. However, the company receives a score of \u20181\u2019 because there is no evidence that these objectives are updated at least on an annual basis. <\/p>\n"},{"question":113,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company makes information about the composition, nomination and appointment of its board publicly available.<\/p>\n
The company provides some information on its website to indicate which board members are executives and state employees, but does not disclose whether any individuals are financial beneficiaries. The information only identifies the General Director as a shareholder and does not disclose whether other members of the board are shareholders. In addition, there is no evidence that the company publishes any further information on the board nomination or 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 majority independent directors. <\/p>\n
The company indicates that the Audit Committee must consist of at least three individuals and if independent directors are elected to the board, that at least one should be elected to the Audit Committee; however there is no evidence that the company has any independent directors nor does it state that its Audit Committee must be majority independent. <\/p>\n"},{"question":115,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company publishes any details about its management of asset transactions, beyond noting that it complies with all laws as stipulated by the Russian Federation. <\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/642","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=642"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=642"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}