There is evidence that the company has a publicly stated anti-corruption commitment, which details the company's stance against any form of corruption within the organisation, which is understood to include bribery. It is clear that this commitment was authorised and endorsed by the company's leadership.<\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is some evidence that the company has an Ethical Charter and Code of Ethics, both of which it indicates apply to all employees. These policies outline the company\u2019s zero tolerance position on corruption and commit to complying with all relevant anti-bribery laws. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that its policies specifically prohibit payments to public officials and facilitation payments. It is also not clear whether the Code of Ethics applies to all board members, including non-executive members.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s Ethics Department is responsible for evaluating and monitoring all anti-corruption policies and processes. The company indicates that this department reports directly to the Chairman-Chief Executive Officer and the board of directors. In addition, there is evidence that the Ethics Department\u2019s responsibilities include formal oversight functions such as reviewing the functioning of the programme and conducting risk mapping exercises. It is clear that this department is the main body responsible for the company\u2019s anti-corruption measures and that it has the authority to require that any necessary changes to the programme are made. <\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is some evidence that a senior individual \u2013 the Senior Vice President Ethics and Compliance \u2013 has responsibility for implementing and managing the company's anti-bribery and corruption programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear publicly available evidence that this individual as a direct reporting line to the Ethics Department, which oversees of the anti-corruption programme, nor is there evidence of reporting and feedback activities between this person and the board as part of the company\u2019s reporting structure. It is also not clear that this individual or position is a senior executive.<\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
There is evidence that the company has a formal bribery and corruption risk assessment procedure in place that informs the design of the anti-corruption and bribery programme. The company indicates that its risk management system includes a mapping of all relevant corruption risks and that there is evidence that the results of such reviews are used to update specific parts of its anti-corruption programme. <\/p>\n
However, there is no clear publicly available evidence that such assessments are undertaken on at least an annual basis, nor is there clear evidence that the results are reviewed at board level. <\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is some evidence that the company\u2019s anti-corruption programme is subject to annual audit or review. The company indicates that it has systems in place to review and evaluate its anti-corruption measures, and there is evidence to indicate that the Ethics Department is responsible for implementing planned updates to the programme on the basis of such reviews. <\/p>\n
However, it is not clear from publicly available information that the company\u2019s review process includes clear internal and\/or external audits of the entire anti-corruption programme, to ensure that it is consistent with best practice and the business risks facing the company. There is also no clear publicly available evidence to indicate how frequently these reviews are undertaken, nor is it clear that high-level findings are presented to the board.<\/p>\n"},{"question":60,"commitment_area":8,"score":"0","comments":"
There is some evidence that the company has procedures in place to deal with allegations, incidents and whistleblowing reports relating to possible bribery and corruption. The company indicates that it has established an internal alert procedure and that the Ethics Department, which reports to the Chairman-Chief Executive Officer, is responsible for this process. <\/p>\n
However, the company receives a score of \u20180\u2019 because there is no publicly available evidence that the company has a specific procedure to deal with whistleblowing cases that stipulates clear documentation and actions to be taken at each step. There is also no clear evidence that the company takes steps to ensure the independence of its investigations, nor that it commits to inform whistleblowers of the outcome of investigations. The company\u2019s investigation procedure, from receipt to final outcome, is not clear from publicly available information.<\/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 investigations, for example by indicating that staff conducting investigations are properly trained, by implementing a policy to handle complaints about the process or by reviewing the investigation process every three years. <\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company has an investigative procedure in place which includes a commitment to report material findings of bribery and corruption to the board and any criminal conduct to the relevant authorities.<\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption investigations or disciplinary actions involving its employees.<\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides training sessions on the basic principles of the anti-bribery and corruption policy to employees and managers who are most exposed to corruption risk. <\/p>\n
However, there is no clear evidence that the company provides such training to all employees across all divisions, all countries regions of operation or in all appropriate languages. In addition, the company does not provide further publicly available information regarding the content of its training so it is not clear whether these sessions cover the whistleblowing options available to employees. It is also unclear how frequently employees must undertake or refresh their training in this area. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company provides tailored anti-corruption training to certain employees based on an assessment of their role and exposure to corruption risk. The company indicates that it provides such training to managers and those most exposed to possible corruption and influence-peddling. <\/p>\n
However, there is no publicly available evidence that the company provides tailored anti-corruption training to board members. It is also not clear how frequently employees in high risk positions must undertake and refresh their training in this area. <\/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. The company indicates that it has a system in place to evaluate its internal controls, however it is not clear from publicly available information that this specifically includes measuring effectiveness nor that it covers the company\u2019s anti-corruption training and communications initiatives. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company\u2019s incentive schemes incorporate ethical or anti-bribery and corruption principles. The company provides some details on its compensation policy in its Annual Report, however there is no evidence that it includes clear information on how it incentivises employees to promote ethical behaviour and discourage corrupt practices. <\/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":"0","comments":"
There is some evidence that the company has a policy of non-retaliation against whistleblowers, in line with relevant national legislation, and that this policy applies to all employees and those employed by subsidiaries. <\/p>\n
However, there is no publicly available evidence that this commitment extends beyond whistleblowers to any employees who report bribery and corruption-related allegations and incidents through other channels. In addition, there is no evidence that the company assures itself of its employees\u2019 confidence in this commitment through surveys or other clearly stated means.<\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company has an internal alert procedure to allow employees to report incidents or possible breaches of its Anti-Corruption Code. The company indicates that this system is open to outside employees, including temporary staff and those working for subsidiaries or third parties.<\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further publicly available information on its whistleblowing and reporting mechanisms. There is no evidence that the company provides an external reporting mechanism, for example a channel operated by an independent third party, nor is there evidence that the company\u2019s alert system allows for anonymous or confidential reporting. In addition, it is not clear from publicly available information that these channels are available to all employees in all countries of operation, or in multiple languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is some evidence that the company has a policy on conflicts of interest. The company\u2019s Ethical Charter indicates that all employees should avoid direct or indirect conflicts where possible, and there is some evidence that this statement addresses possible conflicts arising from personal relationships and financial interests. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that this policy addresses conflicts possible conflicts arising from outside employment or government relationships. There is also no clear evidence to indicate that this applies to board members. <\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the company has procedures to identify, declare and manage conflict of interest or to manage the oversight of any identified conflicts.<\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no publicly available 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 publishes details of the contracted services of any serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence to indicate that the company has a policy on corporate political contributions. The company indicates that it does not finance political parties, elected officials or candidates unless such activities are in full compliance with existing relevant laws. Since the company does not prohibit political contributions, it receives a score of \u20180\u2019. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any details of its political contributions, nor is there evidence that it publishes a statement to indicate that it has not made any such contributions in the past 12 months.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company has a policy or procedure on charitable donations and sponsorships to ensure that such expenses are not used as vehicles for bribery and corruption. The company provides some information about the charities that it supports and sponsorship programmes; however there is no clear evidence of a policy to support this, nor is there evidence that the company publishes full details of its contributions made, such as 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 publishes a statement on its website to indicate that it complies with a piece of French legislation from December 2016 that applies to lobbying activities; however, the company does not provide any further publicly available information on any specific controls, oversight mechanisms or standards of conduct that it has in place to ensure compliance. <\/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 about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has a policy on the giving and receipt of gifts and hospitality. The company indicates that any gifts provided must be within accepted limits and states that certain types of gifts, such as offers of travel or participation in non-professional events, must be declined. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further publicly available information on its policy to manage and handle gifts and hospitality, for example by addressing the risks associated with gifts given to or received from public officials or by establishing clear financial limits and approval procedures. In addition, there is no publicly available evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register or database that is accessible to those responsible for oversight of the process. <\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is some publicly available evidence that the company has a specific body responsible for the oversight of its supplier base. The company states that it has a Supply Chain Committee composed of those responsible for the supply process, and indicates that this body is responsible for making decisions in this area. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicy available evidence that this Committee is the main body or department responsible for the establishment and oversight of its entire supply base, nor is there evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means at least every three years.<\/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. The company indicates that it has procedures in place to assess suppliers and map any associated risks, but it does not provide further publicly available evidence to indicate whether this includes establishing the ultimate beneficial ownership of suppliers nor is it clear that such a process is undertaken and repeated at regular intervals. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company requires that its suppliers have adequate ethics and anti-corruption standards in place by ensuring that they follow its Code of Ethics. There is evidence to indicate that this includes a ban on commercial bribery and any improper gifts or hospitality. The company also indicates that all parties must comply with relevant anti-bribery legislation. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further publicly available information on its supplier standards to indicate that such partners must have policies in place to prohibit facilitation payments or procedures to address conflicts of interest and whistleblowing. In addition, there is no clear evidence to indicate how the company takes active steps to ensure supplier compliance in this area, whether at the start of the relationship or on a regular basis thereafter.<\/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-bribery and 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 clear policy on the use of agents. The company indicates that it has implemented procedures for assessing and mapping risks relating to intermediaries, but there is no further publicly available information regarding its approach to managing the corruption risks associated with agents or intermediaries. <\/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 and intermediaries. The company indicates that it has implemented procedures for assessing and mapping risks relating to intermediaries, but there is no further publicly available information regarding its approach to formal due diligence and evaluations of agents or intermediaries prior to engagement and throughout the business relationship.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company aims to establish the ultimate beneficial ownership of its agents and intermediaries, nor is there evidence that it commits to not engage or terminate its engagement with such entities 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 service providers abide by its own Code of Ethics and that this forms part of the company\u2019s general purchasing conditions. There is evidence to indicate that this includes a ban on commercial bribery and any improper gifts or hospitality. The company also indicates that all parties must comply with relevant anti-bribery legislation.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear publicly available evidence that it takes active steps to ensure that intermediaries comply with its ethical standards by including anti-corruption clauses in contracts with such entities, with clear audit and termination rights.<\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company's incentive structures for agents are designed to minimise risks of anti-bribery and corruption.<\/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 and 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 bribery and corruption-related reports, investigations or 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 or that it requires anti-bribery and corruption clauses in its contracts with joint venture partners. There is some evidence that the company requires that its suppliers and service providers comply with its Code of Ethics, but it is not clear whether this requirement includes or extends to joint ventures. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no publicly available 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 publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company conducts risk-based anti-bribery and corruption due diligence on all aspects of 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 clear details of its offset obligations or contracts. The company provides some information on one particular offset project associated with the Indian government which represented 50% of the contract value, however in publicly available ifnromation the company does not provide any further details nor does it provide details of any other indirect or direct offset contracts or projects. <\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
Based on publicly available information, there is some evidence that the company has a risk assessment procedure in place that informs its operations and anti-corruption measures. However, there is no clear publicly available evidence that this process includes an assessment of the corruption risks of operating in different markets, nor is it clear that has risk management procedures that are used to inform the company\u2019s operations in high risk markets. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is some evidence that the company publishes information on its organisational structure on its website. The company indicates that it has three wholly-owned subsidiaries and that it holds some shares in one other company. For each entity, the company indicates its percentage ownership and a country, which is understood to represent the country of incorporation. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it provides details on the country or countries of operation for each entity. In addition, it is not clear that this list is updated on an annual basis, nor is there evidence to confirm that this chart represents all of the company\u2019s fully consolidated and non-fully consolidated holdings such as associates, joint ventures and other related entities.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed on multiple stock exchanges in the European Economic Area, and therefore it does not need to disclose further information on its beneficial ownership to receive a score of \u20182\u2019. In addition, there is evidence that the company publishes information on its significant shareholding entities on its website and in its Annual Report. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes clear information on its defence sales by customer. The company publishes some information on its significant orders and deliveries of certain products, however in publicly available evidence it does not indicate the customers of these orders nor does it provide a percentage breakdown of its defence sales by 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\/812","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=812"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=812"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}