There is evidence that the company has a publicly stated commitment to integrity and high ethical standards which is endorsed by the company\u2019s President and CEO. The publicly available statement directly refers to addressing the challenge of bribery of foreign public officials, and there is evidence that this text appears at the start of the company\u2019s Code of Conduct, which includes an anti-bribery commitment. <\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company publishes a Code of Conduct that applies to all employees of the group. The company\u2019s policy clearly prohibits bribery and payments to public officials. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it prohibits facilitation payments, nor is it clear that the policy applies to board members.<\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
Based on publicly available information, there is evidence that the company\u2019s Compliance Committee maintains responsibility for the company\u2019s anti-bribery and corruption programme. There is evidence that the Compliance Committee is chaired by a senior executive and has a direct reporting line to the board, which holds ultimate accountability. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear publicly available evidence that this committee sits at board level, nor is it clear that the committee\u2019s responsibilities include reviewing reports from management on the programme\u2019s performance.<\/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 Compliance Officer \u2013 has ultimate responsibility for implementing and managing the company\u2019s compliance programme. There is evidence that the Chief Compliance Officer 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 structure.<\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has an enterprise risk management system in place. The company indicates that its risk assessment procedures include compliance-related risks and there is evidence that it has designed and implemented mitigation plans on this basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that these assessments take account of bribery and corruption risks or that the assessment informs the design of the company\u2019s anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is some evidence that the company has procedures to conduct internal audits, however there is no clear evidence that its anti-bribery and corruption programme specifically is subject to audit or review.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly commits to investigating violations of its Code of Conduct and that it maintains a whistleblowing hotline which is available to employees in Japan and the United States. There is evidence that the company commits to informing whistleblowers of the outcome of investigations. The company provides information on the whole investigation process from receipt to final decision, and there is evidence that the Legal Division is responsible for reviewing information on cases. <\/p>\n
However, there is no clear evidence that the company takes steps to ensure the independence of its investigations, for example by establishing an independent investigation team or reporting to an independent board member.<\/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 its internal investigations by ensuring that staff are properly trained, implementing a system to handle complaints about the procedure, or reviewing its procedure at least every three years.<\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company has an investigative procedure which includes a commitment to report material findings to the board or relevant authorities. The company\u2019s reporting structure indicates that the Compliance Committee reports to the board, however it is not clear from publicly available information that the Legal Division must report all findings to the Compliance Committee, nor that the all findings must be communicated to the board.<\/p>\n"},{"question":63,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publishes some high-level information on the number of whistleblowing reports it receives on an annual basis. <\/p>\n
However, there is no evidence that the company publishes further information on its reporting systems, such as the number of investigations launched, the number of disciplinary actions as a result of investigation findings and the number of reports received through other channels. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company provides training for its employees that outlines the basic principles of its anti-bribery and corruption policy. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the training is provided to all employees across all divisions, all countries of operation or in all appropriate languages. There is also no clear indication that the training includes an outline of the whistleblowing options available to employees.<\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company provides tailored training to employees based on their roles and exposure to corruption risks. The company indicates that it provides tailored training to senior executives and line managers, as well as to participants overseas. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it provides tailored training for employees in high risk positions, nor that employees in such positions must refresh their training on an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company measures and reviews the effectiveness of its anti-bribery and corruption training and communications programme. The company publishes data on the number of personnel who received compliance training on an annual basis, and indicates that it conducts internal surveys to assess the quality of its internal initiatives in areas such as compliance. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not publish further information on the way in which it measures effectiveness of its anti-corruption initiatives specifically, for example through regular dedicated staff surveys or specific audits. <\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company\u2019s incentive schemes for employees incorporate ethical and anti-corruption principles. The company indicates that its performance evaluations for employees include integrity and trust as a category and that this is a factor in personnel development. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no further publicly available information on how its approach to employee incentives is designed to promote ethical behaviour while discouraging corrupt practices. There is no evidence that the company\u2019s approach considers different risks relating to high risk employees.<\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is no clear 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":"
Based on publicly available information, there is evidence that the company has a policy of non-retaliation against whistleblowers and those who report bribery and corruption concerns. This statement appears in the company\u2019s Code of Conduct which applies to all employees across the organisation. <\/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. It is also not clear whether this policy applies to those employed by the group as third parties, suppliers and joint venture partners. <\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has multiple whistleblowing and advice channels. There is evidence that these channels are sufficiently varied to allow employees to raise concerns across the management chain and externally, through an independently operated hotline. The company also indicates that its channels allow for confidential and anonymous reporting. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that these channels are available to all employees in any country of operation, in multiple languages, or to the employees of third parties, suppliers or joint venture partners. The company indicates that its hotline may only extend to certain countries of operation.<\/p>\n"},{"question":71,"commitment_area":10,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company has a policy on conflicts of interest. The company includes a statement in its Code of Conduct that all employees should avoid conflicts of interest, but does not provide any further publicly available information on its policy to address and regulate any possible risks.<\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence the company has procedures in place to identify, declare and manage conflicts of interest.<\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the company has a policy regulating the employment of current or former public officials.<\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the company reports details of the contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy on political donations. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any details of its political contributions.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy or procedure on charitable donations and sponsorships.<\/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":"0","comments":"
There is no evidence that the company publishes any information on its lobbying aims, topics or activities.<\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any details about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy or procedure on gifts and hospitality.<\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is evidence that the company has a central Procurement and Strategic Planning department, and that it involves product-specific procurement experts in the selection of suppliers. However, there is no clear evidence that this department is the main body responsible for the establishment and oversight of the company\u2019s entire supply base. There is also no evidence that the company has procedures to assure itself of the proper functioning of its procurement procedures on a regular basis. <\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company conducts risk-based anti-bribery and corruption due diligence on its suppliers.<\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company requires that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company indicates that such policies must cover bribery, as well as gifts and hospitality. There is evidence that the company includes contractual terms in its agreements with business partners to address these risks. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that all suppliers must have policies in place that prohibit facilitation payments, or procedures that address conflicts of interest and whistleblowing. It is also not clear how frequently the company assures itself of the quality of its supplier\u2019s initiatives.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.<\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company has a policy on the use of agents. The company provides some information on its business partners, however it is not clear from publicly available information that this term includes agents or intermediaries, nor does this evidence recognise the specific risks associated with such entities.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its agents and intermediaries.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company aims to establish the ultimate beneficial ownership of its agents and intermediaries.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that that company\u2019s anti-bribery and corruption policy applies to agents and intermediaries, nor that it requires anti-corruption clauses with such entities. The company indicates that its policy applies to business partners, but it is not clear from publicly available information that this term may include agents and intermediaries. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company recognises 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 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 investigations, incidents or disciplinary actions involving its agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its joint venture partners.<\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that that company commits to implement anti-bribery and corruption policies in its joint ventures, nor that it includes anti-corruption clauses in its contracts with such entities. The company indicates that its policy applies to business partners, but it is not clear from publicly available information that this term may include joint venture partners.<\/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 its joint ventures.<\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body is responsible for monitoring the company's offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company 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 its behalf.<\/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":"0","comments":"
Based on publicly available information, there is some evidence that the company acknowledges the corruption risks associated with operating in different markets. However, there is no clear evidence that the company has procedures in place to conduct corruption-specific risk assessments, nor that such assessments have a direct impact on business decisions or inform the company\u2019s operations in high risk markets.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes some information on its main affiliates and associated companies, including domestic and overseas entities. The company makes specific reference to a country for each overseas entity, which is understood to reflect the country of incorporation. <\/p>\n
However, there is no publicly available evidence that the company publishes further information such as its percentage ownership and country or countries of operation for each entity. It is also not clear based on publicly available information whether this represents a complete list of the company\u2019s subsidiaries, and there is also no evidence that the information is updated on an annual basis.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed on the Tokyo Stock Exchange (TYO) and therefore it is not required to disclose further information on its beneficial ownership in order to receive a score of \u20182\u2019. The company also publishes information about its major shareholders on its website.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is evidence that the company publishes some information on its sales by region, to indicate that Japan accounts for a significant proportion (though less than 50%) of its total sales. However, the company does not disaggregate defence and commercial sales, and as such there is no evidence that the company publishes information on the customers of its defence-specific sales.<\/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\/835","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=835"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=835"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}