Based on public evidence, the company has a publicly stated commitment to integrity in its Code of Conduct, which includes its anti-bribery and corruption policy. The Code of Conduct is endorsed by the company\u2019s CEO. However, the company receives a score of \u20181\u2019 because this statement does not specifically make reference to 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 publishes a comprehensive anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery and facilitation payments. This policy applies to all employees and board members. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that a designated board committee oversees the company\u2019s anti-bribery and corruption programme and engages in formal oversight functions. There is evidence that the Compliance Committee supervises the company\u2019s compliance and ethics activities and that it has the authority to require that any necessary 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\/board committee that provides oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this person and the board as part of the company\u2019s reporting structure.<\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company has a formal risk assessment procedure that is used to inform the company\u2019s anti-bribery and corruption policy. There is some evidence to indicate that the company has risk management systems in place, but it is not clear that this specifically includes anti-bribery and corruption considerations nor that it is used to inform the company\u2019s anti-bribery and corruption activities. <\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is no clear evidence that the company\u2019s anti-bribery and corruption programme is subject to regular audit or review. The company states that it has procedures to conduct compliance audits of areas such as safety, sales and export controls, but there is no evidence that it covers the company\u2019s anti-bribery and corruption programme. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company commits to investigating incidents, and there is a specific procedure in place to deal with whistleblowing cases. <\/p>\n
However, the company receives a score of \u20181\u2019 because its procedure does not stipulate actions to be taken at each step, and it is unclear whether investigations are handled by an independent team which reports to an independent member of the board. There is also no stated commitment to provide whistleblowers with updates on the outcome of investigations. Furthermore, there is no evidence that the information on each investigation is documented and that summary information is reviewed by a central body on an annual basis. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company assures itself of the quality of its internal investigations. The company indicates that staff tasked with conducting investigations are experienced, but it is not clear that they receive specific training to perform this function. There is also no evidence that the company has a procedure in place to handle the escalation of complaints about the investigation process, if necessary. <\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
There is no evidence to suggest that the company\u2019s investigative procedure includes a commitment to report material findings to the board or to relevant authorities. <\/p>\n"},{"question":63,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publishes high-level information on its ethics and compliance-related incidents involving employees, including the number of reports received and the number of disciplinary actions as a result of investigation findings. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is unclear whether this information applies to employees at all levels. Additionally, the company does not publish the number of investigations launched as a result of reports and the information provided does not cover the past 12 months. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company provides a training module that outlines the basic principles of its anti-bribery and corruption policy. The company indicates that this training is provided on an annual basis. <\/p>\n
However, there is no evidence that the training is systematically provided to all employees across all divisions, all country regions of operation or in all appropriate languages or that the training includes 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 tailors its compliance training to certain employees. However, the company does not make specific reference to all three categories of employee referred to in the question and there is no evidence that the training is refreshed at least on an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is no 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 evidence that the company\u2019s incentive schemes incorporate ethical or anti-bribery and corruption principles. The company publishes some information about its remuneration system, but there is no evidence that anti-bribery and corruption considerations factor into this, nor that it applies to all employees across the organisation. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company commits to support or protect employees who refuse to act unethically.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is clear evidence that this policy applies to all employees across the organisation. <\/p>\n
However, the company receives a score of \u20181\u2019 because 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. It is also not clear that the policy applies to 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 the company has whistleblowing and advice channels that are available to all employees in all countries of operations and in all appropriate languages. There is evidence that the company provides both internally- and externally-operated channels. <\/p>\n
However, it is not clear that the channels are not available to employees of third parties, suppliers or joint venture partners. Furthermore, these channels are not explicitly stated to be anonymous or confidential. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy for conflicts of interest that covers perceived conflicts of interest as well as specific categories of conflict such as employee relationships, financial interests and other employment. The policy applies to all employees and board members. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its policy covers potential or actual conflicts, or conflicts that may arise from government relationships. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has procedures to identify, declare and manage conflict of interest, including actual, potential and perceived, with oversight from the Law and Human Resources Department. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not state that all employee and board member declarations are held in a dedicated register or central depository that is accessible to those responsible for oversight of the process. The policy also does not indicate that disciplinary measure will apply of breached. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company has a policy regulating the employment of current or former public officials. <\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company reports details of the contracted services of serving politicians. <\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is evidence that the company prohibits corporate political contributions, regardless of whether they may be permitted under local laws. However, the company receives a score of \u20180\u2019 because there is some indication that the company may make political contributions in certain circumstances, with proper authorisation and approval. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company discloses any details of its political contributions, nor a statement that it has not made any contributions. <\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is evidence that the company makes charitable donations, referred to as \u2018social contributions\u2019. However, the company receives a score of \u20180\u2019 because there is no evidence that it has a clear policy on charitable donations and sponsorships to ensure that such donations are not used as vehicles for bribery and corruption. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no 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 details about 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. There is evidence that this policy addresses the risks associated with gifts and hospitality given to and received from domestic or foreign public officials. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not specify financial or proportional limits or different approval procedures for different types of promotional expenses, and there is no evidence that gifts and hospitality above a certain threshold are recorded in a dedicated register that is accessible to those responsible for oversight of the process. <\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base. <\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
Based on publicly available information, there is some evidence that the company conducts due diligence on its business partners. However, the company does not provide further information on this process and there is no evidence that due diligence specifically includes anti-bribery and corruption considerations, so the company receives a score of \u20180\u2019.<\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company encourages its suppliers to act in the spirit of its Code of Conduct, which includes its anti-bribery and corruption policy. <\/p>\n
However, there is no evidence of steps that the company takes to ensure this in practice, nor whether it assures itself of this for all its suppliers or if this assurance is conducted when onboarding new suppliers or when there is a significant change in the business relationship. <\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company encourages its suppliers to cascade the substance of its Code of Conduct, which includes its anti-bribery and corruption programme and standards, to sub-contractors throughout the supply chain. <\/p>\n
However, the company receives a score of \u20181\u2019 because this evidence is in the form of a simple statement and it is unclear what steps the company takes to ensure this in practice.<\/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":"1","comments":"
Based on publicly available information, there is some evidence that the company has a policy covering the use of agents. The company indicates that the employment and payment of sales agents or representatives must comply with any relevant laws or regulations. <\/p>\n
However, the company receives a score of \u20181\u2019 because its policy does not address the corruption risks associated with the use of agents and does not provide details of specific controls to mitigate these risks. The policy also does not explicitly commit to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. It is unclear whether this policy applies to subsidiaries and joint ventures.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is some evidence that the company conducts due diligence on its business partners. However, the company does not provide further information on this process and there is no evidence that due diligence specifically includes anti-bribery and corruption considerations, so the company receives a score of \u20180\u2019. <\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company aims to establish the beneficial ownership of its agents, nor does it explicitly commit to not engaging or terminate its engagement with agents or intermediaries if beneficial ownership cannot be established.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries. <\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company addresses incentive structures for agents as a factor in bribery and corruption risk. There is evidence that the company makes payments in accordance with local laws of the country in which the agent is located, and that unreasonable requests for commission payments are handled primarily by the Law Department. The company also acknowledges the risk that payments to agents may be transferred to government employees, and states that it will not engage where this risk is present. <\/p>\n
However, the company receives a score of \u20191\u2019 because there is no evidence that the company imposes a threshold on the payment of sales commissions to agents nor that remuneration is paid in stage payments throughout the contractual relationship.<\/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 behalf of the company.<\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption-related investigations, or the associated disciplinary actions, involving agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is some evidence that the company conducts due diligence on its business partners, which may include joint venture partners. However, the company does not provide further information on this process and there is no evidence that due diligence specifically includes anti-bribery and corruption considerations, so the company receives a score of \u20180\u2019. <\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no 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 evidence that the company addresses the corruption risks associated with offset contracting, or that a dedicated team is responsible for monitoring the company's offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company has a procedure 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 the company.<\/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 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":"2","comments":"
There is evidence that the company publishes a list of its consolidated and non-fully consolidated holdings. For each entity, the company publishes its percentage voting rights \u2013 which is understood to reflect percentage ownership \u2013 as well as the country of operation and incorporation. There is evidence that this list is current and updated on an annual basis due to the fact that the information is published in the Annual Report. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is a publicly listed entity at the Tokyo Stock Exchange and therefore automatically receives a score of \u20182\u2019. There is also evidence that the company publishes general information on its beneficial ownership in its Annual Report. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes a percentage breakdown of its defence sales by customer. <\/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\/847","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=847"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=847"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}