There is no publicly available evidence that the company makes a publicly stated commitment to ethical or anti-bribery and corruption standards, nor is there clear evidence that its anti-corruption policy is endorsed by its senior leadership.<\/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 clearly 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 of directors is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. The company indicates that the board\u2019s responsibilities include reviewing reports from management on the programme\u2019s performance and there is evidence that the board has the authority to require that changes 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 has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the board which provides oversight of the anti-bribery and corruption programme and there is evidence of reporting and feedback activities between this person and the board.<\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is some evidence to indicate that the company conducts compliance-related risk assessments. The company indicates that such surveys form part of the Compliance Officer\u2019s annual work plan and that the board or audit committee is responsible for reviewing and approving such findings. <\/p>\n
However, it is not clear from publicly available information that the results of risk assessments are used to develop tailored mitigation plans and to update specific parts of the company's anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company\u2019s anti-bribery and corruption programme is subject to regular review. There is evidence to indicate that these reviews are conducted on a periodic basis with any changes to the programme reported to the company\u2019s board on a quarterly basis. The company\u2019s management is responsible for making changes to the programme.<\/p>\n
However, there is no clear evidence that the company\u2019s anti-bribery and corruption programme is subject to internal or external audits, nor that the company\u2019s review process ensures that the programme is consistent with high standards of best practice and the business risks facing the company.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly commits to investigating incidents, which are conducted by the Compliance Officer and the Ombudsman. There is evidence that the investigative findings are reported to senior management and the board, and the company indicates that the Compliance Officer provides updates on cases or violations of the compliance programme to the CEO and Audit Committee on a quarterly basis. <\/p>\n
However, it is not clear from publicly available information that the company publishes information on the whole investigation process from receipt to final outcome, nor is there evidence that it publicly commits to inform whistleblowers of outcome of investigations 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":"2","comments":"
Based on publicly available information, there is evidence that the company commits to report material findings of bribery and corruption from investigations to the President and board-level Audit Committee. In addition, there is evidence to indicate that the Ombudsman is responsible for ensuring that the disclosure of material findings to relevant authorities is evaluated and acted upon if necessary.<\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or corruption-related reports, investigations or disciplinary actions involving its employees.<\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides training for its employees that outlines the basic principles of the anti-bribery and corruption policy, including the whistleblowing options available. The company indicates that this training is provided on an annual basis to employees in certain positions or departments.<\/p>\n
However, there is no clear publicly available evidence that the company provides training to all employees across all divisions, all countries of operation and in all appropriate languages on a regular basis.<\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides specific compliance and anti-corruption training to employees in certain positions depending on their role and department. The company indicates that it provides such training to employees in high-risk positions, such as in the marketing division, as well as to middle management and to senior officers in certain departments. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that employees in high risk positions must undertake and refresh their compliance training on an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company reviews the effectiveness of its anti-bribery and corruption communications and training programme. The company indicates that the Compliance Officer is responsible for conducting checks on the programme to ensure proper implementation, but it is not clear that this includes measures of effectiveness or that the results of such checks are directly used to update specific parts of the company\u2019s anti-corruption training and communications 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 the company has a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. This policy applies to all employees and there is evidence to indicate that it extends to those employed by the group as third parties. <\/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":"1","comments":"
Based on publicly available information, there is evidence the company provides an internal whistleblowing line for its employees to report incidents or allegations of bribery and corruption. The company indicates that its channel allows for confidential reporting. There is evidence that the whistleblowing line is open and accessible to business partners of the company. <\/p>\n
However, it is not clear from publicly available information that the company provides employees with an external reporting channel operated by an independent third party, nor is it clear that the internal channel may be used to seek advice on the anti-corruption programme. In addition, it is not clear whether the company\u2019s whistleblowing line is available to all employees in any country of operation or in multiple relevant languages. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence the company has a policy on conflicts of interest that refers to actual conflicts. The company\u2019s policy also addresses possible conflicts arising from employee relationships and outside employment. There is evidence the policy applies to all employees and board members. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that its policy addresses possible conflicts associated with government relationships or financial interests. It is also not clear that the company\u2019s policy for all employees applies to perceived or potential conflicts of interest. <\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company has procedures to manage conflict of interest or their oversight. The company indicates that employees should avoid conflict of interest situations, but it does not provide further publicly available information on the procedures that it has in place to accompany its policy.<\/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 evidence that the company publishes details of the contracted services of any serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
There is evidence that the company has a policy on political contributions which recognises the risks associated with such expenditure and states that contributions are permissible when made in line with relevant laws. Among other procedures, the company indicates that any contributions must be consistent with its values, properly documented and approved in advance by the company\u2019s Compliance Officer. <\/p>\n
The company receives a score of \u20180\u2019 since it does not prohibit political contributions in line with the scoring criteria. <\/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":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy covering charitable donations and sponsorships. The company\u2019s policy includes measures to ensure that donations are not used as vehicles for bribery and corruption, including a requirement for advance approval by the Compliance Officer and proper documentation of expenditure, among other controls. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes any details of the charitable donations and sponsorships made in the most recently reported financial year, such as the details of the recipient, amount, country of recipient and which corporate entity made the payment.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy or procedure on lobbying. <\/p>\n"},{"question":79,"commitment_area":11,"score":"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 of its global lobbying expenditure.<\/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 the giving and receipt of gifts and hospitality with procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. The company\u2019s policy clearly addresses the risks associated with gifts and hospitality given to and\/or received from public officials. There is evidence that all gifts and hospitality above certain thresholds are recorded in centrally through a system that is accessible to those responsible for oversight of the process.<\/p>\n
However, there is no publicly available evidence that the company\u2019s policy includes financial or proportional limits or different approval procedures for different types of promotional expenses.<\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is some evidence to indicate that the company\u2019s procurement department is involved in the establishment and oversight of supplier relationships. <\/p>\n
However, there is no clear evidence that the company assures itself of the procurement department\u2019s proper involvement in the procurement process at least every three years through clearly stated means, such as an audit or other assurance process. In addition, it is not clear from publicly available information that the procurement department is the main body responsible for oversight of the company\u2019s supplier base.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has formal procedures in place to conduct due diligence on suppliers and business partners. <\/p>\n
However, it is not clear from publicly available information that the company conducts due diligence on all suppliers. There is no evidence that the company\u2019s due diligence procedures include checks on ultimate beneficial ownership nor that the highest risk suppliers are subject to enhanced due diligence. The frequency of the checks is also unclear and 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.<\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
Based on publicly available information, 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. The company states that its compliance programme applies to relevant third party business partners but it is not clear whether this includes suppliers.<\/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 corruption-related reports, investigations or the 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 and procedures to control 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, there is some evidence that the company aims to establish and verify that the use of an agent is, in each case, necessary to perform a legitimate business function. This policy applies to all divisions within the organisation which might employ agents, including subsidiaries and joint ventures.<\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence the company has formal procedures in place to conduct anti-bribery and corruption due diligence prior to engaging agents. There is evidence indicating that some agents are subject to enhanced due diligence and that the company may be willing to terminating the agreement if red flags are identified. <\/p>\n
However, it is not clear from publicly available information that all agents and highest risk intermediaries are subject to enhanced due diligence. In addition, although the company states that it monitors its agents, there is no clear evidence that due diligence is repeated at least every two years and\/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 aims to establish the identity of its agents through background checks. However, it is not clear from publicly available information that such checks include full details of ultimate beneficial ownership nor that agreements with agents and intermediaries may be terminated in cases where beneficial ownership cannot be established. <\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is evidence that the company includes anti-bribery and corruption clauses in its contracts with agents. The company\u2019s Code of Business Conduct also applies to all third parties acting on the company\u2019s behalf, which can be understood to include agents. However, although there is some indication that the company includes termination rights in its contracts with agents, there is no clear evidence that these clauses also include audit rights.<\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company recognises payments structures for agents as a factor in bribery and corruption risk. The company indicates that it prohibits cash payments to such entities and that payments must be made to an account in the name of the agent. <\/p>\n
However, there is no further publicly available evidence that the company imposes a threshold on the payment of sales commissions to agents, nor that there is a requirement 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 currently contracted to act for and\/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 corruption-related investigations, incidents or the associated disciplinary actions involving its agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has procedures to conduct anti-bribery and corruption due diligence on its joint venture partnerships.<\/p>\n
However, it is not clear from publicly available information 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, nor is it clear that due diligence is repeated every two years or whenever there is a change in the business relationship. <\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company requires anti-bribery and corruption clauses in its contracts with joint venture partners. The company provides information to indicate that such clauses also include termination rights.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that its contracts with joint venture partners include audit rights. <\/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.<\/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, department or team is responsible for monitoring 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":"0","comments":"
There is no publicly available 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":"
There is evidence company publishes some information about its subsidiaries, including some information about their countries of incorporation. The company indicates that at least two of its subsidiaries are fully-owned. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that the company publishes information on the percentage ownership and country or countries of operation for each entity. It is also not clear whether this represents a complete list of the company\u2019s fully and non-fully consolidated holdings, including associates and joint ventures, or whether this list is updated on an annual basis.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company publishes a clear statement on its website to indicate that it is wholly-owned by the State of Israel, thereby indicating that the state holds 100% of its shares and voting rights.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no publicly available evidence that the company publishes information on its major customers. <\/p>\n"},{"question":111,"commitment_area":16,"score":"N\/A","comments":"
The company publishes a clear statement on its website to indicate that it is wholly-owned by the State of Israel, thereby indicating that the state holds 100% of its shares and voting rights.<\/p>\n"},{"question":112,"commitment_area":16,"score":"0","comments":"
The company publishes some details of its global vision, however there is no clear evidence that the company publishes any information on its commercial or public policy objectives. <\/p>\n"},{"question":113,"commitment_area":16,"score":"0","comments":"
There is no publicly available evidence that the company publishes information on the composition of its board, nor that it publishes details of the board nomination and appointment process. <\/p>\n"},{"question":114,"commitment_area":16,"score":"0","comments":"
There is no publicly available evidence to indicate that the company has an audit committee, nor that such a committee would be composed of a majority of independent directors.<\/p>\n"},{"question":115,"commitment_area":16,"score":"0","comments":"
There is no publicly available evidence that the company has a system in place to manage asset transactions.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/838","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=838"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=838"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}