The company states that employees must commit to maintaining high ethical standards in their professional conduct, without mentioning bribery or corruption, and this statement is not authorised or endorsed by the company's leadership.<\/p>\n"},{"question":55,"commitment_area":7,"score":"0","comments":"
The company does not publish an anti-bribery and corruption policy. The company states that employees must behave ethically, without specifically mentioning bribery and corruption. Although the company references a Code of Corporate Ethics and an Anti-Corruption Policy, these documents are not publicly available. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
The company states that the Board of Directors and the Audit Committee provide oversight of the company's anti-bribery and corruption programme. There is evidence that both the Board and the Audit Committee engage in formal oversight functions, such as reviewing the results of audits and risk assessments. <\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
There is no evidence that a specific senior individual has ultimate responsibility for implementing and managing the company\u2019s anti-bribery and corruption programme. <\/p>\n"},{"question":58,"commitment_area":8,"score":"2","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. There is evidence that the results of assessments are shared at board-level on at least an annual basis and that the company\u2019s anti-bribery and corruption programme is updated based on these risk assessments.<\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
The company states that the Internal Audit Directorate of the company evaluates its risk management system, which includes its anti-corruption programme.<\/p>\n
While the company indicates that the risk management system is reviewed on an annual basis by the Board of Directors, it states only that the audits themselves are conducted regularly. <\/p>\n"},{"question":60,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company has a procedure for dealing with bribery and corruption allegations, incidents or whistleblowing reports.<\/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":"1","comments":"
There is evidence that the company has a system in place for informing the Board of Directors of any suspected violations of the law or its Code of Ethics. <\/p>\n
However, it is not explicitly stated that this includes material findings of bribery and corruption and 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":"
The company does not publish any data on ethical or bribery and corruption investigations or disciplinary actions involving its employees.<\/p>\n"},{"question":64,"commitment_area":9,"score":"0","comments":"
The company states that training forms a part of risk management procedures. However, there is no evidence that the company provides anti-bribery and corruption training to all employees.<\/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.<\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company measures or reviews the efficacy 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 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":"0","comments":"
The company has a policy of non-retaliation against employees who report bribery and corruption incidents. However, the policy does not explicitly refer to whistleblowers, and it is unclear whether it applies to those employed by third parties, suppliers and joint venture partners. There is also 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":"0","comments":"
Although the company makes reference to the existence of a hotline, it provides no further details and therefore cannot receive a score of \u20181\u2019. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy covering actual and potential conflicts of interest, which applies to all employees and board members. This policy covers conflicts relating to other employment and financial interests. <\/p>\n
However, the policy does not make reference to government relationships or personal relationships.<\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
The company states that it has created systems for shareholders and board members to identify and manage conflicts of interest. However, there is no evidence that declarations are held in a dedicated register and there is no reference to a specific body or individual with oversight and accountability for handling cases. It is also not sufficiently clear whether there are procedures in place for employees to identify, declare and manage 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":"2","comments":"
The company publishes a clear statement that it does not make corporate political contributions.<\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":""},{"question":77,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is some indication that the company makes charitable donations and sponsorships. However, there is insufficient evidence in relation to whether the company has a policy and\/or procedure covering charitable donations and sponsorships to ensure that they are not used as vehicles for bribery and corruption.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy and\/or procedure on lobbying.<\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
The company publishes insufficient information on its lobbying aims, topics or activities.<\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
The company discloses its donations to some interest groups which have conducted lobbying on the company\u2019s behalf, however this is insufficiently detailed to merit a score of \u20181\u2019. <\/p>\n"},{"question":81,"commitment_area":11,"score":"0","comments":"
There is evidence that the company has a policy in relation to the receipt of gifts, which is applicable to board members only. However, this only addresses the receiving of gifts and does not mention the company\u2019s policy on giving of gifts and hospitality. Furthermore, there is no evidence to indicate that the company has clear controls in place which apply to the company\u2019s employees to counter the bribery and corruption risks posed by gifts and hospitality, such as approval procedures, or a dedicated register. As a result, the publicly available evidence is insufficient to receive a score of \u20181\u2019. <\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is evidence that the company\u2019s Procurement Commission is involved, in some capacity, in the establishment and oversight of supplier relationships. There is evidence to suggest that this department is the main body responsible for oversight of the company\u2019s supplier base. <\/p>\n
However, the company does not state that the involvement of the Procurement Commission is required for establishing any new suppliers over a certain threshold and there is no evidence that the company assures itself of the Procurement Commission\u2019s involvement at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
The company simply states that it carries out checks against third parties, without specifying that these checks are conducted for suppliers, or providing any further details. <\/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 company states that it prevents and prohibits corruption in its supplier relationships, but does not specifically refer to any anti-bribery and corruption measures.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.<\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.<\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company has a clear policy on the use of agents. <\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company 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 beneficial ownership of its agents.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company includes anti-bribery and corruption clauses in contracts with agents and intermediaries. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
The company makes no reference to incentive structures as a risk factor in agent behaviour.<\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
The company does not publish any details of the agents currently contracted to act for or 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 the company requires anti-bribery and corruption clauses in its contracts with joint venture partners.<\/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.<\/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 all aspects of its offset obligations. <\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company\u2019s offset programme.<\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
The company does not publish any details of its offset obligations or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is some evidence that the company acknowledges the corruption risks of operating in different markets, however there is no publicly available information which suggests that risk assessment procedures are used to inform the company\u2019s operations in high risk markets.<\/p>\n"},{"question":108,"commitment_area":15,"score":"0","comments":"
The company does not publish a list of fully consolidated subsidiaries and non-fully consolidated holdings (associates, joint ventures and other related entities).<\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
The company discloses the identity of its majority shareholder as of March 2019; it is assumed that this information is still accurate. <\/p>\n
However, the company does not disclose details in an open data format and there is no ownership information published in a central public register.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
The company does not publish a percentage breakdown of its defence sales by customer.<\/p>\n"},{"question":111,"commitment_area":16,"score":"0","comments":"
The SOE does not publish a breakdown of its shareholder voting rights.<\/p>\n"},{"question":112,"commitment_area":16,"score":"2","comments":"
The SOE's commercial and public policy objectives are made publicly available on its website. There is evidence that these objectives are updated on an annual basis. <\/p>\n"},{"question":113,"commitment_area":16,"score":"0","comments":"
The company discloses insufficient information about the composition of its board of directors to satisfy the requirements to receive a score of \u20181\u2019.<\/p>\n"},{"question":114,"commitment_area":16,"score":"0","comments":"
There is no evidence that the SOE's Audit Committee is composed of a majority of independent directors, as the structure of the company's Audit Committee is not disclosed.<\/p>\n"},{"question":115,"commitment_area":16,"score":"0","comments":"
The company states that independent appraisers should be involved in asset transactions. However, it is not clear from publicly available evidence whether responsibility for managing asset transactions is always held at board level, and there is no further detail regarding whether the company has a system to assure itself that asset transactions follow a transparent process to ensure they accord to market value.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/644","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=644"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=644"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}