There is evidence that the company publishes a statement in support of ethical conduct and integrity, which is authorised and endorsed by the company\u2019s President and CEO. However, the company receives a score of \u20181\u2019 because this publicly available statement does not directly mention or address the company\u2019s commitment to anti-bribery and corruption. <\/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 applies to all employees and board members as described in (a) and (b) in the question. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that the board-level Audit Committee is ultimately responsible for oversight of the company\u2019s anti-bribery and corruption programme. This includes reviewing reports from management on the programme\u2019s performance and the results of audits. In addition, there is evidence that the Audit 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 a designated senior executive \u2013 the Chief Ethics and Compliance Officer \u2013 has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this individual has a direct reporting line to the board-level Audit Committee which provides oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this person and the Audit Committee. <\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a formal risk assessment procedure in place that informs the design of its ethics and compliance programme. The results of risk assessments are reviewed by the board\u2019s Audit Committee on at least an annual basis. There is evidence that the results of such reviews are used to update specific parts of the company's ethics and compliance programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s ethics and compliance programme is subject to a regular audit process. The company indicates that it conducts audits on an annual basis and that the results are reviewed by the board-level Audit Committee, which provides oversight of the compliance programme. There is evidence to indicate that the company\u2019s Ethics & Compliance Office is tasked with implementing planned updates and improvements to the ethics and compliance programme.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly commits to investigating incidents, and that it has a specific procedure in place to deal with whistleblowing cases. There is evidence that the information on each investigation is documented and that summary information on investigations is reviewed centrally on a regular basis.<\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide publicly available information on the whole investigation process from receipt to final outcome. There is also no evidence that it takes steps to ensure the independence of its investigations, for example by stating that cases are handled by an independent team or that staff conducting investigations report to an independent board member. There is also no clear evidence that the company 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":"1","comments":"
Based on publicly available information, there is evidence that the company commits to report material findings of criminal conduct to the board-level Audit Committee. However, 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":"1","comments":"
The company publishes some high-level information on bribery and corruption-related incidents reported to its Standards of Business Conduct team. This data relates to the most recent reporting year and there is evidence indicating that it is updated annually.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is unclear whether the data includes the number of reports received via whistleblowing channels. There is also no evidence that the company publishes information on the number of investigations launched or the number of disciplinary actions as a result of investigation findings. <\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides training to all employees that outlines the principles of its anti-bribery and corruption policy, including the whistleblowing options available. The company states that it provides training in all appropriate languages and that employees are required to take an anti-corruption refresher course annually. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is 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. The company indicates that it provides tailored training to employees in high-risk positions, as well as senior business leaders which can be understood to include middle management. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that board members receive tailored anti-corruption training. It is also unclear whether tailored training for employees in high-risk positions is updated on at least an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence the company reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme annually. There is evidence that the company has a system to do this, using data from compliance-related reviews. It is clear that the results of such reviews are used to update specific parts of the company's anti-bribery and corruption communications and training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company\u2019s incentive schemes employees incorporate ethical or anti-bribery and corruption principles.<\/p>\n"},{"question":68,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company will support employees who refuse to act unethically, even when it might result in a loss in business. <\/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 statement through anonymised surveys or other clearly stated means.<\/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 incidents. There is evidence that this policy applies to all employees across the organisation, including business 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 has multiple channels to report instances of suspected corrupt activity and seek advice on its anti-bribery and corruption programme. The company indicates that channels are sufficiently varied to allow employees to raise concerns across the management chain, as well as through an external channel operated by an independent third party. These channels allow for confidential and, wherever possible, anonymous reporting. <\/p>\n
In addition, there is evidence that these are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, and in all relevant languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has policies that define conflicts of interest, including actual, potential and perceived conflicts. The company\u2019s policy clearly apply to all employees and board members and address possible conflicts arising from government relationships, outside employment, financial interests and employee relationships.<\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is some evidence the company has procedures to manage conflicts of interest, including actual, potential and perceived conflicts. The company states that employees are required to disclose potential conflicts to their manager, while directors must report potential conflicts to the Chairman of the board. <\/p>\n
However, there is no evidence that all employee and board member declarations are held in a dedicated central register that is accessible to those responsible for oversight of the process. There is no evidence that a specific body or individual has overarching oversight and accountability for handling cases, nor that its policy provides examples of criteria for recusals or indicate that disciplinary measures will apply if breached. <\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence the company has a policy that addresses the risks associated with the employment of public officials. The company\u2019s policy stipulates that the compliance officer must give prior approval for the initiation of any employment discussions with former or current public officials. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that its recruitment process for current or former public officials includes a review of actual, potential or perceived conflicts of interest, or that restrictions may be placed on their activities if such conflicts of interest are identified. There is also no evidence that the company has a policy to implement a cooling-off period of at least 12 months before public officials are permitted to have any form of contact or relationship with their former organisation on the company\u2019s behalf. It is noted that the company has a separate policy which may contain more information on its approach, but this document does not appear to be publicly accessible. <\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company publishes details of any contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is evidence that the company has a policy on corporate political contributions. The company indicates that political contributions are permissible in limited circumstances and when approved by the Vice President of HPE Corporate Affairs and reviewed by the board. The company states that it does not make any political donations where there is a risk of creating the appearance of undue influence. In addition, there is evidence that the company is associated with a Political Action Committee (PAC) in the United States.<\/p>\n
Since the company does not prohibit political donations and is associated with a PAC, it receives a score of \u20180\u2019 in line with the scoring criteria. <\/p>\n"},{"question":76,"commitment_area":11,"score":"2","comments":"
There is evidence that the company publishes full information of its corporate political contributions, including details of the recipient, amount, country of recipient and the name of the corporate entity that made the contribution. The company also publishes details of the donations made by its Political Action Committee (PAC), including the name of the candidate, state, party, office and amount donated. There is evidence that this data is updated and released on an annual basis. <\/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 both charitable donations and sponsorships to ensure that such expenses are not used as vehicles for bribery. The company\u2019s policy stipulates procedures for senior sign-off on all donations and sponsorships. In addition, the company provides some information of its charitable donations and philanthropic activities, including the number of charities supported around the world.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it publishes full details of its charitable contributions and sponsorships, 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":"1","comments":"
There is some evidence that the company has a policy in place to ensure that its engagement in lobbying is ethical, legal and transparent. In addition, there is evidence that the company provides clear standards of conduct and guidelines for responsible behaviour for its third parties, which clearly include lobbyists. <\/p>\n
However, there is no publicly available evidence that the company\u2019s approach includes oversight mechanisms for lobbyists, nor is it clear that the company\u2019s standards of behaviour apply to all in-house, external and association lobbyists. There is also no evidence that the company provides a clear definition of responsible lobbying. <\/p>\n"},{"question":79,"commitment_area":11,"score":"2","comments":"
There is evidence that the company publishes some details of the aims and topics on which it conducts lobbying. The company publishes clear policy priorities for different areas of the business and provides some information on their relevance to stakeholders. In addition, there is evidence to indicate that these priorities cover multiple relevant jurisdictions and it is clear that this information is updated on an annual basis.<\/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. The company indicates that it has an internal document entitled \u2018Reporting of Lobbying Activities\u2019 which may contain more information on this subject, but it does not appear to be publicly accessible. <\/p>\n"},{"question":81,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, 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 bona fide and not used for bribery. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. <\/p>\n
In addition, the company\u2019s policy clearly addresses the risks associated with gifts and hospitality given to and\/or received from public officials, by specifying a different financial threshold. There is evidence that all gifts and hospitality above certain thresholds are recorded in a dedicated central tool that is accessible to those responsible for oversight of the process. <\/p>\n"},{"question":82,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence that the company requires the involvement of its procurement department in the establishment of new suppliers. It is clear that this department is ultimately responsible for providing oversight of the company's supplier base. In addition, there is evidence that the company assures itself that it performs proper procedures regarding the onboarding of suppliers on an annual basis, through audits and reviews.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has formal procedures to conduct due diligence on all suppliers, with the highest risk suppliers subject to enhanced due diligence. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear how frequently the company conducts due diligence, nor that its procedures include checks on beneficial ownership. In addition, there is no clear evidence to suggest that the company might be willing to review or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated. It is noted that the company provides additional policies which may contain more information on its approach to supply chain management, but these documents do not appear to be publicly accessible.<\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place, including policies that prohibit foreign and domestic bribery and facilitation payments, as well as procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. The company outlines these expectations in both its Supplier Code of Conduct and its Partner Code of Conduct. <\/p>\n
In addition, there is evidence that the company ensures itself of partners\u2019 anti-corruption programmes by assessing their programmes and ensuring standards are implemented where gaps are identified. The company indicates that this assurance is carried out when onboarding new suppliers and then regularly throughout the business relationship. <\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is 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. The company states that suppliers should conduct corruption due diligence on all third parties and require subcontractors to comply with policies of the same stringency as the company\u2019s Supplier Code of Conduct. <\/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 reports, investigations or associated disciplinary actions involving its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has a policy 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. In addition, there is evidence that this policy applies to all of the company\u2019s employees worldwide, including those employed by third parties and subsidiaries. <\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has formal procedures in place to conduct anti-bribery and corruption due diligence prior to engaging agents and intermediaries. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it commits to not engage or terminate its engagement with agents or intermediaries where risks identified in the due diligence cannot be mitigated. In addition, it is not clear that all agents and the highest risk intermediaries are subject to enhanced due diligence, nor that it conducts and refreshes this due diligence at least every two years or when there is a significant change in the business relationship.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is some evidence that the company assesses the ownership of third parties in instances where it suspects government officials may have a direct or indirect interest in the company. However, there is no clear evidence that the company aims to establish the beneficial ownership of all its agents as part of its due diligence process, nor os there clear evidence that it commits to not engage or terminate its relationship with an agent if beneficial ownership cannot be established. <\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s Partner Code of Conduct applies to all agents and intermediaries acting for or on its behalf. The company indicates that all agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include audit and termination rights to detect, control and prevent breaches.<\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company indicates that any sales-based commissions must be proportionate to the level and type of services provided and that such fees must be in line with a commission matrix. In addition, the company states that all payments are subject to approval procedures and that fees are only released upon proof of work completed. The company also commits to paying agents and intermediaries into local bank accounts. <\/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":"1","comments":"
Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering joint ventures. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the company\u2019s due diligence includes checks on the ultimate beneficial ownership of the partner company. There is also no evidence to suggest that joint ventures operating in high risk markets or with high risk partners are subject to enhanced due diligence. It is also unclear whether or how frequently the company repeats due diligence on joint venture partners.<\/p>\n"},{"question":101,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company commits to establishing and implementing anti-bribery and corruption policies and procedures in its joint ventures, by requiring the partner to conduct audits as part of its Partner Code of Conduct. There is also evidence that the company includes anti-corruption clauses in its contracts with such entities, with clear audit and termination rights to detect, control and prevent breaches.<\/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, for example by stipulating provisions for secondments of its senior management, providing specific anti-corruption training or establishing a separate internal audit function.<\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring of its offset activities.<\/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 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":"
Based on publicly available information, there is evidence that the company acknowledges the corruption risks associated with operating in different markets and that it has a dedicated assessment process in place to assess such risks. There is evidence to suggest that the results of these assessments have an impact on business decisions and trigger the implementation of additional controls. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a list of its principal consolidated subsidiaries and affiliates on an annual basis. This list includes information on the country of incorporation for each entity.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it discloses the percentage ownership and the country or countries of operation for each entity. The company\u2019s publicly available evidence also indicates that the list only contains information on principal subsidiaries and affiliates, and therefore it is not clear that the list represents all of the company\u2019s holdings. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is a publicly listed entity trading on the New York Stock Exchange (NYSE) and therefore it is not required to disclose further information on its beneficial ownership in order to receive a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes any information on 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\/823","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=823"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=823"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}