There is no clear evidence that the company has a public commitment to ethical or anti-bribery and corruption standards.<\/p>\n"},{"question":55,"commitment_area":7,"score":"0","comments":"
There is no evidence that the company publishes an anti-bribery and corruption policy.<\/p>\n"},{"question":56,"commitment_area":7,"score":"0","comments":"
There is no evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme.<\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
There is no evidence that a specific managerial-level employee has ultimate responsibility for implementing and managing the company\u2019s anti-bribery and corruption programme.<\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company has a formal risk assessment procedure which is used to inform the company\u2019s anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company\u2019s anti-bribery and corruption programme is subject to audit or review.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company commits to investigating incidents, and that there is a specific procedure in place to deal with whistleblowing cases, which stipulates actions to be taken at each step. There is evidence that information on each investigation is recorded through the hotline system and that the company commits to informing whistleblowers with updates on the outcome of investigations.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that investigations are handled by an independent team and\/or report to an independent board member, and there is no clear evidence that summary information is reviewed by a central body, or that the central body reviews the status of investigations on a regular or at least an annual basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company assures itself of the quality of its internal investigations.<\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
There is evidence that the company commits to reporting evidence of bribery and corruption to law enforcement in accordance with Russian federal law. However, there is no clear evidence of internal responsibility for reporting findings from investigations to the company\u2019s leadership or board.<\/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":"0","comments":"
There is no evidence that the company provides anti-bribery and corruption training to all employees.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company tailors its 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":"0","comments":"
There is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company\u2019s incentive schemes incorporate ethical or anti-bribery and corruption principles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no 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":"
The company states that employees and third parties reporting incidents via its hotline reporting service will not be subject to retaliation or sanction.<\/p>\n
However, the company receives a score of \u20181\u2019 as there is no evidence that it assures itself of employees\u2019 confidence in this commitment through surveys, usage data or other means. <\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
There is evidence that the company operates whistleblowing channels which allow for anonymous and confidential reporting. There is also evidence that these reporting channels \u2013 including a phone line, email address, postal address and the ethics hotline \u2013 are available to all third parties, which is understood to include joint ventures and subsidiaries. <\/p>\n
However, the company receives a score of \u20181\u2019, as it is unclear based on publicly available information whether any of the options are operated by independent third parties, and there is no evidence that these reporting channels can be used by employees to obtain advice on the ethics and anti-corruption policies or issues.<\/p>\n"},{"question":71,"commitment_area":10,"score":"0","comments":"
There is no clear evidence to suggest that the company has a policy on conflict of interest. The company makes reference to conflicts of interest in its publicly available information on its hotline whistleblowing service; however, there is no evidence of a policy defining conflicts of interest across the company.<\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company maintains procedures to manage conflict of interest or of their oversight.<\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no 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 reports details of the contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
According to publicly available information, there is no evidence that the company has no policy on corporate political contributions.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company discloses full details of its political contributions.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy and\/or procedure covering both charitable donations and sponsorships.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy and\/or procedure on lobbying.<\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any information on its lobbying aims, topics or activities.<\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company provides any details about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence of a policy or procedure on gifts or hospitality.<\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is evidence that the parent company maintains a policy stipulating the involvement of its procurement department in some capacity, in the establishment and oversight of supplier relationships throughout the corporation\u2019s holdings. There is evidence that the parent company\u2019s procurement department is the main body responsible for oversight of the company\u2019s supplier base.<\/p>\n
However, the company scores \u20181\u2019 because there is no evidence that the company assures itself of the procurement department\u2019s involvement at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct anti-corruption-based due diligence on every supplier, as stated in the publicly available group-wide procurement statement produced by its parent company. This policy indicates that a supplier may be \u2018removed\u2019 from the procurement process if found to be in breach of certain regulations or if information is found to be inaccurate.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that due diligence includes checks on, at least, ultimate beneficial ownership, nor that highest risk suppliers are subject to enhanced due diligence. There is also no evidence that the company might be willing to review and\/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated. <\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
There is no clear evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no 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 investigations relating to its suppliers, or the associated disciplinary actions.<\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company has a policy covering the use of agents.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company aims to establish the beneficial ownership of its agents.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is no clear evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries.<\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company addresses incentive structures as a risk factor in agent behaviour.<\/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 behalf of the company.<\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving to agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
There is no 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 evidence that the company commits to actively preventing bribery and corruption in all of its joint ventures.<\/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 the company's offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company has a procedure to conduct risk-based 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 the company\u2019s 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 and\/or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company\u2019s operations in high risk markets.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company\u2019s parent company publishes a list of the company\u2019s subsidiaries. The list does not include percentage ownership data so it is unclear whether these companies are 100% owned by the company or whether they are joint ventures or non-fully consolidated holdings. In its most recent published Annual Report from 2014, the company publishes a list of its wholly-owned subsidiaries alongside ownership data on all its holdings and information on these companies\u2019 incorporation. <\/p>\n
The company receives a score of \u20181\u2019 because there is no evidence that the company has made more recent information on its shareholdings publicly accessible and the list of subsidiaries is not clear regarding the type of incorporation. <\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
The company discloses that it is a subsidiary of Rostec, a state-owned entity, without providing further details. According to information published by Rostec, it owns 100% of the company\u2019s share capital. The company does not publish ownership data on a central public register. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes the customers of at least 50% of its defence sales.<\/p>\n"},{"question":111,"commitment_area":16,"score":"2","comments":"
In its most recent publicly available annual report, published in 2015, the company publishes information about its shareholder voting rights, broken down by percentage allocated to each shareholder. <\/p>\n
It is noted that this information was correct as of 2015 and is possibly out of date. <\/p>\n"},{"question":112,"commitment_area":16,"score":"2","comments":"
The company's commercial and public policy objectives are made publicly available on its website. There is evidence that these policies are updated whenever there is a change in objectives.<\/p>\n"},{"question":113,"commitment_area":16,"score":"0","comments":"
The company makes insufficient information about its board members publicly available.<\/p>\n"},{"question":114,"commitment_area":16,"score":"0","comments":"
There is no evidence to suggest that the company has an audit committee.<\/p>\n"},{"question":115,"commitment_area":16,"score":"0","comments":"
The company does not publish sufficient details about its management of asset transactions to merit a score of \u20181\u2019.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/826","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=826"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=826"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}