There is evidence that the company\u2019s Code of Business Ethics outlines the company's stance against bribery and corruption. It is clear that the Code of Business Ethics was authorised and endorsed by the company's leadership in the form of an introductory message signed by Chief Executive Officer. However, this message does not specifically mention anti-bribery and corruption and therefore a score of \u20181\u2019 applies.<\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company publishes an anti-bribery and corruption policy as part of its Code of Business Ethics, which applies to all employees, directors, as well as the staff and leadership of the company\u2019s wider corporate group. There is evidence that the policy explicitly prohibits bribery. <\/p>\n
However, the company receives a score of \u20181\u2018 because there is no evidence that the policy also prohibits facilitation payments or payments to public officials. <\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is evidence that a designated board committee \u2013 the Audit Committee \u2013 is ultimately responsible for oversight of the company's compliance programme and Code of Business Ethics, which includes the company\u2019s anti-bribery and corruption policy. <\/p>\n
However, there is no clear evidence that this committee engages in formal oversight functions such as reviewing reports from management on the company\u2019s anti-bribery and corruption programme\u2019s performance, or the results of internal and external audits, or that it has the authority to require that changes are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
There is evidence that a designated senior executive \u2013 the Chief Compliance Officer \u2013 has ultimate responsibility for managing the company's compliance and ethics programme, which is understood to include the company\u2019s anti-bribery and corruption programme. <\/p>\n
However, there is no evidence that this individual has a direct reporting line to the board or board committee that provides oversight of the anti-bribery and corruption programme.<\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
There is some evidence to suggest that the company recently conducted a risk assessment that was used to inform the design of its anti-corruption programme. However, there is no clear evidence that bribery and corruption risk assessments are reviewed on at least an annual basis, or that the results are reviewed at board level. <\/p>\n
It is noted that the company has broader risk assessment procedures in place, however there is no evidence that these assess bribery and corruption risk, nor that the results of such reviews are used to develop tailored mitigation plans and to update specific parts of the company's anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is some evidence to suggest that the company\u2019s anti-corruption programme is subject to regular review. However there is no clear evidence that such reviews include a formal audit or review process, nor is there evidence that high-level findings are presented to the board or that a specific individual or body has responsibility for making improvements to the programme.<\/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 a specific procedure in place to deal with whistleblowing cases, which stipulates some of the documentation and actions that will be taken. There is also evidence that whistleblowing investigations are handled by an independent team.<\/p>\n
However, the company receives a score of \u20181\u2019 because no evidence has been identified which describes the entire investigative process, from receipt to final outcome. There is also no evidence that the company commits to provide whistleblowers with updates on the outcome of investigations. Furthermore, there is no evidence that a central body reviews information on cases on at least an annual basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
There is evidence that the company assures itself of the quality of its internal investigations, stating that investigative teams are trained to perform their roles. There is also some evidence that there is a system in place for escalating concerns if an unacceptable response is not received in the first instance. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further details with regards to how complaints about the investigation process are handled, or who is responsible for the handling of such complaints. There is also no evidence that the company reviews its investigations procedure at least every three years or in response to any changes in the regulatory environment.<\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company has an investigative procedure which includes a commitment to report material findings to the board. Although there is evidence that indicates the company may report findings to the relevant authorities, there is 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, bribery or corruption-related investigations or associated disciplinary actions involving its employees. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides ethics and compliance training for all employees, which is understood to include its anti-bribery and corruption policy. The company indicates that employees must undertake and refresh this training on an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that this training applies to employees in all countries and regions of operation or in all appropriate languages. There is also no clear publicly available evidence that this training covers the whistleblowing options available to employees. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides tailored anti-bribery and corruption training to employees in high risk positions. However, it is not clear from the available evidence that employees in high risk positions are required to undertake and refresh their training on at least an annual basis. There is also no evidence that the company provides tailored anti-bribery and corruption training to middle management or board members. <\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
There is evidence that the company measures and reviews the effectiveness of its ethics and compliance training and communication programme, which includes anti-corruption training. There is evidence that the company has a system to do this, for example through staff surveys and monitoring the use of ethics and compliance resources, and that the company monitors the number of personnel trained and completion rates. There is evidence that the company uses the results of such reviews to update the company's ethics and compliance communications and training programme. <\/p>\n
The company receives a score of \u20181\u2019 because it is unclear whether the company conducts a full review of its ethics and compliance communications and training programme at least every three years.<\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company\u2019s incentive schemes for employees incorporate ethical and anti-bribery and corruption principles. The company indicates that employees must complete its ethics and compliance training in order to be eligible for any annual rewards. <\/p>\n
However, there is no evidence to suggest that incentives are designed to reward behaviour in line with the company\u2019s ethical values as identified through performance appraisals or conduct in the workplace. In addition, it is not clear whether financial rewards must be proportionate to the employee\u2019s salary in the case of high risk employees, such as sales roles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is evidence that the company commits to support employees to \u201cmake good decisions\u201d and \u201cdo the right thing\u201d when faced with ethical dilemmas in the workplace. However, there is no clear evidence that the company clearly commits to support or protect employees who refuse to act unethically, even where such actions result in a loss to the company, nor that it assures itself of employees\u2019 confidence in this commitment. <\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":"
There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. This policy applies to all employees across the organisation, including those engaged by the group as third parties and suppliers. There is evidence that the company commits to assure itself of its employees\u2019 confidence in this commitment through periodic anonymised surveys.<\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides multiple channels for its employees to report instances of suspected corrupt activity and seek advice on its anti-bribery and corruption programme. There is evidence that channels are sufficiently varied to allow the employee to raise concerns across the management chain and externally to an independently-operated helpline. These channels allow for confidential and, wherever possible, anonymous reporting. There is evidence that the channels are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners, and in all relevant languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence that the company formally addresses conflicts of interest as a corruption risk, and has a clear policy that defines conflicts of interest, including actual, potential and perceived conflicts. There is evidence that this policy explicitly covers all of the categories of possible conflicts listed in the guidance. There is also evidence that the company states that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities.<\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has procedures to manage conflicts of interest, including actual, potential and perceived conflicts. There is evidence that the Audit Committee is responsible for investigating potential violations of its conflict of interest policy, which is understood to extend to oversight of the policy implementation overall. The company states that disciplinary measures will apply if the conflicts of interest policy is breached.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is also no evidence that all employee and board member conflicts of interest declarations are recorded in a dedicated central register that is accessible to those responsible for oversight of the process. Furthermore, there is no evidence that the company provides examples of criteria for recusals.<\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy which outlines controls to assess and regulate employment and offers of employment or consultancy engagement to current and recently departed public officials. There is evidence that the company requires legal approval for the initiation of any employment discussions with current or former public officials. There is also evidence that restrictions can be placed on the activities of former public officials upon joining the company, including whether they can have contact or a relationship with their former organisation on the company\u2019s behalf. <\/p>\n
The company receives a score of \u20181\u2019 because the publicly available evidence suggests that its policy applies specifically to the employment of current or former public officials in the United States. There is no publicly available evidence in relation to the company\u2019s policy regarding the recruitment of public officials in other jurisdictions. In addition, there is no evidence that the company\u2019s U.S. policy includes cooling-off periods. <\/p>\n
It is noted that the company makes reference to a policy entitled Recruiting of Government Employees \/ \"Revolving Door\" Recruiting, but this does not appear to be publicly accessible.<\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company publishes details of the contracted services of serving politicians. <\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is evidence that the company has a policy that prohibits corporate political contributions to any parties, candidates or campaigns. The company indicates that this policy extends to any payments on its behalf, both financial and in-kind. In addition, there is evidence that the company is associated with a Political Action Committee (PAC) in the United States. The company states that its PAC is managed by the Office of Government Relations and that all relevant activities are overseen by a committee composed of senior leaders from across the U.S. business. <\/p>\n
Since it is associated with a PAC in the United States, the company receives a score of \u20180\u2019 in line with the scoring criteira. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
The company publishes some information on its political expenditures, including a list of all membership dues paid to trade associations in the United States. However, the company receives a score of \u20180\u2019 because there is no evidence that it publishes details of the donations made through any Political Action Committee (PAC). <\/p>\n
It is noted that the company states that its PAC contributions are published on the United States Federal Election Commission (FEC) website, however there is no direct link on the company\u2019s website to relevant disclosures.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is evidence that the company has a policy and procedure covering both charitable donations and sponsorships. There is also evidence that the company discloses the causes it supports and provides summaries of its financial donations to charitable and social causes. <\/p>\n
However, the company receives a score of \u20180\u2019 because there is no evidence that its policy incorporates anti-corruption controls to ensure that donations and sponsorships are not used as vehicles for bribery and corruption, such as specifying criteria for donations or due diligence on recipients. There is also no evidence that the company provides full details of its charitable donations, such as the name, amount and location of each recipient entity.<\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy on lobbying, which applies to all employees, board members and third parties engaged to work on its behalf. There is also evidence that the company\u2019s Audit Committee, senior management and Office of Government Relations provide oversight of the company\u2019s lobbying activities.<\/p>\n
However, the company receives a score of \u20181\u2019 because the company\u2019s policy does not define responsible lobbying, and it does not mention specific standards of conduct or oversight mechanisms that apply to all lobbyists. <\/p>\n
It is noted that the company makes reference to a policy entitled Contacts with Public Officials, but this document is not publicly available. <\/p>\n"},{"question":79,"commitment_area":11,"score":"1","comments":"
The company publishes some information on its lobbying topics and activities in the United States by making its quarterly federal lobbying reports publicly available via a direct link on its website. <\/p>\n
However, the company does not provide details about its broader public policy aims or positions. The company also does not publish any information about its lobbying activities outside of the United States, nor does it indicate that it does not engage in lobbying elsewhere.<\/p>\n"},{"question":80,"commitment_area":11,"score":"1","comments":"
There is evidence that the company publishes summary information of its lobbying expenditure in the United States, alongside a breakdown of how the total expenditure was calculated, on an annual basis. In addition, the company\u2019s website includes a direct link to its federal quarterly lobbing reports, which include a lobbying expenditure figure. <\/p>\n
However, this expenditure data is not broken down into internal, external or association lobbyists and does not include an explanation of how these figures have been calculated. Furthermore, there is no evidence that the company publishes its lobbying expenditure for other jurisdictions around the world in which it conducts lobbying, nor a statement that it does not lobby outside of the United States.<\/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 not used as vehicles for bribery and corruption, which includes approval procedures. There is also evidence that the company specifically addresses the risks associated with gifts and hospitality given to\/received from domestic and foreign public officials. <\/p>\n
However, the company receives a score of \u20181 because it does not publicly indicate that it implements financial or proportional limits or different approval procedures for different types of promotional expenses. There is also 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
It is noted that the company appears to make reference to a \u2018Gifts, Meals, Entertainment and Travel\u2019 policy which may contain more information, but this is not publicly available.<\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is evidence that the company's procurement department is involved, in some capacity, in the establishment and oversight of supplier relationships. The evidence suggests that this department is the main body responsible for the establishment of new supplier relationships and oversight of the supplier base. <\/p>\n
The company receives a score of \u20181\u2019 because there is no evidence that the company assures itself of the procurement department\u2019s involvement at least every three years through clearly stated means, such as an audit or other assurance process.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct due diligence on all suppliers. There is evidence to suggest that the company is willing to review and\/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence process cannot be mitigated. <\/p>\n
However, there is no evidence that the company\u2019s due diligence process includes, at least, checks on ultimate beneficial ownership. There is also no evidence to suggest that highest risk suppliers are subject to enhanced due diligence. In addition, although there is some evidence to suggest that due diligence is conducted periodically throughout the business relationship, the frequency of these checks is unclear; there is no evidence to suggest that due diligence is conducted at least every two years or when there is a change in the business relationship.<\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company indicates that it requires its suppliers adhere to its Code of Business Ethics, which prohibits bribery and includes provisions for conflicts of interest, gifts and hospitality and whistleblowing. In addition, there is evidence that the company requires its suppliers to comply with a supplementary Supplier Standards of Conduct, which also addresses bribery and corruption. <\/p>\n
However, while the company\u2019s Supplier Standards of Conduct includes a section detailing the company\u2019s audit rights, there is no evidence which specifically states that the company assures itself of its suppliers\u2019 anti-bribery and corruption programme when onboarding new suppliers and\/or when there is a significant change in the business relationship.<\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
There is evidence that the company takes steps to ensure that its sub-contractors have adequate anti-bribery and corruption programmes in place and that the substance of its anti-corruption and bribery programme and standards are included throughout the supply chain. This evidence is in the form of a set of supplier principles outlining the minimum standards of ethical behaviour expected 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 investigations or associated disciplinary actions relating to its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has a policy on the use of agents, which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. There is evidence that this policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures. <\/p>\n
However, there is no evidence that the company explicitly commits to verifying in each case that the use of an agent is necessary to perform a legitimate business function. <\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging with its third parties and agents. <\/p>\n
However, it is not clear that highest risk agents and intermediaries are subject to enhanced due diligence. Also, while the company states that due diligence is conducted periodically throughout the business relationship, the frequency of this process is unclear. There is also no clear evidence that due diligence is 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 that it commits to not engaging or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is evidence that the company\u2019s anti-corruption policies explicitly apply to all agents and third parties acting for or on behalf of the company. However, there is no evidence that the company includes anti-bribery and corruption clauses in contracts with agents and intermediaries to detect, control and prevent breaches. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company addresses 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 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, bribery or corruption-related investigations, or the associated disciplinary actions, involving its agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering and while operating in all joint ventures. <\/p>\n
However, there is no evidence that the company\u2019s due diligence explicitly includes checks on the ultimate beneficial ownership of the partner company. There is also no evidence that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence. Additionally, while the company states that due diligence is conducted periodically throughout the business relationship, there is no clear evidence that it is repeated at least every two years or when there is a significant change in the business relationship.<\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is evidence that entities controlled by the company are required to comply with the standards contained in its Code of Business Ethics. <\/p>\n
However, the company scores \u20180\u2019 because there is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in all of its joint ventures. Furthermore, there is no evidence that it 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 taking 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 managing the company\u2019s 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 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 indirect offset obligations and\/or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is some evidence that the company recognises the corruption risks of operating in different markets, however there is no clear evidence that risk assessment procedures are used to design tailored mitigation plans or 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 consolidated subsidiaries and non-fully consolidated holdings. It also publishes the country of incorporation alongside each entity. There is evidence that the data is updated on an annual basis.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is unclear if the published list includes all of the company\u2018s holdings, including all joint ventures, or whether it just includes the company\u2019s main subsidiaries. In addition, the list does not include the percentage owned or information on the country of operation for each entity. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publilcy listed on the New York Stock Exchange (NYSE) and therefore it is not required to disclose further information on its beneficial ownership to receive a score of \u20182\u2019. The company also indicates that it is publicly listed in its Annual Report. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes a percentage breakdown of its major defence customers. The company provides some summary information on the portion of revenue generated from each industry group, but this does not specifically refer to aerospace and defence and does not provide any information on its main customers. <\/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\/785","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=785"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=785"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}