There is evidence that the company has a publicly stated commitment to integrity, compliance and high ethical standards which is authorised and endorsed by the company\u2019s Chairman and CEO, Darius Adamczyk. This commitment appears at the start of the company\u2019s Code of Business Conduct, which addresses bribery and improper payments as a specific risk. The company receives a score of \u20181\u2019 because there is no evidence that the company\u2019s senior leadership makes a clear and direct statement on anti-bribery and corruption.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a Code of Business Conduct which prohibits bribery, commercial bribery and improper payments to public officials. The company also publishes highlights of its Anti-Corruption Policy, which prohibits facilitation payments. There is evidence that the Code of Business Conduct applies to all employees and directors of the company, while the Anti-Corruption Policy applies to all employees, including those employed by subsidiaries and other controlled entities. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that the company's Corporate Governance and Responsibility Committee is accountable to the board for oversight of the Code of Business Conduct, which outlines the company\u2019s anti-bribery and corruption stance and wider compliance programme. This committee's functions include monitoring and reviewing reports on adherence to the code of conduct and the performance of the compliance programme. <\/p>\n
In addition, there is evidence that both the Corporate Governance and Responsibility Committee and the Audit Committee engage in formal oversight functions relating to compliance with ethics and integrity, including reviewing audits and formal reports on the company\u2019s compliance activities. There is evidence that these bodies have the authority to require that any necessary changes to the programme are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
There is some evidence to indicate that a specific managerial-level individual \u2013 the Vice President Global Compliance \u2013 has ultimate responsibility for implementing and managing the company\u2019s anti-bribery and corruption programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that this individual is a senior executive, nor is there evidence of clear reporting and feedback between this individual and the board.<\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
There is evidence that the company has formal procedures in place to conduct risk assessments on its operations which covers commercial, strategic, legal, compliance and reputational risks. There is some indication that these risks include ethics and anti-corruption as part of compliance. There is also evidence that both the Audit Committee and the Board review the results of these assessments on an annual basis.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available evidence that the results of such risk assessments are used to inform the company\u2019s anti-bribery and corruption programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
There is evidence that the company reviews its internal procedures to identify legal and compliance risks on an annual basis, and there is also some evidence that the company\u2019s Code of Business Conduct is reviewed on a regular basis. There is also evidence that the Board and Audit Committee are involved in this review process. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that the company\u2019s internal procedures \u2013 including its anti-bribery and corruption programme \u2013 are subject to internal audit or similar assurance process to ensure that the programme is consistent with best practice and to update the policies accordingly.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly commits to investigating bribery and corruption allegations and\/or incidents, and that there are procedures in place to track, investigate and respond to such concerns through the Integrity and Compliance programme. In addition, there is evidence that the Audit Committee is responsible for reviewing all significant integrity and compliance investigations on a quarterly basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further publicly available information on its investigative procedures from receipt to outcome, with ownership and actions to be taken at each step. There is also no evidence that information on each investigation is documented, nor that the company clearly commits to ensure that whistleblowers are informed of the outcome, if they so wish.<\/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":"
There is evidence that the company commits to report material findings from internal investigations to the appropriate authorities when necessary, upon the advice of the Law Department. There is some indication that the company\u2019s Senior Vice President and General Counsel reviews material matters with the Audit Committee on a regular basis, and this individual is understood to be associated with the Law Department and therefore a key individual in evaluating the decision to disclose criminal offences to the authorities when necessary. <\/p>\n
However, there is no clear publicly available evidence that the company commits to report material findings from investigations to the board of directors. The company\u2019s publicly available information on the reporting link between the Law Department and the Senior Vice President and General Counsel is not entirely clear. <\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company publishes data on ethical or bribery and corruption reports, investigations or disciplinary actions involving its employees. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company provides training on its anti-bribery and corruption policies. There is evidence that this training includes information on the company\u2019s whistleblowing channels and that it applies to all employees. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear how frequently employees must undertake anti-corruption training; it is not clear that all employees must refresh their training in this area every three years. It is also not clear from publicly available information that the company provides anti-corruption training to those in all countries of operation and in all relevant languages.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company provides tailored anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk. The company indicates that managers and executives must certify their adherence to the Code of Business Conduct on an annual basis, but it is not clear from publicly available information that these categories of employees receive any additional or tailored anti-corruption training. <\/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. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company\u2019s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company commits to support employees who refuse to act unethically. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company promotes a clear policy of non-retaliation against any employee who reports bribery and corruption incidents. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the company assures itself of its employees\u2019 confidence in this commitment through surveys, usage data, or other clearly stated means. In addition, it is not clear that the policy of non-retaliation applies to all third parties, suppliers and joint venture partners engaged by the company who may use its reporting channels. <\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides multiple channels for employees to report instances of suspected corruption and seek advice on its anti-bribery and corruption programme. These channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an external channel operated by an independent third party. There is evidence that these channels allow for confidential and, wherever possible, anonymous reporting. <\/p>\n
In addition, the company indicates that its reporting channels are available to employees across all operations and jurisdictions, as well as to all suppliers and third parties, and that the company\u2019s whistleblowing service is available 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 formally addresses conflicts of interest as a corruption risk and that it has clear policies to define actual, potential and perceived conflicts. There is evidence that the company\u2019s policy specifically addresses possible conflicts arising from outside employment, financial interests, dealings with family members and recruitment of former government officials. The company states that all employees and directors must adhere to its policies covering these risks.<\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has procedures in place to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company states that employees can report any conflicts to the HR, Law, or Global Integrity and Compliance departments. The company also gives various examples of potential scenarios which highlight conflicts of interest. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that all employee and director conflict of interest declarations are held in a dedicated central register or database accessible to those with responsibility for oversight. There is also no clear evidence that breaches of the conflict of interest policy may result in disciplinary action; the company only states that conflicts of interest must be avoided. In addition, it is not clear that a specific body has ultimate oversight of all conflict of interest cases.<\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is evidence that the company acknowledges the possible bribery and conflict of interest risks associated with the recruitment of government officials. The company indicates that employees must receive approval from the HR and Global Integrity and Compliance departments before appointing a current or former government official. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further publicly available details on its procedures to mitigate the risks from such appointments, for example by implementing cooling-off periods, requiring a conflict of interest review and potentially imposing restrictions on the individual\u2019s activities if any conflicts are identified.<\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the company publishes details of the 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 political contributions. The company indicates that corporate political contributions are generally prohibited, unless authorised by the Government Relations function and approved by the Senior Vice President and General Counsel specifically. The company states that it has not made any contributions since 2009, with the exception of two contributions to 501(c)(4) organisations which are publicly disclosed. In addition, there is evidence that the company is associated with a Political Action Committee (PAC) in the United States, which is subject to formal approval procedures and periodic audits. <\/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 details of its political contributions. The company states that it has only made two corporate political contributions since 2009, in the form of donations to 501(c)(4) organisations. For each donation, the company lists the name of the recipient organisation and the amount donated; it is also clear that both organisations are located in the United States. In addition, there is evidence that the company publishes a direct link to the U.S. Federal Election Commission (FEC), where full details of the disbursements made through its Political Action Committee (PAC) can be accessed. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy to ensure that charitable donations and sponsorships are not used as vehicles for bribery and corruption. The company states that all such contributions must follow its internal policies and indicates that all charities and proposed activities must be approved by management and the Law Department. In addition, the company states that its Integrity and Compliance department must approve any donation of over US$10,000 that may benefit a government official in a 12 month period. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it publishes full details of all charitable contributions and sponsorships made, such as details of the recipient, amount, country of recipient and which corporate entity made the payment. In addition, it is not clear that the company has procedures in place to conduct due diligence on recipients, nor does it publish information on criteria for donations.<\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy on lobbying. The company indicates that all lobbying activities are overseen by its Law Department, Global Compliance Department and Government Relations department. There is also evidence that the board and executive leadership receive regular reports on the company's lobbying activities. <\/p>\n
However, there is no publicly available evidence that the company\u2019s policy provides clear guidelines or standards of conduct that constitute responsible lobbying. It is also not clear from publicly available information that the company\u2019s policy and its oversight mechanisms apply to all employees and individuals engaged in lobbying, including all internal, external and association lobbyists. <\/p>\n"},{"question":79,"commitment_area":11,"score":"1","comments":"
There is evidence that the company publishes information on its significant legislative and regulatory priorities, alongside explanations of their relevance to the company's commercial activities. The company also provides some information on the key legislation and issues on which it has lobbied on a quarterly basis, by providing a direct link to its legally mandated Lobbying Disclosure Reports in the United States. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that this represents the aims and topics of its lobbying in all jurisdictions, nor does it provide a statement to indicate that it does not engage in lobbying outside of the United States. <\/p>\n"},{"question":80,"commitment_area":11,"score":"1","comments":"
There is evidence that the company publishes details of its lobbying expenditure, by making its federal quarterly lobbying reports up to the most recently reported financial year available via a direct link on its website.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that this expenditure data is broken down into expenditure through internal, external or association lobbyists. In addition, it is not clear from publicly available information that this represents the company\u2019s lobbying expenditure in all jurisdictions, nor does it provide a statement to indicate that it does not engage in lobbying outside of the United States.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy on gifts and hospitality to ensure that such business courtesies are not used as vehicles for corruption or bribery. The company\u2019s policy acknowledges the risks associated with any gifts and hospitality, in particular when given or received as part of dealings with domestic and foreign government officials. In addition, there is evidence that the company\u2019s policy sets clear financial limits for specific types of business courtesies and that senior approval may be required in some cases. <\/p>\n
However, the company receives a score of \u20181\u2019 because although it states that all business courtesies must be appropriately documented, there is no evidence that all gifts and entertainment given or received are recorded in a 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":"
Based on publicly available information, there is evidence that the company's procurement department is involved in the establishment and oversight of supplier relationships. The company states that employees must work with the Legal and Procurement Departments before appointing new suppliers, and it is clear that all agreements or purchase orders must be authorised and issued by procurement representatives. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company assures itself that the proper procurement procedures are being followed in practice, though regular audit or other means.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
The company publicly states that it carries out due diligence into certain types of suppliers. The company also states that failure to comply with the its Supplier Code of Conduct could result in a termination of the business relationship. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further publicly available details on its due diligence procedures, for example whether it aims to establish ultimate beneficial ownership of suppliers or whether it conducts enhanced due diligence on high risk suppliers. There is also no clear evidence that the company may be willing to not engage or terminate its relationship with a supplier if any red flags highlighted in the due diligence cannot be mitigated. <\/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 adhere to ethics and anti-corruption principles and to certain compliance procedures. The company indicates that such required procedures include a clear ban on commercial bribery and training for employees, and states that staff of suppliers may use its reporting mechanisms. There is evidence that the company may take measures to assure itself of supplier compliance with its ethics and anti-corruption standards, for example through the possibility of site visits or audits of supplier facilities.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that its standards for suppliers include prohibiting facilitation payments and procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. It is also not clear that the company assures itself of its suppliers\u2019 standards for all entities and on a regular basis or when there is a significant change in the business relationship. <\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
There is evidence that the company takes steps to ensure that the standards outlined in its Supplier Code of Conduct, including anti-bribery and corruption provisions, are communicated to sub-contractors throughout the supply chain. The company indicates that all suppliers should have a management system in place which includes a clear process to communicate the standards of its Supplier Code and procedures to monitor compliance with these standards. The company states that it expects these standards from all suppliers.<\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company publishes data on ethics or corruption-related reports, investigations and disciplinary actions involving its suppliers. <\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has a clear 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. 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. The company states that its policy applies to all divisions within the organisation, as well as subsidiaries and joint ventures.<\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
There is evidence that the company conducts anti-corruption-focused due diligence when engaging and re-engaging with its agents and sales intermediaries. <\/p>\n
However, the company does not provide further publicly available evidence to indicate whether it conducts and refreshes the due diligence on its intermediaries at least every two years or when there is a significant change in the business relationship. In addition, there is no evidence that the company has provisions to conduct enhanced due diligence on the high risk agents, nor that it may be willing to not engage or terminate its relationship with intermediaries where risks identified in the due diligence cannot be mitigated.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents and intermediaries as part of its due diligence process.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is some evidence that all of the company\u2019s third parties must comply with its Anti-Corruption Policy, as well as with relevant anti-corruption laws and regulations. In addition, the company\u2019s Code of Business Conduct states that its rules \u2013 which outline the company\u2019s anti-bribery and corruption policy \u2013 apply to all third parties working on behalf of the company. However, there is no publicly available evidence that the company takes steps to ensure that its third parties adhere to these standards by requiring anti-corruption clauses in contracts with its agents, with clear audit and termination rights.<\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company acknowledges incentive structures for agents as a risk factor in bribery and corruption risk. The company indicates that any third party receiving a commission or similar success fee must go through a clear due diligence process, with approval from the Global Integrity and Compliance Department. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further publicly available information on the specific controls that it has in place to reduce these risks, such as imposing a threshold on the payment of sales commissions to agents, or requiring that remuneration is paid in stage payments or 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 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 ethics and corruption-related reports, investigations and disciplinary actions involving its contracted 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 in place to conduct anti-corruption-focused due diligence on all joint venture partners. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear publicly available evidence that these due diligence checks include establishing the beneficial ownership of partner entities, nor is it clear whether the company has a risk-based approach to conduct enhanced due diligence on joint ventures operating in high risk markets or with high risk partners. It is also not clear how frequently due diligence into joint venture partners is conducted or refreshed. <\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company requires anti-corruption clauses in its contracts with joint venture partners, nor that the company has policies to incorporate anti-bribery and corruption policies in all of its joint ventures. The company indicates that joint ventures and acquired companies must follow its procedures on integrity and anti-corruption, but it does not provide further information on how it ensures compliance in practice.<\/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 providing dedicated anti-corruption training to joint venture staff or seconding employees to leadership or other key positions in the joint venture.<\/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 offsets contracting, nor is there evidence that a specific team or department is responsible for managing the company's offset activities. There is no evidence that the company publishes a statement that it does not engage in offset contracting.<\/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 agents, brokers or consultancy firms 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 about its offset projects. <\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is some evidence that the company acknowledges the risks of operating in different markets. However, there is no clear publicly available evidence that the company has a corruption risk assessment and management procedure in place to identify these specific risks, nor is it clear that the results of risk assessments have a direct impact on business decisions. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a list of its fully consolidated and majority-held subsidiaries. For each entity, the company provides details of its percentage ownership and the country of incorporation. The company publishes this information on at least an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it publishes information on its non-fully consolidated or minority holdings, nor is there evidence that it discloses the country or countries of operation for each entity.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed on the New York Stock Exchange (NYSE), and therefore it does not need to disclose further information on its beneficial ownership to receive a score of \u20182\u2019. In addition, the company publicly discloses all shareholders that own over 5% stakes in the company in its Proxy Statement, indicating that no natural person owns 25% or more of shares or voting rights in the company. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
The company publishes some information on its defence sales, to indicate that its sales to the United States Department of Defense (DoD) accounted for US$2,832 million in sales in 2018. The company publishes figures on its overall sales to indicate that the United States is its biggest customer across all divisions. <\/p>\n
However, the company receives a score of \u20180\u2019 because it does not publish further information on its major customers, nor does it distinguish between defence and commercial sales. It is therefore not clear whether the United States accounted for more than 50% of the company\u2019s defence sales in 2018.<\/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\/832","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=832"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=832"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}