There is evidence that the company publishes statements from both the CEO and Chairman of the Board that outline a commitment to integrity and high ethical standards. In addition, the company indicates that its CEO has personally endorsed the Code of Conduct, but there is no direct evidence of this in practice. The company receives a score of \u20181\u2019 because there is no evidence that the company\u2019s senior leadership publish a statement outlining its commitment to anti-bribery and corruption within the organisation. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company publishes an anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and there is evidence to indicate that it also applies to board members and directors. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that the board, through its Audit and Risk Committee, is responsible for oversight of the company's ethics programme. There is evidence that the committee\u2019s oversight responsibilities include reviewing reports from management on the programme\u2019s performance, and it is clear that the committee has the authority to require that any necessary changes to the programme are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s CEO is ultimately responsible for the management and implementation of the anti-bribery and corruption programme, with daily operational responsibility delegated to the Sector Chief Executives and Managing Directors. The CEO has a direct reporting line to the board and there is evidence of reporting and feedback activities between the CEO and the board, as well as to the Audit and Risk Committee. <\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is clear evidence that the company has a formal bribery and corruption risk assessment procedure that informs the design of the anti-bribery and corruption programme. The company states that all departments produce a corruption risk assessment twice a year, and that the results are reviewed by the company\u2019s central risk management function. In addition, there is evidence that high level findings from risk assessments are reviewed by the board and 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":"1","comments":"
Based on publicly available information, there is evidence the company\u2019s anti-bribery and corruption programme is subject to regular review. The company indicates that the results of such reviews are presented to the board. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that its entire programme is subject to internal or external audit on a regular basis to ensure that it is consistent with high standards of best practice and the business risks facing the company.<\/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. The company indicates that whistleblowing reports are initially handled by an independent third party, then transferred to the company\u2019s senior management for investigation. There is evidence to suggest that summary information on investigations is reviewed at the Audit and Risk Committee\u2019s quarterly meetings. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes information on its whole investigation process from receipt to final outcome, nor is there evidence that it publicly commits to provide whistleblowers with updates on the outcome of investigations. It is also not clear how the company ensures the independence of its investigations, for example through an independent investigations team or reporting to an independent board member.<\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company assures itself of the quality of its internal investigations by ensuring that staff are properly trained, implementing a system to handle complaints about the procedure, or reviewing its procedure at least every three years.<\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly commits to report material findings of bribery and corruption from internal investigations to the board-level Audit and Risk Committee. However, the company receives a score of \u20181\u2019 because 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 high-level data on ethical or bribery and corruption investigations or disciplinary actions involving its employees. The company publishes the number of reports received through its whistleblowing channels on an annual basis, however there is evidence that this does not include reports received through other channels and it does not include further details such as number of investigations or disciplinary actions taken as a result. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is some evidence the company provides training for all employees that outlines the basic principles of the company\u2019s Anti-Bribery and Corruption Policy and Code of Conduct, both of which include information on the whistleblowing options available. There is evidence that all employees across all across all divisions worldwide are required to undertake an online training module.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear how frequently employees are required to undertake and refresh their training on anti-bribery and corruption. There is also no clear evidence that the company provides training in all appropriate languages.<\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company provides tailored anti-bribery and corruption training for employees in certain positions, based on an assessment of their role and exposure to corruption risk. The company indicates that it provides training for employees in high risk positions, which may include those in marketing, contracting, procurement or client-facing roles. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it provides tailored anti-corruption training to middle management and board members. In addition, there is no evidence that employees in high risk positions must refresh their anti-corruption training on at least an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company measures or reviews the effectiveness of its anti-bribery and corruption communications or training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company\u2019s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles. The company publishes some information on its performance-based incentives for senior executives, but there is no evidence that this includes ethical factors nor that it applies to general employees. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no clear evidence that the company publicly commits to support or protect employees who refuse to act unethically. The company indicates that employees should seek advice on its ethics programme and states that it will support employees who raise concerns, but it is not clear that the company encourages employees to refuse to act unethically even where such actions may result in a loss of business. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption concerns. The company indicates that this policy applies to all employees across the organisation, including those employed by the group as third parties, such as suppliers and joint venture partners. <\/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 commitment through surveys, usage data, or other clearly stated means.<\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, 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. The company indicates that these channels are sufficiently varied to allow the employee to raise concerns across the management chain, as well as externally to an independent third party. These channels allow for confidential and anonymous reporting and are available and accessible to all employees in all jurisdictions where the company operates. There is evidence indicating that the company\u2019s whistleblowing channels are available to third parties, including suppliers and joint venture partners.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy for conflicts of interest, which refers to actual, potential and perceived conflicts of interest. The company has procedures on conflicts of interest for employees and board members, and there is some indication that its approach covers possible conflicts arising from employee relationships and business relationships. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its policy addresses and covers possible conflicts arising from government relationships, financial interests or outside employment.<\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company states that disciplinary measures will apply if its Anti-Bribery and Corruption Policy or Code of Conduct, which include its conflict of interest policy, are breached. The company indicates that director declarations are stored in a central register made available to the board, which has responsibility for managing director conflicts of interest. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that all employee conflicts declarations are held in a dedicated central register. It is also not clear whether a specific body or individual holds responsibility for oversight and accountability for handling conflicts of interests of all employees. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the company has a policy or procedure regulating the appointment of directors, employees or consultants from the public sector.<\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company publicly reports details of any contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy that clearly all corporate prohibits political donations, whether made directly or indirectly. The company that this police includes both financial expenditures and in-kind donations to political parties, campaigns or candidates. There is evidence that any requests to deviate from this policy would be handled by the Group CEO, and indicates that it has not made any such donations in the past two years. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
The company publishes a clear statement that it does not make political contributions, and therefore it is exempt from scoring on this question. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence the company has a policy covering charitable donations and sponsorships, to ensure that such donations are not used as vehicles for bribery and corruption. There is evidence that these procedures include measures to ensure this, by specifying criteria for donations, procedures for senior sign-off and due diligence on donation recipients.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes details of its charitable donations and sponsorships made in the most recently reported financial year, such as the recipient, amount, country of recipient and which corporate entity made the payment.<\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy that defines lobbying and outlines certain practices which constitute legitimate lobbying activity. The company indicates that all lobbying activity undertaken by the company must receive the prior approval of the Group CEO. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its policy describes certain standards of conduct or specific oversight mechanisms that apply to all types of lobbyists. The company does not publish further information on controls to prevent and reduce corruption risks in 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 publishes any details of its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"2","comments":"
There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, which stipulates procedures to ensure that such promotional expenses are bona fide and not used for bribery. There is evidence that the company requires all business units to establish specific financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The company also explicitly addresses the risks associated with gifts and hospitality given to and\/or received from public officials. There is evidence that all gifts and hospitality are recorded centrally and this information is held by the Group General Counsel. <\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company's procurement department is involved in the establishment and oversight of supplier relationships. However, the company receives a score of \u20181\u2019 because there is no clear evidence that it assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means, such as an audit or other assurance process, at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence when engaging and re-engaging with any suppliers. The company indicates that this due diligence process includes establishing the ultimate beneficial ownership of the supplying company. There is evidence that the highest risk suppliers are subject to enhanced due diligence and that the company might be willing to review supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated. In addition, the company indicates that it conducts such checks at the selection stage and that the business relationship is monitored on an ongoing, proportionate basis. <\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company states that all suppliers are expected to adhere to its anti-bribery and corruption policy or implement equivalent policies which prohibit foreign and domestic bribery and facilitation payments. In addition, the company indicates in its Supplier Code of Conduct that suppliers must adhere to procedures addressing conflicts of interest, gifts and hospitality, and whistleblowing. There is evidence that the company assures itself of this when onboarding new suppliers and on an ongoing, proportionate basis thereafter. <\/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 programme and standards are included in subcontracts throughout the supply chain. The company provides a clear description of the minimum standards of anti-corruption and ethics that it expects to be observed throughout its supply chain, and indicates that it will work alongside suppliers to help to implement these standards.<\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company publishes any high-level data on ethical or anti-bribery and corruption investigations or disciplinary actions involving its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has a policy and procedures to control the use of agents, which address the corruption risks associated with their use and provide details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of an agent is, in each case, necessary to perform a legitimate business function. There is evidence indicating that this policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures. <\/p>\n"},{"question":89,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and\/or re-engaging any agents and intermediaries. There is also evidence that all agents and highest risk intermediaries are subject to several layers of enhanced due diligence. The company indicates that it refreshes this due diligence every two years and that all agent relationships are reviewed as part of an annual risk assessment process. <\/p>\n
In addition, there is some evidence to indicate that the company may escalate the findings of due diligence to a Sector Manager or one of the Group\u2019s lawyers if red flags arise. The company states that the appointment of agents may only proceed in compliance with the due diligence process, indicating that it may terminate its engagement with agents in cases where red flags identified cannot be mitigated.<\/p>\n"},{"question":90,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence the company has formal procedures to establish the beneficial ownership of agents prior to engaging them as part of its due diligence process. There is evidence that the company commits to independently verify the beneficial ownership information provided by high risk agents with due diligence repeated at least every two years. <\/p>\n
In addition, there is some evidence to indicate that the company may escalate to a Sector Manager or one of the Group\u2019s lawyers if red flags arise. The company states that the appointment of agents may only proceed in compliance with the due diligence process, indicating that it may terminate its engagement with agents in cases where beneficial ownership cannot be established.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is evidence the company\u2019s anti bribery and corruption policy applies to all agents acting for or on behalf of the company. The company includes anti-bribery and corruption clauses in its contracts with such entities. However, the company receives a score of \u20180\u2019 because there is no clear evidence that these contractual clauses include audit and termination rights.<\/p>\n"},{"question":92,"commitment_area":13,"score":"2","comments":"
There is clear publicly available evidence the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company indicates that compensation for agents must be based on the work provided and commensurate with legitimate market rates in the given jurisdiction, to avoid disproportionate or significant success fees or commissions. In addition, the company commits to question any requests for payments into foreign bank accounts. Although the company does not explicitly state that agents are paid based on clear milestones, there is sufficient evidence that all payments are monitored and that must be appropriately invoiced that the company can receive a score of \u20182\u2019. <\/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. The company indicates that it maintains a database of all agents, including name, term of appointment, territory, project and the services rendered; however, this database does not appear to be publicly available. <\/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 disciplinary actions involving its agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all of its joint venture partnerships. There is evidence that this process includes establishing the beneficial ownership of the partner company, as well as enhanced due diligence for joint ventures operating in high risk countries or when other red flags are identified. In addition, there is evidence to indicate that the company repeats these checks at least every two years or when there is a significant change in the business relationship.<\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence the company commits to establishing and implementing anti-bribery and corruption policies in all of its joint ventures. The company states that joint venture partners are expected to adopt its own Anti-Bribery and Corruption Policy or implement equivalent standards. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that it takes steps to detect, control and prevent breaches through the inclusion of audit and termination rights in its contracts with such entities.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no publicly available 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":"1","comments":"
Based on publicly available information, there is clear evidence that the company formally recognises the corruption risks associated with offset contracting. The company indicates that all offset projects must be approved by the Group through a formal process. However, the company receives a score of \u20181\u2019 because there is no evidence that a dedicated body, department or team with appropriate qualifications is responsible for monitoring of the company's offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset agents. There is also evidence indicating that due diligence includes checks on the beneficial ownership of offset agents and that the company seeks to assure itself of the legitimacy of the investment. The company refreshes due diligence on agents at least every two years.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that it conducts due diligence on offset beneficiaries nor that the process includes checks on conflicts of interest.<\/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":"2","comments":"
There is evidence the company acknowledges the corruption risks associated with operating in different markets, and there is evidence that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. The company indicates that the results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. The company provides examples of such possible controls, such as enhanced due diligence checks and a requirement for approval by the Group Chief Executive for seeking business in new markets.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a list of its fully consolidated subsidiaries and non-fully consolidated holdings, including associated companies, joint ventures and other related entities. For each entity, the company discloses its percentage ownership and the country of incorporation. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes any clear information on the country or countries of operation for each entity. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed, trading on the London Stock Exchange (LSE) and therefore it is not required to disclose further information on its beneficial ownership to receive a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"1","comments":"
The company publishes some information on its defence sales, indicating that the United Kingdom Ministry of Defence (MOD) is its single biggest customer. In addition, the company\u2019s financial statements indicate that the United Kingdom accounted for approximately 66% of its sales in the most recently reported financial year; however this figure appears to include both commercial and defence sales. <\/p>\n
The company receives a score of \u20181\u2019 because it publishes its major customers that account for over 50% of its sales, despite not disaggregating commercial and defence sales, and there is some indication that the UK is its most significant defence customer. <\/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\/801","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=801"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=801"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}