There is evidence that the company has a publicly stated anti-bribery and corruption statement, contained in the company\u2019s Standards of Ethics and Business Conduct. It is clear that this commitment is endorsed by the company\u2019s CEO, who states that the company and all its employees must share a commitment to ethical and honest business practices. However, the company receives a score of \u20181\u2019 because there is no evidence that the company\u2019s leadership directly addresses the organisation\u2019s stance against bribery and corruption. <\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company publishes an anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials and commercial bribery. In addition, there is evidence that this policy applies to all employees and board members as described in (a) and (b) in the question. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it has a policy to address or prohibit facilitation payments.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that the Culture, Character, Integrity and Ethics Committee of the Board of Directors is ultimately responsible for oversight of the company's anti-bribery and corruption programme. The company indicates that the Committee\u2019s responsibilities include reviewing reports from management on the programme\u2019s performance, along with the results of internal and external audits, and there is evidence that it had the authority to require that any necessary changes are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior executive \u2013 the General Counsel \u2013 has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. There is evidence that this person has a direct reporting line to the board committee that provides oversight of the anti-bribery and corruption programme. In addition, there is evidence of reporting and feedback activities between this person and the board as part of the company\u2019s reporting structure; for example, attendance or participation at board-level committee meetings.<\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is some evidence that the company has a risk assessment procedure in place that informs the design of its compliance-related policies. There is evidence that the board-level Culture, Character, Integrity and Ethics Committee is responsible for reviewing results of risk assessments and ensuring that the results of such assessments are used to update specific parts of the anti-corruption programme. In addition, there is evidence to indicate that the board reviews and evaluates the company\u2019s business ethics policies on an ongoing basis, and that it has oversight of related risks facing the company. <\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
There is some evidence that the company\u2019s anti-bribery and corruption programme is subject to regular review. The company indicates that the Culture, Character, Integrity and Ethics Committee is responsible for such reviews.<\/p>\n
However, it is not clear from publicly available information that the company\u2019s entire anti-bribery and corruption programme is subject to a formal audit or equivalent assurance process to ensure that it is consistent with 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 promptly, and that it has a specific procedure in place to deal with whistleblowing cases. The company indicates that reports received through its whistleblowing channel are handled by the General Counsel and a group of other senior individuals for further investigation and evaluation. The company also publicly commits to take appropriate action where improper conduct is identified. <\/p>\n
However, there is no publicly available evidence that the company provides information on the whole investigation process from receipt to final outcome, for both whistleblowing cases and reports through direct channels. In addition, there is no publicly available information to indicate that the company commits to inform whistleblowers of the outcome of investigations, nor is there evidence that a central body reviews summary information of all cases and their status in the organisation on an annual basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is some evidence that the staff responsible for conducting the company\u2019s internal investigations are properly trained and qualified to perform the function. <\/p>\n
However, there is no further publicly available information on how the company ensures the quality of its investigations, for example by indicating that it has a procedure in place to receive and escalate complaints about the handling of investigations or by reviewing its investigative procedure at least every three years or in response to any changes in the regulatory environment. It is also not clear from publicly available evidence that staff responsible for handling allegations received through direct channels are properly trained and qualified, in addition to those associated with the whistleblowing channel. <\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
There is evidence that the company commits to report material findings of bribery and corruption from internal investigations to various senior individuals, including the General Counsel and the Chairman of the Audit Committee, depending on the nature of the report and the channel through which it was reported. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that material findings are reported to the board of directors as part of the investigation process. In addition, although the company states that it will disclose criminal offences to the relevant authorities, there is no clear evidence that an appropriate senior individual is responsible for ensuring that such disclosures are 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 or bribery and corruption reports, investigations or disciplinary actions involving its employees.<\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides annual training on its Standards of Ethics and Business Conduct, which includes the company\u2019s anti-corruption policy and whistleblowing options available to employees. The company indicates that this training applies to all employees and states that staff must certify their understanding of the Standards on an annual basis. The company does not state that it provides training in multiple languages, however there is no clear evidence that it operates in jurisdictions where training could not be provided in English.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company provides tailored 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":"1","comments":"
There is evidence that the company measures and reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme. The company indicates that the Culture, Character, Integrity and Ethics Committee is responsible for reviewing implementation and effectiveness, and there is evidence that the findings of such reviews are used to update elements of anti-corruption training programme. <\/p>\n
However, company receives a score of \u20181\u2019 because it does not provide further publicly available information on the way in which it measures effectiveness, for example through staff surveys, specific audits or training completion rates. In addition, it is not clear that the company makes use of these mechanisms on an annual basis, nor is there evidence that it undertakes a full review of the programme every three years.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company\u2019s incentive schemes for employees are designed to incorporate ethical or anti-bribery and corruption principles.<\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company commits to support or protect employees who refuse to act unethically.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","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. There is evidence that this policy applies to all employees, directors and consultants across the organisation. <\/p>\n
However, there is no publicly available evidence that the company assures itself of its employees\u2019 confidence in this commitment through surveys, usage data, or other clearly stated means.<\/p>\n"},{"question":70,"commitment_area":9,"score":"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 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 externally through an independently operated hotline. The company indicates that its channels allow for confidential and, wherever possible, anonymous reporting. <\/p>\n
In addition, there is evidence to indicate that the company\u2019s whistleblowing hotline is available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties and suppliers. There is also evidence that the channels are available in multiple languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence that the company formally addresses conflict of interest as a corruption risk, and that it has a clear policy in place that defines conflicts of interest, including actual, potential and perceived conflicts. There is evidence that the company\u2019s policy addresses possible conflicts arising from employee relationships, government relationships, financial interests, outside employment. In addition, there is evidence 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 some evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company states that directors must notify the General Counsel if they become aware of any conflicts as outlined in its policy. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further publicly available information on its procedures to declare and manage conflicts of interest. There is no publicly available evidence that all employee and board member declarations are held in a central register or database that is accessible by those with oversight of the process. In addition, there is no evidence that the company provides examples of criteria for recusals, nor does it clearly indicate that disciplinary measures will apply if its policy is breached. It is noted that the company\u2019s publicly available information refers to separate policies on specific types of conflicts, but there is no evidence that these documents are publicly accessible. <\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy with controls to assess and regulate the employment \u2013 as well as offers of employment or offers of consultancy engagement \u2013 of current and recently departed public officials. The company\u2019s policy indicates that the General Counsel must give approval before the initiation of any employment discussions with former or current public officials. In addition, the company indicates that the Chief Executive Officer must give approval before any offers of employment to former military officers above a certain rank or former senior civilian officials.<\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further publicly available information on whether it has procedures to conduct a conflicts of interest review prior to engagement, nor that the company may impose restrictions on their activities if such conflicts are identified. It is also not clear whether the company has a policy to implement a cooling-off period of at least 12 months before such public officials are permitted to have any form of contact with their former organisation on the company\u2019s behalf. It is noted that the company states that it has a separate policy covering the employment of individuals from the public sector, but this document does not appear to be publicly available.<\/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":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy that clearly prohibits corporate political contributions. The company indicates that this applies to any contributions to government officials or politicians, whether made directly or indirectly. There is evidence that this policy applies company-wide in the United States and in other jurisdictions. In addition, the company clearly states that it is not associated with a Political Action Committee (PAC) in the United States, and no publicly available evidence was identified to contradict this statement. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
The company publishes a clear statement that it does not make any forms of 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 that the company has a policy on charitable donations and sponsorships. There is evidence that this policy includes criteria for donations and specific approval procedures for donations, as well as separate financial thresholds and sign-off requirements for any donations to organisations where the recipient is associated with a company director. The company also provides some information on the charities that it supports, including the names of the organisations. <\/p>\n
However, there is no evidence that the company\u2019s policy includes further controls such as due diligence on recipients, nor is there evidence that the company publishes full details of its charitable donations made in the last 12 months, including details of the recipient, amount, country of recipient and which corporate entity made the payment.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a clear policy or procedure on lobbying. The company provides publicly available information on the regulations in the United States that it must follow when undertaking any lobbying activities, for example the disclosure of payments and avoiding improper influence on the political process; however, there is no evidence that the company outlines specific standards of conduct or oversight mechanisms to ensure that all internal, external and association lobbyists comply with these regulations. <\/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":"1","comments":"
There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with clear procedures designed to ensure that such promotional expenses are not used as vehicles for bribery. The company\u2019s policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy also addresses the risks associated with gifts and hospitality given to and\/or received from domestic and foreign public officials. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it has a procedure in place to record gifts and hospitality in a dedicated central register or database that is accessible to those responsible for oversight of the process. It is noted that the company has a separate policy covering gifts and gratuities, which may contain more information on its procedures in this area, but this document does not appear to be publicly available.<\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company has a procurement department and that this body is involved in managing the company\u2019s supplier relationships. <\/p>\n
However, there is no publicly available evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means, such as an audit or other assurance process, on a regular basis. In addition, it is not clear from publicly available evidence that this department is the main body responsible for establishing and onboarding all new suppliers. <\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its supply chain. <\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
There is no clear publicly available evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard. The company states that its staff are prohibited from engaging in corrupt practices in dealings with suppliers, however there is no further publicly available evidence to indicate that the company places requirements on suppliers regarding anti-corruption. <\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no publicly available 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-corruption related reports, investigations or disciplinary actions involving its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company has a policy on the use of agents.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries. The company indicates that it will not enter into agreements with individuals or entities under trade restrictions or that are found to have violated relevant laws, however it is not clear from publicly available evidence that such information is identified through due diligence or an equivalent evaluation. <\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents, nor is there evidence that the company commits to not engage 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 some evidence that the company requires that its third party consultants adhere to its anti-corruption and ethics policies, though it is not clear from publicly available information that such entities may include agents and intermediaries. In addition, although the company indicates that contracts with such parties include termination clauses, there is no evidence that the company includes audit rights in its employment contracts with third parties. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company addresses incentive structures as a risk factor in agent behaviour, nor that such incentives include measures to mitigate potential bribery and 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 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 or corruption-related reports, investigations or the associated disciplinary actions involving its agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
There is no publicly available 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 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":"0","comments":"
There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor 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 publicly available evidence that the company conducts 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 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":"0","comments":"
There some evidence that the company acknowledges some of the corruption risks of operating in different markets as part of its international business. However, there is no clear publicly available evidence to indicate that it has a risk management system in place to identify and address these corruption risk, nor is there clear evidence that the results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is some evidence that the company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings which is updated on an annual basis. This information includes a jurisdiction for each entity, which is understood to represent the country of incorporation. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company publishes its percentage ownership or the relevant country or countries of operation for each entity. In addition, the publicly available information indicates that this list includes significant subsidiaries, so therefore it is not clear that this list represents all of the company\u2019s fully and non-fully consolidated holdings, joint ventures and other associates. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly 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 on the NYSE in its documents for investors. <\/p>\n"},{"question":110,"commitment_area":15,"score":"2","comments":"
There is evidence that the company publishes some information on its sales by customer, to indicate that the United States government is its most significant defence customer. The company indicates that U.S. Department of Defence (DoD) is its main departmental customer, accounting for 66% of total sales in the 2016 financial year. Since the other entities listed appear to be non-defence or commercial sales, there is sufficient evidence to indicate that the United States represents the majority of the company\u2019s defence sales. <\/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\/806","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=806"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=806"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}