There is evidence that the company makes a general anti-bribery and corruption commitment. However, there is no evidence that it is authorised or supported by a senior figure, and therefore the company receives a score of \u20180\u2019. <\/p>\n
It is noted that although the company publishes a copy of the Anti-Corruption Charter of Russian Business on its website, there is no evidence that the company has incorporated the principles of the charter into its wider anti-bribery and corruption framework. This Charter is therefore not considered as evidence for this assessment.<\/p>\n"},{"question":55,"commitment_area":7,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company publishes an anti-corruption policy that goes beyond compliance with anti-bribery laws and which explicitly applies to all employees and board members of the company. <\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is evidence that the company has a Commission on \u201ccompliance with the requirements for the official conduct of employees and the settlement of the conflict of interests\u201d, which is responsible for the company\u2019s anti-corruption programme. This body includes at least one member of the company\u2019s board of directors. However the company receives a score of \u20181\u2019 because there is no clear evidence that this body performs oversight functions, such as reviewing reports from management or audit results.<\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
There is evidence that the company\u2019s Deputy General Director is responsible for anti-corruption activities within the organisation. However, despite this individual being a member of the board, there is no evidence of reporting and feedback activities between this individual and the board of directors. <\/p>\n
It is also noted that the list of members of the executive management team published on the company\u2019s website mentions four individuals with the title \u2018Deputy General Director\u2019, despite company documents referring primarily to one named individual in relation to this role. <\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company has established its own formal risk assessment procedure which is used to inform and update its anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company\u2019s anti-bribery and corruption programme is subject to audit or review. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publishes a policy on the reporting of corruption incidents by employees to compliance officers. In addition, the company provides a link on its website to a document outlining whistleblowing procedures developed by its parent company. It is therefore understood that this policy applies to the company, despite the company not making this explicitly clear. <\/p>\n
Based on these publicly available documents, there is evidence of that the company commits to investigating incidents and that it has is a specific procedure in place to deal with whistleblowing cases. There is evidence that this procedure stipulates documentation and actions to be taken at each step, covering the procedure from receipt of the report to final outcome. However, there is no evidence that the company makes a commitment to providing whistleblowers with updates on the outcome of investigations. There is also no evidence that investigations are handled by an independent team or that a central body reviews summary information of all ongoing cases.<\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company assures itself of the quality of its internal investigations.<\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company\u2019s policies include a commitment to report material findings from investigations to the board of directors. In addition, the company states that the \u2018responsible official\u2019 is responsible for deciding whether to report any material findings to the authorities, however the seniority nor specific position of this role is not clear. The company therefore receives a score of \u20180\u2019.<\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company publishes data on ethical or bribery and corruption-related investigations or disciplinary actions involving its employees.<\/p>\n"},{"question":64,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company provides anti-bribery and corruption training to all its employees which outlines the available whistleblowing options. The Anti-Corruption Charter of Russian Business contains some limited information on this subject, but it is not sufficiently clear that the company has integrated this into its own anti-bribery and corruption framework, so this evidence is not considered in the assessment. <\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company provides tailored anti-corruption training to employees based on an assessment of their role and exposure to corruption risk. The Anti-Corruption Charter of Russian Business contains some limited information on this subject, but it is not sufficiently clear that the company has integrated this into its own anti-bribery and corruption framework, so this evidence is not considered in the assessment.<\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme. The Anti-Corruption Charter of Russian Business contains some limited information on this subject, but it is not sufficiently clear that the company has integrated this into its own anti-bribery and corruption framework, so this evidence is not considered in the assessment.<\/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 publicly available evidence that the company has established its own policy to support or protect employees who refuse to act unethically. The Anti-Corruption Charter of Russian Business contains some limited information on this subject, but it is not sufficiently clear that the company has integrated this into its own anti-bribery and corruption framework, so this evidence is not considered in the assessment.<\/p>\n"},{"question":69,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company has a non-retaliation policy against whistleblowers or employees who report bribery and corruption incidents. The regulations established by its parent company state that employees using its hotline will not be subject to any sanctions; however it is not clear whether the company makes the same commitment regarding employees who report incidents through its own channels.<\/p>\n"},{"question":70,"commitment_area":9,"score":"0","comments":"
There is evidence that the company provides some whistleblowing and incident reporting channels, in addition to the whistleblowing service operated by its parent company. Although there is evidence that the parent company\u2019s whistleblowing hotline allows for anonymous reporting, the company indicates that reports received through its own channels that are anonymous may not be investigated. <\/p>\n
In addition, there is no clear evidence that these channels are available to all employees including those employed by third parties, suppliers or joint venture partners. There is also no evidence that the company provides channels through which employees can seek advice on the company\u2019s anti-bribery and corruption programme, nor is there evidence that it provides channels for employees to raise concerns externally. <\/p>\n"},{"question":71,"commitment_area":10,"score":"0","comments":"
There is no clear evidence that the company has a policy on conflicts of interest that defines certain types of conflict and that applies to actual, potential and perceived conflicts. In its most recently published Annual Report (2015), the company states that it has a policy covering conflicts of interest; however it does not provide further information and the policy document does not appear to be publicly available. <\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is some evidence that conflict of interest cases are managed by a specific Commission within the company. However, the company receives a score of \u20180\u2019 because it does not provide further information on any procedures to identify, declare and manage actual, potential and perceived conflicts of interest.<\/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 covering corporate political contributions. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company discloses any details of its political contributions.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy and\/or procedure covering charitable donations or sponsorships. The Anti-Corruption Charter of Russian Business contains some limited information on this subject, but it is not sufficiently clear that the company has integrated this into its own anti-bribery and corruption framework, so this evidence is not considered in the assessment.<\/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 provides 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.<\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company requires the involvement of its procurement department in the establishment and\/or oversight of its supplier base. It is noted that in its most recently published Annual Report (2015) the company makes reference to a set of regulations on procurement, however this document is not publicly available. <\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain. <\/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. The Anti-Corruption Charter of Russian Business contains some limited information on this subject, but it is not sufficiently clear that the company has integrated this into its own anti-bribery and corruption framework, so this evidence is not considered in the assessment.<\/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. The Anti-Corruption Charter of Russian Business contains some limited information on this subject, but it is not sufficiently clear that the company has integrated this into its own anti-bribery and corruption framework, so this evidence is not considered in the assessment.<\/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 investigations relating to its suppliers, or the associated disciplinary actions.<\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is evidence that the company publishes a policy regarding the use of agents. There is no evidence that the company publishes any data on ethical or anti-bribery and corruption-related investigations relating to its suppliers, or the associated disciplinary actions.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no evidence that the conducts anti-bribery and corruption due diligence on its agents or intermediaries.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company aims to establish the ultimate beneficial ownership of its agents and intermediaries.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.<\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company considers 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 on behalf of the company.<\/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 the associated disciplinary actions involving agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its joint ventures.<\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, or that it requires anti-bribery and corruption clauses in its contracts with joint venture partners. The Anti-Corruption Charter of Russian Business contains some limited information on this subject, but it is not sufficiently clear that the company has integrated this into its own anti-bribery and corruption framework, so this evidence is not considered in the assessment.<\/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 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 conducts anti-bribery and corruption due diligence on all aspects of 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, nor is there evidence to suggest 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 subsidiaries and affiliated companies on its website. However, from the data provided it is not clear whether the companies are joint ventures, subsidiaries or affiliated companies in which the company holds a minority stake, nor is it clear whether the companies listed represent a complete list of all of its subsidiaries and holdings.<\/p>\n
There is no evidence that the company discloses the percentages ownership or countries of operation for each entity, although it is stated that all the companies listed are registered in Russia. There is also no indication that the evidence is correct and up-to-date for the most recent reporting period. The company\u2019s 2015 Auditor\u2019s Report contains ownership information for some affiliated companies, but there is no evidence that this list is comprehensive nor that it has been updated since 2015. <\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
There is evidence in the company\u2019s most recently published Annual Report that it is wholly owned by \u201cRostec\u201d, a state-owned corporation, and the company\u2019s website appears to confirm this. However, the company receives a score of \u20181\u2019 because there is no clear evidence that this ownership information is current and up-to-date. It is noted the company does not disclose details of its ownership on a national public register or global ownership database.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes any information about its major defence sales or customers. <\/p>\n"},{"question":111,"commitment_area":16,"score":"2","comments":"
The company publishes a statement that it is wholly owned by \u201cRostec\u201d, a Russian state-owned corporation, and clearly indicates that this entity is the sole owner of its shares and voting rights. <\/p>\n"},{"question":112,"commitment_area":16,"score":"1","comments":"
There is evidence that the company publishes some information about its strategic goals and objectives. However, the company receives a score of \u20181\u2019 because there is no evidence that this information is current or updated on an annual basis. <\/p>\n"},{"question":113,"commitment_area":16,"score":"0","comments":"
There is evidence that the company publishes some information about the composition of the board on its website, however it does not provide details to indicate whether each individual has any connection to the company or the state, or whether they are an independent director. The company\u2019s 2015 Annual Report provides some information on the composition of the board, however there is no indication that this is correct and up-to-date. There is also no evidence that the company publishes any information about the board nomination and appointment process. <\/p>\n"},{"question":114,"commitment_area":16,"score":"0","comments":"
There is no evidence that the company has an audit committee that is composed of a majority of independent directors.<\/p>\n"},{"question":115,"commitment_area":16,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a system in place to manage asset transactions, with responsibility for managing major transactions held at board level. There is evidence that all major transactions are recorded and documented. However, the company receives a score of \u20181\u2019 because it is not clear whether asset transactions are subject to scrutiny by an audit body, nor is there evidence that the financial results from asset acquisitions are made publicly available in reporting documents. <\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/643","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=643"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=643"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}