There is evidence that the company has a publicly stated commitment to 'integrity' and 'high ethical standards' which is supported and endorsed by the Chairman and CEO. Although this statement does not explicitly mention anti-bribery and corruption, it forms part of the company\u2019s wider code of conduct, which outlines the company\u2019s commitment to anti-bribery and corruption.<\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company\u2019s Guide to Business Conduct provides details on its anti-bribery and corruption policy. There is evidence that it prohibits payments to public officials and that the policy applies to all employees. <\/p>\n
However, the company receives a score of \u20181\u2019 because its policy does not specifically refer to commercial bribery and it does not extend beyond a general commitment to comply with anti-bribery legislation. Although the company describes facilitation payments, it does not clearly refer to them by name and does not prohibit them. In addition, the company does not clearly indicate that its anti-bribery and corruption policy applies to board members, or the staff and leadership of subsidiaries and other controlled entities. There is some indication that the company has an additional anti-corruption document, however this does not appear to be not publicly accessible. <\/p>\n"},{"question":56,"commitment_area":7,"score":"0","comments":"
There is no evidence that the company has a designated board committee or individual board member responsible for anti-bribery and corruption. There is some indication that the company has a managerial-level Ethics Committee, which reports to the Vice-President of Human Resources, Chief Financial Officer, and General Counsel. It is not clear that the Ethics Committee reports to the board or a designated board committee. <\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
There is evidence that the company has an Ethics Committee that reports to the Vice-President of Human Resources, Chief Financial Officer, and General Counsel. However, it is not clear whether any of these individuals, or any other managerial-level individual, is ultimately responsible for implementing and managing the company's anti-bribery and corruption programme.<\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company has a formal risk assessment procedure that is used to inform its anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company\u2019s anti-bribery and corruption programme is subject to audit or review.<\/p>\n"},{"question":60,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company has a publicly stated procedure for dealing with bribery and corruption allegations, incidents or whistleblowing reports, despite some indication that it provides a whistleblowing helpline. There is no evidence that the company commits to investigating reported concerns or allegations, nor does it provide information on the conduct of internal investigations, such as whether cases are handled by an independent team and\/or report to an independent board member. There is no evidence that a central body reviews summary information on all ongoing investigations on a regular basis. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company assures itself of the quality of its internal investigations, for example, by ensuring that staff conducting investigations are properly trained or by stipulating a procedure to handle complaints about the investigation process. <\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is no evidence the company\u2019s investigative procedure includes a commitment to report material findings to the board and, if necessary, to relevant authorities.<\/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 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 its employees with regular training, however it is not explicitly clear that this training covers anti-bribery and corruption. There is no evidence to indicate how frequently employees are required to undertake training, nor whether training is provided to all employees across all divisions and countries of operation, and in all appropriate languages.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company provides tailored anti-bribery and corruption training for 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 and reviews the effectiveness of its anti-bribery and corruption or compliance programme. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company\u2019s incentive schemes for employees incorporate anti-bribery and corruption principles. There is some evidence to indicate that the promotion of an ethical culture forms part of the incentive structure for the company\u2019s leadership, however there is no evidence that this applies across the organisation to all employees. <\/p>\n"},{"question":68,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company commits to support and protect employees who refuse to act unethically, when where such decisions may result in a loss of business or profit. The company\u2019s Guide to Business Conduct encourages employees to ask questions about workplace behaviour if necessary and states that employees should not deviate from company values in order to make a profit.<\/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 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 has a publicly stated policy of non-retaliation against whistleblowers and employees who report concerns around unethical business practices. <\/p>\n
However, 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. There is also no clear evidence that this policy applies to those engaged by the group as third parties, suppliers and joint venture partners.<\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides multiple channels for employees to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. There is evidence that these channels are sufficiently varied to allow the employee to raise concerns across the management chain and to external bodies through an independent third party hotline. These channels allow for anonymous reporting and there is evidence that they are available to employees in countries of operation where the company has a significant presence. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not indicate that reports are treated confidentially and there is no evidence that channels are available in all countries of operation or all appropriate languages. Moreover, although suppliers are able to use the whistleblowing line, there is no indication that third parties and joint venture partners are also invited to use the channels. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy on conflicts of interest for its employees, which specifically refers to actual and perceived conflicts. There is evidence that the categories of conflict it covers include employee relationships and financial interests. The company also has a separate policy that applies to its board members and refers to actual, potential and perceived conflicts. <\/p>\n
However, the company receives a score of \u20181\u2019 because its employee conflict of interest policy does not cover government relationships or other employment, and its board member policy does not discuss any of the possible categories of conflict outlined in the scoring criteria. <\/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. The company states that employees must inform the company\u2019s legal counsel of any apparent conflicts, while directors must inform the chairperson of the board. In situations where board members are found to have conflicts, there is evidence that they may be required to resign from the board or be exempt from voting on related matters. <\/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 policy also does not mention examples of criteria for recusal and does not specifically state that disciplinary measures apply if the company\u2019s policy on conflicts is 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":"0","comments":"
There is some evidence that the company has a policy on corporate political contribution. The company\u2019s policy indicates that it does not make political contributions in the United States in line with local regulations, but states that it may make political donations in other countries where permitted and subject to prior approval. Although there is evidence that any donations must be properly documented and recorded, there is no evidence that approval must be given from an individual with legal expertise. The company also states that it does not currently make donations through a Political Action Committee but indicates that it may in the future. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes 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 or procedure covering charitable donations and sponsorships, despite evidence that it engages in such activities. The company provides some information on the types of charitable initiatives that it supports on its website, but does not disclose specific details such as the recipient, amount, country of recipient, or which corporate entity made the payment. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is some evidence that the company has controls in place to regulate lobbying activities by requiring employees to comply with all relevant laws. There is some indication that the company\u2019s legal counsel has oversight of lobbying activities but this is not clear. <\/p>\n
The company receives a score of \u20180\u2019 because there is no evidence that it publicly defines lobbying, nor that it outlines what it considers to be responsible lobbying principles. Additionally, the company\u2019s policy is unclear and does not mention standards of conduct or specific oversight mechanisms that apply to all types of lobbyists. The company does not outline any controls or guidelines. It is also not clear whether this policy applies to board members and third parties engaged in lobbying activities on the company\u2019s behalf. <\/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. The company states that it will express its views to governments on subjects that might affect the company\u2019s welfare, but provides no further information on the topics that this may include.<\/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":"1","comments":"
There is evidence that the company has a policy on the giving and receipt of gifts and hospitality to ensure that such promotional expenses are bona fide and not used for bribery. The company\u2019s policy indicates that employees should generally refuse gifts and hospitality, and specifically states that the giving and receipt of promotional expenses to\/from government officials is not permitted under any circumstances. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not specify financial limits or approval procedures for different types of gifts and hospitality. There is also no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.<\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company requires and ensures the involvement of its procurement department in the establishment and\/or oversight of its supplier base. The company provides a description of good practice in procurement within its Guide to Business Conduct but this does not mention the procurement department or a central team responsible for the process. <\/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 suppliers. The company states that it will not engage with suppliers with a history of fraudulent or unethical activity, but it is not clear how the company assures itself of this. <\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
There is evidence that the company expects certain standards of conduct from its suppliers, but there is no clear evidence that the company ensures that its suppliers have specific anti-bribery and corruption standards in place that meet a high standard. The company\u2019s General Terms and Conditions of Purchase simply state that suppliers must comply with anti-corruption laws.<\/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 policy covering the use of agents. The company states that employees should not use a consultant or other presentative to break the law, but it is not clear that this specifically includes agents nor does it outline controls to prevent this from occurring. <\/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. The company does not commit to not engaging or terminate its engagement with agents or intermediaries if beneficial ownership cannot be established.<\/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 recognises incentive structures as a risk factor in agent behaviour, nor that incentive structures are designed to minimise bribery or corruption risks. <\/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 and\/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. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to taking 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 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 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 its behalf. <\/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 provides a list of its subsidiaries in its annual filing to the U.S. Securities and Exchange Commission. For each entity, the company lists the country of incorporation. Since this information is published in an annual reporting document, it is understood that this list is updated on an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because the company does not provide further details for each entity such as the percentage ownership and country of operation. Although it the list forms part of an annual reporting document, this list is not accompanied by a statement that it is complete at the time of publication so it is not fully clear whether the list includes all of the company\u2019s holdings such as joint ventures or associates. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed on the Nasdaq Stock Market and therefore it automatically receives a score of \u20182\u2019. The company also indicates that it is publicly listed in its report to the U.S. Securities and Exchange Commission.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is evidence that the company provides some information on its major customers in its filing to the U.S. Securities and Exchange Commission. The company indicates that the U.S. government comprised approximately 25% of its revenue in 2019 but this figure is understood to represent a portion of overall company sales rather than defence specifically. The company does not provide a percentage breakdown of sales for other customers and therefore does not reach the minimum threshold of 50% to receive a score of \u20181\u2019.<\/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\/646","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=646"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=646"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}