The company publishes a statement endorsed by its leadership that commits to ethical business conduct and principles, but it does not explicitly mention anti-bribery and corruption.<\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
The company publishes an anti-bribery and corruption policy, which applies to managers and employees. <\/p>\n
However, there is no evidence that the policy prohibits payments to public officials and facilitation payments. Additionally, there is no evidence that the company\u2019s policy applies to staff and leadership of subsidiaries and other controlled entities, or that the policy applies to all board members, including non-executive directors. <\/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 its anti-bribery and corruption programme.<\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
There is no evidence that a specific managerial-level employee has ultimate responsibility for implementing and managing the company\u2019s anti-bribery and corruption programme.<\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company has a formal risk assessment procedure which is used to inform the company\u2019s anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
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.<\/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 has a publicly stated investigative procedure which includes a commitment to report material findings. <\/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 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 emplyees who refuse to act unethically. <\/p>\n"},{"question":69,"commitment_area":9,"score":"0","comments":"
There is some evidence to suggest that the company has a policy of non-retaliation against those who report allegations or incidents of bribery or corruption. However, the company receives a score of \u20180\u2019 because the policy is unclear and there is no evidence that it applies to all employees company-wide and to those employed 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 has a whistleblowing channel. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its channels are anonymous or confidential, or that the company has any externally operated channels. There is no evidence that the company has an advice channel. There is also no evidence that the company\u2019s whistleblowing channels are available to all employees in any country of operation, in multiple languages, and to employees of third parties, suppliers or joint venture partners.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is some evidence that the company has a policy on conflicts of interest, which covers conflicts of interest related to employee relationships, other employment and financial interests. There is evidence that the company policy includes potential or actual conflicts of interest. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not refer to conflicts of interests related to government relationships. There is also no evidence that the policy explicitly applies to all employees and board members, including those of subsidiaries and other controlled entities.<\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company has procedures to manage conflict of interest or their oversight.<\/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 clear evidence that the company has a policy on corporate political contributions. The company provides some information to indicate that it does not participate in or suppor political activities, however it is not clear whether this applies to individual employees or the company as a whole, and therefore it is insufficiently clear to receive a score of \u20181\u2019. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes details of its political contributions.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is some evidence that the company has a policy covering charitable donations and sponsorships, which includes submitting an application for approval. However, the company receives a score of \u20180\u2019 because there is no evidence that these policies include measures to ensure donations are not used as vehicles for bribery and corruption, for example by specifying criteria for donations, procedures for senior sign-off, or due diligence on recipients.<\/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":"
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":"1","comments":"
There is some evidence that the company has a policy covering gifts and hospitality, which includes some financial limits on gifts employees may accept. <\/p>\n
However, the company does not clarify whether this extends to the giving of gifts and hospitality. Additionally, the policy does not address the risks associated with gifts and hospitality given to\/received from domestic or foreign public officials. Additionally, there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.<\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company's procurement department is involved, in some capacity, in the establishment and oversight of supplier relationships. <\/p>\n
However, the company receives a score of \u20181\u2019 as there is no evidence that the involvement of the procurement department is required for establishing any new suppliers over a certain threshold or that it is the main body responsible for oversight of the company\u2019s supplier base. There is also no clear 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":"0","comments":"
The company simply states that it conducts due diligence on its suppliers, without providing any further details.<\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
The company states that its suppliers must meet a certain standard of ethical business conduct, but does not specifically refer to any of the anti-bribery and corruption measures necessary to receive a score of \u20181\u2019. <\/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.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company states that it 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 its contracts with agents and intermediaries. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company mentions 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 pubilshes 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.<\/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 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 the company\u2019s 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, or 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 holdings, alongside its percentage ownership. Evidence indicates that the data represents all of the company\u2019s holdings.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is unclear that the company\u2019s data is updated at least annually. The company\u2019s data is also not accompanied by a statement that it is complete at the time of publication to the best of the company\u2019s knowledge. There is also no evidence that the list includes the countries of incorporation and operation for each entity. <\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
The company discloses all beneficial owners with an ownership interest in the company. All entities are referred to by name, along with their percentage ownership in the company. The company\u2019s ownership information indicates that the Turkish government holds 45.45% of shares through the Undersecretariat for Defence Industries, making the company partially state-owned. <\/p>\n
However, the company receives a score of \u20181\u2019 because this information is published only on the company\u2019s website and not in a freely accessible public register.<\/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 SOE publishes details of its shareholder voting rights. The company publishes information on its major shareholders, but does not provide any accompanying details of the voting rights for each entity.<\/p>\n"},{"question":112,"commitment_area":16,"score":"1","comments":"
The company publishes its commercial and public policy objectives on its website. The company indicates that its primary objectives are to meet the country\u2019s national security requirements, serve the Turkish Air Force and become a leader in the aerospace industry. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that these objectives are updated on at least an annual basis or whenever there is a change in objectives.<\/p>\n"},{"question":113,"commitment_area":16,"score":"0","comments":"
There is evidence that the company publishes some information on the composition of its board, including the names and positions of each board member. However, the company receives a score of \u20180\u2019 because it does not provide any further information on the nomination and appointment process, nor does it indicate whether each board member is independent, non-executive or a state representative. <\/p>\n"},{"question":114,"commitment_area":16,"score":"0","comments":"
There is no evidence to indicate that the company has an audit committee.<\/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.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/736","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=736"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=736"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}