There is evidence that the company publishes a clear statement the outlines its commitment against all forms of bribery and corruption. It is clear that this statement is directly supported and endorsed by members of the company\u2019s executive leadership.<\/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 and commercial bribery. There is evidence that this policy applies to all employees and board members of the company.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that the company prohibits facilitation payments or payments to public officials.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated board committee \u2013 the Compliance Committee \u2013 is responsible for oversight of the company's anti-bribery and corruption programme. There is evidence that the Compliance Committee and the board engage in formal oversight functions including reviewing reports from management on the programme\u2019s performance and it has the authority to require that any necessary changes are made. There is further evidence indicating that the Compliance Committee reviews audits of the company\u2019s anti-corruption compliance programme. <\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior executive, the Corporate Compliance Officer, has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the board, and there is evidence of reporting and feedback activities between this person and the board as part of the company\u2019s reporting structure. <\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
There is some evidence that the company has a formal bribery and corruption risk assessment procedure that informs the design of the anti-corruption and bribery programme. The company indicates that its Corporate Compliance Officer (CCO) is responsible compliance risk assessments and there is some evidence that the CCO reports to the board on a regular basis; however, there is no clear publicly available information that the results of risk assessments are reviewed by the board on at least an annual basis. There is also no clear evidence 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 that the company conducts compliance reviews on its business processes, however it does not provide any further publicly available evidence to indicate that this may include an internal or external audit of the anti-corruption programme itself. There is also no clear evidence that high-level findings are presented to the board, nor is it clear that ownership for planned improvements is assigned to a specific individual or committee. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company commits to investigating incidents and there is a specific procedure in place to deal with whistleblowing cases through its independent corporate ombudsman. The board reviews findings related to bribery and corruption incidents within the company, although it is not explicitly stated that it reviews summary information on investigations on at least a quarterly basis.<\/p>\n
However, the company receives a score of \u20181\u2019 because in publicly available information it does not publish details of its whole investigation process from receipt to final outcome. There is also no publicly available evidence that it commits to providing whistleblowers with updates on the outcome of investigations. <\/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":"2","comments":"
There is clear evidence that the company commits to report material findings of bribery and corruption from investigations to the board. In addition, there is evidence that an appropriate senior individual \u2013 the Corporate Compliance Officer \u2013 is ultimately 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":"
The company states that it received reports from employees on bribery and corruption in the most recently reported financial year, and indicates that it conducted investigations and took disciplinary actions as a result. However, there is no evidence that the company publishes any data to accompany this statement, such as the number of reports received, number of investigations launched and number of disciplinary actions taken as a result. <\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides training for its employees that outlines the principles of the anti-bribery and corruption policy, including the whistleblowing options available. There is evidence that the company provides this training to all employees across all divisions and countries of operation, and in all appropriate languages. The company states that employees are required to undertake refresher courses or modules on the anti-bribery and corruption programme at least every three years.<\/p>\n"},{"question":65,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides tailored anti-bribery and corruption training based on the different levels of risk facing employees in different roles. The company makes specific reference to employees in high risk positions, middle management positions and board members. There is evidence that employees working in high risk positions, such as those in sales and purchasing, are required to refresh their training in this area on at least an annual basis. <\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
There is evidence that the company measures the effectiveness of its anti-bribery and corruption communications and personnel training programme. The company indicates that it has a system in place to do this, by tracking participation rates, obtaining participant feedback and face-to-face conversations. There is evidence that the company conducts this assurance on a continuous basis with the results used to update specific parts of the company\u2019s anti-bribery and corruption communications training programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear publicly available evidence that the company undertakes a formal review of the whole programme at least every three years. <\/p>\n"},{"question":67,"commitment_area":9,"score":"2","comments":"
There is some evidence that the company\u2019s incentive schemes for employees are designed in such a way to promote ethical behaviour and discourage corrupt practices. There is evidence that any financial rewards included in the company\u2019s incentive schemes must be proportionate to the employee\u2019s salary in the case of high risk employees. The company also states that such provisions are included in employment contracts and that it may reduce or eliminate bonuses in situations where employees are found to have violated its compliance procedures. It is noted that, beyond contractual requirements, the company does not provide additional information on how it incentivises ethical behaviour on a continuous basis, for example through performance appraisals or evaluations. <\/p>\n"},{"question":68,"commitment_area":9,"score":"1","comments":"
There is evidence that the company commits to protecting and supporting any employee who refuses to act unlawfully, in keeping with the company\u2019s anti-corruption commitments, even where such actions result in a loss of business or another disadvantage to the company. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company assures itself of its employees\u2019 confidence in this statement through anonymised surveys or other clearly stated means.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is evidence the company promotes a 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 across the organisation as well as those engaged by the group as third parties, including suppliers and joint venture partners.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no 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 to an independent external ombundsman. These channels allow for confidential and anonymous reporting. In addition, the company indicates that its reporting 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. The company also indicates that employees may submit reports in multiple languages, and that it has procedure in place to translate such reports as soon as possible. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence the company has a policy on conflicts of interest that applies to all employees company-wide. However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that its policy accounts for potential or perceived conflicts, nor is there evidence that it defines and addresses specific types of relationships that may present a possible conflict of interest risk. <\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the company has procedures in place to identify, declare or manage conflicts of interest, nor is there evidence that a specific body or individual is responsible for oversight of this process. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the company has a policy to regulate the employment of current or former public officials.<\/p>\n"},{"question":74,"commitment_area":10,"score":"2","comments":"
The company publishes a clear statement that it has not contracted the services of any serving politicians in the past 12 months. <\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy to regulate corporate political contributions.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any details of its corporate political contributions.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
The company publishes some information about its charitable foundations, however there is no clear evidence that the company has a policy or procedure on charitable donations and sponsorships to ensure donations are not used as vehicles for bribery and corruption. There is also no evidence that the company publishes full details of its charitable contributions, 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 policy or procedure on lobbying.<\/p>\n"},{"question":79,"commitment_area":11,"score":"1","comments":"
The company publishes some information on the subjects on which it lobbies, in particular at the European Union level. There is evidence to indicate that this information is up to date for the most recent financial year.<\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further publicly available information on its core positions or aims of its lobbying activities, nor does it indicate their relevance to stakeholders. There is also no evidence that the company publishes the aims and topics of its lobbying activities at the national level or for any other relevant jurisdictions worldwide. <\/p>\n"},{"question":80,"commitment_area":11,"score":"1","comments":"
The company provides some details of its lobbying expenditure in the form of a total figure for the financial year 2017. <\/p>\n
However, the company receives a score of \u20181\u2019 because this data is not correct to the most recently reported financial year, nor does it include further details such as expenditure by corporate entity, geography, and a breakdown of internal lobbying, external lobbying and association lobbying as well as an explanation of how the figures in the data have been calculated. It is also not clear that the expenditure figure represents all jurisdictions in which the company has conducted lobbying activities. <\/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. The policy addresses the risks associated with gifts and hospitality given to and received from domestic or foreign public officials. The company also indicates that employees must keep written documentation of approvals for gifts and hospitality. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process. There is also evidence that the company\u2019s policy specifies financial or proportional limits for different types of promotional expense.<\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base.<\/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 when engaging or re-engaging with its suppliers. The company indicates that it conducts due diligence on specific business partners, but it is not clear whether this would include all suppliers or whether such partners are selected based on an assessment of their exposure to corruption risk. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. There is evidence that the company takes active steps to ensure this by requiring that all suppliers follow its own anti-bribery and corruption policy. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that all suppliers must have policies that prohibit facilitation payments, and procedures to address conflicts of interest, gifts and hospitality and whistleblowing. There is also no clear evidence that the company assures itself of the quality of suppliers\u2019 policies when onboarding and when there is a significant change in the business relationship.<\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. However, the company receives a score of \u20181\u2019 because it does not provide any further information on the steps that it takes to ensure this in practice. <\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company publishes any data on ethical or anti-bribery and corruption reports, investigations or disciplinary actions involving 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 their use and provides details of specific controls to mitigate these risks. The company indicates that it has procedures in place to ensure that any sales representatives meet high standards of integrity and to ensure compliance with all relevant regulations. In addition, there is evidence that the Corporate Compliance Officer (CCO) has oversight of all agreements with sales representatives. There is some evidence that this policy applies to all divisions and subsidiaries that might employ agents. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. <\/p>\n"},{"question":89,"commitment_area":13,"score":"2","comments":"
There is evidence the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging any agents and intermediaries. The company indicates that due diligence is repeated at least every two years and when there is a significant change in the business relationship. There is evidence that all agents and highest risk intermediaries are subject to enhanced due diligence. In addition, the company commits to not engage or terminate its engagement with agents or intermediaries where any risks identified in the due diligence cannot be mitigated. <\/p>\n"},{"question":90,"commitment_area":13,"score":"2","comments":"
There is evidence the company has formal procedures in place to establish the beneficial ownership of agents prior to engaging them, and at least every two years and when there is a significant change in the business relationship. The company operates a risk based beneficial ownership verification policy, whereby all agent provided information is verified and high risk agent\u2019s information is independently verified. There is evidence that the company commits to not engage or terminate its engagement with agents or intermediaries where ultimate beneficial ownership cannot be established. <\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
There is evidence that the company\u2019s anti-bribery and corruption policy applies to all agents and intermediaries. The company also provides evidence to indicate that these parties are subject to anti-bribery and corruption clauses in their contracts, which include clear audit rights and termination rights to detect, control and prevent breaches.<\/p>\n"},{"question":92,"commitment_area":13,"score":"2","comments":"
There is evidence that the company highlights and addresses incentive schemes for agents as a factor in bribery and corruption risk. There is evidence the company places a threshold on sales-based commissions to agents, and that all such remuneration requires approval from the Corporate Compliance Officer (CCO). The company also indicates that it remunerates agents in stage payments, based on clear milestones outlined in a written agreement. In addition, the company commits to only paying the agreed fees into local bank accounts or to a bank account in Germany.<\/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 bribery and corruption-related reports, investigations or 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. The company indicates that it conducts due diligence on specific business partners, but it is not clear whether this would include joint ventures or whether such partners are selected based on an assessment of their exposure to corruption risk.<\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures.<\/p>\n"},{"question":103,"commitment_area":14,"score":"1","comments":"
There is evidence that the company acknowledges the corruption risks associated with offset contracting. There is evidence that dedicated individuals within the company are responsible for managing its offset activities, and the company indicates that these individuals receive tailored anti-bribery and corruption training. Although the company does not explicitly state that these individuals form part of a dedicated body, department or team, there is sufficient evidence that the company has procedures in place to monitor and review its offset projects, so it receives a score of \u20182\u2019. <\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company has formal procedures in place to conduct 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 details of its offset obligations or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"2","comments":"
There is evidence that 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. 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 also provides examples of these possible controls, such as on-site visits by the CCO or country-specific training. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes a list of its fully consolidated subsidiaries and non-fully consolidated holdings, including associates, and other related entities. For each entity, the company discloses its percentage ownership and the country of incorporation. There is evidence that this list is current and updated on at least an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes details of the country or countries of operation for each entity. <\/p>\n"},{"question":109,"commitment_area":15,"score":"0","comments":"
The company indicates that it is a limited partnership entity managed by Diehl Verwaltungs-Stiftung. However, there is no evidence that the company publicly discloses information about its beneficial ownership or control structure, nor a statement that no individual owns 25% or more of shares or voting rights. There is some evidence that the company\u2019s ownership information is available via a national corporate register, but there is no evidence that this information is freely accessible without a charge. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company discloses a percentage breakdown of its defence sales by customer. The company indicates that its defence business accounts for approximately 14% of its total sales, however it does not provide any publicly available information on its major 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\/815","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=815"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=815"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}