There is evidence that the company\u2019s CEO publicly endorses the company\u2019s Code of Ethics and Compliance, which includes its anti-bribery and corruption policy. However, the company scores \u20181\u2019 as this statement does not directly mention or support the company\u2019s anti-bribery and corruption stance. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company publishes an anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. This policy applies to all employees and board members as described in (a) and (b) in the question. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that a designated board committee \u2013 the Audit and Compliance Committee \u2013 is ultimately responsible for oversight of the company\u2019s anti-bribery and corruption programme. There is evidence that the committee is engaged in formal oversight functions and it is clear that this committee has the authority to require that any necessary changes to the programme are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a designated Compliance Officer responsible for implementing and managing the company's anti-bribery and corruption programme. However, it is not clear from publicly available information whether this individual is a senior executive or whether they have a direct reporting line to the board committee that provides oversight of the anti-bribery and corruption programme.<\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a formal bribery and corruption risk assessment procedure in place that informs the design of its anti-bribery and corruption programme. The company indicates that such assessments are conducted on an annual basis. There is evidence indicating that the results are reviewed at board level and the assessments are used to update the company\u2019s anti-bribery and corruption programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s anti-bribery and corruption programme is subject to annual audit and review to ensure that it is consistent with high standards of best practice and the business risks facing the company. In 2018 the company also conducted an external audit of its compliance programme and there is evidence to suggest that external audits will be updated on an annual basis. The results of audits are reviewed by the company\u2019s Audit and Compliance Committee, and there is evidence that the Compliance Unit is responsible for implementing improvements to the programme. <\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
There is evidence that the company publicly commits to investigating incidents and that investigations are conducted by the company\u2019s Compliance Unit. The company provides details of the investigation process and the bodies involved at each stage. There is evidence that information on each investigation is documented and that the company commits to update whistleblowers and those who report concerns on the outcome of investigations. In addition, there is evidence that the Audit and Compliance Committee and Compliance Unit review summary information on all cases on a regular basis, at least annually as part of its yearly activity report. <\/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":"
There is evidence that the company commits to report material findings of bribery and corruption from investigations to the board-level Audit and Compliance Committee and to relevant authorities. The company indicates that the Audit and Compliance Committee is responsible for determining whether to disclose criminal offences to the relevant authorities.<\/p>\n"},{"question":63,"commitment_area":8,"score":"2","comments":"
The company publishes some high-level information on ethics and compliance-related incidents and investigations involving company employees on an annual basis. The information includes the number of reports received through the company\u2019s whistleblowing line and the number of disciplinary actions as a result of investigation findings. There is evidence indicating that the Compliance Unit investigates all reports.<\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides training for employees that that outlines the basic principles of its anti-bribery and corruption policy. There is some indication that this also includes the whistleblowing options available to employees, as part of the Code of Ethics. There is evidence to suggest that trainings are provided to all employees across all divisions and all countries of operation. Although the company does not explicitly state that employees must undertake and refresh their training regularly, there is publicly available evidence to suggest that the company provides training to the majority of its staff on an annual basis.<\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides tailored anti-corruption training for employees based on their role and exposure to corruption risk. The company indicates that it provides tailored training to board members and those in management positions, as well as stating that employees in technical positions and those working in the defence and security market receive specific training on the rules of conduct related to that field. <\/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 refresh their training on at least an annual basis. The company indicates that it will provide training in the next year but it is not clear whether this applies to the same employees or new employees receiving the training for the first time. <\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence to indicate that the company reviews its compliance communications and personnel training programme. The company clearly measures and publishes information on its training completion rates and whistle-blower reports received. In addition, there is evidence that the company conducted a review of its compliance programme in 2019 which resulted in updates to its training procedures. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not publish further details on how it measures and reviews the effectiveness of its communications or training beyond tracking completion rates. Although the company indicates that it reviewed these processes in 2019, there is no clear evidence that the company conducts a full review of its anti-corruption training and communications programme on a regular basis, at least every three years.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no clear evidence that the company incentive schemes for employees incorporate ethical or anti-corruption principles. <\/p>\n
For some employees, the company indicates that it has a variable remuneration system which is proportionate and based on their contribution towards the objectives of the company. For executive directors, the company indicates that it has procedures in place to recover any variable compensation that may have been improper or miscalculated. However, there is no evidence that the company\u2019s approach to incentives for all employees incorporates ethical principles, by incentivising employees based on \u2018how\u2019 they achieve their goals through tool such as performance appraisals. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company publishes a clear commitment to support or protect employees who refuse to act unethically.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption concerns. There is evidence that this applies to all employees across the organisation. In addition, there is evidence to indicate that the company\u2019s whistleblowing channel is open to third parties and business partners, so this commitment is understood to extend to the employees of these entities.<\/p>\n
However, there is no evidence that the company 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 that the company provides a whistleblowing channel for its employees that allows for confidential and, where possible, anonymous reporting. The company indicates that these channels are accessible in all relevant countries of operation and available to those employed by its business partners, including suppliers. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it provides an external reporting channel operated by an independent third party. It is also not clear that the company\u2019s channels may be used to ask questions and seek advice on the anti-corruption programme, in addition to reporting allegations or incidents. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy that defines conflicts of interest. The company\u2019s policy addresses actual and potential conflicts and makes clear reference to possible conflicts arising employee relationships and financial interests. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that its policy covers potential and perceived conflicts of interest, nor is there evidence that it addresses possible conflicts arising from government relationships or other employment. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is evidence the company has procedures in place to identify, declare and manage conflicts of interest. The company indicates that its employees must report any actual or perceived conflicts of interest through the company\u2019s Direct Channel, while the board reviews any conflicts associated with directors. Since the Compliance Unit is responsible for reviewing reports from the Direct Channel, there is some evidence that this body is responsible for the handling of cases. There is evidence that disciplinary measures will apply if the company\u2019s policy is breached. <\/p>\n
However, there is no clear evidence that all employee and board member declarations are held in a dedicated central register that is accessible to those responsible for oversight of the process. In addition, or employees, there is also no evidence that a specific body or individual with oversight and accountability for handling cases. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is evidence that the company has a policy to regulate the hiring of any politically exposed persons, which stipulates additional controls to reduce the associated risks. However, in publicly available evidence the company does not provide further details on its policy or the controls that it has in place.<\/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":"2","comments":"
Based on publicly available information, there is evidence that the company publishes a clear statement that it does not make corporate political contributions. The company indicates that this applies to any direct or indirect contributions in Spain or in any other jurisdictions. There is evidence that this policy applies company-wide. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
The company publishes a clear statement that it does not make political contributions and therefore it is exempt from scoring on this question.<\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy on charitable donations and sponsorships, which outlines criteria for such donations.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes full details of all the charitable donations it makes, such as details of the recipient, amount, country of recipient and which corporate entity made the payment. In addition, the company does not indicate that its policy includes further controls such as procedures for senior sign-off or due diligence on recipients; the company makes reference to an internal document which provides further details on these procedures, but this does not appear to be publicly accessible.<\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has procedures on lobbying. The company indicates that employees involved in lobbying activities must abide by its Code of Ethics and Legal Compliance, which provides clear standards of conduct and acceptable behaviours.<\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further publicly available information on the procedures that it has in place to ensure that lobbying is conducted responsibly, for example by outlining specific oversight mechanisms or specific standards of conduct that clearly apply to in-house, external and association lobbyists. <\/p>\n"},{"question":79,"commitment_area":11,"score":"1","comments":"
There is evidence that the company publishes some details of the topics on which it lobbies. The company provides details on its strategy to communicate with public bodies and indicates that its lobbying activities are primarily directed towards supporting its business interests. In addition, the company provides a direct link to the EU Transparency Register and Lobbyfacts, both of which contain records of the major topics on which the company has lobbied and its overarching goals, as well as details of any meetings with European officials. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further publicly available information on its specific aims of its lobbying and the activities that it carries out to achieve them. Although the company provides a link to information about its EU-level lobbying activities, there is no evidence that it publishes such information on any other activities undertaken nationally or internationally in other jurisdictions. <\/p>\n"},{"question":80,"commitment_area":11,"score":"1","comments":"
There is some evidence that the company publishes some details of its lobbying expenditure for the most recently reported financial year. This data includes most significant associations and organisations the company has supported as part of its approach to lobbying. In addition, the company provides a direct link to the EU Transparency Register and Lobbyfacts, both of which contain records of its annual spending on lobbying at the EU-level. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that these details represent all of the company\u2019s expenditure on lobbying activities, including activities conducted through in-house and external lobbyists. Although the company provides a link to information about its EU-level lobbying activities and expenditure, there is no evidence that it publishes such information on any other expenditure made nationally or internationally in other jurisdictions.<\/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. The company\u2019s policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The company\u2019s policy also clearly addresses the risks associated with gifts and hospitality given to public officials, and there is some evidence that the Compliance Unit maintains records of all tickets for entertainment events provided by employees. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that it maintains a dedicated central register of all types of gifts and hospitality which is accessible by the Compliance Unit. <\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company has a procurement procedure in place, and that it has a central supplier management process to onboard new suppliers and exercise ongoing oversight of the company\u2019s supply base. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it assures itself that proper processes for its procurement and supplier management system are being followed through clearly stated means, such as an audit or other assurance process, every three years. <\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
There is evidence that the company has formal procedures in place to review and evaluate suppliers before engaging or re-engaging with them. There is evidence that these checks apply to all suppliers and that they include compliance indicators. In addition, the company indicates that its supplier management system is based on a clear assessment of risk and there is some evidence that it conducts such assessments on an annual basis. The company also indicates that it may review or terminate a supplier relationship if it does not pass the assessment process. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available evidence that its evaluation procedures include establishing the ultimate beneficial ownership of all suppliers.<\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence that the company contractually requires suppliers to comply with its Code of Ethics and Legal Compliance. This Code clearly prohibits bribery and facilitation payments, and also includes procedures related to conflicts of interest, gifts and hospitality, and whistleblowing. There is evidence that the company takes active steps to ensure this by including such considerations in its evaluation process, incorporating its Code of Ethics into contractual clauses with suppliers and by conducting periodic audits. The company also indicates that it provides training on its Code of Ethics and Legal Compliance to some international suppliers.<\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. This evidence is in the form of a contractual clause that all obligations in the agreement apply to its sub-contractors. <\/p>\n
However, there is no further publicly available evidence to indicate how or whether the company assures itself that standards are adhered to throughout the supply chain in practices. It is also not clear whether the statement relates to obligations around contract delivery or performance, or whether this extends to ethical standards. <\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company publishes any high-level data on ethical or corruption-related investigations or associated disciplinary actions involving its suppliers. The company publishes some data on the reports received through its whistleblowing channel, but there is no publicly available evidence to indicate that this includes reports involving suppliers nor does the company provide disaggregated information on suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company has a procedure on the use of agents, which it refers to as commercial consultants and strategic advisors. The company indicates that it conducts an evaluation prior to engagement, including an assessment of any reputational or other risks.<\/p>\n
However, there is no clear publicly available evidence that the company commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. It is noted that the company has an internal document on the hiring of commercial consultants and strategic advisors, but this does not appear to be publicly accessible. <\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company evaluates and conducts reputational due diligence on its agents and consultants. The company indicates that this process includes a review of any political exposed individuals.<\/p>\n
However, there is no clear publicly available evidence that agents and highest risk intermediaries are subject to enhanced due diligence, nor that due diligence is repeated at least every two years or when there is a significant change in the business relationship. There is also no evidence that the company commits to not engaging or terminating its engagement with agents or 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. <\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is evidence that the company\u2019s Code of Ethics and Legal Compliance applies to agents and the company includes anti-bribery and corruption clauses in its contracts with these entities. However, there is no publicly available evidence that the company\u2019s contracts with agents include clear audit and termination rights to detect, control and prevent breaches. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company highlights and addresses incentive structures as a risk factor in agent behaviour. The company indicates that it has a procedure to manage contracts with such entities, however further information on this does not appear to be publicly available. <\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes the details of the agents currently contracted to act for or on its behalf. The company publishes a list of its business partners, but there is no evidence to indicate whether this includes third parties acting as agents or intermediaries on the company\u2019s behalf. <\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any high-level data on ethical or corruption-related investigations or associated disciplinary actions involving its agents. The company publishes some data on the reports received through its whistleblowing channel, but there is no publicly available evidence to indicate that this includes reports involving agents nor does the company provide disaggregated information on 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 ventures. It is noted that the company has an internal regulation on the control and monitoring of joint ventures, but there is no evidence that this document is publicly accessible. <\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures. The company indicates that its Code of Ethics and Legal Compliance applies to all subsidiaries and third parties regardless of jurisdiction. In organisations where it does not have majority control, the company states that it takes steps to ensure that these entities have policies and procedures in place that meet the equivalent standard of its own Code of Ethics. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear publicly available evidence that it includes anti-bribery and corruption clauses in its contracts with joint venture partners. It is noted that the company has an internal regulation on the control and monitoring of joint ventures which may contain more information on this subject, but there is no evidence that this document is publicly accessible.<\/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. The company states that it has internal procedures on the monitoring of joint ventures, however further information on this does not appear to be publicly accessible. <\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company has a policy in place to address the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company\u2019s 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 or on behalf of its offset programme.<\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of its offset obligations or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"2","comments":"
There is evidence the company acknowledges the corruption risks associated with operating in different markets, and that it has a risk assessment process in place to account for these specific risks, with procedures in place. The results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. The company indicates that it reviews the country of delivery and customer reputation when reviewing bids. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a list of its fully consolidated subsidiaries and non-fully consolidated holdings, including associates, joint ventures and other related entities. For each entity, the company discloses its percentage ownership. There is evidence that this list is current and updated on an annual basis. <\/p>\n
However, there is no evidence that the company publishes the country or countries of operation for each entity. In addition, although the company also publishes the country of incorporation for some affiliated entities, there is no evidence that it discloses such details for all relevant entities. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed on the Madrid Stock Exchange and the London Stock Exchange among others and therefore it does not need to disclose further information on its beneficial ownership to receive a score of \u20182\u2019. <\/p>\n
The company also publishes information on its major shareholders in its Annual Report, which indicates that the company is partially owned by the Sociedad Estatal de Participaciones Industriales S.A., a Spanish state holding company. <\/p>\n"},{"question":110,"commitment_area":15,"score":"1","comments":"
There is some evidence that the company publishes any information on its sales by customer. The company provides some information on its total sales by geographic area to indicate that its two largest clients are Spain and the United States, which account for approximately 70% of its sales. However, the company receives a score of \u20181\u2019 because in publicly available evidence the company does not distinguish between defence and commercial sales. <\/p>\n"},{"question":111,"commitment_area":16,"score":"2","comments":"
There is evidence that the company publishes information on the voting rights of its major shareholders as part of its annual corporate reporting. There is evidence that the company is publicly listed on the Madrid Stock Exchange and the London Stock Exchange, among others, and therefore it does not need to disclose further information on its beneficial ownership or shareholder voting rights to receive a score of \u20182\u2019. <\/p>\n"},{"question":112,"commitment_area":16,"score":"2","comments":"
There is evidence that the company publishes information on its commercial objectives for the whole business. In addition, there is evidence to indicate that these objectives are updated on an annual basis or whenever there is a change in the company\u2019s Strategic Plan.<\/p>\n"},{"question":113,"commitment_area":16,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides clear information on the nomination process, appointment and composition of its board and provides details of its board members. The company discloses details of its criteria for nomination, the company representatives that are involved in the nomination, and who makes the final appointment decision. For each board member, the company discloses whether that person has any connection to the company, the state or is an independent director.<\/p>\n"},{"question":114,"commitment_area":16,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s Audit and Compliance Committee is composed of a majority of independent directors.<\/p>\n"},{"question":115,"commitment_area":16,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a system in place for asset transactions with related parties. The company indicates that responsibility for scrutinising these transactions is held at board level and that information on transactions are made public in the company\u2019s financial reports. <\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/841","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=841"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=841"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}